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This Privacy Policy applies between you, the User of this Website and Cullinan Promotions Ltd, the owner and provider of this Website. Cullinan Promotions Ltd, takes the privacy of your information very seriously. This Privacy Policy applies to our use of any and all Data collected by us or provided by you in relation to your use of the Website.

This Privacy Policy should be read alongside, and in addition to, our Terms and Conditions.

Definitions and Interpretation

In this privacy policy, the following definitions are used;

• Data: Collectively all information that you submit to Cullinan Promotions Ltd via the Website. This definition incorporates, where applicable, the definitions provided in the Data Protection Laws;
• Cookies: A small text file placed on your computer by this Website when you visit certain parts of the Website and/or when you use certain features of the Website. Details of the cookies used by this Website are set out in the clause below (Cookies);
• Data Protection Laws: Any applicable law relating to the processing of personal Data, including but not limited to the Directive 96/46/EC (Data Protection Directive) or the GDPR, and any national implementing laws, regulations and secondary legislation, for as long as the GDPR is effective in the UK;
• GDPR: The General Data Protection Regulation (EU) 2016/679;
• Cullinan Promotions Ltd, Cullinan, or Us: Cullinan Promotions Ltd, a company incorporated in England and Wales with registered number 13460242 whose registered office is at 20-22 Wenlock Road, London N1 7GU. United Kingdom;
• UK and EU Cookie Law: The Privacy and Electronic Communications (EC Directive) Regulations 2003 as amended by the Privacy and Electronic Communications (EC Directive) (Amendment) Regulations 2011;
• User or You Any third party that accesses the Website and is not either (i) employed by Cullinan Promotions Ltd and acting in the course of their employment or (ii) engaged as a consultant or otherwise providing services to Cullinan Promotions Ltd and accessing the Website in connection with the provision of such services;
• Website: The website that you are currently using, www.cullinanpromotions.co.uk, and any sub-domains of this site unless expressly excluded by their own terms and conditions.

In this privacy policy, unless the context requires a different interpretation;

• the singular includes the plural and vice versa;
• references to sub-clauses, clauses, schedules or appendices are to sub-clauses, clauses, schedules or appendices of this privacy policy;
• a reference to a person includes firms, companies, government entities, trusts and partnerships;
• "including" is understood to mean "including without limitation";
• the headings and sub-headings do not form part of this privacy policy.

Scope of this Privacy Policy

This privacy policy applies only to the actions of Cullinan Promotions Ltd and Users with respect to this Website. It does not extend to any websites that can be accessed from this Website including, but not limited to, any links we may provide to social media websites.

For purposes of the applicable Data Protection Laws, Cullinan Promotions Ltd is the "data controller". This means that Cullinan Promotions Ltd determines the purposes for which, and the manner in which, your Data is processed.

Data Collected

We may collect the following Data, which includes personal Data, from you to fulfil an online purchase;

• name;
• contact information such as email addresses and telephone numbers;
• demographic information such as address, postcode, preferences and interests;
• IP address (automatically collected);
• in each case, in accordance with this privacy policy.

How we Collect Data

We collect Data in the following ways:

• data is given to us by you; and
• data is collected automatically.

Data that is given to Us by You

Cullinan Promotions Ltd will collect your Data in a number of ways, for example;

• when you contact us through the Website, by telephone, post, email or through any other means;
• when you register with us and set up an account to receive our products and or services;
• when you make payments to us, through this Website or otherwise;
• when you elect to receive marketing communications from us;

in each case, in accordance with this privacy policy.

Data that is Collected Automatically

To the extent that you access the Website, we will collect your Data automatically, for example;

• We automatically collect some information about your visit to the Website. This information helps us to make improvements to Website content and navigation, and includes your IP address, the date, times and frequency with which you access the Website and the way you use and interact with its content.
• We will collect your Data automatically via cookies, in line with the cookie settings on your browser. For more information about cookies, and how we use them on the Website, see the section below, headed "Cookies".

Use of Data

Any or all of the above Data may be required by us from time to time in order to provide you with the best possible service and experience when using our Website. Specifically, Data may be used by us for the following reasons;

• internal record keeping;
• improvement of our products and or services;
• transmission by email of marketing materials that may be of interest to you;
• contact for market research purposes which may be done using telephone, post, email or through any other means. Such information may be used to customise or update the Website;

in each case, in accordance with this privacy policy.

We may use your Data for the above purposes if we deem it necessary to do so for our legitimate interests. If you are not satisfied with this, you have the right to object in certain circumstances (see the section headed "Your rights" below).

For the delivery of direct marketing to you via e-mail, we'll need your consent, whether via an opt-in or soft-opt-in;

• soft opt-in consent is a specific type of consent which applies when you have previously engaged with us (for example, you contact us to ask us for more details about a particular product/service, and we are marketing similar products/services). Under "soft opt-in" consent, we will take your consent as given unless you opt-out.
• for other types of e-marketing, we are required to obtain your explicit consent; that is, you need to take positive and affirmative action when consenting by, for example, checking a tick box that we'll provide.
• if you are not satisfied about our approach to marketing, you have the right to withdraw consent at any time. To find out how to withdraw your consent, see the section headed "Your rights" below.

When you register with us and set up an account to receive our services, the legal basis for this processing is the performance of a contract between you and us and/or taking steps, at your request, to enter into such a contract.

Who We Share Data with

We may share your Data with the following groups of people for the following reasons;

• our employees, agents and/or suppliers - to fulfil an order or orders;
• relevant authorities - to facilitate the detection of crime or the collection of taxes or duties;

in each case, in accordance with this privacy policy.

SMS Notifications

These notifications are used only to inform you of the process stage, courier acceptance, track and trace and delivery of products ordered. You can activate or deactivate SMS Notification within your Profile section. Your mobile number(s) will not be used for any marketing purposes and will not be shared with any third parties.

Keeping Data Secure

We will use technical and organisational measures to safeguard your Data, for example;

• access to your account is controlled by a password and a user name that is unique to you.
• we store your Data on secure servers.

Technical and organisational measures include measures to deal with any suspected data breach. If you suspect any misuse or loss or unauthorised access to your Data, please let us know immediately by contacting us via our Secure Contact Form.

If you want detailed information from Get Safe Online on how to protect your information and your computers and devices against fraud, identity theft, viruses and many other online problems, please visit www.getsafeonline.org. Get Safe Online is supported by HM Government and leading businesses.

Data Retention

Unless a longer retention period is required or permitted by law, we will only hold your Data on our systems for the period necessary to fulfil the purposes outlined in this privacy policy or until you request that the Data be deleted. Even if we delete your Data, it may persist on backup or archival media for legal, tax or regulatory purposes.

Your Rights

You have the following rights in relation to your Data;

• Right to Access: The right to request (i) copies of the information we hold about you at any time, or (ii) that we modify, update or delete such information. If we provide you with access to the information we hold about you, we will not charge you for this, unless your request is "manifestly unfounded or excessive." Where we are legally permitted to do so, we may refuse your request. If we refuse your request, we will tell you the reasons why.
• Right to Correct: The right to have your Data rectified if it is inaccurate or incomplete.
• Right to Erase: The right to request that we delete or remove your Data from our systems.
• Right to restrict our use of your Data: The right to "block" us from using your Data or limit the way in which we can use it.
• Right to Data Portability: The right to request that we move, copy or transfer your Data.
• Right to Object: The right to object to our use of your Data including where we use it for our legitimate interests.

To make enquiries, exercise any of your rights set out above, or withdraw your consent to the processing of your Data (where consent is our legal basis for processing your Data), please contact us via our Secure Contact Form.

If you are not satisfied with the way a complaint you make in relation to your Data is handled by us, you may be able to refer your complaint to the relevant data protection authority. For the UK, this is the Information Commissioner's Office (ICO). The ICO's contact details can be found on their website at www.ico.org.uk. It is important that the Data we hold about you is accurate and current. Please keep us informed if your Data changes during the period for which we hold it.

Transfers Outside the European Economic Area

Data which we collect from you may be stored and processed in and transferred to countries outside of the European Economic Area (EEA). For example, this could occur if our servers are located in a country outside the EEA or one of our service providers is situated in a country outside the EEA. We also share information with our group companies, some of which are located outside the EEA.

We will only transfer Data outside the EEA where it is compliant with data protection legislation and the means of transfer provides adequate safeguards in relation to your data, e.g. by way of data transfer agreement, incorporating the current standard contractual clauses adopted by the European Commission, or by signing up to the EU-US Privacy Shield Framework, in the event that the organisation in receipt of the Data is based in the United States of America.

To ensure that your Data receives an adequate level of protection, we have put in place appropriate safeguards and procedures with the third parties we share your Data with. This ensures your Data is treated by those third parties in a way that is consistent with the Data Protection Laws.

Website Use

We may revise the Terms of Use at any time by amendments. You are expected to check the Terms of Use from time to time to take notice of any changes we make, as they are binding on you. Some of the provisions contained in the Terms of Use may also be superseded by provisions or notices published elsewhere on our site.

Changes of Business Ownership and Control

Cullinan Promotions Ltd may, from time to time, expand or reduce our business and this may involve the sale and/or the transfer of control of all or part of Cullinan Promotions Ltd. Data provided by Users will, where it is relevant to any part of our business so transferred, be transferred along with that part and the new owner or newly controlling party will, under the terms of this privacy policy, be permitted to use the Data for the purposes for which it was originally supplied to us. We may also disclose Data to a prospective purchaser of our business or any part of it. In the these instances, we will take steps with the aim of ensuring your privacy is protected.

Cookies

This Website may place and access certain Cookies on your computer. Cullinan Promotions Ltd uses Cookies to improve your experience of using the Website and to improve our range of products. Cullinan Promotions Ltd has carefully chosen these Cookies and has taken steps to ensure that your privacy is protected and respected at all times.

All Cookies used by this Website are used in accordance with current UK and EU Cookie Law.

Before the Website places Cookies on your computer, you will be presented with a message bar requesting your consent to set those Cookies. By giving your consent to the placing of Cookies, you are enabling Cullinan Promotions Ltd to provide a better experience and service to you. You may, if you wish, deny consent to the placing of Cookies; however certain features of the Website may not function fully or as intended.

This Website may place the following Cookies;

• Category 1 - Strictly Necessary Cookies: These cookies are essential to enable you to browse around our website and use the features. Without these cookies, services like shopping baskets and e-billing cannot be provided.
• Category 2 - Analytical and or Performance Cookies: These cookies collect information about how you use our website - for instance, which pages you go to most. This data may be used to help optimise our website and make it easier for you to navigate. These cookies don’t collect information that identifies you. All information these cookies collect is aggregated and therefore anonymous.
• Category 3 - Functionality Cookies: These cookies allow our website to remember choices you make while browsing. For instance, we may store your geographic location in a cookie to ensure that we show you our website localised for your area. We may also remember preferences such as text size, fonts, and other customisable site elements. They may also be used to keep track of what featured products you have have viewed to avoid repetition. The information these cookies collect will not personally identify you, and they cannot track your browsing activity when not on our website.

You can choose to enable or disable Cookies in your internet browser. By default, most internet browsers accept Cookies but this can be changed. For further details, please consult the help menu in your internet browser.

You can choose to delete Cookies at any time; however you may lose any information that enables you to access the Website more quickly and efficiently including, but not limited to, personalisation settings.

It is recommended that you ensure that your internet browser is up-to-date and that you consult the help and guidance provided by the developer of your internet browser if you are unsure about adjusting your privacy settings.

For more information generally on cookies, including how to disable them, please refer to www.aboutcookies.org. You will also find details on how to delete cookies from your computer.

General

You may not transfer any of your rights under this privacy policy to any other person. We may transfer our rights under this privacy policy where we reasonably believe your rights will not be affected.

If any court or competent authority finds that any provision of this privacy policy (or part of any provision) is invalid, illegal or unenforceable, that provision or part-provision will, to the extent required, be deemed to be deleted, and the validity and enforceability of the other provisions of this privacy policy will not be affected.

Unless otherwise agreed, no delay, act or omission by a party in exercising any right or remedy will be deemed a waiver of that, or any other, right or remedy.

This Agreement will be governed by and interpreted according to the law of England and Wales. All disputes arising under the Agreement will be subject to the exclusive jurisdiction of the English and Welsh courts.

Deceptive Emails or SMS

We will never ask you to confirm the details of your Account or Payment Method by email or mobile communication. If you receive such contact, please do not respond to it.

Changes to this Privacy Policy

Cullinan Promotions Ltd reserves the right to change this privacy policy as we may deem necessary from time to time or as may be required by law. Any changes will be immediately posted on the Website and you are deemed to have accepted the terms of the privacy policy on your first use of the Website following the alterations. You may contact Cullinan Promotions Ltd via our Secure Contact Form or by our contact detail below.

Contacting Us

If you have any questions, concerns, or complaints regarding this Privacy Policy, we encourage you to contact us using the details below:
20-22 Wenlock Road,
London N1 7GU.
United Kingdom

This document was last updated on August 11, 2021