GDPR - Level 2

Our Website - general brochure - Single controller Policy 

Privacy Notice

About Us

This is our Privacy Notice and we control the personal information you give us. We are Kirtleway Limited. We share some or all of your personal data with others, being:

  • Sarah’s Kitchen

The Personal Data we collect from you

We collect the personal data you provide us when you fill in the blanks in the website forms. A full list can be found clicking this link.

We also collect the following personal data from you:

- fill in a contact form online

- information you provide when you telephone us about your order or any other reason

- the information in your emails to us

- from cookies you permit to collect personal data or which are needed to make the site work.

- information you provide face to face in conversation

- information you provide over social media

- information you provide in paper based forms or documents

Using your data to fulfil the Contract

To fulfil the request or contract we use your data to allocate you the brochure, materials or products, manage and track your request or order, update you on progress, generate delivery notes and administration generally. We may have to use third parties to help us achieve these aims in accordance with our legitimate interests (see below).

  • Sarah’s Kitchen

Sharing with others to deliver the products and for legitimate interests

To help us fulfil the request or contract we share your data with these parties for the reasons below as it is in our legitimate interests to do so having taken into account all relevant factors around your privacy. If we do not engage these external contractors our prices would have to increase as we would have to engage more staff and buy more infrastructure. We require them to be GDPR compliant and enter data processor contracts with us or ensure their contracts make appropriate statements.

We use an external payment processor on the site to process your payment. We use a third party's shopping cart to handle and process the online order.

We use an external email provider which we use so we can confirm your request or order by email and handle any enquiries. They are a data processor for this purpose but also their own data controller.

We analyse your use of the site and products you buy or view so we can promote similar or related products, sites or services to you.

The following is a list of the outside parties we use:

  • Sarah’s Kitchen

Who else we share your personal data with for legitimate interest reasons

We share your personal data with the following parties for reasons of legitimate interest:

- we use an outside party to bill and collect.

- we use agents, advisers or others involved in running accounts and services for you and your business or collecting what you or your business owe;

- we use Third party vendors who help us to manage and maintain the IT infrastructure, website, and linked services;

- we use Logistics and delivery providers who enable us to deliver brochures, materials or products you request or order on our websites;

- we use professional advisors, such as lawyers, accountants, debt collectors and consultants;

Cookie Policy

We use cookies. To view our cookies and review your preferences, please use the cookie control in the bottom right of our website. You can view our cookies policy here.

Adding Data Together

We aggregate the following data we collect from different sources and put it together:

- data you provide over the telephone (including any text or other messages),

- data you put in any emails to us for any reason including your email address

- from cookies to collect personal data whilst you are on the website which can include which site you came to us from, your browsing history on or site and device information

- data you provide during face to face in conversation

- data you provide over social media

- data you provide in paper based forms or documents

and other sources.

Retention of Data

We will keep your data for 7 years after the year you request or order it so we can comply with contract law issues, product liability issues, insurance issues, company law obligations, record keeping for accounting and tax audits. If there are any complaints or questions on product liability or insurance issues we will keep your data for 6 years after the matter is dealt with. We may hold onto data were there are legal reasons to retain it.

Where we process your personal data to fulfil:

- your request or a contract with you, we will process such personal data until we fulfil that request or contract and for so long thereafter as may be necessary to keep a record of that request or contract, which will typically for a request will be 6 months and for a contract 6 years, and to deal with any complaints or claims relating to that request or contract, which will be until the final resolution of such complaints or claims (having regard to the nature of any potential claims and the limitation of liability periods that apply to them); or

- a legal obligation (such as anti-Money Laundering, tax and accounting obligations), we will process such personal data for so long as necessary to fulfil that obligation; or

Where we process your personal data based on:

- our legitimate interest, we will process such personal data for so long as necessary to achieve that legitimate interest, which will typically be for 6 years after we collect your personal data or the last time we use your personal data (or longer in relation to any legal claims that might arise having regard to the nature of any potential claims and the limitation of liability periods that apply to them); or

-your consent, for example, to send you marketing information, we will process such personal data until you withdraw that consent. Please bear in mind that it may take a short time to process any withdrawal of your consent. We aim to do this as soon as reasonable after receipt of your request, although you may still receive emails that are already in process around the time of your withdrawal.

Your rights regarding your personal information

Data privacy laws provide you with a number of rights over your personal information.

You may be entitled to:

ask us for access to the personal information we hold about you;

request the correction and/or deletion of your personal information;

request the restriction of the processing of your personal information, or object to that processing;

withdraw your consent to the processing of your personal information (where we are processing your personal information based on your consent);

request for the receipt or the transfer to another organisation, in a machine-readable form, of the personal information that you have provided to us; and

complain to your local data protection authority if your privacy rights are violated, or if you have suffered as a result of unlawful processing of your personal information.

If you would like to exercise your rights, please let us know by getting in touch with us as set out in the Contact us section below.

Change of Purpose

We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us. If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so. Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

Data Security

We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality. We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

Contact Us

If you have any questions please contact us:

By filling out the [contact us form]

By Postal address: 1 Shepley Street Old Glossop Derbyshire SK13 7RZ

You can contact Information Commissioner's Office Wycliffe House Water Lane Wilmslow Cheshire SK9 5AF Telephone: 0303 123 1113 Fax: 01625 5245

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