PRIVACY AND COOKIES
How we protect your privacy
Privacy and cookies policy – www.v33.co.uk
1.1 We are committed to safeguarding the privacy of our website visitors; in this policy we explain how we will treat your personal information.
- Collecting personal information
2.1 We may collect, store and use the following kinds of personal information:
(a) Information about your computer and about your visits to and use of this website (including your IP address, geographical location, browser type and version, operating system, referral source, length of visit, page views and website navigation paths). This information is held solely to optimise the performance of the website for your use.
(b) Information that you provide to us when registering with our website and completing your profile on our website (including your name, email address, login password and profile pictures). This information is held for the functional operation of the website.
(c) Information that you provide to us for the purpose of subscribing to our email notifications and/or blogs and newsletters (including your name and email address).
(d) Information that you provide to us when using the services on our website, or that is generated in the course of the use of those services (including the timing, frequency and pattern of service use). This information is held to optimise the performance of the website and guide the development of new features.
(e) Information that you post to our website for publication on the internet.
(f) Information contained in or relating to any communications that you send to us or send through our website (including the communication content and meta data associated with the communication).
2.2 Before you disclose to us the personal information of another person, you must obtain that person’s consent to both the disclosure and the processing of that personal information in accordance with this policy.
- Using personal information
3.1 Personal information submitted to us through our website will be used for the purposes specified in this policy or on the relevant pages of the website.
3.2 We may use your personal information to:
(a) administer our website and business;
(b) personalise our website for you;
(c) send you goods purchased through our website;
(d) supply to you services purchased through our website;
(e) send statements, invoices and payment reminders to you, and collect payments from you;
(f) send you non-marketing commercial communications;
(g) send you email notifications that you have specifically requested;
(h) send you our email newsletter/blog, if you have requested it (you can inform us at any time if you no longer require the newsletter/blog);
(i) send you marketing communications relating to Liberon Limited and associated brands products and services by post or, where you have specifically agreed to this, by email or similar technology (you can inform us at any time if you no longer require marketing communications);
(j) provide third parties with anonymous statistical information about our users (but those third parties will not be able to identify any individual user from that information);
(k) deal with enquiries and complaints made by or about you relating to our website;
(l) keep our website secure and prevent fraud; and
(m) verify compliance with the terms and conditions governing the use of our website.
3.3 We will not, without your express consent, supply your personal information to any third party.
- Disclosing personal information
4.1 We may disclose your personal information to any of our employees, officers, insurers, professional advisers, agents, suppliers or subcontractors insofar as reasonably necessary for the purposes set out in this policy.
4.2 We may disclose your personal information:
(a) to the extent that we are required to do so by law;
(b) in connection with any ongoing or prospective legal proceedings;
(c) in order to establish, exercise or defend our legal rights (including providing information to others for the purposes of fraud prevention and reducing credit risk);
(d) to a third party you have given us express to share with. For instance for technical advice or support
(e) to the purchaser (or prospective purchaser) of any business or asset that we are (or are contemplating) selling; and
(f) to any person who we reasonably believe may apply to a court or other competent authority for disclosure of that personal information where, in our reasonable opinion, such court or authority would be reasonably likely to order disclosure of that personal information.
4.3 Except as provided in this policy, we will not provide your personal information to third parties.
- International data transfers
5.1 Information that we collect may be stored and processed in and transferred between any of the countries in which we operate provided they offer the same data protection as the European Union.
5.2 You expressly agree to the transfers of personal information described in this Section 5.
- Retaining personal information
6.1 This Section 6 sets out our data retention policies and procedure, which are designed to help ensure that we comply with our legal obligations in relation to the retention and deletion of personal information.
6.2 Personal information that we process for any purpose or purposes shall not be kept for longer than is necessary for that purpose or those purposes.
6.3 Notwithstanding the other provisions of this Section 6, we will retain documents (including electronic documents) containing personal data:
(a) to the extent that we are required to do so by law;
(b) if we believe that the documents may be relevant to any ongoing or prospective legal proceedings; and
(c) in order to establish, exercise or defend our legal rights (including providing information to others for the purposes of fraud prevention and reducing credit risk).
6.4 In the event of unsubscribing from the website, user account data will be deleted from our database.
- Security of personal information
7.1 We will take reasonable technical and organisational precautions to prevent the loss, misuse or alteration of your personal information.
7.2 We will store all the personal information you provide on our secure (password- and firewall-protected) servers.
7.4 You acknowledge that the transmission of information over the internet is inherently insecure, and we cannot guarantee the security of data sent over the internet.
8.1 We may update this policy from time to time by publishing a new version on our website.
8.2 You should check this page occasionally to ensure you are happy with any changes to this policy.
- Your rights
9.1 When we receive any information instruction or request contained in section 9 we will:
a) Review the reasonableness of the request;
b) We will require the supply of appropriate evidence of your identity, the nature of which will be assessed on an individual basis;
c) Respond within one calendar month.
9.2 You may instruct us to:
a) Provide you with any personal information we hold about you;
b) Correct any inaccurate personal data we hold about you;
c) Erase all personal information we hold about you;
d) Restrict our usage of personal information we hold about you;
e) Make your personal information portable in a machine readable format;
9.3 Erasure of user data (9.2c) and in some cases restriction of usage (9.2d) may require us to remove products and services we offer to you.
9.4 We may withhold personal information that you request to the extent permitted by law.
- Third party websites
10.1 Our website includes hyperlinks to, and details of, third party websites.
10.2 We have no control over, and are not responsible for, the privacy policies and practices of third parties.
- Updating information
11.1 Please let us know if the personal information that we hold about you needs to be corrected or updated.
- About cookies
12.1 A cookie is a file containing an identifier (a string of letters and numbers) that is sent by a web server to a web browser and is stored by the browser. The identifier is then sent back to the server each time the browser requests a page from the server.
12.2 Cookies may be either “persistent” cookies or “session” cookies: a persistent cookie will be stored by a web browser and will remain valid until its set expiry date, unless deleted by the user before the expiry date; a session cookie, on the other hand, will expire at the end of the user session, when the web browser is closed.
12.3 Cookies do not typically contain any information that personally identifies a user, but personal information that we store about you may be linked to the information stored in and obtained from cookies.
12.4 Cookies can be used by web servers to identity and track users as they navigate different pages on a website and identify users returning to a website.
- Our cookies
13.1 We use both session and persistent cookies on our website.
13.2 These cookies collect information about how visitors use our website, such as the number of visitors and pages visited. We collate and retain information for reporting and monitoring purposes, in order to improve our website.
To opt out of being tracked by Google Analytics across all websites visit http://tools.google.com/dlpage/gaoptout
- Analytics cookies
14.1 We use Google Analytics to analyse the use of our website.
14.2 Our analytics service provider generates statistical and other information about website use by means of cookies.
14.4 The information generated relating to our website is used to create reports about the use of our website.
- Blocking cookies
15.1 Most browsers allow you to refuse to accept cookies; for example:
(a) in Internet Explorer (version 11) you can block cookies using the cookie handling override settings available by clicking “Tools”, “Internet Options”, “Privacy” and then “Advanced”;
(b) in Firefox (version 33) you can block all cookies by clicking “Tools”, “Options”, “Privacy”, selecting “Use custom settings for history” from the drop-down menu, and unticking “Accept cookies from sites”; and
(c) in Chrome (version 38), you can block all cookies by accessing the “Customise and control” menu, and clicking “Settings”, “Show advanced settings” and “Content settings”, and then selecting “Block sites from setting any data” under the “Cookies” heading.
15.2 Blocking all cookies will have a negative impact upon the usability of many websites.
15.3 If you block cookies, you will not be able to use all the features on our website.
- Deleting cookies
16.1 You can delete cookies already stored on your computer; for example:
(a) in Internet Explorer (version 11), you must manually delete cookie files (you can find instructions for doing so at http://windows.microsoft.com/en-gb/internet-explorer/delete-manage-cookies#ie=ie-11);
(b) in Firefox (version 33), you can delete cookies by clicking “Tools”, “Options” and “Privacy”, then selecting “Use custom settings for history”, clicking “Show Cookies”, and then clicking “Remove All Cookies”; and
(c) in Chrome (version 38), you can delete all cookies by accessing the “Customise and control” menu, and clicking “Settings”, “Show advanced settings” and “Clear browsing data”, and then selecting “Delete cookies and other site and plug-in data” before clicking “Clear browsing data”.
16.2 Deleting cookies will have a negative impact on the usability of many websites.
- Our details
17.1 This website is owned and operated by Liberon Limited.
17.2 We are registered in England and Wales under registration number 1576138, and our registered office is at Unit 1, Mountfield Industrial Estate, Learoyd Road, New Romney, TN28 8XU.
17.3 Our principal place of business is at Unit 1, Mountfield Industrial Estate, Learoyd Road, New Romney, TN28 8XU.
17.4 You can contact us by writing to the business address given above, by using our website contact form, by email to firstname.lastname@example.org or by telephone on +44 (0) 1797 367 555.
Online Privacy Notice
Policy Updated August 2021
1.2 This site is owned by Liberon Limited whose office is at Unit 1 Mountfield Industrial Estate Learoyd Road New Romney Kent TN28 8XU
1.3 Our Company registration number is 01576138. We are the ‘data controller’ of the personal information you provide to us.
1.4 We are registered as a Data controller with the Information Commissioners Office our registration number is: ZB 060200
1.5 We have appointed a Data Contact for the business who is Mr Richard Bradley
1.6 You can contact our Data Contact at our postal address given above or via email at Liberon.email@example.com if you have any queries regarding this policy.
1.7 As a Data Controller, we will take all the necessary steps to comply with the GDPR and Data Protection Act 2018 and relevant legislation when handling any personal data which you may provide to us.
We are responsible for ensuring that data is processed:
1.7.1 Fairly and lawfully processed
1.7.2 Processed for limited purposes
1.7.3 Adequate, relevant and not excessive
1.7.4 Accurate and Secure;
1.7.5 Not kept longer than necessary
1.7.6 Processed in accordance with your rights
1.7.7 Not transferred to countries outside the UK without safeguards.
1.7.8 Processed in a manner that ensures appropriate security of the personal data.
1.9 Use of Third Party Computer Applications for Video conferencing: Where we engage with you Online using a Video Conferencing Application the lawful basis will be our Legitimate Interests and the following will apply:
1.9.1 All participants in Video conferencing will be given specific log in details.
1.9.3 As Data Controller we will manage the Personal Data shared by participants and restrict or control access as necessary for the security of other participants and to prevent cyber security issues such as Phishing.
1.9.4 Password access will be controlled by the Moderator and individual passwords issued where an increased risk is perceived such as large groups or public access.
18.104.22.168 To facilitate efficient business video and telecommunications.
22.214.171.124 To protect the safety of our employees and participants on the call from unnecessary real world travelling.
126.96.36.199 To support our primary business objectives.
1.10 Please Note: This Online Privacy information is a precis of our detailed written policies which are held at our business premises. Please contact our Data Contact if you require further information regarding our data protection compliance procedures.
- Our Privacy Notice and Data Protection policies:
2.1 We are committed to protecting your personal data privacy and, in accordance with relevant data protection laws, we uphold strict security procedures for the collection, storage, use and disclosure of your personal information.
2.2 We have described below the personal information we may gather about you, the purposes we will hold it for and the limited categories of people to whom we may disclose it.
- What information do we collect and how may we use it?
3.1 During your visit to our site, we will only collect personal information that you choose to provide. If, for example, you contact us with an enquiry or request us to provide you with further information.
3.2 If you share other people’s data with us, for example if you refer business to us on behalf of another, you will need to check you have lawful authority to do so. E.G. The other party has consented to you providing us with their information. In such a case you are responsible for ensuring the transmission to us of the information is lawful and we may ask you for documentary evidence of this.
3.3 The other types of data we may collect from you includes the following:
3.3.1 Identity data: name, username, title, date of birth. Contact data: billing and delivery address, email address, phone number.
3.3.2 Financial data: None collected by this site.
3.3.3 Transaction data: Details of products purchased, amounts, dates etc.
3.3.4 Technical data: IP address, login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform. Geo location data to assist in directing you to our stockists.
3.3.5 Profile data: None collected by this site.
3.3.6 Usage data: information about how users use our website.
3.3.7 Marketing and communications data: record of Website users preferences in receiving marketing from us about the products we sell.
- We may use the information you provide us with in the following ways:
4.1 To administer any account you have with us.
4.2 To perform our contractual obligations to you.
4.3 To respond to your queries and requests.
4.4 To communicate with you.
4.5 To ensure that the content of our site is presented in the most effective manner.
4.6 To provide you with any information, products and/or services requested from us.
4.7 To provide you with helpful information about our products or services.
4.8 To make improvements to the service we provide you.
4.9 We also reserve the right to disclose your personal information where we are required to do so by law, such as to assist in any disputes, claims or investigations relating to your account or contracts with us and to detect and prevent fraudulent transactions.
4.10 E-mail correspondence with us via our website and email addresses accessible through or obtained from this site may be recorded and/or monitored.
- How do we store and protect your data?
5.1 We have robust information security management systems in place to protect your personal data. We take the security of your information seriously and have implemented appropriate technical and organisational security measures to protect it against any unauthorised or unlawful processing and against any accidental loss, destruction, or damage.
5.2 Data we receive and process is held by us in secure electronic devices and separate back up devices and servers.
5.3 Personal Data may also be held in encrypted 3rd party ‘Cloud’ Servers.
5.4 Further encrypted back ups of data may be held securely in offsite locations which are also subject to physical security at their location.
5.5 We will not sell, rent or otherwise disclose the personal information you provide to us through the site to third parties (other than as listed below) unless we are required to do so by law.
5.6 The Main Establishment for all of our Data Processing is the UK. We do not generally operate or transfer Personal Data outside of the United Kingdom.
5.7 Due to the operation of the Internet and other computer based applications Personal Data under our control may transit countries outside of the UK.
5.8 We will only transfer data outside the UK if adequate safeguards are in place in the destination country.
5.9 Where Personal Data is transferred to a third country or an international organisation we will ensure that an adequacy decision or similar authority exists between the UK and the relevant country or area.
5.10 Where no adequacy decision exists and we rely on the provisions of Standard Contractual Clauses or Binding Corporate Rules evidence of the safeguards provided thereby will be available upon request.
- Third parties who provide services on our behalf
6.1 We may share your personal information with certain third parties who provide services on our behalf.
6.2 Such 3rd Parties only have access to the personal information they need to perform those services.
6.3 Such 3rd parties are bound by contractual arrangements with Ourselves in accordance with Data Protection legislation and are required to keep your personal information secure and confidential. They may only use it as permitted by us in accordance with our Privacy Policies.
6.4 If you have contracted with us we will share data only to the extent necessary for the performance of the contract, otherwise we will obtain specific additional consent from you before sharing your data.
6.5 The third parties who provide services on our behalf fall into the following categories:
6.5.1 Our business partner organisations providing external service support.
6.5.2 Our business partners or advisors who process data on our behalf for the purposes of completing a contract with you.
6.5.3 Marketing agencies appointed to provide services to us.
6.5.4 The service providers operating this site on our behalf.
6.5.5 Accountants, auditors, law firms, payment processors, information technology support providers.
6.5.6 Advertising services, analytics services, Computer Application and Software providers.
- How long do we store your data?
7.1 We will not keep your data for longer than is necessary for the relevant purposes set out in this Privacy Notice and our Company Compliance Policies.
7.2 Where you have purchased a product or service from us, we will hold your relevant personal details to enable us to administer the contract and provide such after-sales services as may be required.
7.3 Speculative enquiries for information, the data will be retained for 12 months, unless the Consent is rescinded, in case of a follow up enquiry. E.g. Website enquiries.
7.4 We also store personal data in line with Regulatory and legal requirements in accordance with the law.
- Your Rights
8.1 Under the UK General Data Protection Regulation (UK GDPR) and The Data Protection Act 2018 (DPA) you have a number of rights with regard to your personal data. To exercise any of your rights contact our Data Contact using the details given above.
8.2 You have the right to request from us access to and rectification or erasure of your personal data; the right to restrict processing; the right to object to processing as well as in certain circumstances the right to data portability as below.
8.3 In the event that you provide your data directly to us for the purpose of a contract, or in circumstances where you have provided your data by consent, you have the right to be provided with your data in a structured, machine-readable format. This is known as Data Portability.
8.4 Following a request relating to Data Portability we will transmit the relevant personal data to the data subject or their nominated data controller where it is possible and technically feasible for us to do so.
8.5 Where you have provided your data voluntarily by Consent you have the right to withdraw your Consent at any time. However, withdrawal of Consent does not affect the lawfulness of any processing of your data based on your Consent prior to its withdrawal.
8.6 You have the right to complain to the Data Regulator at the Information Commissioners Office on 0303 123 1113 or through their website www.ico.org.uk.
8.7 Where we need to process data for the purposes of entering into a Contract with you, if you fail to provide such data it may mean that we cannot establish legal relations between us and the contract may not be able to go ahead. We will inform you if this happens.
8.8 Automated decision making and profiling means making decisions without human intervention, usually with the use of a computer program or software. We do not use automated decision making software.
8.9 Please note we will retain and use your personal information as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements. If we need to use your data for a reason it was not collected and you are not aware of this, we will inform you and in appropriate cases obtain your further consent to such use.
8.10 If we process data about you but we have not obtained the data personally from you, we must provide you with the information described in this Privacy Notice and some additional information.
8.11 The additional information will be provided to you at least by the time we contact you and in any event within the space of one month after we obtain it.
8.12 If the processing is based on Legitimate Interests, you are entitled to know what and whose Legitimate Interests they are.
8.13 You are entitled to know the purpose of the processing, whether we or someone else is processing it and the categories of Personal Data involved.
8.14 You are entitled to know the source of the information and whether the source is publicly accessible.
8.15 There are some exceptions to this additional information rule. If we obtain your Personal Data from a source other than yourself, the additional information rules will apply unless:-
8.15.1 You already have the information regarding our processing; or
8.15.2 it would take a disproportionate effort or be impossible to provide you with it; or
8.15.3 you are already legally protected under separate provisions; or
8.15.4 we have a legal duty not to disclose it.
8.16 We use the lawful basis of Legitimate Interests for processing data in the following circumstances:
8.16.1: When processing data using Video Conferencing software.
- Lawful bases for data processing
9.1 We hold and process your data by lawfully allowed means, these include:
9.1.1 Your Consent: Consent is usually given by yourself when you contact us via this Website or personally when we discuss products or advice with you.
9.1.2 Contractual obligations: This occurs when you purchase products or services from us.
9.1.3 Legal Obligation: When the processing is necessary for us to comply with the Law.
9.1.4 Vital Interests: When the processing is necessary to protect someone’s life.
9.1.5 Public Task: When the processing is necessary for us to perform a task in the public interest or for an official function and the task or function has a clear basis in Law.
9.1.6 Legitimate Interests: When the processing is necessary for our legitimate interests or the legitimate interests of a third party unless there is a good reason to protect the individual’s personal data which overrides those legitimate interests.
N.B. Legitimate Interests can only be used following the application of the prescribed three part Legitimate Interests Assessment Test and then only when a positive outcome is indicated by the conclusions of the test. All Legitimate Interests Assessment Tests will be documented, recorded and retained.
10. Children’s data
10.1 Our site is not directed at children and should not be accessed by them.
10.2 We will not knowingly collect information from persons under 13 years of age without their parent’s or guardian’s consent.
10.3 If a Parent or Guardian of a person under 13 years of age discovers their child has engaged with our Website without their consent, please inform us immediately using the contact email provided above.
10.4 We have considered the elements of the AADC (Children’s code) in relation to our Online activity and concluded that we are not a relevant Information Society Service pursuant to Section 123 Data Protection Act 2018.
10.5 Our Website and our products are only available and relevant to adults over the age of 18 years.
10.6 Due to the considerations of other legislative provisions regarding chemical products our Products and Services are not made available to children under 18 years.
10.7 We do not sell products or services directly from our website.
- Third Party Websites
11.1 From time to time our site may contain links to and from the websites of our suppliers or other third party sites.
11.2 If you visit any of these sites you should confirm they have their own privacy policies and you should check these before submitting any personal data on their site. We cannot accept any responsibility or liability for the policies on any other Websites.
12 Data Access
12.1 You have rights of access to the data we hold about you. Should you wish to exercise these rights please contact our Data Contact whose details are given above.
12.2 There is usually no charge for the Data Access service. As soon as we are satisfied as to your identity, we will send you, without delay and in any case within one Month, the Personal Data we hold relating to you, which we are legally obliged to provide.
12.3 In the event we need more time to gather the requested information we will let you know without delay and in any event within one month.
12.4 A fee may be payable for Data Access services if the request(s) are manifestly unfounded or excessive or repetitive in nature. Alternatively, we may choose to ignore this type of request. In these cases we will inform you of our decision and if applicable any fee that may be required.
12.5 Please contact us if you believe that any personal data or information which we hold about you is incorrect or incomplete. Any information or data which is found to be incorrect will be corrected as soon as practicable.
12.6 Please contact us if you wish to have your personal data removed entirely from our systems. As soon as we are satisfied as to your identity and the data is not required to be kept for any other lawful reason or purpose it will be removed from our systems forthwith.
12.7 If you so wish, your Data will be provided to you electronically in a commonly used format such as email.
12.8 If you are unhappy with any of the responses given to you by us you may complain about us to the regulator at the Information Commissioners Office on 0303 123 1113 or through their website www.ico.org.uk.
- Business Transfer or Sale
13.2 It may be necessary to transfer your data to a Company that is negotiating with us for the purchase of our business but only where it is necessary to evaluate the business purchase transaction.
13.3 In the case of a pre-sale transfer of personal data, the data would be kept safe during the negotiations and destroyed by the third party if the sale or merger did not go ahead.
14. Changes to this policy.
14.1 There may be developments in how we use your data according to changes in the Law.
14.3 Any revised terms shall take effect as at the date of posting.
14.4 If you don’t find your concern addressed here, feel free to contact us by e-mailing our Data Contact at the contact details given above.