Privacy Policy

1. 1.1 We are committed to safeguarding the privacy of our website visitors and service users.
2. 1.2 This policy applies where we are acting as a data controller with respect to the personal data of our website visitors; in other words, where we determine the purposes and means of the processing of that personal data.
3. 1.3 By using our website and agreeing to this policy, you consent to our use of cookies in accordance with the terms of this policy.
   Please see our Cookie Policy for details about our use of cookies on this website.
4. 1.5 In this policy, "we", "us" and "our" refer to Cambridge Guardians Ltd. For more information about us, see Section 10.

1. 2.1 This document was created using a template from SEQ Legal (https://seqlegal.com).

1. 3.1 In this Section 3 we have set out:
   1. (a)the general categories of personal data that we may process;
   2. (c)the purposes for which we may process personal data; and
   3. (d)the legal bases of the processing.
2. 3.2 We may process data about your use of our website and services ("usage data"). The usage data may include your IP address, geographical location, browser type and version, operating system, referral source, length of visit, page views and website navigation paths, as well as information about the timing, frequency and pattern of your service use. The source of the usage data is Google Analytics.
   This usage data may be processed for the purposes of analysing the use of the website and services.
   The legal basis for this processing is our legitimate interests, namely monitoring and improving our website and services.
3. 3.4 We may process your account data and information included in your personal profile on our website ("profile data").
   The profile data may include your name and email address
   The profile data may be processed for the purposes of enabling and monitoring your use of our website and services, operating our website, providing our services, ensuring the security of our website and services, maintaining back-ups of our databases and communicating with you.
   The legal basis for this processing is our legitimate interests (namely the proper administration of our website and business) and / or the performance of a contract between you and us (and/or taking steps, at your request, to enter into such a contract) and / or your legitimate interests by providing you with the services you have asked for.
4. 3.7 We may process information contained in any enquiry you submit to us regarding goods and/or services ("enquiry data").
   The enquiry data may be processed for the purposes of answering your queries and offering, marketing and selling relevant goods and/or services to you.
   The legal basis for this processing is our legitimate interests, namely the proper administration of our website and business and communications with users.
5. 3.9 We may process information that you provide to us for the purpose of subscribing to our email notifications and/or newsletters ("notification data").
   The notification data may be processed for the purposes of sending you the relevant notifications and/or newsletters.
   The legal basis for this processing is consent given by specifically signing up for each such newsletter.
6. 3.10 We may process information contained in or relating to any communication that you send to us ("correspondence data").
   The correspondence data may include the communication content and metadata associated with the communication. Our website will generate the metadata associated with communications made using the website contact forms.
   The correspondence data may be processed for the purposes of communicating with you and record-keeping.
   The legal basis for this processing is our legitimate interests, namely the proper administration of our website and business and communications with users.
7. 3.12 We may process any of your personal data identified in this policy where necessary for the establishment, exercise or defence of legal claims, whether in court proceedings or in an administrative or out-of-court procedure.
   The legal basis for this processing is our legitimate interests, namely the protection and assertion of our legal rights, your legal rights and the legal rights of others.
8. 3.13 We may process any of your personal data identified in this policy where necessary for the purposes of obtaining or maintaining insurance coverage, managing risks, or obtaining professional advice.
   The legal basis for this processing is our legitimate interests, namely the proper protection of our business against risks.
9. 3.14 In addition to the specific purposes for which we may process your personal data set out in this Section 3, we may also process any of your personal data where such processing is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person.
10. 3.15 Please do not supply any other person's personal data to us, unless we prompt you to do so.

1. 4.2 We may disclose your personal data to our insurers and/or professional advisers insofar as reasonably necessary for the purposes of obtaining or maintaining insurance coverage, managing risks, obtaining professional advice, or the establishment, exercise or defence of legal claims, whether in court proceedings or in an administrative or out-of-court procedure.
2. 4.3 We may disclose the personal data on our website (your name and email) to our web developers identified at https://whitewolfdevelopment.co.uk insofar as reasonably necessary for the maintenance and update of our website.
3. 4.6 In addition to the specific disclosures of personal data set out in this Section 4, we may disclose your personal data where such disclosure is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person. We may also disclose your personal data where such disclosure is necessary for the establishment, exercise or defence of legal claims, whether in court proceedings or in an administrative or out-of-court procedure.

1. 5.1 In this Section 5, , we provide information about the circumstances in which your personal data may be transferred to a third country under UK and/or EU data protection law.
2. from new version! If your personal data is sent from the European Economic Area (EEA) it will be transferred to the UK and we will process that personal data in the UK for the purposes set out in this policy, and may permit our our suppliers and subcontractors to do so, during any period with respect to which the UK is not treated as a third country under EU data protection law or benefits from an adequacy decision under EU data protection law; and we may transfer your personal data from the UK to the EEA and process that personal data in the EEA for the purposes set out in this policy, and may permit our suppliers and subcontractors to do so, during any period with respect to which EEA states are not treated as third countries under UK data protection law or benefit from adequacy regulations under UK data protection law.
3. 5.3 Our webserver(s) are located within the UK and any data you supply via the website may be stored on the webserver. We do not store personal data from the website outside of the UK.
4. 5.5 You acknowledge that personal data that you submit for publication through our website or services may be available, via the internet, around the world. We cannot prevent the use (or misuse) of such personal data by others.

1. 6.1 This Section 6 sets out our data retention policies and procedure for data held on our website, which are designed to help ensure that we comply with our legal obligations in relation to the retention and deletion of personal data.
2. 6.2 Personal data that we process for any purpose or purposes shall not be kept for longer than is necessary for that purpose or those purposes.
3. added In the case of personal data supplied to or processed by the website, your data will be retained until you close your account and request that your personal data be removed from the website. This should be initiated in the following way
   1. (a) Contact us using one of the methods in section 10 below. You will be required to provide appropriate evidence of your identity.
   Onc you have done this, any online account you have on the website will be closed and your data will be removed from the website within 28 days.
4. 6.5 Notwithstanding the other provisions of this Section 6, we may retain your personal data where such retention is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person.

1. 7.1 We may update this policy from time to time by publishing a new version on our website.
2. 7.2 You should check this page occasionally to ensure you are happy with any changes to this policy.
3. 6.5 We may notify you of changes to this policy by email

1. 8.1 In this Section 8, we have summarised the rights that you have under data protection law. Some of the rights are complex, and not all of the details have been included in our summaries. Accordingly, you should read the relevant laws and guidance from the regulatory authorities for a full explanation of these rights.
2. 8.2 Your principal rights under data protection law are:
   1. (a)the right to access;
   2. (b)the right to rectification;
   3. (c)the right to erasure;
   4. (d)the right to restrict processing;
   5. (e)the right to object to processing;
   6. (f)the right to data portability;
   7. (g)the right to complain to a supervisory authority; and
   8. (h)the right to withdraw consent.
3. 8.3 You have the right to confirmation as to whether or not we process your personal data and, where we do, access to the personal data, together with certain additional information. That additional information includes details of the purposes of the processing, the categories of personal data concerned and the recipients of the personal data. Providing the rights and freedoms of others are not affected, we will supply to you a copy of your personal data. The first copy will be provided free of charge, but additional copies may be subject to a reasonable fee.
   
   With respect to the data you have supplied to our website (or are able to supply to our website) you can access and amend it at any time by visiting 'My Details' and other user pages when logged into our website. With respect to other data the website may have generated about you this can also be viewed by visiting the relevant user pages when logged into our website.
4. 8.4 You have the right to have any inaccurate personal data about you rectified and, taking into account the purposes of the processing, to have any incomplete personal data about you completed.
   
   With respect to the data you have supplied to our website (or are able to supply to our website) you can access and amend it by visiting 'My Details' and other user pages when logged into our website.
5. 8.5 In some circumstances you have the right to the erasure of your personal data without undue delay. Those circumstances include: the personal data are no longer necessary in relation to the purposes for which they were collected or otherwise processed; you withdraw consent to consent-based processing; you object to the processing under certain rules of applicable data protection law; the processing is for direct marketing purposes; and the personal data have been unlawfully processed. However, there are exclusions of the right to erasure. The general exclusions include where processing is necessary: for exercising the right of freedom of expression and information; for compliance with a legal obligation; or for the establishment, exercise or defence of legal claims.
   
   With respect to the data you have supplied to our website (or are able to supply to our website) and any data that the website may have generated about you, you can request deletion of this data from the website. This should be initiated in the following way:
   1. (a) Contact us using one of the methods in section 10 below and request erasure of your personal details from the website. You will be required to provide appropriate evidence of your identity.
   Onc you have done this, any online account you have on the website will be closed and your data will be removed from the website within 28 days.
6. 8.6 In some circumstances you have the right to restrict the processing of your personal data. Those circumstances are: you contest the accuracy of the personal data; processing is unlawful but you oppose erasure; we no longer need the personal data for the purposes of our processing, but you require personal data for the establishment, exercise or defence of legal claims; and you have objected to processing, pending the verification of that objection. Where processing has been restricted on this basis, we may continue to store your personal data. However, we will only otherwise process it: with your consent; for the establishment, exercise or defence of legal claims; for the protection of the rights of another natural or legal person; or for reasons of important public interest.
7. 8.7 You have the right to object to our processing of your personal data on grounds relating to your particular situation, but only to the extent that the legal basis for the processing is that the processing is necessary for: the performance of a task carried out in the public interest or in the exercise of any official authority vested in us; or the purposes of the legitimate interests pursued by us or by a third party. If you make such an objection, we will cease to process the personal information unless we can demonstrate compelling legitimate grounds for the processing which override your interests, rights and freedoms, or the processing is for the establishment, exercise or defence of legal claims.
8. 8.8 You have the right to object to our processing of your personal data for direct marketing purposes (including profiling for direct marketing purposes). If you make such an objection, we will cease to process your personal data for this purpose.
9. 8.9 You have the right to object to our processing of your personal data for scientific or historical research purposes or statistical purposes on grounds relating to your particular situation, unless the processing is necessary for the performance of a task carried out for reasons of public interest.
10. 8.10 To the extent that the legal basis for our processing of your personal data is:
    1. (a)consent; or
    2. (b)that the processing is necessary for the performance of a contract to which you are party or in order to take steps at your request prior to entering into a contract,
    and such processing is carried out by automated means, you have the right to receive your personal data from us in a structured, commonly used and machine-readable format. However, this right does not apply where it would adversely affect the rights and freedoms of others.
11. 8.11 If you consider that our processing of your personal information infringes data protection laws, you have a legal right to lodge a complaint with a supervisory authority responsible for data protection. You may do so in the EU member state of your habitual residence, your place of work or the place of the alleged infringement.
12. 8.12 To the extent that the legal basis for our processing of your personal information is consent, you have the right to withdraw that consent at any time. Withdrawal will not affect the lawfulness of processing before the withdrawal.
13. 8.13 You may exercise any of your rights in relation to your personal data by written notice to us, in addition to the other methods specified in this Section 8. You will be required to provide appropriate evidence of your identity.

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1. 13.1 This website is owned and operated by Cambridge Guardians Ltd.
2. 13.2 We are registered in England and Wales under registration number 3039304, and our registered office is at 78 Hartington Grove, Cambridge, CB1 7UB, UK.
3. 13.3 Our principal place of business is at 78 Hartington Grove, Cambridge, CB1 7UB, UK.
4. 13.4 You can contact us:
   1. (a)by post, to the postal address given above;
   2. (b)using our website contact form;
   3. (c)by telephone, on the contact number published on our website from time to time; or
   4. (d)by email, using the email address published on our website from time to time.

1. 14.1 Our data protection officer's contact details are: Heather Dyos, 78 Hartington Grove, Cambridge, CB1 7UB, UK.