Privacy Policy

Introduction 

Welcome to the Corston privacy policy. 

Corston respects your privacy and is committed to protecting your personal data. This policy will inform you as to how we look after your personal data when you visit our website (regardless of where you visit it from) and tell you about your privacy rights and how the law protects you. 

This privacy notice is intended for 

  1. visitors to Corston’s website; 
  1. Corston’s consumer and business clients; 
  1. members of the general public who are interested in contacting Corston; and
  2. any individual who has received this notice.

1. Important information and who we are

Purpose of this privacy policy 

    This policy aims to give you information on how Corston collects and processes your personal data through your use of this website, including any data you may provide when you sign up to our newsletter, enquire about a product or service or take part in an event, conference or survey. 

    We understand that your privacy is important to you, and we are committed to treating your personal data with care and integrity. Our privacy notice tells you what personal data we collect and how we collect it, including any data you may provide through this website when you visit the site or enquire about a product or service or take part in an event. It explains what we use your personal data for and how we protect your personal data. This privacy notice explains our general practices. However, where local laws or regulations require that we process information differently, or refrain from such processing, we will always comply with the applicable local law. This website is not intended for children, and we do not knowingly collect data relating to children. 

    It is important that you read this privacy policy together with any other privacy policy or fair processing policy we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. This policy supplements other notices and privacy policies and is not intended to override them.  

    Controller 

    This privacy policy is issued on behalf of Corston Ltd (incorporated in England under company number 08553721, whose registered office is at Bremhill House, Bremhill, Calne, Wiltshire, SN11 9HN, UK). Corston Ltd is the controller and responsible for this website, trading as Corston so when we mention “Corston” or "we", "us" or "our" in this privacy policy, we are referring to Corston who is responsible for processing your data.  

    Contact details  

    If you have any questions about this privacy policy or our privacy practices, please contact us:  

    Full name of legal entity: Corston Ltd 

     Email address: hi@corston.com 

    You have the right to make a complaint at any time to the Information Commissioner's Office (ICO), the UK regulator for data protection issues (https://www.ico.org.uk/), or the data protection regulator in the country where you usually live or work, or where the alleged data protection infringement has taken place. We would, however, appreciate the chance to deal with your concerns before you approach the ICO or the applicable data protection regulator, so please contact us in the first instance. 

    Changes to the privacy policy and your duty to inform us of changes 

    We keep our privacy policy under regular review. This version was last updated on 8th November 2023. 

    It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.  

    Third-party links 

    This website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy policy of every website you visit. 

     2. The data we collect about you 

    Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data). 

    We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows: 

    • Identity data includes first name, maiden name, last name, or similar identifier, marital status, title, date of birth and gender; 
    • Contact data includes email address, postal code, preferences, interests and telephone numbers; 
    • Technical data includes internet protocol (IP) address, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, and other technology on the devices you use to access this website; 
    • Usage data includes information about how you use our website; 
    • Marketing and communications data includes your preferences in receiving marketing from us and your communication preferences; and 
    • Your purchases including your order history 

    We also collect, use and share aggregated data such as statistical or demographic data for any purpose. Aggregated data could be derived from your personal data but is not considered personal data in law as this data will not directly or indirectly reveal your identity. For example, we may aggregate your usage data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect aggregated data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy policy. 

    We do not collect any special categories of personal data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health, and genetic and biometric data). Nor do we collect any information about criminal convictions and offences. 

     3. How is your personal data collected? 

    We use different methods to collect data from and about you including through: 

    • Direct interactions. You may give us your identity and contact data by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you: 
    • enquire about our products or services; 
    • subscribe to our service or publications; 
    • request marketing to be sent to you (including newsletters); 
    • subscribe to an event, conference, webinar or survey;  
    • give us feedback or contact us;  
    • provide a comment on our blog; or 
    • place an order 

    Automated technologies or interactions. As you interact with our website, we will automatically collect technical data about your equipment, browsing actions and patterns. We collect this personal data by using cookies, server logs and other similar technologies. We may also receive technical data about you if you visit other websites employing our cookies. Please see our cookie policy for further details. 

    • Third parties or publicly available sources. We will receive personal data about you from various third parties as set out below: 
    1. analytics providers such as Google based outside the UK; 

     4. How we use your personal data 

    We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances: 

    • Where we need to perform the contract, we are about to enter into or have entered into with you; 
    • Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests; 
    • Where we need to comply with a legal obligation; and 
    • In order to offer you Klarna’s payment methods, we might in the checkout pass your personal data in the form of contact and order details to Klarna, in order for Klarna to assess whether you qualify for their payment methods and to tailor those payment methods for you. Your personal data is processed in line with Klarna’s privacy notice. 

    Generally, we do not rely on consent as a legal basis for processing your personal data although we will get your consent before sending direct marketing communications to you via email. You have the right to withdraw consent to marketing at any time by contacting us at hi@corston.com.  

    Purposes for which we will use your personal data 

    We have set out below a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate. 

    Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground, we are relying on to process your personal data where more than one ground has been set out in the table below.  

    Purpose/activity 

    Type of data

    Lawful basis for processing including basis of legitimate interest 

    To register you as a new customer, process your payment, and fulfil your order with us

    (a) Identity

    (b) Contact

    (c) Payment card or payment information (final four digits only)

    Performance of a contract with you

    To manage our relationship with you which will include:

    (a) Notifying you about changes to our terms or privacy policy

    (b) Asking you to leave a review or take a survey or comment on our blog posts

    (a) Identity

    (b) Contact

    (c) Marketing and communications

    (a) Performance of a contract with you

    (b) Necessary to comply with a legal obligation

    (c) Necessary for our legitimate interests (to keep our records updated and to study how customers use our products/services)

    To administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)

    (a) Identify

    (b) Contact

    (c) Technical

    (a) Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise)

    (b) Necessary to comply with a legal obligation

    To use data analytics to improve our website, products/services, marketing, customer relationships and experiences

    (a) Technical

    (b) Usage

    Necessary for our legitimate interests (to define types of customers for our products and services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy)

    To make suggestions and recommendations to you about goods or services that may be of interest to you. To send you email marketing communications

    (a) Identify

    (b) Contact

    (c) Technical

    (d) Usage

    (e) Marketing and communications

    Necessary for our legitimate interests (to develop our products/services and grow our business) and/or

    your consent to receiving direct marketing and communications

    Marketing 

    We strive to provide you with choices regarding certain personal data uses, particularly around marketing communications from us. 

    You will receive marketing communications from us if you have requested information from us and you have not opted out of receiving that marketing. 

    Other online services and third-party features 

    We may provide links to other online services and websites for your convenience and information, and may include third-party features such as apps, tools, widgets, and plug-ins (e.g. Instagram, Pinterest, Facebook and LinkedIn buttons). These services and websites may operate independently from us. The privacy practices of these third parties, including details on the information they collect about you, are subject to their own privacy statements. To the extent any linked online services or third-party features are not owned or controlled by us, and we are not responsible for these third parties’ information or other practices. 

    Third-party marketing 

    Corston does not share your personal data with any third party for marketing purposes. In the event we wish to do so, we will get your express opt-in consent before we share your personal data with any third party for marketing purposes. 

    Third-party web analytics services  

    We use third-party online analytics services, such as Google Analytics and HubSpot. The service providers that administer these analytics services use cookies and similar technologies to collect and analyse information about use of the site and report on activities and trends and diagnose technical issues. 

    To learn more about Google’s practices, please visit https://policies.google.com/technologies/partner-sites and opt out of them by downloading the Google Analytics opt-out browser add-on, available at https://tools.google.com/dlpage/gaoptout. To learn more about HubSpot's practices please visit https://www.hubspot.com/data-privacy/gdpr

    Opting out 

    You can ask us to stop sending you marketing messages at any time by following the opt-out links on any marketing message sent to you or by contacting us at any time at hi@corston.com

    You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of this website may become inaccessible or not function properly. For more information about the cookies we use, please see our cookie policy. 

    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. 

    5. Disclosures of your personal data 

    We may share your personal data with the parties set out below for the purposes set out in the 

    Purposes for which we will use your personal data table above. 

    We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions. 

    6. International transfers 

    Your personal data may be used, stored and/or accessed by staff operating outside the UK and EEA working for us, other members of our group or suppliers. If we transfer your personal data outside the UK or EEA, we will take appropriate security measures to ensure the respective receipt protects your personal data adequately in accordance with this privacy policy. These measures may include the following:  

    • To countries that have been deemed to provide an adequate level of protection for personal data by the UK and/or EU Commission  
    • To entities in countries based outside the UK and EEA, by entering into the European Commission approved Standard Contractual Clauses and/or the UK equivalent with them 

    7. 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. 

    8. Data retention 

    How long will you use my personal data for? 

    We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you. Insofar as the processing of personal data is based on your consent, we will delete this data if you withdraw your consent. 

    To determine the appropriate retention period for personal data, we consider the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements. 

    9. Your legal rights 

    Under certain circumstances, you have rights under data protection laws in relation to your personal data.   

    If you wish to exercise any of the rights, please contact us at hi@corston.com. 

    No fee usually required 

    You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we could refuse to comply with your request in these circumstances. 

    What we may need from you 

    We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response. 

    Time limit to respond 

    We try to respond to all legitimate requests within one month. Occasionally it could take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated. 

    10. Glossary

    LAWFUL

    BASIS 

    Legitimate interest means the interest of our business in conducting and managing our business to enable us to give you the best service/product and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us. 

    Performance of contract means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract. 

    Comply with a legal obligation means processing your personal data where it is necessary for compliance with a legal obligation that we are subject to. 

    THIRD PARTIES 

    External third parties 

    • Service providers who provide IT and system administration services 
    • Professional advisers including lawyers, bankers, auditors and insurers who may provide consultancy, banking, legal, insurance and accounting services 
    • HM Revenue & Customs, regulators and other applicable authorities who require reporting of processing activities in certain circumstances 
    • Klarna, if you chose to use their payment methods to complete your purchase on our website 

    YOUR LEGAL RIGHTS 

    You have the right to: 

    Request access to your personal data (commonly known as a "data subject access request"). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it. 

    Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us. 

    Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request. 

    Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms. 

    Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios: 

    • If you want us to establish the data's accuracy; 
    • Where our use of the data is unlawful, but you do not want us to erase it; 
    • Where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or 
    • You have objected to our use of your data, but we need to verify whether we have overriding legitimate grounds to use it 

    Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you. 

    Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.