Calverley Ltd (DBA Custom KeySmart) is a business gifting supplier and reseller.
Calverley Ltd, based in the United Kingdom (Registered No. 5027249) is committed to protecting your privacy in accordance with the Data Protection Act 1998 (the ‘Act’) and the General Data Protection Regulation (the ‘GDPR’). If you have any questions about this policy, the representative responsible for Data Protection, the Data Protection Officer, can be contacted by writing to the address below or alternatively by sending an email to firstname.lastname@example.org. Our registered address is (51 The Pantiles, Tunbridge Wells, Kent, TN2 5TE, United Kingdom)
2. What information do we collect?
To use some of our services, you must provide your name, address, email address and in some instances your company name, job title and telephone number. In order to make payments, you must provide credit card, debit card or bank account information. In some cases, we will direct you to one of our service providers who only act under our contractual instructions in order to collect this information from you and fulfil your order. We do not collect any special category data such as information on your racial or ethnic origins, political opinions, trade union affiliations, sexual life or criminal history.
When you access our services online using any device, we collect and store device data including but not limited to geolocation data to provide offers relevant to your region (using cookies). We also collect information such as which pages of our website you visit, IP addresses, the type of browser you use, details of the transactions you have made, time spent on the website, the type of device you are using, and the times you access our website.
We will only keep your information for as long as is necessary for the purpose of providing you with the service you have requested from us or to meet specific anti-fraud and legal requirements. If you would like more information, please contact the Data Protection Officer.
The provision of the information detailed above is a requirement necessary to provide our services. By providing your information and using our service you are entering a contract for the term of the service. If you object or are not willing to provide this information, please do not register or use these services.
3. What do we do with the collected information?
Our primary purpose in collecting your information is to provide you with a service. You agree that we may use your personal information to:
- Provide the service to you
- Notify you about your service
- Carry out internal administration and analysis
- Monitor or improve the performance of, and products and services available through, our websites
If you purchase our products, you will enter into a contract with us. This means that during the contractual period we will communicate with you about this contract. In this respect ‘performance of a contract’ is our legal basis for processing your data.
Similarly, supplier data will be processed under ‘performance of a contract’ if the third party enters into a commercial contract with us.
For client prospect data, we will use ‘Legitimate Interest’ as our legal basis for contacting prospective clients. An opt out for these types of communication will be offered on the channel used, for example, via email or telephone call.
4. How is your information used for marketing?
We will only send you direct marketing communications in circumstances where we have your specific consent or where we believe we can demonstrate a legitimate interest.
When you sign up to any of our services, we ask for your consent to send you direct marketing communication over a variety of channels. We will honour your right to withdraw your consent at any time.
When you enquire about or request a service from us, we may rely on our legitimate business interests to send you marketing communications (via post, email or telephone). This relates to customers and suppliers. These communications will always be related to our services and we believe will be of interest to you. We will always provide you with the opportunity to opt-out of marketing communications when you provide your information to us.
If you want to stop receiving direct marketing from us, you can use the unsubscribe mechanism on any email you receive, tell us when we call you, or alternatively you can contact the Data Protection Officer using the details available in the introduction.
We use web beacons in our emails to track the success of our marketing campaigns. If you open an email from us, we can see which of the pages of our website you visited. Our web beacons communicate with our cookies on your computer and they can tell us when you have opened an email from us. We keep track of the emails that we send you. We also keep a record of what communications you have selected to receive or not to receive. We will only send you marketing emails if you have consented to receive these. You are able to access your preference centre from any marketing email that we send you and update your preferences through this mechanism. You may also unsubscribe by clicking on the ‘unsubscribe’ link in any of our emails to you, or responding with ‘unsubscribe’.
Data Profiling and Remarketing
Periodically we conduct data profiling on the information we collect to better understand our customers in order to provide targeted communications which suit your needs. We rely on ‘legitimate interests’ as our lawful basis for processing this data.
Some of our websites use the Linkedin Insight tag which allows us to analyse behaviour on our own websites and then remarket with relevant messages via LinkedIn. An insight tag is code placed on our website. It helps track conversions from Linkedin ads, optimize ads based on collected data, build targeted audiences for future ads, and remarket to qualified leads. We rely on ‘legitimate interests’ as our lawful basis for processing this data.
We sometimes use Linkedin to create lookalike audiences based on profiling our subscribers.
We also use the Google Display Network as a channel for remarketing to our users.
We may serve targeted adverts for our own products based on user behaviour on our own websites.
Legitimate interest is used as the lawful basis for data profiling and remarketing. However, if we target email data for this activity we will use opted in data where the user has consented to marketing.
If you wish to stop your information being used for data profiling and remarketing, please contact the Data Protection Officer.
5. Sharing your data with 3rd parties.
We will not sell or rent your information to third parties for their marketing purposes without your consent. However, just like most service providers, Calverley Ltd (DBA Custom KeySmart) works with third parties who administer important functions for us that allow us to offer and enhance the services we provide. These providers are covered by an appropriate agreement. Sometimes it will be necessary for us to disclose information required for the specific purpose to them so that the services can be performed.
We reserve the right to disclose to third parties your information to comply with applicable laws including but not limited to disclosure in accordance with the Act, the Regulation of Investigatory Powers Act 2000 and lawful authority requests, to safeguard the proper operation of our systems and to protect ourselves and the companies we work with.
The third parties we work with are;
- Subscription bureau to fulfil orders and manage subscriber data
- Email Service Provider (ESP) for sending emails, organising and managing competitions, and managing user email preferences
- Survey platform for administering surveys or polls
- Google Analytics for website analysis and data analysis & profiling
- Google Adsense to serve interest-based adverts
- Payment processors for processing credit card payments
- Agent websites which sell our products on our behalf
- Conversion Rate Optimisation (CRO) agencies
- Marketing Automation Platform providers
- ERP system providers
- Data enhancing and cleaning providers
Calverley Ltd is committed to handling your information with high standards of information security. We collect, store and process your information on servers primarily located in the United Kingdom.
7. Storing Your Information
Accessing Your Information : You can access the personal information you have provided us by making a Subject Access Request to the Data Protection Officer using the details available in the Introduction. Upon receipt and following any necessary proof of identification checks, Subject Access Requests will be responded to within one calendar month.
Deleting Your Information : A request to have the personal information you have provided to us removed from our systems can be made to the Data Protection Officer using the details available in the Introduction. Your information will be removed from our systems except in circumstances where we are required to retain this information for compliance with legal obligation or for future suppression purposes, where the minimal amount necessary will be retained in order to honour an individual’s right.
Updating Your Information : You can review the personal information you have provided to us and make any desired changes or rectifications at any time either online or by contacting the Data Protection Officer using the details available in the Privacy Summary.
The Right to Object : The GDPR gives individuals the right to object to the processing of their personal data in certain circumstances. Individuals have an absolute right to stop their data being used for direct marketing. An individual can make an objection verbally or in writing. We will respond to an objection within one calendar month.
8. Policy in regards to Children
Children are not eligible to use any service we offer and we ask that minors (persons under the age of 18) do not submit any personal information to us.
9. Queries or Concerns
Calverley Ltd (DBA Custom KeySmart ) may place cookies, which are small text files, on your computer to distinguish you from other users of this website. These cookies monitor how you use this website so that we can make improvements, and give you the best user experience. Some cookies may also be placed by third parties, for example Linkedin and Google, if you use their services via this website to monitor how you use their services and also to target relevant advertising to you when you visit other websites on which they advertise.
In most cases, cookies do not contain personally identifiable data.
Our websites may use the following types of cookies:
- Strictly necessary cookies (Type 1): these cookies are essential in order to enable you to move around this website and use its features, such as accessing secure areas of this website. Without these cookies, certain services you have asked for cannot be provided.
- Analytical/performance cookies (Type 2): these cookies allow us to recognise and count the number of visits to our websites and to see how visitors move around the websites when they are using it, so that we can improve how the websites work. These cookies do not collect personally identifiable information.
- Functionality cookies (Type 3): these cookies remember choices you make to improve your experience; for example, your user name, language or region.
- Targeting cookies (Type 4): these cookies are placed by third parties to collect information about your browsing habits when you elect to use their services, in order to make advertising relevant to you and your interests.
Most web browsers allow some control of most cookies through the browser settings. To find out more about cookies, including how to see what cookies have been set and how to manage and delete them, visit www.allaboutcookies.org. You should note that deleting certain cookies may prevent you from accessing certain parts of our websites and/or may affect your user experience.
To opt out of being tracked by Google Analytics across all websites, and not just our websites, visit: http://tools.google.com/dlpage/gaoptout.