Rayware Limited and all members of its group of companies, as defined below, ("We" or “Us”) are committed to protecting and respecting your privacy. Rayware Limited includes the brands Kilner, Mason Cash, Viners, Typhoon, Price & Kensington and Ravenhead
This policy sets out the basis on which any personal data We collect from you, or that you provide to Us, will be processed by Us. Please read the following carefully to understand our views and practices regarding your personal data and how We will treat it. By visiting our site you are accepting and consenting to the practices described in this policy.
Who We are and how to contact Us
For the purpose of the UK General Data Protection Regulation (UK GDPR), Data Protection Act 2018 or successor national implementing laws, regulations and legislation, as amended or updated from time to time(the “Legislation”), the data controller is Rayware Limited of 26-32 Spitfire Road Liverpool L24 9BF. You can also contact Us by email Us at email@example.com
This policy is effective from 18th November 2021.
Any changes you make to your communication preferences will be processed by Us within three working days of our receipt of your instruction; however, you may still receive non-essential communications in the intervening time between the submission of your change and when We process that change.
We are registered as a fee payer with the Information Commissioner’s Office, with registration number: Z7216458.
For all data protection queries please contact us at firstname.lastname@example.org
What We will do with information
i) “you” means an individual who visits our site or otherwise provides information to Us;
“personal data” or “personal information” means any information relating to an identified or identifiable natural person from which you can be identified directly or indirectly. We process your Personal Data in accordance with the Legislation and guidance issued from the ICO amended from time to time
Lawfulness of our Processing
Under the UK GDPR the lawful bases we rely on for processing personal information about you,:are:
1) We have a contractual obligation: We Process personal information about you in order to fulfil any order you place via our site for future marketing communications that may not meet the soft-opt in requirements of the Privacy and Electronic Communication Regulations (‘PECR’);
2) Your consent: where We have asked for your consent in the box that pops up when you first visit our site and/or as part of the ordering process for future marketing communications that may not meet the soft-opt in requirements of the Privacy and Electronic Communication Regulations (‘PECR’). You are able to remove your consent at any time by contacting email@example.com.
Personal Information that We collect
We will collect and process the following data about you:
· Information you give Us. This is information about you that you give Us by filling in forms on our site (our site) or by corresponding with Us by phone, e-mail or otherwise. It includes information you provide when you register to use our site, search for a product, place an order on our site, sign up to our newsletter, register your Viners guarantee, contact us and when you report a problem with our site. The information you give Us may include your name, address, e-mail address and phone number, date of birth, demographic information such as postcode, preferences and interests and other information relevant to customer surveys and/or offers. When placing an order, we won't store payment details but will hold your name, email address, phone number and product ordered in case we need to refer back to this in the case of faulty goods or claims.
· Information We collect about you. With regard to each of your visits to our site We will automatically collect the following information:
· technical information, including the Internet protocol (IP) address used to connect your computer to the Internet, your login information, browser type and version, time zone setting, browser plug-in types and versions, operating system and platform;
· information about your visit, including the full Uniform Resource Locators (URL), clickstream to, through and from our site (including date and time), products you viewed or searched for, page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs), methods used to browse away from the page and any phone number used to call our customer service number.
· Information We receive from other sources. This is information We receive about you if you use any other websites We operate or other services We provide. In this case We will have informed you when We collected that data if We intend to share those data internally and combine it with data collected on this site. We will also have told you for what purpose We will share and combine your data. We are working closely with third parties to request product reviews by agreeing to our terms and conditions you confirm that we can send you product review requests. We also use third parties to enable Live Chat on the site and to process payments. We will notify you when We receive information about you from them and the purposes for which We intend to use that information.
Why do We collect it and how do We use it?
ESSENTIAL USES: We need the personal information We collect to send you essential information about your purchases and also to help Us with the operation of our site. For example:
- to allow you to register to use our site by sending an email to you to confirm your details and to enable you to commence using our services and purchase our products;
- to respond to any queries you raise with Us and otherwise provide customer support;
- to send you a password reset link if you tell Us that you have forgotten your password;
- as part of our efforts to keep our site safe and secure;
- in case We have any queries concerning any aspect of your use of our site;
- to ensure that content from our site is presented in the most effective manner for your device;
- to allow you to participate in interactive features of our site when you choose to do so;
- to administer our site and for internal operations, including troubleshooting, data analysis, testing and research;
- to measure or understand the effectiveness of advertising We serve to you and others;
- to prevent or investigate prohibited activity; and,
- to enforce the terms and conditions relating to any sale of goods via our site.
You have the right to ask Us to restrict processing of your personal data, to withdraw consent were we are relying on it to process your personal data and a right to object to our processing of your personal data in this way. If you exercise either of these rights you may not be able to make full use of our site and/or We may not be able to provide you with information that you have requested Us to provide to you.
For example, We may use personal information to send you promotional or marketing information about Us, our newsletters (where you subscribe to receive them) or anything in which you show an interest.
Information We collect that is not personal information
Information that is not personal information is not protected by data protection law but We may use such information in the following ways:
· We may anonymise data about our site users generally and use it for a range of purposes, including ascertaining the general location of users. This anonymised data is incapable of being used to identify anyone personally.
· We may aggregate user information so that it is impossible from the aggregated set of data to identify anyone individually, which is valuable to Us for the purposes of analysing market trends. You confirm that you consent to Us viewing, monitoring, collecting and recording information input by you into our site, and to our dealing with it on an aggregated basis, in a manner that does not identify you or attribute any particular information to you. You also agree to Us collating, compiling, reformatting, reproducing, adapting, translating, arranging, publishing, selling, distributing, dealing with or otherwise commercially exploiting any part of such information or otherwise making it available to any third party on such terms as We deem appropriate. Please rest assured that this will not include personal data.
Who do We give information to?
However, you agree that We have the right to share your personal information with:
Any member of our group, which means our subsidiaries, our ultimate holding company and its subsidiaries, as defined in section 1159 of the UK Companies Act 2006. We own the following brands; Viners, Kilner, Mason Cash, Typhoon, Price & Kensington and Ravenhead.·In limited circumstances, where permitted by law, we may need to share your personal data with:
· a prospective seller of buyer in the event that We sell or buy any business or assets;
· a third party, if Rayware Limited or substantially all of its assets are acquired by a third party, in which case personal data held by it about its customers will be one of the transferred assets; and,
As stated above, We may commercially exploit any anonymised or aggregated information on the basis that no individuals are identified or identifiable.
Third party websites
Communication, engagement and actions taken through external social media platforms on which We may participate on are subject to the terms, conditions and privacy policies held with each social media platform respectively. We will never ask for personal information through social media platforms and We encourage users wishing to discuss sensitive details to contact Us through primary communication channels such as by telephone or email. Our site may use social sharing buttons which help share web content directly from web pages to the social media platform in question. You are advised before using such social sharing buttons that you do so at your own discretion and note that the social media platform may track and/or save your request to share a web page through your social media platform account.
We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for. We comply with current best practice guidelines for the retention of your Personal Data. To determine the appropriate retention period for Personal Data, we consider the amount, nature and sensitivity of the Personal Data We hold and the potential risk of harm from unauthorised use or disclosure of your personal data.
Where We store your Personal Data
We have in place appropriate technical and security measures to prevent unauthorised or unlawful access to or accidental loss of or destruction or damage to your information. We store your personal details on a secure server. We use firewalls on our servers. Where We have given you (or where you have chosen) a password which enables you to access certain parts of our site, you are responsible for keeping this password confidential. You are responsible for protecting against unauthorised access to your password and to your computer and you must not share a password with anyone.
Unfortunately, the transmission of information via the internet is not completely secure. We have put in place procedures and technologies to maintain the security of your personal data from the point of collection to the point of destruction. We cannot guarantee the security of your data transmitted to our site; any transmission is at your own risk. Once We have received your information, We will use strict procedures and security features to try to prevent unauthorised access. We endeavour to mitigate any external risks effecting the security of your personal data through technical and organisational measures.
The data that We collect from you may be transferred to, and stored at, a destination outside the United Kingdom. Where there are adequacy regulations in respect of those countries this means that when We transfer your data they are deemed to provide an adequate level of protection for your personal protection. Where there are no adequacy regulations in respect of a country We will ensure that your Personal Data receives an adequate level of protection to ensure that your personal information is treated by those third parties in a way which is consistent with and which respects UK law on data protection,.
To limit the risk of any personal data being breached, We have put in place appropriate security measures. This includes limiting access to your personal data to our employees. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.
All key Rayware Ltd employees have received data protection training and data protection awareness has been communicated within the wider team. We take the following steps to maintain data security:
· only a few members of staff have access to our website data;
· passwords are updated regularly;
· We do not hold passwords for customer accounts;Our building is secured with key fob access during business hours;
· visitors are required to sign in and out at reception;
· the building is secured overnight with only senior members of staff having access;
· system updates are installed in a timely fashion after release; and,
· our web site(s) are hosted by UK Fast who are fully compliant with UK data protection legislation.
You have the following rights in respect of your personal information:
i) Right of access: the right to request from Us copies of your personal data;
ii) Right to rectification: the right to ask Us to rectify personal information you think is inaccurate. You also have the right to ask us to complete information you think is incomplete;
iii) Right to erasure: the right to request erasure of your personal data in certain circumstances;
iv) Right to restriction of processing: the right to ask Us to restrict processing of your personal data and a right to object to our processing of your personal data (but if you do either of these, it may impact on your use of our site and/or We may not be able to provide you with information that you have requested Us to provide to you);
v) Right to object to processing: the right to object to the processing of your personal information in certain circumstances;
vi) Right to data portability: the right to ask that We transfer the personal information we have about you to another organisation, or to you, in certain circumstances.
vii) Right to lodge a complaint about how We treat your personal data with the Information Commissioner’s Office.
You are not required to pay any charge for exercising your rights. If you make a request, we have one month to respond to you.
If you wish to discuss or make a request in respect of any of the above rights, please contact Us at firstname.lastname@example.org
How long we keep personal information
If you agree to be added to our mailing list, We will keep your personal information for that purpose unless and until you tell Us that you want to unsubscribe or be removed from the list. If you advise that you do not want to be added to our mailing list or you ask to be removed, We will delete your Personal Data (aside from keeping a record that you have asked Us not to send you marketing information).
A cookie is a small file which asks permission to be placed on your computer’s hard drive. Once you agree, the file is added and the cookie helps analyse web traffic or lets you know when you visit a particular website. Cookies allow web applications to respond to you as an individual. The web application can tailor its operations to your needs, likes and dislikes by gathering and remembering information about your preferences.
We use necessary cookies which make the website useable by enabling basic functions like page navigation and access to secure areas of the website. The website cannot function properly without these cookies.
We use traffic log cookies to identify which pages are being used. This helps Us analyse data about web page traffic and improve our site in order to tailor it to customer needs. We only use this information for statistical analysis purposes and then the data is removed from the system.
Overall, cookies help Us provide you with a better website, by enabling Us to monitor which pages you find useful and which you do not. A cookie in no way gives Us access to your computer or any information about you, other than the data you choose to share with Us.
You can choose to accept or decline cookies. Most web browsers automatically accept cookies, but you can usually modify your browser setting to decline cookies if you prefer. This may prevent you from taking full advantage of our site. You can find out how to reject or delete cookies by following the instructions for your browser set out here
Where you have given Us consent to use your personal information in any way, you have a right to withdraw that consent at any time.
If you have any concerns about the use of your personal information, you can make a complaint to us at email@example.com.
can also complain to the ICO if you are unhappy with how we have used your
Information Commissioner’s Office
Helpline number: 0303 123 1113 ICO website: https://www.ico.org.uk
The ICO’s address:
Information Commissioner’s Office
Helpline number: 0303 123 1113
ICO website: https://www.ico.org.uk