PRIVACY POLICY

Thames and Kosmos UK LP (“Company”, “we” or “us”) based at 20 Stone Street, Cranbrook, Kent TN17 3HE is the data controller for the purposes of data protection and privacy laws and is therefore responsible for personal information collected and processed as described in this privacy policy. We take our data protection and privacy responsibilities seriously and you can find out more about how we handle your personal information using the links below:-

This privacy policy sets out the basis on which any personal information we collect about you will be used and processed by us in the course of our business activities, including:

How we share personal information within Thames and Kosmos, and what we use it for

Explaining more about direct marketing

How we protect and store personal information

Legal rights available to help manage your privacy

How you can contact us for more support

 

Third Party Websites

You will find links to third party websites (e.g. social media pages such as LinkedIn, Twitter and YouTube) on our websites. Please note that this privacy policy only applies to personal information collected from our website pages. Where you access a third-party website, this privacy policy does not apply to that website. Please refer to the privacy policies of these websites and ensure you are happy with their practices in relation to your personal information before you provide your personal information to the third-party site.

 

WHAT PERSONAL INFORMATION WE COLLECT AND WHEN AND WHY WE USE IT

We collect information about you if you:

  • register with or use one of the Thames and Kosmos or Kosmos websites
  • are a Thames and Kosmos or Kosmos customer
  • visit our stand at a trade show and give us your details
  • or one of your colleagues who has previously been employed in your position has contacted us with regard to using our services, and we have been informed by a person in your company that you have taken up their position.

(collectively “you”).

Please note that in the course of a sale, we would need to share data with our warehouse (Horizon Logistics) in order to forward your purchases to you. We would also need to share your details with a courier, if we are delivering cartons.

If you provide us with personal information about another individual, e.g. a colleague or associate’s details, we expect you to ensure that they know you are doing so and are happy with their information being provided to Thames and Kosmos UK LP. The information will be used in accordance with this privacy policy so please encourage them to read this policy to find out more about what we do with their personal information.

 

Information you provide when you contact us

We collect personal information when you contact us online, by phone or by post in relation to a query, purchase or a complaint. This information will include your name, phone number, any personal information in or relevant to the resolution of your enquiry, purchase or complaint.

We will use your personal information to answer your queries, process your order, or handle your complaints and fulfil any requests you make to us.

 

Legal basis for using your personal information

We will only collect, use and share your personal information where we are satisfied that we have an appropriate legal basis to do this. This will be based on at least one of the following conditions:

  • we need to use your personal information to perform a contract or take steps to enter into a contract with you. For example, to deliver or to take payment for the products we provide you.
  • we need to use your personal information for our legitimate interest as a commercial organisation. For example, for marketing purposes, or to evaluate information to understand how people use our services, in order to improve them. In all such cases, we will look after your information at all times in a way that is proportionate and respects your privacy rights and you have a right to object to processing as explained in the Legal Rights section below; and/or
  • we need to use your personal information to comply with a relevant legal or regulatory obligation that we have. For example, we are required to retain some personal information in order to fulfil our tax obligations.

If you would like to find out more about the legal basis for which we process personal information please [contact us / click here].

 

SHARING PERSONAL INFORMATION WITH OTHERS

In this section you can find out more about how we share personal information:

·       with third parties that help us provide our services

·       with government organisations and agencies, law enforcement and regulators

We do not routinely transfer personal information outside the European Economic Area

We share your personal information in the manner and for the purposes described below:

  • your personal information will be held on our computers in the UK and will be accessed by our staff as necessary to provide you with our services and to manage our business;
  • we will share your personal information with third parties who help manage our business and deliver services. These third parties have agreed to confidentiality restrictions and to use any personal information we share with them or which they collect on our behalf solely for the purpose of providing the contracted service to us. These include:
  • IT service providers who help manage our IT and back office systems or provide us services in relation to our websites or our applications;
  • organisation who help with organising or running our business, for example, IT services and accountants.
  • with government organisations and agencies, law enforcement, regulators, which includes the Information Commissioner’s Office, to comply with all applicable laws, regulations and rules, and requests of law enforcement, regulatory and other governmental agencies. If we receive requests for information from law enforcement or regulators, we will carefully validate these requests before any personal information is disclosed;

You have a right to contact us for more information about the safeguards we have put in place (including a copy of relevant contractual commitments) to ensure the adequate protection of your personal information when this is transferred as mentioned above.

 

EXPLAINING MORE ABOUT DIRECT MARKETING

In this section you can find out more about:

·  how we use personal information to keep you up to date with our products and services.

·  how you can manage your marketing preferences

How we use personal information to keep you up to date with our products and services

We use personal business information to let you know about our products and services that we believe will be of interest to you. We will contact you by email or through other communication channels that we think you may find helpful. In all cases, we will respect your preferences for how you would like us to manage marketing activity with you.

 

How you can manage your marketing preferences

To protect privacy rights and to ensure you have control over how we manage marketing with you:

  • we will take steps to limit direct marketing to a reasonable and proportionate level;
  • only send you communications which we believe will be of interest or relevance to you and at all times in line with your permissions;
  • at any time you can update or correct your personal business information. We will cease further communication with you upon your request;
  • you can ask us to stop direct marketing at any time ‑ you can ask us to stop sending email marketing, by emailing any Thames and Kosmos employee, with the subject matter OPT OUT
  • you can change the way your browser manages cookies, by following the settings on your browser as explained in our Cookie Policy.

We recommend you routinely review the privacy notices and preference settings that are available to you on any social media platforms as well as your preferences within your account with us.

 

HOW WE PROTECT AND STORE YOUR INFORMATION

In this section you can find out more about:

·       the measures we have put in place to secure your personal information

·       our policy in relation to children’s personal information

·       for how long we store your personal information 

Security

We have implemented and maintain appropriate technical and organisational security measures, policies and procedures designed to reduce the risk of accidental destruction or loss, or the unauthorised disclosure or access to such information appropriate to the nature of the information concerned.

Measures we take include:

  • placing confidentiality requirements on Thames and Kosmos staff and service providers;
  • destroying or permanently anonymising personal information if it is no longer needed for the purposes for which it was collected;
  • following strict security procedures in the storage and disclosure of your personal information to prevent unauthorised access to it;
  • As the security of information depends in part on the security of the computer you use to communicate with us and the security you use to protect user IDs and passwords, please take appropriate measures to protect this information.

 

Children

We do not knowingly collect information from children. Our website is targeted at adults, and on-line registration is restricted to adults who are professionally engaged in the businesses we serve. The exception to this rule occurs when details are taken about children who are involved directly with the press for example bloggers and vloggers. On these occasions the details of a guardian are taken to ensure to protect the interests of the children. If you are under 18, you may not use our websites, our services, or provide any information to our websites without involvement of a parent or a guardian. We do not knowingly collect information from, and/or about children without the involvement of a parent or a guardian.

 

Storing your personal information

We will store your personal information for as long as is reasonably necessary for the purposes for which it was collected, as explained in this privacy policy. Where your information is no longer needed, we will ensure that it is disposed of in a secure manner. In some circumstances we store your personal information for longer periods of time, for instance where we are required to do so in accordance with legal, regulatory, tax or accounting requirements.

In specific circumstances we store your personal information for longer periods of time so that we have an accurate record of your dealings with us in the event of any complaints or challenges, or if we reasonably believe there is a prospect of litigation relating to your personal information or dealings.

Please contact us if you have any questions regarding how long we store your personal information.

 

Right to access personal information

You have a right to request that we provide you with a copy of your personal information that we hold and you have the right to be informed of; (a) the source of your personal information; (b) the purposes, legal basis and methods of processing; (c) the data controller’s identity; and (d) the entities or categories of entities to whom your personal information may be transferred.

 

Right to rectify or erase personal information

You have a right to request that we rectify inaccurate personal information. We will seek to verify the accuracy of the personal information before rectifying it. You can also request that we erase your personal information. We are not required to comply with your request to erase personal information if the processing of your personal information is necessary:

  • for compliance with a legal obligation; or
  • for the establishment, exercise or defence of legal claims;

 

Right to object to the processing of your personal information

You can object to any processing of your personal information which has our legitimate interests as its legal basis, if you believe your fundamental rights and freedoms outweigh our legitimate interests.

If you raise an objection, we have an opportunity to demonstrate that we have compelling legitimate interests which override your rights and freedoms.

 

Right to object to how we use your personal information for direct marketing purposes

You can request that we change the manner in which we contact you for marketing purposes.

 

Right to obtain a copy of personal information safeguards used for transfers outside your jurisdiction

You can ask to obtain a copy of, or reference to, the safeguards under which your personal information is transferred outside of the European Union.

We may redact data transfer agreements to protect commercial terms.

 

Right to lodge a complaint with your local supervisory authority

You have a right to lodge a complaint with your local supervisory authority if you have concerns about how we are processing your personal information.

We ask that you please attempt to resolve any issues with us first, although you have a right to contact your supervisory authority at any time.

 

CONTACT US

The primary point of contact for all issues arising from this privacy policy is our Privacy Officer. Our Privacy Officer can be contacted in the following ways:

  • by email: accounts@thamesandkosmos.co.uk
  • In writing: 20 Stone Street, Cranbrook, Kent TN17 3HE

If you have any questions, concerns or complaints regarding our compliance with this privacy policy, the information we hold about you or if you wish to exercise your rights, we encourage you to first contact our Privacy Officer. We will investigate and attempt to resolve complaints and disputes and make every reasonable effort to honour your wish to exercise your rights as quickly as possible, and in any event, within the timescales provided by data protection laws.

 

To contact your data protection supervisory authority

You have a right to lodge a complaint with your local data protection supervisory authority, which in the UK is the Information Commissioner’s Office, at any time. We ask that you please attempt to resolve any issues with us before you contact your local supervisory authority.

 

 

Issue Date of Privacy Notice: 25 May 2018