CSS Platinum
Privacy Notice

CSS Platinum Privacy Notice

This Privacy Notice is v1.0.0 and is valid from 0001hrs on 27 January 2020. It replaces and supersedes all other Privacy Notices associated with CSS Platinum.

CSS Platinum takes your privacy very seriously. This Privacy Notice details what personal data we collect and how we shall use it. Please take time to read this Privacy Notice and ensure that you understand its contents.

Changes to this Privacy Notice.

We continually review our Privacy Notice and update it where necessary. We advise that you regularly check our Privacy Notice for updates. CSS Platinum does not wish to inconvenience their clients with lots of minor amendments, but where we make significant changes to our policy, we shall contact you to inform you.

Your personal data – what is it?

Personal data relates to information about a living individual who can be identified from that data. Identification can be by the information alone or in conjunction with any other information in the data controller’s possession, or likely to come into such possession. From 25 May 2018, the processing of personal data is governed by the General Data Protection Regulation (GDPR). In the event that the United Kingdom leaves the European Union on 31 October 2019 the processing of Personal Data shall be governed by the Data Protection Act 2018.

Our Name & Contact Details.

The Data Controller of your personal data is CSS Platinum. CSS Platinum is a trading style of CSS Platinum Limited. This means that CSS Platinum decides how your personal data is processed and for what purposes. Our contact details are:

CSS Platinum Limited

Burleigh Manor

Peel Road

Douglas

Isle of Man

IM1 5EP

Data Protection Officer Contact Details.

In observance of the General Data Protection Regulation, the Data Protection Act 2018 and other International Data Protection Regulation, CSS Platinum have chosen to establish a Data Protection Officer. Should you wish to contact our Data Protection Officer regarding a data protection matter you can do so by emailing [email protected] or writing to:

Data Protection Officer

CSS Platinum Limited

Burleigh Manor

Peel Road

Douglas

Isle of Man

IM1 5EP

For what purposes do we process personal data, and what are the lawful basis’ by which we process data?

CSS Platinum processes your Personal Data for the following purposes:

For What Purposes Do We Process Personal Data?

“CSS Platinum processes your personal data to…”

What is the lawful basis by which we process data?

Communicate with clients to fulfil, administer or enforce contractual obligations via email, telephone, SMS text, postal mail and push notifications;

Contract

Communicate with clients where we have their consent to do so via email, telephone, SMS text, postal mail and push notifications;

Consent

Communicate with clients on matters where we have a legal obligation to do so via email, telephone, SMS text, postal mail and push notifications;

Legal Obligation

Communicate with clients on matters where we have a legitimate Interest to do so (see legitimate interest section below), via email, telephone, SMS text, postal mail and push notifications;

Legitimate Interest

Communicate news, events, activities and services provided by CSS Platinum to those who have consented;

Consent

Inform existing clients about CSS Assure’s new products and services;

Legitimate Interest

Request specific consent to share information about specific aligned/similar products/services with specific fulfilment partners;

Legitimate Interest

Verify the identity of individuals where necessary including for Subject Access Requests (SAR);

Legitimate Interest

Update clients about significant changes to our Privacy Notice via email, telephone, SMS text, postal mail;

Legal Obligation

Update clients about changes to how we process their personal data and/or new processing activities via email, telephone, SMS text, postal mail;

Legal Obligation

Gather feedback for service and product improvement via email, telephone, SMS text, postal mail;

Legitimate Interest

Share testimonials, case studies and feedback on CSS Platinum website and in future marketing;

Consent

Manage our staff

Contract

Resolve complaints and/or disputes;

Legitimate Interest

Request continuation of Consent prior to consent expiry;

Consent

Collect payments or arrears should we have the need to do so;

Legitimate Interest

Protect our organisation, staff, associates, suppliers, partners and clients;

Legitimate Interest

Prevent, detect and investigate fraud;

Legal Obligation

Prevent, detect and investigate crime;

Legal Obligation

Comply with the law;

Legal obligation

Fulfil our statutory or regulatory obligations;

Legal obligation

Conduct due diligence checks;

Legitimate Interest

Maintain our own accounts and records;

Legal obligation

For reporting, analytics and product/service improvement (including training);

Legitimate Interest

Improve and maintain data accuracy or completeness;

Legitimate Interest

Track your email engagement;

Legitimate Interest

Personalise your online experience;

Legitimate Interest

Conduct market research.

Legitimate Interest

What are our legitimate interests for processing your data?

Where we have used legitimate interest as the lawful basis for processing your personal data, we may use your personal data to:

  • Direct market products and services to you via post, emails, telephone, SMS text and push notifications where they are similar/aligned to our current products and services;
  • Maintain our own accounts and records, including recording any contact we have with you via post, emails, telephone, SMS text and push notifications;
  • Prevent, detect and investigate fraud;
  • Prevent, detect and investigate crime;
  • Fulfil our statutory or regulatory obligations;
  • Resolve complaints and/or disputes;
  • Collect payments or arrears, including funds due to the charity should we have the need to do so;
  • Protect our organisation, staff, supporters, volunteers, caseworkers, associates, suppliers, partners and clients;
  • Reporting, analytics and product/service improvement, (including internal training);
  • Improve data accuracy or completeness;
  • Track your email engagement;
  • Personalise your online experience. This could include customising the content and/or layout of our pages for individual users, for both visitors and contributors;
  • Conduct market research. Including research on the demographics, interests and behaviour of our customers in order to help us gain a better understanding of different audiences and enable us to improve our service. This research may be carried out internally by our employees or we may ask another company to do this work for us. Data will be anonymised to protect your data rights for research purposes.
  • Verify staff suitability and experience for employment.
  • Verify an individuals’ eligibility to work in the UK.

Sharing your personal data

CSS Platinum may choose to sell and/or share your personal data internally and externally to the business. Where we choose to sell and/or share your information, we shall do so for the following reasons:

  • Where we have your “Consent” to do so. Where we process your data under the consent lawful basis you have the right to withdraw consent. Please refer to “Your Right to Withdraw Consent” section below;
  • Where necessary to fulfil the services and/or products we are “Contracted” to provide to you;
  • Where we have a “Legal Obligation” and are required by law and to law enforcement agencies, judicial bodies, government entities, tax authorities or regulating bodies around the world, this includes communicating with you to update you about our privacy notice and changes to how we process your personal data;
  • Where we have “Legitimate Interest” to do so, including;
  • For the purposes listed in the “What are our legitimate interests for processing your data?” section above.
  • Where one of our registered trading styles and/or current associated businesses provides a product or service similar/aligned with our organisation’s aim to help clients maximise the potential of their data in a fair, lawful and transparent manner that we do not currently provide ourselves. Presently these include:
  • Cyber Security Strategies Ltd;
  • CSS Assure (A trading style of CSS Platinum Limited);
  • Crew Check (A trading style of Cyber Security Strategies);
  • Where an external 3rdParty, with whom we are yet to have a relationship, provides a product or service that we do not currently provide ourselves, and which we reasonably believe would be of benefit to you and you would reasonably expect to receive and is similar/aligned to our organisation. In this case we would contact you using Legitimate Interest to request specific Consent to share your personal.
  • Where we believe it is necessary to protect or defend our rights, property or the personal safety of our people or visitors to our premises or websites;
  • Where required for a proposed sale; reorganisation; transfer; financial arrangement; asset disposal; or any other transaction relating to our business and/or assets held by our organisation.

Categories

Who do we use

Link to their Privacy Notice

Payment service providers

Stripe

https://stripe.com/gb/privacy

Order fulfilment service providers

Woo Commerce

https://automattic.com/privacy/

Website chat support providers

Drift

https://www.drift.com/privacy-policy/

Web analytics service providers

Google Analytics

https://policies.google.com/technologies/partner-sites?hl=en-US

Social Media Provider

LinkedIn

https://www.linkedin.com/legal/privacy-policy

Facebook

https://en-gb.facebook.com/privacy/explanation

Twitter

https://twitter.com/en/privacy

Instagram

https://help.instagram.com/519522125107875

Cookie Provider

Cookiebot

https://www.cookiebot.com/en/privacy-policy/

E-Mail support provider

Mailchimp

https://mailchimp.com/legal/privacy/

Legal support providers;

Keystone Law

https://www.keystonelaw.com/privacy-policy

Data Accuracy Support Provider

UK Search

TBC

Debt collection support providers;

UK Search

TBC

Feedback/review service providers;

TBD

N/A

Order fulfilment service providers

Not presently used; although, we may choose to do so in the future

N/A

Website chat support providers

Not presently used; although, we may choose to do so in the future

N/A

Customer Relationship Management System

Not presently used; although, we may choose to do so in the future

N/A

Cookie Provider

Not presently used; although, we may choose to do so in the future

N/A

Associate Time Tracking Service

Not presently used; although, we may choose to do so in the future

N/A

Human resources support providers (staff only);

Not presently used; although, we may choose to do so in the future

N/A

Data Accuracy Support Provider

Not presently used; although, we may choose to do so in the future

N/A

Debt collection support providers;

Not presently used; although, we may choose to do so in the future

N/A

Medical and health providers (staff only);

Not presently used; although, we may choose to do so in the future

N/A

IT support providers;

Not presently used; although, we may choose to do so in the future

N/A

Mail support providers

Not presently used; although, we may choose to do so in the future

N/A

Call centre support providers;

Not presently used; although, we may choose to do so in the future

N/A

Research agencies;

Not presently used; although, we may choose to do so in the future

N/A

Auditing firms;

Not presently used; although, we may choose to do so in the future

N/A

Credit reference agencies;

Not presently used; although, we may choose to do so in the future

N/A

Fraud protection agencies;

Not presently used; although, we may choose to do so in the future

N/A

Travel management support providers (staff only);

Not presently used; although, we may choose to do so in the future

N/A

Training and learning providers (staff only);

Not presently used; although, we may choose to do so in the future

N/A

Perk providers (staff only)

Not presently used; although, we may choose to do so in the future

N/A

  • For reporting, analytics and service improvement purposes across our trading styles and/or within any future group construct should CSS Platinum establish or become part of a group.
  • Where we outsource support functions of our organisations to trusted partners. The categories of these recipients include:

Where we choose and/or have your permission to share your personal data with 3rd Parties we will, where appropriate, ensure that they have signed data sharing agreement and/or contract that requires them to:

  • Abide by the requirements of all relevant data protection and privacy legislation;
  • Treat your information as carefully as we would;
  • Only use the information for the purposes it was supplied (and not for their own purposes or the purposes of any other organisation); and
  • Allow us to carry out checks to ensure they are doing all these things.

International Personal Data Transfer – Countries & Organisations.

CSS Platinum does not presently transfer Personal Data to any countries outside of the EU or international organisation.

If in the future we choose to do so, and the country to which we transfer your personal data does not have a recognised EU or UK Adequacy Agreement, we shall ensure that the endorsed ICO Safeguard contract is in place with the Data Controller or Data Processor within the Country which contractually obliges them to protect your information to the same standard required by the General Data Protection Regulation.

Personal Data Retention Period

CSS Platinum has the following data retention policies:

  • Where a Regulating Body directs a statutory retention period, we shall retain the relevant data for the statutory period. For example, your financial transactions data shall be retained for 7 years;
  • Where you have contracted CSS Platinum’s services, we shall retain any personal details (name, email, telephone, postal address) applicable to the contract delivery for a period of 7 years after the contract has ceased. During this time, we may contact you using legitimate interest to market additional fundraising or donation opportunities.
  • Where you have signed up to receive information emails from CSS Platinum, we shall retain your contact details (name, email, mobile telephone number, company, job title) for 7 years, or until you withdraw your consent.
  • Where you have downloaded free content from our site, we shall retain your contact details (name, email, mobile telephone number, company, job title) for a period of 7 years from your last download. During this time, we may contact you using legitimate interest to market similar free content that may be of interest to you.

When we no longer need this information, we will erase or anonymise your data and/or dispose of it securely.

The rights available to individuals in respect of the processing.

Unless subject to an exemption under legislation, you have the following rights with respect to your personal data:

  • Your right of access. You have the right to ask us for copies of your personal information. This right always applies. There are some exemptions, which means you may not always receive all the information we process. You can read more about your Right to Access here.In most cases CSS Platinum will not charge for this service however we do have the right to charge an administrative cost should we feel the request is excessive (excessive means that you submit a subject access request multiple times for the same or similar information). Fees will not exceed £50. Information will be provided within 30 calendar days from the day you request it. We will take all reasonable steps to verify your identity before providing you with details of any personal information we may hold about you.
  • Your right to data portability. This only applies to information you have given us. You have the right to ask that we transfer the information you gave us from one organisation to another or give it to you. The right only applies if we are processing information based on your consent or under, or in talks about entering into a contract and the processing is automated. You can read more about your Right to Data Portability here.

If you wish to exercise any of your individual Rights, you can do so by informing a member of our team or by contacting our Data Protection Officer by emailing [email protected], or writing to:

Data Protection Officer

CSS Platinum Limited

Burleigh Manor

Peel Road

Douglas

Isle of Man

IM1 5EP

Your Right to Withdraw Consent

You have the right to withdraw your consent to CSS Platinum processing your data at any time. Please note that this only applies for personal data processed under the Consent Lawful Basis. To determine what of your personal data is processed under the Consent Lawful Basis, please refer to the “What are the lawful basis’ by which we process data?” section above.

If you decide you wish to withdraw your Consent from a processing activity that uses the lawful basis of Consent you can do so by informing a member of our team or by contacting our Data Protection Officer by emailing [email protected] or writing to:

Data Protection Officer

CSS Platinum Limited

Burleigh Manor

Peel Road

Douglas

Isle of Man

IM1 5EP

Automated decision-making, including profiling.

CSS Platinum does not use currently use automated decision-making tools or profiling in the processing of your personal data.

Your Right to Lodge a Complaint with the ICO

You have the right to lodge a complaint with the Isle of Man’s Supervising Authority: The Information Commissioners Office. Prior to lodging a complaint, CSS Platinum Assure would like the opportunity to address any complaint you may have.

Should you have a complaint please in the first instance contact our Data Protection Officer by emailing [email protected] or writing to:

Data Protection Officer

CSS Platinum Limited

Burleigh Manor

Peel Road

Douglas

Isle of Man

IM1 5EP

If your complaint has not been resolved, you can lodge a complaint with the Information Commissioner’s Office by completing this complaints form and emailing it to [email protected] or by writing to:

Information Commissioner’s Office

First Floor, Prospect House

Prospect Hill

Douglas, Isle of Man

IM1 1ET

Or by Phone on +44 (0)330 133 0797