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Privacy Policy
1. Introduction
This website is operated by 18 Clues Limited ('18 Clues'). The privacy of our users is extremely important to us and therefore we encourage all users to read this policy very carefully because it contains important information regarding:
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who we are;
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how and why we collect, store, use and share personal information;
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your rights in relation to your personal information; and
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how to contact us and supervisory authorities in the event that you have a complaint.
2. Who We Are
18 Clues ('we', 'us', 'our') collects, uses and is responsible for storing certain personal information about you ('you', 'your', 'yours').
We may be contacted on:
info@18clues.co.uk
Berrydown House
Berrydown Lane
Preston Candover
Hampshire RG25 2HG
United Kingdom
3. The Personal Information We Collect and Use
Personal information is information which you can be identified from (and does not include any anonymised forms of information).
3.1 Types of personal information
We may process the following types of personal information in relation to you:
3.1.1 Communication data that includes any communication that you send to us whether that be through forms on our website, through email, text, social media messaging,
3.1.2 Customer data that includes data relating to any purchases of goods and/or services, such as your name, title, billing address, delivery address email address, phone number, contact details, purchase details, your card details and records of such transactions.
3.1.3 User data that includes data about how you use our website and any online services together with any data that you post for publication on our website or through other online services.
3.1.4 Technical data that includes data about your use of our website and online services such as your IP address, your login data, details about your browser, length of visit to pages on our website, page views and navigation paths, details about the number of times you use our website, time zone settings and other technology on the devices you use to access our website. The source of this data is from our analytics tracking system.
3.1.5 Marketing data that includes data about your preferences in receiving marketing from us and our third parties and your communication preferences.
3.1.6 Visual data such as photographic or video data, identifying you as a subject (eg as a user of one or our products or as a prize winner). We will not use your image data without first receiving your written consent.
4. How Your Personal Data is Collected
Your personal information will be collected as follows:
4.1 Personal information obtained from you directly
We will sometimes obtain information from you directly, including when you:
4.1.1 If you sign up to our mailing list
4.1.2 If you purchase a product/products from us.
4.1.3 If you create an account with us.
4.1.4 If you submit a query/request to us.
4.1.5 If you enter an 18 Clues competition.
4.2 Personal information obtained by use of cookies or other automated means
4.2.1 We will sometimes obtain information via automated technology. This shall be by use of cookies and other similar technology. A cookie is a small text file which is placed onto your computer or electronic device when you access our website. Similar technologies include web beacons, action tags, local shared objects ('flash cookies') and single-pixel gifs. Such technologies can be used to track users' actions and activities, and to store information about them. Usually this will be in order to monitor and obtain information regarding How you use our website, for instance, how many times you use our website, which pages you use, etc.
4.2.2 On the first occasion that you use our site we will ask whether you consent to our use of cookies and/or other similar processing technologies. If you do not consent, such technologies will not be used. Thereafter you can opt-out of using cookies at any time or you can set your browser not to accept cookies. However, some of our website features may not function as a result.
4.1.3 For further information on our use of cookies and other similar technologies, please see our Website Cookie Policy.
4.3 Changes to the way in which we collect your personal information
4.3.1 In the event that we need to obtain personal information in relation to you from any other source than those described above, we shall notify you of this.
5. How We Use Your Personal Information
5.1 General purposes
In general, your personal information will generally be processed for the following purposes:
5.1.1 To communicate with you on an ongoing basis where clesr permission has been given by you for us to do so.
5.1.2 To enter into a contract with you for the sale/purchase of goods through our website.
5.1.3 To manage our business and website, and provide you with an efficient and unproblematic user experience.
5.2 Use of your information for marketing purposes
We have described above that one of the general purposes for which your data shall be processed is for our marketing purposes.
We wish to make you aware that you have the right to object or to opt-out of any direct marketing by:
Requesting that we 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 as follows:
Email us at info@18clues.co.uk
6. Lawful Basis for Processing of Your Personal Information
We have described above the purposes for which we may process your personal information. These purposes will at all times be justified by UK data protection law
6.1 The lawful basis upon which we are able to process your personal data are:
6.1.1 where we have your consent to use your data for a specific purpose;
6.1.2 where it is necessary to enter into a legal contract with you or to perform obligations under a legalcontract with you;
6.1.3 where it is necessary to enable us to comply with a legal obligation;
6.1.4 where it is necessary to ensure our own legitimate interests or the legitimate interests of a third party (provided that your own interests and rights do not override those interests). Wherever we rely upon this basis, details of the legitimate interests concerned shall be provided to you;
6.1.5 where we need to protect your own vital interests (or the vital interests of another person); and/or
6.1.6 where it is needed in the public interest (or where we are acting in our official functions), provided that the task or function has a clear basis in law.
In general, in order to meet the purposes we have described above, we will process your personal information where it is necessary in order to enter into a contract with you or in order to carry out a legal contract.
6.2 Lawful basis specifically applicable to marketing
We will only ever use your personal information to send you marketing directly where we have your explicit consent (which will be obtained in a format separately to this policy).
7. Sharing of Your Personal Information
7.1 On any occasion where any of your personal information is shared with any third party, we shall only permit them to process such information for our required purposes, under our specific instruction, and not for their own purposes. We are required to enter into a formal legal agreement to enable such sharing to take place.
7.2 In order to meet the purposes we have described above, we may on some occasions need to share your personal information with other third parties. Those third parties will be:
7.1.1 Royal Mail, in order to ship product to you as part of the contract for sale.
7.1.2 Professional advisers including lawyers, bankers, auditors and insurers.
7.1.3 Government bodies that require us to report processing activities.
7.1.4 Freelance service providers acting on our behalf, including event facilitation staff.
7.1.5 Third parties to whom we may, in the future, sell, transfer, or merge parts of our business or assets.
7.1.6 Prize Providers should a user win a Prize Draw,
7.1.7 Affiliated providers of other services we offer should we be unable to provide them.
8. Necessity of Information
8.1 Where information is requested from you and you do not provide this:
8.1.1 It may prevent you from using this website and/or receiving products/services and/or entering a prize draw.
8.2 We will inform you at the point of collecting information from you, whether you are required to provide the information to us.
9. How Long Your Personal Information Will Be Kept
Your personal information will only be kept for the period of time which is necessary for us to fulfil the above purposes.
9.1 We envisage that your personal information shall be retained by us as follows:
9.1.1 We will not store your data for any longer than is necessary. If you are a user of our services, then your information will be held for as long as you continue to use our services. Note, however, that for tax purposes the law requires us to keep basic information about our customers (including Contact, Identity, Financial and Transaction Data) for six years after they stop being customers.
9.2 After the period described above, your information shall be properly deleted or anonymised.
10. Keeping Your Information Secure
10.1 We will ensure the proper safety and security of your personal information and have measures in place to do so.
10.2 We will also use technological and organisation measures to keep your information secure. These measures are as follows:
10.2.1 18clues.co.uk is built and operated by Wix. Information Security and the protection of user and site visitor data is of the highest priority at Wix. The Wix Security team uses an Information Security Program based on international best practices, and it’s constantly evolving to address emerging threats. They also implement data encryption using HTTPS, TLS 1.2 and above, and SSL. Wix software engineers develop their platform with a security by design approach, which means they keep security and privacy top of mind throughout all design phases. Wix seeks to add as many default and out-of-the-box security boundaries to its systems as possible, in order to reduce the probability of vulnerabilities and to support secure development. All Wix sites come with an SSL certificate.
10.2.2 We have proper procedures in place to deal with any data security breach, which shall be reported and dealt with in accordance with data protection laws and regulations. You shall also be notified of any suspected data breach concerning your personal information.
11. Children
Our website is not intended for children (anybody under the age of 18). We do not intend to collect data from children.
12. Your Rights
12.1 Under the UK General Data Protection Regulation you have a number of important rights free of charge. In summary, those include rights to:
12.1.1 fair processing of information and transparency over how we use your use personal information;
12.1.2 access to your personal information and to certain other supplementary information that this Privacy Statement is already designed to address;
12.1.3 require us to correct any mistakes in your information which we hold;
12.1.4 require the erasure of personal information concerning you in certain situations;
12.1.5 receive the personal information concerning you which you have provided to us, in a structured, commonly used and machine-readable format and have the right to transmit this information to a third party in certain situations;
12.1.6 object at any time to processing of personal information concerning you for direct marketing;
12.1.7 object to decisions being taken by automated means which produce legal effects concerning you or similarly significantly affect you;
12.1.8 object in certain other situations to our continued processing of your personal information, or ask us to suspend the processing procedure in order for you confirm its assurance or our reasoning for processing it;
12.1.9 object to processing our your personal information where we are doing so in reliance upon a legitimate interest of our own or of a third party and where you wish to raise to an objection to this particular ground;
12.1.10 otherwise restrict our processing of your personal information in certain circumstances;
12.1.11 claim compensation for damages caused by our breach of any data protection laws; and/or
12.1.12 in any circumstance where we rely upon your consent for processing personal information, you may withdraw this consent at any time.
12.2.For further information on each of those rights, including the circumstances in which they apply, see the Guidance from the UK Information Commissioner's Office (ICO) on your rights under the General Data Protection Regulations.
12.3 If you would like to exercise any of these rights please contact Sandi McDonell Batchelor in the following manner:
By email to info@18clues.co.uk
13. Your Requirements
If you would like this policy in another format (for example: audio, large print, braille) please contact us using the details below.
14. Complaints Procedure
We hope that we can resolve any query or concern you raise about our use of your information.
The UK General Data Protection Regulation also gives you right to lodge a complaint with the supervisory authority. The supervisory authority in the United Kingdom is the Information Commissioner.
15. Changes to the Privacy Policy
This privacy policy was published on 1st August July 2024 and last updated on 1st August 2024.
We may change this privacy policy from time to time and will notify you of any changes as follows if you have opted in to receive emails from us
16. Contacting Us
The relevant person to contact regarding your personal information is: Sandi McDonell Batchelor.
Any requests or questions regarding the use of your personal information should be made to the above named person using the following method:
By email to info@18clues.co.uk
17. Sources of Further Information
This policy provides key information to you regarding the processed of your information. For certain areas of our information processing, we have further comprehensive details contained in our Website Cookie Policy regarding the use of cookies and other similar technologies.