Privacy Policy
Website privacy notice
We are Gawith Hoggarth & Co Ltd (incorporating Gawith Hoggarth Tobacco Trading Limited and operating the website http://www.gawithhoggarth.ltd and those other domains that redirect to this same website). We are registered with Companies house in England and Wales with company number XXX (Gawith Hoggarth & Co) and XXX (Gawith Hoggarth Tobacco Trading Ltd) , whose registered address is Mintsfeet Place, Mintsfeet Road North, Kendal, LA9 6LL.
In this privacy notice, we will refer to ourselves as ‘we’, ‘us’ or ‘our’.
We are the Data Controller of the personal information we collect, hold and use about you, as explained in this notice.
You can get hold of us in any of the following ways:
- by phoning us on 01539 720047;
- by emailing us at enquiries@gawithhoggarth.ltd or
- by writing to us at Mintsfeet Place, Mintsfeet Road North, Kendal, LA9 6LL
We take the privacy, including the security, of personal information we hold about you seriously.
This privacy notice is designed to inform you about how we collect personal information about you and how we use that personal information. Please read this privacy notice carefully so that you know what information we collect and hold and understand why and how we use that information.
Chris Gawith is our registered data protection officer. You can contact him using the details above.
We may update this privacy notice from time to time.
1. Key definitions
The key terms that we use throughout this privacy notice are defined below, for ease:
1.1. Data Controller: under UK data protection law, this is the organisation or person responsible for deciding how personal information is collected and stored and how it is used.
1.2. Data Processor: a Data Controller may appoint another organisation or person to carry out certain tasks in relation to the personal information on behalf of, and on the written instructions of, the Data Controller. (This might be the hosting of a site containing personal data, for example).
1.3. Personal Information: in this privacy notice, we refer to your personal data as ‘personal information’. ‘Personal information’ means any information from which a living individual can be identified. It does not apply to information that has been anonymised.
2. Our Commitment To Privacy
We value your privacy and therefore provide this notice explaining our online information practices and the choices you can make regarding the way your information is collected and used. To make this notice easy to find, we make it available at the bottom of our home page.
3. Details of personal information that we collect and hold about you
This notice applies to all information collected or submitted on the www.gawithhoggarth.ltd website. We collect information in three primary ways: through normal usage of the website, through the creation of an account for retailers and through full-filling orders (for registered retailers).
| General Category | Types of Personal Data in that category | Retention Periods |
| Identity information | This is information relating to your identity such as your name (including any previous names and any titles that you use) and address. | Account information including name, address - 6 years from account closure |
| Contact information | This is information relating to your contact details such as email address, addresses, telephone numbers | 6 years from account closure |
| Account information | This is information relating to your account with us (including username and password) | 6 years from account closure |
| Payment information | This is information relating to the methods by which you provide payment to us such as [bank account details, credit or debit card details] and details of any payments (including amounts and dates) that are made between us | We do not store your card information - details of your transaction 24 months from the date of purchase |
| Transaction information | This is information relating to transactions between us such as details of the goods, services and/or digital content provided to you and any returns details | 6 years from account closure |
| Survey information | This is information that we have collected from you or that you have provided to us in respect of surveys and feedback | 12 months for surveys containing personal information No limit for anonymised surveys |
| Marketing information | This is information relating to your marketing and communications preferences | 12 months from account closure |
| Website, Device and Technical Information | This is information about your use of our website and technical data which we collect (including your IP address, the type of browser you are using and the version, the operating system you are using, details about the time zone and location settings on the device and other information we receive about your device) | 12 months from site visit |
Below are the general categories and details of retention periods in relation to those categories (see section 8 below for more details about retention) and in each case the types of personal information that we collect, use and hold about you:
4. Details of how and why we use personal information
4.1. We are only able to use your personal information for certain legal reasons set out in data protection law. There are legal reasons other than those listed below; but, in most cases, we will use your personal information for the following legal reasons:
- Contract Reason: this is in order to perform our obligations to you under a contract we have entered into with you;
- Legitimate Interests Reason: this is where the use of your personal information is necessary for our (or a third party’s) legitimate interests, so long as that legitimate interest does not override your fundamental rights, freedoms or interests;
- Legal Obligation Reason: this is where we have to use your personal information in order to perform a legal obligation by which we are bound; and
- Consent Reason: this is where you have given us your consent to use your personal information for a specific reason or specific reasons.
4.2. It is important that you keep your personal information up to date. If any of your personal information changes, please contact us as soon as possible to let us know.
4.3. Where we rely on consent for a specific purpose as the legal reason for processing your personal information, you have the right under data protection law to withdraw your consent at any time. If you do wish to withdraw your consent, please contact us using the details set out at the beginning of this notice. If we receive a request from you withdrawing your consent to a specific purpose, we will stop processing your personal information for that purpose, unless we have another legal reason for processing your personal information – in which case, we will confirm that reason to you.
4.4. Below are the different purposes for which we use your personal information and, in each case, the legal reason(s) allowing us to use your personal information.
| Purpose | Legal Reason(s) for using the personal information |
| To enrol you as a retail customer | Contract Reason |
| To process your order, which includes taking payment from you, advising you of any updates in relation to your order or any enforcement action against you to recover payment | Contract Reason |
| To manage our contract with you and to notify you of any changes | Contract Reason Legal Obligation Reason |
| To comply with audit and accounting matters | Legal Obligation Reason |
| For record keeping, including in relation to any guarantees or warranties provided as part of the sale of goods | Contract Reason Legal Obligation Reason |
| To improve the goods and services that we supply | Legitimate Interests Reason |
| To recommend and send communications to you about goods, services, and/or digital content that you may be interested in. More details about marketing are set out below | Legitimate Interests Reason (in order to grow our business) Consent Reason |
| To ensure the smooth running and correct operation of our website | Legitimate Interests Reason (to ensure our website runs correctly) |
| To understand how customers and visitors to our website use the website and interact with it via data analysis | Legitimate Interests Reason (to improve and grow our business, including our website, and to understand our customer’s needs, desires and requirements) |
4.5. We will only use your information in order to maintain your retail account with us and to process orders through the retail customer back office.
4.6 We do not share this information with outside parties except to the extent that it maybe be necessary to complete your order.
4.7 We may use your email address to answer any email we receive from you. Email addresses will only be used for the above purposes and are not shared with outside parties.
4.8 We use non-identifying and aggregate information to better design our website.
4.9 We never use or share the personally identifiable information provided to us online, and we will never divulge personally identifying information without a court order.
4.10 Sometimes we may anonymise personal information so that you can no longer be identified from it and use this for our own purposes. In addition, sometimes we may use some of your personal information together with other people’s personal information to give us statistical information for our own purposes. Because this is grouped together with other personal information and you are not identifiable from that combined data we are able to use this.
4.11. Under data protection laws, we can only use your personal information for the purposes we have told you about, unless we consider that the new purpose is compatible with the purpose(s) we told you about. If we want to use your personal information for a different purpose that we do not think is compatible with the purpose(s) we told you about, then we will contact you to explain this and what legal reason is in place to allow us to do this.
5. Details about who personal Information may be shared with
We do use some third parties to provide infrastructure services, and to help us provide customer support and email notifications. We have performed our due diligence to try and ensure we are satisfied with their privacy, security, and confidentiality practices,
The list of third parties used is:
Google……
CloudFy
We may need to share your personal information with other organisations or people. These organisations include:
- Suppliers: such as IT support services, payment providers, administration providers, marketing agencies, who are based in the UK;
- Government bodies and regulatory bodies: such as HMRC, fraud prevention agencies;
- Our advisors: such as lawyers, accountants, auditors, insurance companies;
- Our bankers;
- Email platforms who are based in the UK;
5.2. Depending on the circumstances, the organisations or people who we share your personal information with will be acting as either Data Processors or Data Controllers. Where we share your personal information with a Data Processor, we will ensure that we have in place contracts that set out the responsibilities and obligations of us and them, including in respect of security of personal information.
5.3. We do not sell or trade any of the personal information that you have provided to us.
7. Details about how long we will hold your personal information
We will only hold your personal data for as long as is necessary. How long is necessary will depend upon the purposes for which we collected the personal information (see section 3 above) and whether we are under any legal obligation to keep the personal information (such as in relation to accounting or auditing records or for tax reasons).
8. Automated decision making
8.1. ‘Automated decision making’ is where a decision is automatically made without any human involvement. Under data protection laws, this includes profiling. ‘Profiling’ is the automated processing of personal data to evaluate or analyse certain personal aspects of a person (such as their behaviour, characteristics, interests and preferences).
8.2. Data protection laws place restrictions upon us if we carry out any automated decision making (including profiling) that produces a legal effect or similarly significant effect on you.
8.3. Automated decision making is used in our business for the purposes of fraud prevention by utilising third party fraud scoring tools when making a payment to us.
9. Your rights under data protection law
9.1. Under data protection laws, you have certain rights in relation to your personal information, as follows:
- Right to request access: (this is often called ‘subject access’). This is the right to obtain from us a copy of the personal information that we hold about you. We must also provide you with certain other information in response to these requests to help you understand how your personal information is being used.
- Right to correction: this is the right to request that any incorrect personal data is corrected and that any incomplete personal data is completed.
- Right to erasure: (this is often called the 'right to be forgotten').This right only applies in certain circumstances. Where it does apply, you have the right to request us to erase all of your personal information.
- Right to restrict processing: this right only applies in certain circumstances. Where it does apply, you have the right to request us to restrict the processing of your personal information.
- Right to data portability: this right allows you to request us to transfer your personal information to someone else.
- Right to object: you have the right to object to us processing your personal information for direct marketing purposes. You also have the right to object to us processing personal information where our legal reason for doing so is the Legitimate Interests Reason (see section 4 above) and there is something about your particular situation that means that you want to object to us processing your personal information. In certain circumstances, you have the right to object to processing where such processing consists of profiling (including profiling for direct marketing).
9.2. In addition to the rights set out in section 9.1, where we rely on consent as the legal reason for using your personal information, you have the right to withdraw your consent.
9.3. If you want to exercise any of the above rights in relation to your personal information, please contact us using the details set out at the beginning of this notice. If you do make a request, then please note:
- we may need certain information from you so that we can verify your identity;
- we do not charge a fee for exercising your rights unless your request is unfounded or excessive; and
- if your request is unfounded or excessive, then we may refuse to deal with your request.
10. Using The Website
Gawith Hoggarth uses a combination of internal reporting tools and external reporting tools to monitor and measure website performance. As part of these tools, the following information will be collected:
- IP Address
- Browser & Operating System
This data is used by us only to monitor site performance and to measure the results of our marketing efforts. GawithHoggarth.ltd uses Google Analytics as our web analytics program. You can find out more information on Google Analytics and how the data is used here.
11. Account Creation
When a retail customer creates an account with us, we will collect the following information:
- Business Name
- Business Address
- Email Address
- Telephone
- XXXX
This information is used in the creation of a retail customer account and for the purpose of maintaining that account. None of the information collected will be shared with a third party and will be used for the sole purpose of placing and dispatching orders through gawithhoggarth.ltd and for marketing activities to retail customers. Your email address will be used for marketing and other necessary communications in the terms of our business with you and can be used for authentication purposes by the user when signing in to your gawithhoggarth.ltd back office.
12. Order Fulfillment
When a retail customer places an order with us through the back office of the website we will collect the following information in addition to the above on account creation:
- Credit / Debit Card Information
- Browser & Operating System
- IP Address
This information is used solely for the purpose of completing an order. When a customer places an order we will utilize a 3rd party to process credit cards and to monitor for fraud. This information is used only for a single transaction and is not shared or used for any other purpose.
Your email address will never be shared with a third party for any reason.
13. How We Use Cookies
GawithHoggarth.ltd uses cookies to provide you with the best experience and a more customised service. Among other things, cookies allow you to log in, create a saved list of products, and receive email notifications. The following Cookie Policy explains what cookies are, how we use them, and what benefits they bring.
13.1 What Is A Cookie?
Cookies are small text files that are sent to and stored on your computer, smartphone or other device for accessing the Internet, whenever you visit a website. Each cookie is unique to your web browser. It will contain some anonymous information such as a unique identifier, the site name, and some digits and numbers. Cookies are specific to the server that created them and cannot be accessed by other servers, which means that they cannot be used to track your movements around the web. Passwords and credit card numbers are not stored in cookies.
Most websites you visit will use cookies in order to improve your user experience by enabling that website to "remember" you, either for the duration of your visit (using a "session cookie") or for repeat visits (using a "persistent cookie").
GawithHoggarth.ltd uses cookies for several reasons, such as allowing you to navigate between pages efficiently, verifying you as the user, and carry out other essential security.
Cookies make the interaction between you and the website faster and easier. If a website doesn't use cookies, it will think you are a new visitor every time you move between pages on the site. For example, you would have to log back in every time you went to a new page within your back office.
Cookies may be set by the website you are visiting ("first party cookies") or they may be set by other websites who run content on the page you are viewing ("third party cookies").
We don't sell the information collected by cookies, nor do we disclose the information to third parties, except where required by law.
14. Email Communication & Regular Product Updates
As a registered retail customer with an account on our website, you may receive updates about our products and the launch of any new products, invitations to special events we may hold, information about new marketing material made available to you and details of any special offers, promotions or discounts.
15. Data Security & Storage
To prevent unauthorised access, maintain data accuracy, and ensure the correct use of information, we have put in place appropriate physical, electronic, and managerial procedures to safeguard and secure the information we collect online.
16. How You Can Access Or Correct Your Information
You can access all of your personally identifiable information that we have asked you to provide or input by logging in with the username and password chosen during account creation.
To protect your privacy and security, we will also take reasonable steps to verify your identity before granting access or making corrections.
17. Complaints
If you are unhappy about the way that we have handled or used your personal information, you have the right to complain to the UK supervisory authority for data protection, which is the Information Commissioner’s Office (ICO). Please do contact us in the first instance if you wish to raise any queries or make a complaint in respect of our handling or use of your personal information, so that we have the opportunity to discuss this with you and to take steps to resolve the position.
18. Third-party websites
Our website may contain links to third-party websites. If you click and follow those links, then these will take you to the third-party website. Those third-party websites may collect personal information from you and you will need to check their privacy notices to understand how your personal information is collected and used by them
19. How To Contact Us
Should you have other questions or concerns about this privacy policies, please contact us using the details given on the website.