Cycle Revolution Privacy Policy & Cookies

A1. Thomas’s Cycle Revolution values your privacy, and therefore do not disclose information to third parties. Cookies are used on this shopping site only to keep track of the contents of your shopping cart once you have selected an item, and to store delivery addresses when you register. There is an option to store a cookie on the PC when you first register. When you pay for goods your details are passed through the Citrus Lime system purely for payment processing and anti-fraud purposes, for your protection.

We are committed to protecting your privacy. We will only use the information that we collect about you lawfully in accordance with the Data Protection Act 1998. We will collect any information given at the time of the ordering process only to enable us to input and process your order.

We will not e-mail you in the future unless you have given us your consent. If you wish to be deleted from our mailing list at any time please follow the unsubscribe link at the bottom of the email.

If you wish to contact us regarding our privacy policy please email us: support@cycle-revolution.net

ACCURACY

A2. This website has been prepared solely on the information supplied by the contributors and manufacturers. Its accuracy cannot be guaranteed. The publishers and their production team cannot accept liability for inaccuracies, errors or omissions in such information howsoever arising. Prices are correct at the time of submission to the site, excluding genuine mistakes.

Specifications are advised by the manufacturer, and are subject to change by the manufacturer at any time.

GDPR:

 

 

  1. Introduction

 


Thomas’s Cycle Revolution Ltd is committed to conducting its business in accordance with all applicable Data Protection laws and regulations and in line with the highest standards of ethical conduct.

This policy details expected behaviours of Thomas’s Cycle Revolution Ltd.’s Employees and Third Parties in relation to the collection, use, retention, transfer, disclosure and destruction of any Personal Data belonging to a Thomas’s Cycle Revolution Ltd.’s Customers and Staff (i.e. the Data Subject) and irrespective of the media used to store the information.

Personal Data is any information (including opinions and intentions) which relates to an identified or Identifiable Natural Person. Personal Data is subject to certain legal safeguards and other regulations, which impose restrictions on how organisations may process Personal Data.

An organisation that handles personal data and makes decisions about its use is known as a Data Controller. Thomas’s Cycle Revolution Ltd, as a Data Controller, is responsible for ensuring compliance with the Data Protection requirements outlined in this policy.

Non-compliance may expose Thomas’s Cycle Revolution Ltd to complaints, regulatory action, fines and/or reputational damage.

Thomas’s Cycle Revolution Ltd leadership is fully committed to ensuring continued and effective implementation of this policy and expects all Thomas’s Cycle Revolution Ltd Employees and Third Parties to share in this commitment.

Any breach of this policy will be taken seriously and may result in disciplinary action or business sanction

 

  1. Scope

 

 

    1. This policy applies to all Thomas’s Cycle Revolution Ltd Entities where a Data Subject’s personal data is processed:

    • in the context of the business activities of the Thomas’s Cycle Revolution Ltd Entity

    • for the provision or offer of goods or services to individuals (including those provided or offered free-of-charge) by Thomas’s Cycle Revolution Ltd

    • to actively monitor the behaviour of individuals.

    1. Monitoring the behaviour of individuals includes using data processing techniques such as persistent web browser cookies or dynamic IP address tracking to profile an individual with a view to:

    • taking a decision about them

    • analysing or predicting their personal preferences, behaviours and attitudes.

    1. This policy applies to all processing of personal data in electronic form (including electronic mail and documents created with word processing software) or where it is held in manual files that are structured in a way that allows ready access to information about individuals.

    2. This policy has been designed to establish a baseline standard for the processing and protection of personal data by all Thomas’s Cycle Revolution Ltd Employees. Where national law imposes a requirement that is stricter than that imposed by this policy, the requirements in national law must be followed. Furthermore, where national law imposes a requirement that is not addressed in this policy, the relevant national law must be adhered to.

 

  1. Scope – Continue

 

 

  1. The protection of personal data belonging to Thomas’s Cycle Revolution Ltd Employees is not within the scope of this policy.

  2. The DPO is responsible for overseeing this Privacy Standard and, as applicable, developing Related Policies and Privacy Guidelines. The DPO is within our company is Darren Thomas – Operations Director – darren@cycle-revolution.net

  3. Please contact the DPO with any questions about the operation of this Privacy Standard or the GDPR, or if you have any concerns that this Privacy Standard is not being or has not been followed. In particular, you must always contact the DPO in the following circumstances:

    • if you are unsure of the lawful basis which you are relying on to process Personal Data (including the legitimate interests used by the Company)

    • if you need to rely on Consent and/or need to capture Explicit Consent

    • if you need to draft Privacy Notices or Fair Processing Notices

    • if you are unsure about the retention period for the Personal Data being Processed

    • if you are unsure about what security or other measures you need to implement to protect Personal Data

    • if there has been a Personal Data Breach

    • if you are unsure on what basis to transfer Personal Data outside the EEA

    • if you need any assistance dealing with any rights invoked by a Data Subject

    • whenever you are engaging in a significant new, or change in, Processing activity which is likely to require a DPIA or plan to use Personal Data for purposes others than what it was collected for

    • if you plan to undertake any activities involving Automated Processing including profiling or Automated Decision-Making

    • if you need help complying with applicable law when carrying out direct marketing activities; or

    • if you need help with any contracts or other areas in relation to sharing Personal Data with Third Parties (including our vendors).

 

 

  1. Definition

 

TERM

DEFINITION

Anonymisation

Data amended in such a way that no individuals can be identified from the data (whether directly or indirectly) by any means or by any person.

Binding Corporate Rules

The Personal Data protection policies used for the transfer of Personal Data to one or more Third Countries within a group of undertakings, or group of enterprises engaged in a joint economic activity.

Consent

Any freely given, specific, informed and unambiguous indication of the Data Subject’s wishes by which he or she, by a statement or by a clear affirmative action, signifies agreement to the Processing of Personal Data relating to him or her.

Customer

Any past, current or prospective [Insert Company Name] customer.

Data Controller

A natural or legal person, Public Authority, Agency or other body which, alone or jointly with others, determines the purposes and means of the Processing of Personal Data.

Data Processor

A natural or legal person, Public Authority, Agency or other body which Processes Personal Data on behalf of a Data Controller.

Data Protection

The process of safeguarding Personal Data from unauthorised or unlawful disclosure, access, alteration, Processing, transfer or destruction.

Data Protection Officer (DPO)

The person required to be appointed in specific circumstances under the GDPR. Where a mandatory DPO has not been appointed, this term means a data protection manager or other voluntary appointment of a DPO or refers to the Company data privacy team with responsibility for data protection compliance.

Data Subject

Anyone who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier, or one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.

EEA

The 28 countries in the EU, and Iceland, Liechtenstein and Norway.

Employee

An individual who works part-time or full-time for [Insert Company Name] under a contract of employment, whether oral or written, express or implied, and has recognised rights and duties – includes temporary employees and independent contractors.

Encryption

The process of encoding a message or information in such a way that only authorised parties can access it.

Information Commissioner’s Office (ICO)

An independent Public Authority in the UK responsible for monitoring the application of the relevant Data Protection regulation set forth in national law.

Personal Data Breach

A breach of security leading to the accidental or unlawful destruction, loss, alteration, unauthorised disclosure of, or access to, Personal Data transmitted, stored or otherwise Processed.

Process, Processed, Processing

Any operation or set of operations performed on Personal Data or on sets of Personal Data, whether or not by automated means. Operations performed may include collection, recording, organisation, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction.

Profiling

Any form of automated processing of Personal Data, where Personal Data is used to evaluate specific or general characteristics relating to a data subject. In particular to analyse or predict certain aspects concerning that natural person’s performance at work, economic situations, health, personal preferences, interests, reliability, behaviour, location or movement.

Pseudonymisation

Data amended in such a way that no individuals can be identified from the data (whether directly or indirectly) without a ‘key’ that allows the data to be re-identified.

Special Categories of Data

Personal Data pertaining to or revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, trade-union membership, data concerning health or sex life and sexual orientation, genetic data or biometric data.

 

 

  1. Policy

 

 

  1. Governance

    • Policy Dissemination and Enforcement

The management team of Thomas’s Cycle Revolution Ltd must ensure that all Thomas’s Cycle Revolution Ltd Employees responsible for the Processing of Personal Data are aware of and comply with the contents of this policy. In addition, Thomas’s Cycle Revolution Ltd will make sure all Third Parties engaged to Process Personal Data on their behalf (i.e. their Data Processors) are aware of and comply with the contents of this policy. Assurance of such compliance must be obtained from all Third Parties, whether companies or individuals, prior to granting them access to Personal Data controlled by Thomas’s Cycle Revolution Ltd.

    • Data Protection by Design

To ensure that all Data Protection requirements are identified and addressed when designing new systems or processes and/or when reviewing or expanding existing systems or processes, each of them must go through an approval process before continuing.

Thomas’s Cycle Revolution Ltd must ensure that a Data Protection Impact Assessment (DPIA) is conducted, for all new and/or revised systems or processes for which it has responsibility. Thomas’s Cycle Revolution Ltd should consult with a Data Protection subject matter expert during the course of completing the DPIA. The subsequent findings of the DPIA must then be submitted to the senior risk office for Thomas’s Cycle Revolution Ltd for review and approval. Where applicable, the Information Technology (IT) department, as part of its IT system and application design review process, will cooperate with the Data Protection subject matter expert to assess the impact of any new technology uses on the security of Personal Data.

    • Compliance Monitoring

To confirm that an adequate level of compliance is being achieved by Thomas’s Cycle Revolution Ltd in relation to this policy, Thomas’s Cycle Revolution Ltd will carry out an annual Data Protection compliance audit. Each audit will, as a minimum, assess compliance with this policy and the operational practices in relation to the protection of Personal Data, including:

  • the assignment of responsibilities

  • raising awareness

  • training of Employees

  • adequacy of organisational and technical controls to protect Personal Data

  • records management procedures (including data minimisation)

  • adherence to the qualified rights of the Data Subject

  • Privacy by Design and Default

  • consent for direct marketing

  • Personal Data transfers

  • Personal Data incident management (including Personal Data breaches)

  • Personal Data complaints handling

  • the currency of Data Protection policies and Privacy Notices

  • the accuracy of Personal Data being stored

  • the conformity of Data Processor activities

  • the adequacy of procedures for redressing poor compliance.

 

Any major deficiencies identified will be reported to and monitored by [Insert Company Name] Executive Management team.

 

    1. Principles

      • Data Protection

Thomas’s Cycle Revolution Ltd has adopted the following principles to govern its collection, use, retention, transfer, disclosure and destruction of Personal Data.

 

 

PRINCIPLE

DEFINITION

Principle 1: Lawfulness, Fairness and Transparency

Personal Data shall be processed lawfully, fairly and in a transparent manner in relation to the Data Subject. This means, Thomas’s Cycle Revolution Ltd must tell the Data Subject what Processing will occur (transparency), the Processing must match the description given to the Data Subject (fairness), and it must be for one of the purposes specified in the applicable Data Protection regulation (lawfulness).

Principle 2: Purpose Limitation

Personal Data shall be collected for specified, explicit and legitimate purposes and not further Processed in a manner that is incompatible with those purposes. This means Thomas’s Cycle Revolution Ltd must specify exactly what the Personal Data collected will be used for and limit the Processing of that Personal Data to only what is necessary to meet the specified purpose.

Principle 3: Data Minimisation

Personal Data shall be adequate, relevant and limited to what is necessary in relation to the purposes for which they are Processed. This means Thomas’s Cycle Revolution Ltd must not store any Personal Data beyond what is strictly required.

Principle 4: Accuracy

Personal Data shall be accurate and kept up to date. This means Thomas’s Cycle Revolution Ltd must have in place processes for identifying and addressing out-of-date, incorrect and redundant Personal Data.

Principle 5: Storage Limitation

Personal Data shall be kept in a form which permits identification of Data Subjects for no longer than is necessary for the purposes for which the Personal Data is Processed. This means Thomas’s Cycle Revolution Ltd must, wherever possible, store Personal Data in a way that limits or prevents identification of the Data Subject.

Principle 6: Integrity & Confidentiality

Personal Data shall be Processed in a manner that ensures appropriate security of the Personal Data, including protection against unauthorised or unlawful Processing, and against accidental loss, destruction or damage. Thomas’s Cycle Revolution Ltd must use appropriate technical and organisational measures to ensure the integrity and confidentiality of Personal Data are maintained at all times.

 

 

 

    • Accountability

The Data Controller shall be responsible for, and be able to demonstrate, compliance. This means Thomas’s Cycle Revolution Ltd must demonstrate that the six Data Protection Principles (outlined above) are met for all Personal Data for which it is responsible.

    1. Data Collection

Personal Data should be collected only from the Data Subject unless one of the following applies:

  • The nature of the business purpose necessitates collection of the Personal Data from other persons or bodies.

  • The collection must be carried out under emergency circumstances in order to protect the vital interests of the Data Subject or to prevent serious loss or injury to another person.

  • If Personal Data is collected from someone other than the Data Subject, the Data Subject must be informed of the collection unless one of the following apply:

    • the Data Subject has received the required information by other means

    • the information must remain confidential due to a professional secrecy obligation

    • a national law expressly provides for the collection, Processing or transfer of the Personal Data.

Where it has been determined that notification to a Data Subject is required, notification should occur promptly, but in no case later than:

  • one calendar month from the first collection or recording of the Personal Data

  • at the time of first communication, if used for communication with the Data Subject

  • at the time of disclosure, if disclosed to another recipient.

 

  • Data Subject Consent

Thomas’s Cycle Revolution Ltd will obtain Personal Data only by lawful and fair means and, where appropriate, with the knowledge and Consent of the individual concerned.

Where a need exists to request and receive the Consent, via an agreement or positive action, from an individual prior to the collection, use or disclosure of their Personal Data, Thomas’s Cycle Revolution Ltd is committed to seeking such Consent.

Thomas’s Cycle Revolution Ltd shall establish a system for obtaining and documenting Data Subject consent for the collection, processing, and/or transfer of their personal data. The system must include provisions for:

  • determining what disclosures should be made in order to obtain valid Consent

  • ensuring the request for Consent is presented in a manner which is clearly distinguishable from any other matters, is made in an intelligible and easily accessible form, and uses clear and plain language

  • ensuring the Consent is freely given (i.e. is not based on a contract that is conditional to the processing of Personal Data that is unnecessary for the performance of that contract)

  • documenting the date, method and content of the disclosures made, as well as the validity, scope, and volition of the Consents given

  • providing a simple method for a Data Subject to withdraw their Consent at any time.

 

    • External Privacy Notes

Each external website provided by Thomas’s Cycle Revolution Ltd will include an online ‘Privacy Notice’ and an online ‘Cookie Notice’ fulfilling the requirements of applicable law.

    1. Data Use

      • Data Processing

Thomas’s Cycle Revolution Ltd uses the Personal Data of its Customers for the following broad purposes:

  • the general running and business administration of [Insert Company Name]

  • to provide goods or services to [Insert Company Name] customers.

  • the ongoing administration and management of customer services.

The use of a Customer’s information should always be considered from their perspective and whether the use will be within their expectations or if they are likely to object. For example, it would clearly be within a Customer’s expectations that their details will be used by Thomas’s Cycle Revolution Ltd to respond to a Customer’s request for information about the products and services on offer. However, it will not be within their reasonable expectations that Thomas’s Cycle Revolution Ltd would then provide their details to Third Parties for marketing purposes.

Thomas’s Cycle Revolution Ltd will Process Personal Data in accordance with all applicable laws and applicable contractual obligations. More specifically, Thomas’s Cycle Revolution Ltd will not Process Personal Data unless at least one of the following requirements are met:

  • The Data Subject has given Consent to the Processing of their Personal Data for one or more specific purposes.

  • Processing is necessary for the performance of a contract to which the Data Subject is party or in order to take steps at the request of the Data Subject prior to entering into a contract.

  • Processing is necessary for compliance with a legal obligation to which the Data Controller is subject.

  • Processing is necessary in order to protect the vital interests of the Data Subject or of another natural person.

  • Processing is necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in the Data Controller.

  • Processing is necessary for the purposes of the legitimate interests pursued by the Data Controller or by a Third Party (except where such interests are overridden by the interests or fundamental rights and freedoms of the Data Subject, in particular where the Data Subject is a child).

There are some circumstances in which Personal Data may be further processed for purposes that go beyond the original purpose for which the Personal Data was collected.

    • Special Categories of Data

Special categories or data (also known as sensitive data) include the following:

  • racial or ethnic origin

  • political opinions

  • religious or philosophical beliefs

  • trade union membership

  • data concerning sex life, sexual orientation or health

  • genetic data

  • biometric data, where processed in a manner that will uniquely identify a person.

Thomas’s Cycle Revolution Ltd will only Process Special Categories of Data where the Data Subject expressly Consents to such Processing or where one of the following conditions apply:

  • The Processing relates to Personal Data which has already been made public by the Data Subject.

  • The Processing is necessary for the establishment, exercise or defence of legal claims.

  • The Processing is specifically authorised or required by law.

  • The Processing is necessary to protect the vital interests of the Data Subject or of another natural person where the Data Subject is physically or legally incapable of giving Consent.

  • Further conditions, including limitations, based upon national law related to the Processing of genetic data, biometric data or data concerning health.

Where Special Categories of Data are being Processed, Thomas’s Cycle Revolution Ltd will adopt additional protection measures.

    • Data Quality

Thomas’s Cycle Revolution Ltd will adopt all necessary measures to ensure that the Personal Data it collects, and Processes is complete and accurate in the first instance and is updated to reflect the current situation of the Data Subject.

The measures adopted by Thomas’s Cycle Revolution Ltd to ensure data quality include:

  • correcting Personal Data known to be incorrect, inaccurate, incomplete, ambiguous, misleading or outdated, even if the Data Subject does not request rectification

  • keeping Personal Data only for the period necessary, to satisfy the permitted uses or applicable statutory retention period

  • the removal of Personal Data if in violation of any of the Data Protection principles or if the Personal Data is no longer required

  • restriction, rather than deletion of Personal Data, insofar as:

    • a law prohibits erasure

    • erasure would impair legitimate interests of the Data Subject

    • the Data Subject disputes that their Personal Data is correct, and it cannot be clearly ascertained whether their information is correct or incorrect.

    • Profiling and Automated Decision-Making

Thomas’s Cycle Revolution Ltd will only engage in Profiling and automated decision-making where it is necessary to enter into, or to perform, a contract with the Data Subject or where it is authorised by law.

Where Thomas’s Cycle Revolution Ltd utilises Profiling and automated decision-making, this will be disclosed to the relevant Data Subjects. In such cases, the Data Subject will be given the opportunity to:

  • obtain an explanation for the automated decision

  • review the logic used by the automated system

  • supplement the automated system with additional data

  • have a human carry out a review of the automated decision

  • contest the automated decision

  • object to the automated decision-making being carried out.

Thomas’s Cycle Revolution Ltd must also ensure that all Profiling and automated decision-making relating to a Data Subject is based on accurate data. Appropriate mathematical or statistical profiling procedures must be in place, and the Data Controller must ensure suitable technical and organisational measures are undertaken to minimise the risk of errors.

    • Direct Marketing

As a general rule, Thomas’s Cycle Revolution Ltd will not send promotional or direct marketing material to a Thomas’s Cycle Revolution Ltd Customers through digital channels such as mobile phones, email and the Internet, without first obtaining their Consent.

The GDPR and Privacy and Electronic Communications (which governs Direct Marketing Activities within the EU) imports the GDPR standard for consent. That is:

  • The consent must be freely given, specific, informed and unambiguous.

  • The consent must be expressed by a statement or clear affirmative action. Silence, pre-ticked boxes or inactivity should therefore not constitute consent.

  • The consent must be as easy to withdraw as it was to provide consent in the first place.

  • The organisation must be able to demonstrate that the individual has consented.

  • The consent language must be intelligible and use clear and plain language.

Contacting recipients via email to establish whether consent is in place also constitutes direct marketing and is prohibited without first obtaining consent from the Customer.

The request for consent must be clearly distinguished from other matters. New marketing rules will apply equally to B2B and B2C marketing. Prior consent, before sending commercial electronic communications for direct marketing purposes will be required. This would mean if [Insert Company Name] were proposing to email prospective or existing customers the Company would have to obtain prior opt-in/subscribe consent from individual members.

Where Personal Data Processing is approved for digital marketing purposes, the Data Subject must be informed at the point of first contact that they have the right to object, at any stage, to having their data Processed for such purposes. If the Data Subject puts forward an objection, digital marketing related Processing of their Personal Data must cease immediately, and their details should be kept on a suppression list with a record of the opt-out decision, rather than being completely deleted.

It should be noted that where digital marketing is carried out in a ‘business to business’ context, there is no legal requirement to obtain an indication of Consent to carry out digital marketing to individuals, provided that they are given the opportunity to opt-out.

A soft opt-in also remains for the use of e-mail contact details within the context of an existing customer relationship where [Insert Company Name] has obtained personal details during the course of a previous sale or transaction.

    1. Data Retention

To ensure fair Processing, Personal Data will not be retained by Thomas’s Cycle Revolution Ltd for longer than necessary in relation to the purposes for which it was originally collected, or for which it was further Processed.

The length of time for which Thomas’s Cycle Revolution Ltd needs to retain Personal Data is set out in the Thomas’s Cycle Revolution Ltd ‘Personal Data Retention Schedule’. This takes into account the legal and contractual requirements, both minimum and maximum, that influence the retention periods set forth in the schedule. All Personal Data should be securely deleted or destroyed as soon as possible where it has been confirmed that there is no longer a need to retain it.

    1. Data Protection

      • Thomas’s Cycle Revolution Ltd will adopt physical, technical, and organisational measures to ensure the security and protect the confidentiality, integrity and availability of the Personal Data, defined as follows:

  • Confidentiality means that only people who have a need to know and are authorised to use the Personal Data can access it.

  • Integrity means that Personal Data is accurate and suitable for the purpose for which it is processed.

  • Availability means that authorised users are able to access the Personal Data when they need it for authorised purposes

 

This includes the prevention of loss or damage, unauthorised alteration, access or Processing, and other risks to which it may be exposed by virtue of human action or the physical or natural environment.

A summary of the Personal Data related security measures is provided below:

  • Prevent unauthorised persons from gaining access to data processing systems in which Personal Data are Processed.

  • Prevent persons entitled to use a data processing system from accessing Personal Data beyond their needs and authorisations.

  • Ensure that Personal Data in the course of electronic transmission during transport cannot be read or copied.

  • Ensure that access logs are in place to establish whether, and by whom, the Personal Data was entered into, modified on or removed from a data processing system.

  • Ensure that in the case where Processing is carried out by a Data Processor, the data can be Processed only in accordance with the instructions of the Data Controller.

  • Ensure that Personal Data is protected against undesired destruction or loss.

  • Ensure that Personal Data is not kept longer than necessary.

  • Regularly evaluate and test the effectiveness of safeguards to ensure security of Processing of Personal Data.

  1. Data Subject Rights

    • The process for attending to the following Data Subject rights is outlined in the Data Subject Access Policy:

  • information access

  • objection to Processing.

  • objection to automated decision-making and Profiling

  • restriction of Processing

  • data portability

  • data rectification

  • data erasure.

 

No administration fee will be charged for considering and/or complying with such a request unless the request is deemed to be unnecessary or excessive in nature.

Data Subjects are entitled to, based upon a request made in and upon successful verification of their identity, the following information about their own Personal Data:

  • the purposes of the collection, Processing, use and storage of their Personal Data

  • the source(s) of the Personal Data, if it was not obtained from the Data Subject

  • the categories of Personal Data stored for the Data Subject

  • the recipients, or categories of recipients, to whom the Personal Data has been or may be transmitted, along with the location of those recipients

  • the envisaged period of storage for the Personal Data or the rationale for determining the storage period

  • the use of any automated decision-making, including Profiling

  • the retention periods applied to the data

  • a summary of the security measures in place to protect the data

  • request to erase Personal Data if it is no longer necessary in relation to the purposes for which it was collected or Processed or to rectify inaccurate data or to complete incomplete data.

    • A response to each request will be provided within 30 days of the receipt of the written request from the Data Subject. That period may be extended by two further months where necessary, taking into account the complexity and number of the requests.

    • Appropriate verification must confirm that the requestor is the Data Subject or their authorised legal representative. Data Subjects shall have the right to require Thomas’s Cycle Revolution Ltd to correct or supplement erroneous, misleading, outdated, or incomplete Personal Data.

    • Please refer to the Individuals Rights Policy for detailed guidance and procedures for responding to such requests.

Third-Party Data
    • It should be noted that situations may arise where providing the information requested by a Data Subject would disclose Personal Data about another individual. In such cases, information must be redacted or withheld as may be necessary or appropriate to protect that person’s rights.

    • When Personal Data is collected indirectly (for example, from a third party or publicly available source), Thomas’s Cycle Revolution Ltd will provide the Data Subject with all the information required by the GDPR as soon as possible after collecting/receiving the data. Thomas’s Cycle Revolution Ltd will also check that the Personal Data was collected by the third party in accordance with the GDPR and on a basis which contemplates proposed Processing of that Personal Data.

  1. Law Enforcement Requests and Disclosures

    • In certain circumstances, it is permitted that Personal Data be shared without the knowledge or Consent of a Data Subject. This is the case where the disclosure of the Personal Data is necessary for any of the following purposes:

  • the prevention or detection of crime;

  • the apprehension or prosecution of offenders

  • the assessment or collection of a tax or duty

  • by order of a court or by any rule of law.

  1. Data Protection Training

    • All Thomas’s Cycle Revolution Ltd Employees and Employees of Third Parties (Data Processors) that have access to Personal Data will have their responsibilities under this policy outlined to them as part of their staff induction training. In addition, Thomas’s Cycle Revolution Ltd and Third Parties will provide regular Data Protection training and procedural guidance for their staff.

    • The training and procedural guidance set forth will consist of, at a minimum, the following elements:

  • the Data Protection Principles set forth in Section 4.2 above

  • each Employee’s duty to use and permit the use of Personal Data only by authorised persons and for authorised purposes

  • the need for, and proper use of, the forms and procedures adopted to implement this policy

  • the correct use of passwords, security tokens and other access mechanisms

  • the importance of limiting access to Personal Data, such as by using password protected screen savers and logging out when systems are not being attended by an authorised person

  • securely storing manual files, printouts and electronic storage media

  • information on how to detect a phishing email

  • proper disposal of Personal Data by using secure shredding facilities

  • any special risks associated with particular departmental activities or duties.

  1. Data Transfer

    • Thomas’s Cycle Revolution Ltd may transfer Personal Data to internal or Third-Party recipients located in another country where that country is recognised as having an adequate level of legal protection for the rights and freedoms of the relevant Data Subjects.

    • Where transfers need to be made to countries lacking an adequate level of legal protection (i.e. Third Countries), they must be made in compliance with an approved transfer mechanism.

    • Thomas’s Cycle Revolution Ltd may only transfer Personal Data where one of the transfer scenarios listed below applies:

  • the Data Subject has given Consent to the proposed transfer.

  • the transfer is necessary for the performance of a contract with the Data Subject

  • the transfer is necessary for the implementation of pre-contractual measures taken in response to the Data Subject’s request

 

  • the transfer is necessary for the conclusion or performance of a contract concluded with a Third Party in the interest of the Data Subject.

  • the transfer is legally required on important public interest grounds

  • the transfer is necessary for the establishment, exercise or defence of legal claims

  • the transfer is necessary in order to protect the vital interests of the Data Subject.

Transfers to Third Parties
    • Thomas’s Cycle Revolution Ltd will only transfer Personal Data to, or allow access by, Third Parties when it is assured that the information will be Processed legitimately and protected appropriately by the recipient. Where Third-Party Processing takes place Thomas’s Cycle Revolution Ltd will first identify if, under applicable law, the Third Party is considered a Data Controller, or a Data Processor of the Personal Data being transferred.

    • Where the Third Party is deemed to be a Data Controller, Thomas’s Cycle Revolution Ltd will enter into an appropriate agreement with the Controller to clarify each party’s responsibilities in respect to the Personal Data transferred.

    • Where the Third Party is deemed to be a Data Processor, will enter into an adequate Processing agreement with the Data Processor. The agreement must require the Data Processor to protect the Personal Data from further disclosure and to only Process Personal Data in compliance with Thomas’s Cycle Revolution Ltd instructions. In addition, the agreement will require the Data Processor to implement appropriate technical and organisational measures to protect the Personal Data, as well as procedures for providing notification of Personal Data Breaches.

    • When outsourcing services to a Third Party (including Cloud Computing services), Thomas’s Cycle Revolution Ltd will identify whether the Third Party will Process Personal Data on its behalf and whether the outsourcing will entail any Third Country transfers of Personal Data.

    • Regular audits of Processing of Personal Data performed by Third Parties, especially in respect of technical and organisational measures they have in place, should be undertaken. Any major deficiencies identified will be reported to and monitored by the Thomas’s Cycle Revolution Ltd Executive Management team.

  1. Complaints Handling

    • Data Subjects with a complaint about the Processing of their Personal Data should put forward the matter in writing. An investigation of the complaint will be carried out to the extent that is appropriate based on the merits of the specific case. Thomas’s Cycle Revolution Ltd will inform the Data Subject of the progress and the outcome of the complaint within a reasonable period.

    • If the issue cannot be resolved through consultation with the Data Subject, then the Data Subject should be advised that they may, at their option, seek redress through mediation, binding arbitration, litigation, or via a complaint to the Information Commissioner’s Office (ICO).

  2. Breach Reporting

    • Any individual who suspects that a Personal Data Breach has occurred due to the theft or exposure of Personal Data must immediately notify the Data Privacy officer providing a description of what occurred. Notification of the incident can be made via e-mail to darren@cycle-revolution.net. The Data Privacy officer should update the internal breach log, including pertinent facts relating to the incident, effects and remedial actions taken.

    • All reported incidents will be investigated to confirm whether or not a Personal Data Breach has occurred. For severe Personal Data Breaches, Data Privacy officer must inform the ICO within 72 hours of becoming aware of the breach. In some cases, affected Data Subjects should be advised of the personal data breach.

    • Guidance can be found in the Incident Management Policy.

 

 

5. Policy Maintenance

 


 

    1. Publication

      1. This policy shall be available to all Employees through the [Insert Company Name] Policy Portal/intranet [intranet url]. In the case of areas which employ non-desk-based employees, then a hard copy will be made available in the staff area.

    1. Effective Date

    2. Revisions

 

 

  1. Related Documents

 

 

  • Individual Rights Policy

  • Incident Management Policy

  • Data Retention Policy

 

Our Website Cookies Policy

A cookie is a small file of text which we transfer to your hard drive through your web browser, as with most websites, when you visit our website and use certain pages or features on the site, especially when placing an order. It enables our own system to recognise you when you visit our website again and improve our service to you. This information can be used to enhance the content of our website and make your use of it easier. For more information about cookies please visit www.allaboutcookies.org

Cookies

When we provide services, we want to make them easy, useful and reliable. Where services are delivered on the internet, this sometimes involves placing small amounts of information on your device, for example, computer or mobile phone. These include small files known as cookies. They cannot be used to identify you personally.

These pieces of information are used to improve services for you through, for example:

- enabling a service to recognise your device so you don't have to give the same information several times during one task
- recognising that you may already have given a username and password so you don't need to do it for every web page requested
- measuring how many people are using services, so they can be made easier to use and there's enough capacity to ensure they are fast

You can manage these small files yourself and learn more about them through Internet browser cookies - what they are and how to manage them.


Our use of cookies

When we provide services, we want to make them easy, useful and reliable. Where services are delivered on the internet, this sometimes involves placing small amounts of information on your device, for example, your computer or mobile phone. These include small files known as cookies. They cannot be used to identify you personally.

These pieces of information are used to improve services for you through, for example:

- recognising that you may already have given a username and password so you don't need to do it for every web page requested
- measuring how many people are using services, so they can be made easier to use and there's enough capacity to ensure they are fast
- analysing anonymised data to help us understand how people interact with govt services so we can make them better

You can manage these small files and learn more about them from the article, Internet Browser cookies- what they are and how to manage them.

Learn how to remove cookies set on your device.

There are two types of cookie you may encounter when using Cycle Revolution :

First party cookies: these are our own cookies, controlled by us and used to provide information about usage of our site.

Third party cookies: these are cookies found in other companies' internet tools which we are using to enhance our site, for example Facebook or Twitter have their own cookies, which are controlled by them.


First party cookies

*Cycle Revolution uses cookies in several places - we've listed each of them below with more details about why we use them and how long they will last.

We will endeavour to let you know before we store a cookie on your computer.

Our Own PERSISTANT cookies

Name Purpose Typical content
_Session This cookie speeds up your experience on our website if you visit us more than once by remembering key information if you have set your browser to allow it. For example your username when logging in, or your preferences when browsing our website. It is an anonymous customer ID cookie, so we do not save any specific data about you at all, just a unique _Session reference number

Cookies set by Cycle Revolution website

Name Purpose Expires
ASP.NET_SessionId
HttpReferer
Referer
dd_object
These only last for the session (visit) to our website, and help with your movement through the website, and also let us know if you have visited from a 'Referer' i.e. another website where we may have a link, or an article about us. Expires on exit

Third party cookies

We use a number of suppliers who may also set cookies on their websites' on its behalf. Cycle Revolution do not control the dissemination of these cookies. You should check the third party websites for more information about these.

Provider Name Purpose More Info
Google Analytics _utma
_utmb
_utmc
_utmz
These cookies are used to collect information about how visitors use our site. We use the information to compile reports and to help us improve the site. The cookies collect information in an anonymous form, including the number of visitors to the site, where visitors have come to the site from and the pages they visited. They do not contain any personally identifiable information. Google Privacy policy
Add This _atuvc The _atuvc cookie is created and read by our JavaScript on the client side in order to make sure the user sees the updated count if they share a page and return to it before our share count cache is updated. No data from that cookie is sent back to AddThis. Add This privacy

Changes to this privacy policy

If this privacy policy changes in any way, we will place an updated version on this page. Regularly reviewing this page ensures that you are always aware of what information we collect, how we use it and under what circumstances, if any, we will share it with other parties.

You can use the settings of your browser to block, or delete cookies as you wish. Do please note that blocking cookies may slow down your experience on our website, or cause issues with placing an order, as cookies are often required to help with a smooth checkout process!

If you have any questions about our cookies policy or feedback please contact us on 01206 764545 or via our contact us page link at the top of the page.