CKB Ltd

How We Use Your Information:

Website Privacy & Cookies Policy (Business-to-Customer)

December 2023

Background:
CKB Ltd ® and its group brands including Gifts Tomorrow ™, Lanyards Tomorrow ® and Bar Amigos ® understand that your privacy is important to you and that you care about how your personal data is used and shared online. We respect and value the privacy of everyone who visits Our Site and will only collect and use personal data in ways that are described here, and in a manner that is consistent with Our obligations and your rights under the law. We have also analysed Our Site and its appeal in respect of the Age-Appropriate Design Code 2020.

Please read this Website Privacy and Cookies Policy carefully and ensure that you understand it. If you do not accept and agree with this Policy, you must stop using Our Site immediately.

1. Definitions and Interpretation
In this Policy, the following terms shall have the following meanings:

2. Information About Us
2.1 Our Site is owned and operated by CKB Ltd ®, a limited company registered in England under 07123102, whose registered address is St. Christopher’s House, Ridge Road, Letchworth Garden City, Hertfordshire, SG6 1PT, England and whose main trading address is Unit 5, Business Centre East, Fifth Avenue, Letchworth Garden City, Hertfordshire, SG6 2TS. We also operate under our other group company brands as outlined above.
2.2 Our VAT number is 991324508.
2.3 Our Data Protection Officer is the position holder of Company Secretary, and can be contacted at Unit 5, Business Centre East, Fifth Avenue, Letchworth Garden City, Hertfordshire, SG6 2TS.
2.4 If you are in the European Union, you may address privacy-related inquiries to our EU Representative pursuant to Article 27 EU-GDPR:

EU-REP.Global GmbH
www.eu-rep.global
Attn: CKB Ltd.
Hopfenstr. 1d, 24114 Kiel, Germany
[email protected]

3. What Does This Policy Cover?
This Policy applies only to your use of Our Site. Our Site may contain links to other websites. Please note that We have no control over how your data is collected, stored, or used by other websites and We advise you to check the privacy policies of any such websites before providing any data to them.

4. Your Rights
4.1 As a data subject, you have the following rights under the UK-GDPR, which this Policy and Our use of personal data have been designed to uphold:
4.1.1 The right to be informed about Our collection and use of personal data;
4.1.2 The right of access to the personal data We hold about you (see Part 12);
4.1.3 The right to rectification if any personal data We hold about you is inaccurate or incomplete (please contact Us using the details in Part 14);
4.1.4 The right to be forgotten – i.e. the right to ask Us to delete any personal data We hold about you (We hold your personal data for a certain time period, as explained in Part 6 but if you would like Us to delete it sooner, please contact Us using the details in Part 14);
4.1.5 The right to restrict (i.e. prevent) the processing of your personal data;
4.1.6 The right to data portability (obtaining a copy of your personal data to re-use with another service or organisation);
4.1.7 The right to object to Us using your personal data for particular purposes including in sending you direct marketing
4.1.8 The right to withdraw consent. This means that if the Company is relying on your consent as the legal basis for using your personal data, you are free to withdraw that consent at any time; and
4.1.9 Rights with respect to automated decision making and profiling (including your right to object to this).
Please note that the Company undertakes no direct e-mail. postal or telephone marketing activity to promote products to individual customers. Any profiling activity undertaken by the Company is done to analyse visitor behaviour on Our Site. This is done using an IP address which provides details of where a visitor has come from on the internet and how long a visitor spends on each of the Company web pages. Cookie preferences can be altered at any time to cease profiling activity. For more information, please refer to the Company Data Protection Policy located on Our Site.
4.2 If you have any cause for complaint about Our use of your personal data, please contact Us using the details provided in Part 14 and We will do Our best to solve the problem for you. If We are unable to help, you also have the right to lodge a complaint with the UK’s supervisory authority, the Information Commissioner’s Office.
4.3 For further information about your rights, please contact the Information Commissioner’s Office or your local Citizens Advice Bureau.

5. What Data Do We Collect?
Depending upon your use of Our Site, we may collect some or all of the following personal and non-personal data (please also see Part 13 on Our use of Cookies and similar technologies):
5.1 name;
5.2 business/company name
5.3 contact information such as email addresses, postal addresses and telephone numbers;
5.4 Order history;
5.5 demographic information such as post code and over 18 age confirmation for age rated products (if applicable);
5.6 IP address;
5.7 web browser type and version;
5.8 operating system; and
5.9 a list of URLs starting with a referring site, your activity on Our Site, and the site you exit to.

6 How Do We Use Your Data?
6.1 All personal data is processed and stored securely, for no longer than is necessary in light of the reason(s) for which it was first collected. We will comply with Our obligations and safeguard your rights under the UK-GDPR at all times. For more details on security see Part 7, below.
6.2 Our use of your personal data will always have a lawful basis, either because it is necessary for Our performance of a contract with you, because you have consented to Our use of your personal data (e.g. by holding an Account), because it is required for financial accounting purposes or because it is in Our legitimate interests. Specifically, We may use your data for the following purposes:
6.2.1 Providing and managing your Account (consent);
6.2.2 Providing and managing your access to Our Site (legitimate interests);
6.2.3 Personalising and tailoring your experience on Our Site (legitimate interests/ consent options);
6.2.4 Supplying Our products to you – i.e. fulfilling an order (please note that We require your personal data in order to enter into a contract with you) (contractual);
6.2.5 Personalising and tailoring Our products for you including for the purpose of order fulfilment – for example, to fulfil a personalised order such as for lanyards. This may include you dealing directly with a third-party supplier for a product proof and delivery of your order (contractual);
6.2.6 Replying to emails and communications from you (contractual);
6.2.7 Analysing your use of Our Site and gathering feedback to enable Us to continually improve Our Site and your user experience (including personalising and tailoring Our product adverts on social media, for example, for you and providing functionality to enable users to share/ like product updates on social media) (legitimate interests/ consent options); and
6.2.8 As is required under the law for financial accounting purposes, for example (financial).
6.3 We will not use individual customer data for marketing purposes which includes contacting you by e-mail, telephone, text message and/ or post with news or information about our company or our products.
The Company may, however, undertake marketing activity to promote products to businesses based on Our legitimate interests and in accordance with Our marketing strategy.
6.4 Third parties utilised by the Company, such as Facebook, may, however, engage in what is known as “behavioural advertising”; advertising which is tailored to your preferences, based on your activity. Your activity is monitored using Cookies, as detailed below in Part 13. You can control and limit your data used in this way by adjusting your web browser’s privacy settings. Please note that We do not control the activities of such advertisers, nor the information they collect and use which is based on the third party’s filters. Limiting the use of your data in this way will not necessarily remove the advertising, but it may make it less relevant to your interests and activities.
6.5 Third parties (including customer review sites such as eKomi and Google Trusted Store and payment service providers including PayPal, and Braintree) whose content appears on Our Site may use third party Cookies, as detailed below in Part 13. Please refer to Part 13 for more information on controlling Cookies. Please note that We do not control the activities of such third parties, nor the data they collect and use and advise you to check the privacy policies of any such third parties.
6.6 You have the right to withdraw your consent to Us using your personal data at any time, and to request that We delete it.
6.7 We do not keep your personal data for any longer than is necessary in light of the reason(s) for which it was first collected. Data will therefore be retained for the following periods (or its retention will be determined on the following bases):
6.7.1 For the time period required for legal and financial accounting purposes; and/ or
6.7.2 Because you have consented to Our use of your personal data (e.g. by setting up an Account). We will retain your data until you unsubscribe from having an Account. Should you decide you no longer wish to have an Account, please e-mail [email protected] confirming whether you wish to cancel your Account with Gifts Tomorrow ™ or Lanyards Tomorrow ®,. Should you wish to cancel Accounts on both of Our Sites, an e-mail should be sent to [email protected] confirming this and arrangements will be made for the removal.

7 How and Where Do We Store Your Data?
7.1 We only keep your personal data for as long as We need to and/ or are required to and/ or have your permission to in order to use it as described above in Part 6.
7.2 The UK has issued regulations confirming that a country ensures an adequate level of protection (referred to as ‘adequacy decisions’ or ‘adequacy regulations’) in respect of data transfers outside of the UK following Brexit. Since 1st January 2021, transfers of personal data from the UK to the European Economic Area (“the EEA”) (The EEA consists of all EU member states, plus Norway, Iceland, and Liechtenstein) continue to be permitted. Pre-existing EU Commission adequacy decisions in effect pre-Brexit as at 31/12/2020 are also recognised, subject to ongoing review by the UK Government.
7.3 Some or all of your data may be stored outside of the EEA. You are deemed to accept and agree to this by using Our Site and submitting information to Us. If We do store data outside the EEA, We will take all reasonable steps to ensure that your data is treated as safely and securely as it would be within the UK and under data protection regulations including:
7.3.1 Approaching any relevant partner/ supplier organisations for confirmation that their data storage processes are acceptable (see Part 8); and
7.3.2 putting in place suitable physical, electronic and managerial procedures to safeguard and secure data collected through Our Site.
7.4 Data security is very important to Us, and to protect your data We have taken suitable measures to safeguard and secure data collected through Our Site.
7.5 Steps We take to secure and protect your data include: Our Site is PCI DSS compliant and uses a SSL (Secure Sockets Layer Software) Certificate to protect your personal information.
7.6 Notwithstanding the security measures that We take, it is important to remember that the transmission of data via the internet may not be completely secure and that you are advised to take suitable precautions when transmitting to Us data via the internet.

8 Do We Share Your Data?
8.1 We may share your data within our Company group of brands which includes CKB Ltd ®, Lanyards Tomorrow ®, Gifts Tomorrow ™ and Bar Amigos ®.
8.2 We may contract with third parties to supply services to you on Our behalf. These include payment processing, product and service feedback reviews and delivery of goods. In some cases, the third parties may require access to some or all of your data. Where any of your data is required for such a purpose, We will take all reasonable steps to ensure that your data will be handled safely, securely, and in accordance with your rights, Our obligations, and the obligations of the third party under the law.
8.3 We may compile statistics about the use of Our Site including data on traffic, usage patterns, user numbers, sales, and other information. All such data will be anonymised and will not include any personally identifying data, or any anonymised data that can be combined with other data and used to identify you. We may from time to time share such data with third parties such as prospective investors, affiliates, partners, and advertisers. Data will only be shared and used within the bounds of the law.
8.4 We may sometimes use third party data processors that are located outside of the EEA. Where We transfer any personal data outside the EEA, We will take all reasonable steps to ensure that your data is treated as safely and securely as it would be within the UK and under data protection regulations including:
8.4.1 Approaching any relevant partner/ supplier organisations for confirmation that their data storage and processing activities are acceptable.
8.5 In certain circumstances, We may be legally required to share certain data held by Us, which may include your personal data, for example, where We are involved in legal proceedings, where We are complying with legal requirements, a court order, or a governmental authority. We do not require any further consent from you in order to share your data in such circumstances and will comply as required with any legally binding request that is made of Us.
9 What Happens If Our Business Changes Hands?
9.1 We may, from time to time, expand or reduce Our business and this may involve the sale and/or the transfer of control of all or part of Our business. Any personal data that you have provided will, where it is relevant to any part of Our business that is being transferred, be transferred along with that part and the new owner or newly controlling party will, under the terms of this Policy, be permitted to use that data only for the same purposes for which it was originally collected by Us.
9.2 In the event that any of your data is to be transferred in such a manner, you will not be contacted in advance and informed of the changes as we do not issue marketing and information communications. You will, however, continue to have the choice to have your data deleted.
10 How Can You Control Your Data?
10.1 In addition to your rights under the UK-GDPR, set out in Part 4, when you submit personal data via Our Site, you will be given options to restrict Our use of your data (e.g. via accessing the Cookie consent function).

11 Your Right to Withhold Information
11.1 You may access certain areas of Our Site without providing any data at all. However, to use all features and functions available on Our Site you may be required to submit or allow for the collection of certain data.
11.2 You may restrict Our use of Cookies. For more information, see Part 13.
12 How Can You Access Your Data?
12.1 You have the right to ask for a copy of any of your personal data held by Us (where such data is held). Under the UK-GDPR, no fee is payable, and We will provide any and all information in response to your request free of charge. Please contact Us for more details using the contact details below in Part 14.
13 Our Use of Cookies
13.1 A cookie is a small file, typically of letters and numbers, downloaded on to a device when the user accesses certain websites. Cookies allow a website to recognise a user’s device and provide enhanced website functionality for the user as a result. Cookies are generated when you first visit Our Site as they tell us useful analytical information including which site you have visited from. You can decline consent for such cookies once on our Site. However, prior to this, acceptance of such cookies is deemed to occur via implied consent as you visited Our Site, and the consent option is presented to you once on Our Site (for those landing cookies). We also consider We have a legitimate interest to gather this landing data to inform the success of our investment in online advertising, for example, as a small family run business.
13.2 Cookies can be session cookies or persistent cookies. Session cookies only last for the duration of your online session and disappear from your device when you close your browser. Persistent cookies, however, stay on your device after the browser has been closed and last for the period of time specified in the cookie. Furthermore, persistent cookies are activated each time you visit the site that the cookie was generated by and include analytics tools.
13.3 Our Site may place and access certain first party Cookies on your computer or device. First party Cookies are those placed directly by Us and are used only by Us. We use Cookies to facilitate and improve your experience of Our Site and to provide and improve Our products. We have carefully chosen these Cookies and have taken steps to ensure that your privacy and personal data is protected and respected at all times.
13.4 By using Our Site you may also receive certain third party Cookies on your computer or device. Third party Cookies are those placed by websites, services, and/or parties other than Us. Third party Cookies are used on Our Site for analysing website usage and trends, for example. For more details, please refer to Part 6, above, and to Part 13.6 below. These Cookies are not integral to the functioning of Our Site and your use and experience of Our Site will not be impaired by refusing consent to them.
13.5 All Cookies used by and on Our Site are used in accordance with current Cookie Law.
13.6 Before Cookies are placed on your computer or device, you will be shown a message requesting your consent to set those Cookies (apart from the landing cookies as outlined in 13.1). By giving your consent to the placing of Cookies (‘functional’ and ‘performance’ Cookies) you are enabling Us to provide the best possible experience and service to you. You may, if you wish, deny consent to the placing of Cookies; however certain features of Our Site may not function fully or as intended. You may also later go back into the Cookie consent options after initially consenting and change your consent preferences.
13.7 Certain features of Our Site depend on Cookies to function. Cookie Law deems these Cookies to be “strictly necessary”. These Cookies are shown below in Part 13.8. Your consent will not be sought to place these Cookies as they are based on our legitimate interests in the functioning of Our Site, but it is still important that you are aware of them. You may still block these Cookies by changing your internet browser’s settings as detailed below in Part 13.12, but please be aware that Our Site may not work properly if you do so. We have taken great care to ensure that your privacy is not at risk by allowing them.
13.8 The following first party Cookies may be placed on your computer or device:

and the following third party Cookies may be placed on your computer or device:

13.9 Our Site uses analytics services provided by Google. Website analytics refers to a set of tools used to collect and analyse anonymous usage information, enabling Us to better understand how Our Site is used. This, in turn, enables Us to improve Our Site and the products offered through it. You do not have to allow Us to use these Cookies, however whilst Our use of them does not pose any risk to your privacy or your safe use of Our Site, it does enable Us to continually improve Our Site, making it a better and more useful experience for you.
13.10 The analytics service(s) used by Our Site use(s) Cookies to gather the required information. Information pertaining to Location information is also gained from an IP address for consumer behaviour analysis.
13.11The analytics service(s) used by Our Site use(s) the following Cookies:

13.12 In addition to the controls that We provide which are accessed via the Cookie consent function, you can choose to enable or disable Cookies in your internet browser. Most internet browsers also enable you to choose whether you wish to disable all cookies or only third party Cookies. For further details, please consult the help menu in your internet browser or the documentation that came with your device.
13.13You can choose to delete Cookies on your computer or device at any time, however you may lose any information that enables you to access Our Site more quickly and efficiently including, but not limited to, login and personalisation settings.
13.14We also use software to enhance Our Site’s functionality. We use postcode prediction software to pre-fill the address field based on a postcode as well as using currency prediction software and translation software to update Our Site’s currency to a local currency and/ or language* to a local language based on the initial part of an IP address (*language option relates to www.giftstomorrow.co.uk only). We also utilise anti-click fraud prevention software for AdWords. Details of the software providers have not been included in the table under Part 13.8 for reasons of Our requirement to protect our business knowledge and security. Should a data subject wish to enquire further about this please contact our Data Protection Officer at Unit 5, Business Centre East, Fifth Avenue, Letchworth Garden City, Herts, SG6 2TS.
13.15It is recommended that you keep your internet browser and operating system up-to-date and that you consult the help and guidance provided by the developer of your internet browser and manufacturer of your computer or device if you are unsure about adjusting your privacy settings.

14. Contacting Us
14.1 If you have any questions about Our Site or this Policy, please contact Us by email at [email protected], by telephone on +44 (0)1462 682020, or by post at Unit 5, Business Centre East, Fifth Avenue, Letchworth Garden City, Hertfordshire, SG6 2TS. Please ensure that your query is clear, particularly if it is a request for information about the data We hold about you (as under Part 12, above).

15. Changes to Our Website Privacy and Cookies Policy
15.1 We may change this Policy from time to time (for example, if the law changes). Any changes will be immediately posted on Our Site and you will be deemed to have accepted the terms of the Policy on your first use of Our Site following the alterations. We recommend that you check this page regularly to keep up-to-date.

16. Implementation of Policy
16.1 This Policy shall be deemed effective as of 1st December 2023. No part of this policy shall have retroactive effect and shall thus apply only to matters occurring on or after this date.

V15 Website Privacy & Cookies Policy – effective date 1st December 2023