Privacy Policy

Master Distributor Ltd trading as Cloud Nine

Privacy Policy and Cookie Policy 21st May 2018

Background:

Master Distributor Ltd understands that your privacy is important to you and that you care about how your information is used and shared online. We respect and value the privacy of everyone who visits Our Site and will only collect and use information in ways that are useful to you and in a manner consistent with your rights and Our obligations under the law.

This Policy applies to Our use of any and all data collected by us in relation to your use of Our Site. Please read this Privacy Policy carefully and ensure that you understand it. Your acceptance of Our Privacy Policy is deemed to occur upon your first use of Our Site. If you do not accept and agree with this Privacy Policy, you must stop using Our Site immediately.

1. Definitions and Interpretation

In this Policy the following terms shall have the following meanings:

“Account” means an account required to access and/or use certain areas of the features of Our site;
“Cookie” means a small text file placed on your computer or device by Our Site when you visit certain parts of Our Site and/or when you use certain features of Our Site. Details of the Cookies used by Our Site are set our in section 12, below;
“Our Site” means this website, www.cloudninehair.com
“UK and EU Cookie Law” means the relevant parts of the Privacy and Electronics Communications (EC Directive) Regulations 2003 as amended in 2004,2011 and 2015; and
“We/Us/Our” means Master Distributor Ltd, a limited company registered in England under 07079855 whose registered address is Sanderson House, Station Road, Horsforth, Leeds, LS18 5NT, and whose main training address is A2, Hornbeam Square West, Hornbeam Park, Harroagte, North Yorkshire, HG2 8PA.

2. Information About Us

2.1 Our Site, www.cloudninehair.com is owned and operated by Master Distributor Ltd, a limited company registered in England under 07079855, whose registered address is Sanderson House, Station Rd, Horsforth, Leeds, LS18 5NT and whose main trading address is A2, Hornbeam Square West, Hornbeam Park, Harrogate, North Yorkshire, HG2 8PA.

2.2 Our data protection officer is Sandra Elliott who can be contacted at sandra.elliott@cloudninehair.com

3. Scope – What Does This Policy Cover?

This Privacy Policy applies only to your use of Our Site. It does not extend to any websites that are linked to from Our Site (whether We provide those links or whether they are shared by other users). 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. What Data Do We Collect?

Some data will be collected automatically by Our Site (for further details, please see section 12 on Our use of Cookies), other data will only be collected if you voluntarily submit it and consent to Us using it for the purposes set out in section 5, for example, when signing up for an Account. Depending upon your use of Our Site, We may collect some or all of the following data:

4.1 Name;
4.2 date of birth;
4.3 gender;
4.4 business/company name
4.5 job title;
4.6 profession;
4.7 contact information such as email addresses and telephone numbers;
4.8 demographic information such as post code, preferences and interests;
4.9 financial information such as credit / debit card numbers;
4.10 IP address (automatically collected);
4.11 web browser type and version (automatically collected);
4.12 operating system (automatically collected);
4.13 a list of URLs starting with a referring site, your activity on Our Site, and the site you exit to (automatically collected);

5. How Do We Use Your Data?

5.1 All personal data is stored securely in accordance with the EU General Data Protection Regulation (Regulation (EU) 2016/679) (GDPR). For more details on security see section 6, below.

5.2 We use your data to provide the best possible products services to you. This includes:

5.2.1 Providing and managing your Account;
5.2.2 Providing and managing your access to Our Site;
5.2.3 Personalising and tailoring your experience on Our Site;
5.2.4 Supplying Our products and services to you;
5.2.5 Personalising and tailoring Our products and services for you;
5.2.6 Responding to communications from you;
5.2.7 Supplying you with emails e.g. newsletters, alerts, birthday wishes etc. that you have subscribed to (you may unsubscribe or opt-out at any time by using the Unsubscription link within the footer of the emails or by contacting our customer service department);
5.2.8 Market research;
5.2.9 Analysing your use of Our Site and gathering feedback to enable Us to continually improve Our Site and your user experience;

5.3 In some cases, the collection of data may be a statutory or contractual requirement, and We will be limited in the products and services We can provide you without your consent for Us to be able to use such data.

5.4 With your permission and/or where permitted by law, We may also use your data for marketing purposes which may include contacting you by email AND/OR telephone AND/OR text message AND/OR post with information, news and offers on Our products AND/OR services. We will not, however, send you any unsolicited marketing or spam and will take all reasonable steps to ensure that We fully protect your rights and comply with Our obligations under the GDPR and the Privacy and Electronic Communications (EC Directive) Regulations 2003, as amended in 2004, 2011 and 2015.

5.5 Under GDPR we will ensure that your personal data is processed lawfully, fairly, and transparently, without adversely affecting your rights. We will only process your personal data if at least one of the following basis applies:

a) you have given consent to the processing of your personal data for one or more specific purposes;
b) processing is necessary for the performance of a contract to which you are a party or in order to take steps at the request of you prior to entering into a contract;
c) processing is necessary for compliance with a legal obligation to which we are subject;
d) processing is necessary to protect the vital interests of you or of another natural person;
e) 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 controller; and/or
f) processing is necessary for the purposes of the legitimate interests pursued by us or by a third party, except where such interests are overridden by the fundamental rights and freedoms of the data subject which require protection of personal data, in particular where the data subject is a child.

6. How and Where Do We Store Your Data?

6.1 We only keep your data for as long as We need to in order to use it as described above in section 5, and/or for as long as We have your permission to keep it. In any event, We will conduct an annual review to ascertain whether we need to keep your data. Your data will be deleted if we no longer need it in accordance with the terms of our Data Retention Policy. Our Data Retention Policies are:

Data Retention Policy

Introduction:

This data retention policy sets out the obligations of Master Distributor Ltd (“us/we/our”) and the basis upon which we shall retain, review and destroy data held by us, or within our custody or control.

This policy applies to our entire organisation including our officers, employees, agents and sub-contractors and sets out what the retention periods are and when any such data may be deleted.

We are registered under the Information Commissioner’s Office under registration number 07079855

Objectives

It is necessary to retain and process certain information to enable our business to operate. We may store data in the following places:

  • our own servers;
  • any third party servers;
  • potential email accounts;
  • desktops;
  • employee-owned devices (BYOD);
  • potential backup storage; and/or
  • our paper files.

This policy applies equally to paper, electronic media and any other method used to store personal data. The period of retention only commences when the record is closed.

We are bound by various obligations under the law in relation to this and therefore, to comply with the law, information must be collected and used fairly, stored safely and not disclosed to any other person unlawfully in respect of their personal data under the General Data Protection Regulation (“the Regulation”).

The Regulation defines “personal data” as any information relating to an identified or identifiable natural person (a data subject); an identifiable natural person is one 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 to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural, or social identity of that natural person.

This Policy sets out the procedures that are to be followed when dealing with personal data and how we aim to comply with the Regulation in so far as it is possible. In summary, the Regulation states that all personal data shall be:

a) processed lawfully, fairly, and in a transparent manner in relation to the data subject;

b) collected for specified, explicit, and legitimate purposes and not further processed in a manner that is incompatible with those purposes; further processing for archiving purposes in the public interest, scientific or historical research purposes or statistical purposes shall not be considered to be incompatible with the initial purposes;

c) adequate, relevant and limited to what is necessary in relation to the purposes for which it is processed;

d) accurate and, where necessary, kept up to date; every reasonable step must be taken to ensure that personal data that is inaccurate, having regard to the purposes for which they are processed, is erased or rectified without delay;

e) 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; personal data may be stored for longer periods insofar as the personal data will be processed solely for archiving purposes in the public interest, scientific or historical research purposes or statistical purposes subject to implementation of the appropriate technical and organisational measures required by the Regulation in order to safeguard the rights and freedoms of the data subject;

f) 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, using appropriate technical or organisational measures.

The Fourth and Fifth Data Protection Principles require that any data should not be kept longer than necessary for the purpose for which it is processed and when it is no longer required, it shall be deleted and that the data should be adequate, relevant and limited for the purpose in which it is processed.

With this in mind, this policy should be read in conjunction with our other policies which are relevant such as our data protection policy and IT security policy.

Security and Storage

All data and records are stored securely to avoid misuse or loss. We will take appropriate security measures against unlawful or unauthorised processing of personal data, and against the accidental loss of, or damage to, personal data.
We will put in place procedures and technologies to maintain the security of all personal data from the point of collection to the point of destruction. Personal data will only be transferred to a data processor if there is agreement by them to comply with those procedures and policies, or if there are adequate measures in place.

Examples of our storage facilities are as follows:

Documents and files - Locked filing cabinets,
Digital Data – Secure and password protected server with online back up
We will maintain data security by protecting the confidentiality, integrity and availability of the personal data, defined as follows:

(a) Confidentiality means that only people who are authorised to use the data can access it.

(b) Integrity means that personal data should be accurate and suitable for the purpose for which it is processed.

(c) Availability means that authorised users should be able to access the data if they need it for authorised purposes. Personal data should therefore be stored on the [COMPANY’S] central computer system instead of individual PCs.

Retention Policy

Data retention is defined as the retention of data for a specific period of time and for back up purposes.

We shall not keep any personal data longer than necessary, but acknowledge that this will be dependent on the different types of documents and data that we have responsibility for. As such, our general data retention period shall be for a period of 6 years. Our specific data retention periods are set out below.

Type of data Retention Period
Customers 6 Years
Business Contacts 6 Years
Employees 6 Years
Contractors 6 Years
Potential Employees 1 Years
Sensitive Data 2 Years
Insert others


From time to time, it may be necessary to retain or access historic personal data under certain circumstances such as if we have contractually agreed to do so or if we have become involved in unforeseen events like litigation or business disaster recoveries.

Destruction and Disposal

Upon expiry of our retention periods, we shall delete confidential or sensitive records categorised as requiring high protection and very high protection, and we shall either delete or anonymise less important documents.

Our Data Lead (Sandra Elliott) is responsible for the continuing process of identifying the records that have met their required retention period and supervising their destruction. The destruction of confidential, financial, and personnel-related records shall be securely destroyed electronically or by shredding if possible. Non-confidential records may be destroyed by recycling.

6.2 Your data will only be stored within the European Economic Area (“the EEA”) (The EEA consists of all EU member states, plus Norway, Iceland and Liechtenstein).

6.3 Data security is of great importance to Us, and to protect your data We have put in place suitable physical, electronic and managerial procedures to safeguard and secure data collected through Our Site.

We have put in place suitable physical, electronic and managerial procedures to safeguard and secure the information we collect online. We use industry standard encryption technologies when collecting or transferring customer credit card information exchanged with our Site server - all your card details are passed from your browser to our secure payment gateway using secure sockets layer (SSL) encryption. Our payment gateway providers use secure sockets layer (SSL) encryption system. All other information transferred is conducted through a secure connection.

Where we have given you (or where you have chosen) a password which enables you to access certain parts of the Site, you are responsible for keeping this password confidential. We ask you not to share your password with anyone. All information provided through the Site is stored on servers located in the European Economic Area (EEA). It will be processed by staff operating in the UK who work for Cloud Nine. Such staff may be engaged in, among other things, the processing of your payment details and the provision of support services. By submitting your personal information, you agree to this transfer, storing or processing. Cloud Nine will take all steps reasonably necessary to ensure that your data is treated securely in accordance with this Privacy and Cookies Policy.

6.4 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.

7. Do We Share Your Data?

7.1 We may share your data with other companies in Our group. This includes Our subsidiaries AND/OR Our holding company and its subsidiaries.

7.2 We may contract with third parties to supply products and services to you on Our behalf. These may include payment processing, delivery of goods, search engine facilities, advertising and marketing. 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. We currently contract with:

  • Sagepay
  • Paypal
  • Sage200
  • Stonehouse logistics
  • Orbis
  • EnergyCell
  • VividNorth
  • Parcel Force
  • MetaPack
  • DHL
  • Amazon Web Services
  • Rackspace
  • Dotmailer
  • GBG
  • Feefo
  • PG Branding

7.3 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 information. 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.

7.4 In certain circumstances We may be legally required to share certain data held by Us, which may include your personal information, for example, where We are involved in legal proceedings, where We are complying with the requirements of legislation, 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.

8. What Happens If Our Business Changes Hands?

8.1 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. Data provided by users will, where it is relevant to any part of Our business so transferred, be transferred along with that part and the new owner or newly controlling party will, under the terms of this Privacy Policy, be permitted to use the data for the purposes for which it was originally collected by Us.

8.2 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.

9. How Can You Control Your Data?

9.1 When you submit information via Our Site, you may be given options to restrict Our use of your data. We aim to give you strong controls on Our use of your data (including the ability to opt-out of receiving emails from Us which you may do by unsubscribing using the links provided in Our emails and at the point of providing your details AND/OR by managing your Account.

9.2 You may also wish to sign up to one or more of the preference services operating in the UK: The Telephone Preference Service (“the TPS”), the Corporate Telephone Preference Service (“the CTPS”), and the Mailing Preference Service (“the MPS”). These may help to prevent you receiving unsolicited marketing. Please note, however, that these services will not prevent you from receiving marketing communications that you have consented to receiving.

10. Your Right to Withhold Information and Your Right to Withdraw Information After You Have Given it

10.1 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.

10.2 You may restrict your internet browser’s use of Cookies. For more information, see section 12.

10.3 You may withdraw your consent for Us to use your personal data as set out in section in 5 at any time by contacting Us using the details set out in section 15, and We will delete Your data from Our systems. However, you acknowledge this may limit Our ability to provide the best possible products and services to you.

11. How Can You Access Your Data?

You have the legal right to ask for a copy of any of your personal data held by Us (where such data is held). Please contact Us for more details at sandra.elliott@cloudninehair.com or using the contact details below in section 14.

12. What Cookies Do We Use and What For?

12.1 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 and services. For more details, please refer to section 5, above, and to section 12.6 below. We have carefully chosen these Cookies and have taken steps to ensure that your privacy is protected and respected at all times.

12.2 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. We use third party Cookies on Our Site to:

  • place advertisements for our products on other external sites. We do this by allowing third parties including Google and Adserve to place cookies on our Site which allows them to identify your visit to our Site and preferences shown whilst on it, and your visits to subsequent third party websites in their adserving network. This allows us to serve tailored advertisements to you on those third party websites based on the information we have collected on your interests whilst you were visiting our Site.
  • help the Site to function correctly and ensure that the ‘add to bag’, navigation and country site settings are maintained.
  • monitor the Site’s performance and ensure that we deliver a fast browsing experience.
  • allow you to share content with social networks, express interest in content and connect with your social media networks.
  • to allow us to collect anonymous data about Site usage to help us improve the usability, content and user experience of the Site. This includes site analytics cookies such as Google Analytics. We also use Google Analytics to collect information about your online activity on the Site, such as the web pages you visit, the links you click, and the searches you conduct on the 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. For more information about the information gathered using Google Analytics please visit http://www.google.com/intl/en_uk/analytics/tos.html
  • to assess third party conversion by allowing us to collect anonymous data about how our marketing is performing.

For more details, please refer to section 5, above, and to section 12.6 below. These Cookies are not integral to the functioning of Our Site.

12.3 All Cookies used by and on Our Site are used in accordance with current English and EU Cookie Law.

12.4 Before any Cookies are placed on your computer or device subject to section 12.4 AND/OR section 12.8, you will be shown a pop-up/message bar requesting your consent to set those Cookies. By giving your consent to the placing of 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 will be given the opportunity to allow only first party Cookies and block third party Cookies.

12.5 Certain features of Our Site depend on Cookies to function. UK and EU Cookie Law deems these Cookies to be “strictly necessary”. These Cookies are shown below in section

12.6. Your consent will not be sought to place these Cookies. You may still block these Cookies by changing your internet browser’s settings as detailed below in section 12.10, but please be aware that Our Site may not work as intended if you do so. We have taken great care to ensure that your privacy is not at risk by allowing them.

12.7 The following Necessary Cookies may be placed on your computer or device. Necessary cookies help make a website usable by enabling basic functions like page navigation and access to secure areas of the website. The website cannot function properly without these cookies.

12.8 The following Preference cookies may be placed on your computer or device. Preference cookies enable a website to remember information that changes the way the website behaves or looks, like your preferred language or the region that you are in.

12.9 The following Statistics cookies may be placed on your computer or device. Statistic cookies help website owners to understand how visitors interact with websites by collecting and reporting information anonymously.

12.10 The following Marketing cookies may be placed on your computer or device. Marketing cookies are used to track visitors across websites. The intention is to display ads that are relevant and engaging for the individual user and thereby more valuable for publishers and third party advertisers.

12.11 Our Site uses analytics services provided by Google Univesral Analytics; Google Advance E-Commerce Tracking; Facebook Insights. Website analytics refers to a set of tools used to collect and analyse usage statistics, enabling Us to better understand how people use Our Site. This, in turn, enables Us to improve Our Site and the products and services offered through it. You do not have to allow Us to use these Cookies, as detailed below, 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.

12.12 The analytics service(s) used by Our Site use(s) Cookies to gather the required information. Some of these Cookies may be placed immediately when you first visit Our Site and it may not be possible for Us to obtain your prior consent. You may remove these Cookies and prevent future use of them by following the steps set out below in section

12.13 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. By default, most internet browsers accept Cookies but this can be changed. For further details, please consult the help menu in your internet browser or the documentation that came with your device.

12.14 You can choose to delete Cookies 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.

12.15 It 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.

Cookies used by our site

13 Summary of Your Rights under GDPR

Under the GDPR, you have:

13.1 the right to request access to, deletion of or correction of, your personal data held by Us;

13.2 the right to complain to a supervisory authority;

13.3 be informed of what data processing is taking place;

13.4 the right to restrict processing;

13.5 the right to data portability;

13.6 object to processing of your personal data;

13.7 rights with respect to automated decision-making and profiling (see section 14 below).

To enforce any of the foregoing rights or if you have any other questions about Our Site or this Privacy Policy, please contact Us using the details set out in section 15 below.

14 Automated Decision-Making and Profiling

14.1 In the event that We use personal data for the purposes of automated decision-making and those decisions have a legal (or similarly significant effect) on You, You have the right to challenge to such decisions under GDPR, requesting human intervention, expressing their own point of view, and obtaining an explanation of the decision from Us.

14.2 The right described in section 14.1 does not apply in the following circumstances:

  • 14.1.1.1 The decision is necessary for the entry into, or performance of, a contract between the You and Us;
  • 14.1.1.2 The decision is authorised by law; or
  • 14.1.1.3 You have given you explicit consent.

14.3 Where We use your personal data for profiling purposes, the following shall apply:

  • 14.1.1.3.1 Clear information explaining the profiling will be provided, including its significance and the likely consequences;
  • 14.1.1.3.2 Appropriate mathematical or statistical procedures will be used;
  • 14.1.1.3.3 Technical and organisational measures necessary to minimise the risk of errors and to enable such errors to be easily corrected shall be implemented; and
  • 14.1.1.3.4 All personal data processed for profiling purposes shall be secured in order to prevent discriminatory effects arising out of profiling.

15 Contacting Us

If you have any questions about Our Site or this Privacy Policy, please contact Us by email at Sandra Elliott, by telephone on +44 1423 223327 or by post at A2, Hornbeam Square West, Hornbeam Park, Harrogate, North Yorkshire, HG2 8PA. Please ensure that your query is clear, particularly if it is a request for information about the data We hold about you (as under section 11, above).

16 Changes to Our Privacy Policy

We may change this Privacy Policy as we may deem necessary from time to time, or as may be required by law. Any changes will be immediately posted on Our Site and you will be deemed to have accepted the terms of the Privacy Policy on your first use of Our Site following the alterations. We recommend that you check this page regularly to keep up-to-date.

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