As the operators of this website, M&G Crowe Limited (company registration number: 9991696) and Silkmoth Ltd 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 this website (“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.
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 and 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 out in section 13, below;
“Cookie Law”means the relevant parts of the Privacy and Electronic Communications (EC Directive) Regulations 2003;
“personal data”means any and all data that relates to an identifiable person who can be directly or indirectly identified from that data. In this case, it means personal data that you give to Us via Our Site. This definition shall, where applicable, incorporate the definitions provided in the EU Regulation 2016/679 – the General Data Protection Regulation (“GDPR”); and
“We/Us/Our”Means M&G Crowe Limited (company registration number: 9991696), whose main trading address is 89 Booths Lane, Great Barr, West Midlands, B42 2RG and Silkmoth Ltd, a limited company registered in England under company number 4204791, whose registered and main trading address is Charter House, 1-3 Charter Way, Macclesfield, Cheshire, SK10 2NG.
2. Information About Us
2.1Our Site is owned and operated by Silkmoth Ltd, a limited company registered in England under company number 4204791, whose registered and main trading address is Charter House, 1-3 Charter Way, Macclesfield, Cheshire, SK10 2NG.
2.2Our VAT number is GB 823 9772 00.
2.3Silkmoth have an appointed Data Protection Officer who can be contacted by email at firstname.lastname@example.org, by telephone on 01625 433388, or by post at Charter House, 1-3 Charter Way, Macclesfield, Cheshire, SK10 2NG.
2.4Our Site is operated by Silkmoth Ltd on behalf of M&G Crowe Limited (company registration number: 9991696) operating at 89 Booths Lane, Great Barr, West Midlands, B42 2RG .
3. What Does This Policy Cover?
4. Your Rights
4.1As a data subject, you have the following rights under the GDPR, which this Policy and Our use of personal data have been designed to uphold:
4.1.1The right to be informed about Our collection and use of personal data;
4.1.2The right of access to the personal data We hold about you (see section 12);
4.1.3The right to rectification if any personal data We hold about you is inaccurate or incomplete (please contact Us using the details in section 14);
4.1.4The right to be forgotten – i.e. the right to ask Us to delete any personal data We hold about you (We only hold your personal data for a limited time, as explained in section 6 but if you would like Us to delete it sooner, please contact Us using the details in section 14);
4.1.5The right to restrict (i.e. prevent) the processing of your personal data;
4.1.6The right to data portability (obtaining a copy of your personal data to re-use with another service or organisation);
4.1.7The right to object to Us using your personal data for particular purposes; and
4.1.8Rights with respect to automated decision making and profiling.
4.2If you have any cause for complaint about Our use of your personal data, please contact Us using the details provided in section 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.
4.3For further information about your rights, please contact the Information Commissioner’s Office or your local Citizens Advice Bureau.
5. What Data Do We Collect?
5.2web browser type and version;
5.4a list of URLs starting with a referring site, your activity on Our Site;
6. How Do We Use Your Data?
6.1All 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 GDPR at all times. For more details on security see section 7, below.
6.2Our 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 subscribing to emails), or because it is in Our legitimate interests. Specifically, We may use your data for the following purposes:
6.2.1Analysing your use of Our Site and gathering feedback to enable Us to continually improve Our Site and your user experience;
6.3With your permission and/or where permitted by law, We may also use your data for marketing purposes which may include contacting you by email, telephone, text message, post with information, news and offers on Our products and 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.
6.4Third parties whose content appears on Our Site may use third party Cookies, as detailed below in section 13. Please refer to section 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.
6.5You have the right to withdraw your consent to Us using your personal data at any time, and to request that We delete it.
6.6We 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):
6.6.1Customer and order information is kept for a period of five years from the date of collection so that we may contact you in the event of a manufacturer’s product recall;
6.6.2Web server logs are deleted on a rolling 30-day period;
6.6.3Refer to Google's Compliance Statement for data held in Google Analytics (https://privacy.google.com/businesses/compliance/).
7. How and Where Do We Store Your Data?
7.1We only keep your personal data for as long as We need to in order to use it as described above in section 6, and/or for as long as We have your permission to keep it.
7.2Some or all of your data may be stored outside of the European Economic Area (“the EEA”) (The EEA consists of all EU member states, plus Norway, Iceland, and Liechtenstein). 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 the GDPR.
7.3Data 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.
7.4Steps We take to secure and protect your data include:
7.4.1Encrypted (https) access to Our Site;
7.4.2Strict access control and logging;
7.4.3Policy for data retention and destruction.
8. Do We Share Your Data?
8.1Subject to section 8.2, We will not share any of your data with any third parties for any purposes.
8.2In 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 obligations, a court order, or a governmental authority.
8.3We 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.
8.4We may sometimes use third party data processors that are located outside of the European Economic Area (“the EEA”) (The EEA consists of all EU member states, plus Norway, Iceland, and Liechtenstein). 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 the GDPR including:
8.4.1Microsoft Azure (see https://azure.microsoft.com/en-gb/overview/trusted-cloud/);
8.4.2Google Analytics (see https://privacy.google.com/businesses/compliance);
8.5In 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.
9. What Happens If Our Business Changes Hands?
9.2In 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.
10. How Can You Control Your Data?
10.1In addition to your rights under the GDPR, set out in section 4, when you submit personal data via Our Site, you may be given options to restrict Our use of your data. In particular, We aim to give you strong controls on Our use of your data for direct marketing purposes (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).
10.2You 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.
11. Your Right to Withhold Information
11.1You may access 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.
12. How Can You Access Your Data?
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 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 at email@example.com, or using the contact details below in section 14.
13.2By 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 analytical and site usage purposes. For more details, please refer to section 6, above, and to section 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.
13.3All Cookies used by and on Our Site are used in accordance with current Cookie Law.
13.4Before Cookies are placed on your computer or device, you will be shown a pop-up message 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.
13.5Certain features of Our Site depend on Cookies to function. Cookie Law deems these Cookies to be “strictly necessary”. These Cookies are shown below in section 13.6. Your consent will not be sought to place these Cookies, 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 section 13.10, 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.
13.6The following first party Cookies may be placed on your computer or device:
|Name of Cookie||Purpose||Strictly Necessary|
|ASP.NET_SessionId||This cookie is essential for the site to operate. It is used to track information about the decisions you make during your visit.||Yes|
|cookiepolicy||Records whether or not you have accepted the cookiepolicy so that you do not have to be asked again on your next visit||Yes|
|ai_session, ai_user||Azure Insights cookies for performance monitoring||Yes|
and the following third party Cookies may be placed on your computer or device:
|Name of Cookie||Provider||Purpose|
13.7Our 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 and services 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.
13.8The analytics service(s) used by Our Site use(s) Cookies to gather the required information.
13.9The analytics service(s) used by Our Site use(s) the following Cookies:
|Name of Cookie||First / Third Party||Provider||Purpose|
|_ga, _gat, _gid||First||This website||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.|
13.10In addition to the controls that We provide, 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.
13.11You 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.
13.12It 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