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PRIVACY POLICY

Background

We understand that your privacy is important and that you care about how your
personal data is used and shared. We respect the privacy of everyone who visits
our website, uses our online services and purchases our products.

We are committed to respecting, securing, and protecting your privacy and
private data. We are also committed to being transparent about what we collect
from you and how we use it.

This privacy notice provides you with information about what personal data we
collect, how we use your data, how we ensure your privacy is maintained, and
your legal rights relating to your personal data.

1. Who We Are

We are Crown Paints Limited (“Crown Paints”). Our registered office address is
Crown House, Hollins Road, Darwen, Lancashire, BB3 0BG

Our brands include: Crown Paints, Crown Trade, Sadolin, Sandtex, Macpherson and
Crown Contract

You can contact us by:

 * Telephone – 0330 0240297

 * Email – privacy@crownpaints.co.uk

 * Post – Customer Relations Team, Crown Paints Limited, Crown House, Hollins
   Road, Darwen, Lancashire, BB3 0BG

2. Your Rights

Under the General Data Protection Regulation (GDPR) and The Data Protection Act
2018 (DPA) you have a number of rights with regard to your personal data; which
this policy and our use of your data has been designed to uphold:

 * Right of access – you have the right to request a copy of the information
   that we hold about you. You can do this by contacting us using the above
   details.

 * Right of rectification – you have a right to correct data that we hold about
   you that is inaccurate or incomplete.

 * Right to be forgotten – in certain circumstances you can ask for the data we
   hold about you to be erased from our records.

 * Right to be informed – you have the right to be informed about our collection
   and use of your personal data.

 * Right to restriction of processing – where certain conditions apply, you have
   a right to restrict our processing.

 * Right of portability – you have the right to have the data we hold about you
   transferred to another organisation.

 * Right to object – you have the right to object to certain types of processing
   (such as direct marketing).

If you have cause for complaint about our use of your data, or you would like to
exercise any of your rights, then please contact us using the details provided
in Section 1 and we will do our best to solve the problem for you.

If we are unable to help, or you aren’t satisfied with our response, you also
have the right to lodge a complaint with the UK’s supervisory authority – The
Information Commissioner’s Office (ICO). The ICO can be contacted:

 * By post – The Information Commissioner’s Office, Wycliffe House, Water Lane,
   Wilmslow, SK9 5AF

 * By telephone – 0303 123 1113

 * Via its website – www.ico.org.uk

3. What Data Do We Collect from You?

If you use our websites, we will collect some data automatically from you when
you use our website. That information is:

 * Your IP address, login information, browser type and version, time zone
   setting, browser plug-in types, geolocation information about where you might
   be, operating system and version.

 * Your URL clickstreams (the path you take through our site), products/services
   viewed, page response times, download errors, how long you stay on our pages,
   what you do on those pages, how often, and other actions.

If you are a customer we will collect additional information which you provide
to us:

 * Contact Details – Your name, company name, address, phone numbers, email
   address.

 * Purchase & Quote Details – Information about products and services you have
   purchased or enquired about.

 * Financial Information – Your bank or payment details and relevant tax
   information when you purchase from us.

 * If you are a subscriber to our marketing content, or use our contact forms on
   our websites:

 * Contact Details – Your name, email address and telephone number.

4. How We Use Your Data

Data protection law means that we can only use your data for certain reasons and
where we have a legal basis to do so. Here are the reasons for which we process
your data:

 * Orders & Purchases: We’ll use the details you provide to process any orders
   that you make with us using our websites, apps, or in-store. If we don’t
   collect this information we won’t be able to process your order and comply
   with our legal obligations. Our legal basis for this is contractual
   obligation.

 * Keeping Our Website Running: providing and managing your access to our
   website and services, personalising and tailoring your experience on our
   website and services. Our legal basis for this is legitimate interest (see
   below).

 * Improving Our Website: Testing features, interacting with feedback platforms
   and questionnaires, managing landing pages, heat mapping our site, traffic
   optimization and data analysis and research, including profiling and the use
   of machine learning and other techniques over your data and in some cases
   using third parties to do this. Our legal basis for this is legitimate
   interest (see below).

 * Marketing Purposes: We may send you emails and messages about new features,
   products and services, and content. You will always be able to unsubscribe
   from these. Our legal basis for doing that is consent (if provided),
   otherwise our legitimate interests (see below).

 * Answering Your Queries & Customer Support: We will use your email and contact
   details to answer your contact requests and queries. Our legal basis for
   doing so is contractual obligation.

5. Legal Basis

We have identified a legal basis for each of our purposes in paragraph 4. This
is what they mean:

Legitimate Interest:

Processing your data is necessary for our legitimate interests or the legitimate
interests of a third party, provided those interests are not outweighed by your
rights and interests. These legitimate interests are:

 * gaining insights from your behaviour on our website

 * delivering, developing and improving our service

 * enabling us to enhance, customise or modify our services and comms

 * enhancing data and physical security

 * promoting our products, services and business.

 * responding to customer enquiries, contact requests and promoting our
   services.

 * In each case, these legitimate interests are only valid if they are not
   outweighed by your rights and interests.

You can always object to our processing of your data based on legitimate
interest. If you do so and we have no other legal basis for processing your data
we will stop. If we do have another legal basis we will continue to do so,
subject to your legal rights.

Consent:

You have given clear consent for us to process your personal data for a specific
purpose.

You can always withdraw your consent. You can do this by clicking on unsubscribe
in any marketing email we send, or by getting in touch via the contact details
in paragraph 1.

If you withdraw your consent and we have no other legal basis for processing
your data we will stop. If we do have another legal basis we will continue to do
so, subject to your legal rights.

Contractual Obligation:

Processing your data is necessary for a contract you have with us, or because we
have asked you to take specific steps before entering into that contract.

6. Storing and Sharing Your Data

Data security is very important to us and we take appropriate security measures
(both technical and organisational) to safeguard and secure your data. We
regularly audit and test the effectiveness of our security measures.

As a multinational business your data may be processed outside the country where
you live. We endeavour to keep all of your personal information in the UK or
European Economic Area (EEA). The EEA includes all EU Member States plus Norway,
Iceland and Liechtenstein.

In limited and necessary circumstances your information may be transferred
outside of the EEA. Where this does happen, we will put special protections in
place. We will only move data to countries or organisations:

Where the EU Commission has deemed their data protection measures to be
adequate;

Or under a contract which enforces the EU Commission approved “standard data
protection clauses” which can be viewed at
https://ec.europa.eu/justice/data-protection/international-transfers/transfer/index_en.htm.

We will never sell your personal data to a third party.

We will never transfer or disclose your personal data to any third party except:

 * Crown Paints is owned by Hempel Group. We may transfer your data to other
   parts of Hempel Group for internal administrative purposes – for example
   fulfilment of your orders, provision of internal support services, or where
   marketing is provided by other parts of Hempel Group. We will ensure your
   data is processed securely and in accordance with this privacy notice.

 * We may sometimes contract with trusted service providers to provide goods and
   services on our behalf. These may include, for example, payment processing,
   delivery of goods, search engine facilities, advertising, marketing and IT
   systems. This will sometimes necessitate the transfer of your personal data
   to those trusted service providers.

 * Where we transfer your data to our trusted service providers we will have
   confirmed that they will apply data protection and security measures to the
   same standard we would. We will always impose contractual terms on all of our
   providers to ensure your data remains secure.

In certain limited circumstances we may be legally required to share your
personal data – for example where we are involved in legal proceedings, or where
we are complying with a court order, regulatory requirement, or government
department with appropriate legal authority to compel us to do so.

7. How Long We Keep Your Data

We do not keep your personal data for any longer than it is necessary in light
of the reason(s) for which it was first collected and for our obligation under
other laws.

We may need to keep your information to establish, bring or defend legal claims.
We’ll therefore always keep your personal data for 7 years after the date it is
no longer necessary for us to hold it.

At the end of that period your data will be either deleted completely or
anonymised.

Exceptions to the above will be:

 * Where you have exercised your right to have the information where it applies.

 * Where the law requires us to keep your data for longer or delete it sooner.

 * Where a legal claim is in progress – we’ll keep your data until that claim is
   concluded.

8. Cookies

Like many other websites, ours uses cookies. Cookies are small pieces of
information sent by an organisation to your computer or device and stored on
your computer or device to allow a website to recognise you when you visit. They
help us collect statistical data about your browsing actions and patterns but
should not contain personal data (other than the cookie itself, which is defined
as personal data under GDPR).

All cookies used by and on our website are used in accordance with the current
cookie law.

Before cookies are placed on your computer or device you will be shown a pop-up
requesting your consent to set such cookies as detailed below. By giving us your
consent, you are allowing us to provide the best possible experience of our
website. You may refuse consent to cookies; however, certain parts of our
website may then not function correctly. You can alter your browser settings to
refuse all cookies.

There are four types of cookies:

 * Strictly Necessary Cookies – These are essential to make a website work and
   provide features you’ve asked for. Generally, these are used to provide
   shopping baskets and similar. Without these cookies the website may not work
   as intended.

 * Performance Cookies – These collect anonymous information about users for the
   purposes of tracking the performance of a website. Common uses include
   well-known analytics tools such as Google Analytics.

 * Targeting/Advertising Cookies – These are similar to performance cookies.
   However, they are used to track users’ behaviour and that information is then
   used on a “per user” basis to advertise products/services on the basis of the
   behavioural information collected.

 * Functionality Cookies – These are used to remember automatically the choices
   that users have made in order to improve their experience on the website; for
   example, selecting desired layout or language.

The cookies we use on our website are:

Cookie Type: Google Analytics

 * Name: __utma, __utmb, __utmc, __utmt, __utmz, _gat, _gid

 * Purpose: These cookies are used to collect information about how visitors use
   our website and WordPress blog. We use the information to compile reports and
   to help us improve the website. The cookies collect information in an
   anonymous form, including the number of visitors to the website and blog,
   where visitors have come to the website from and the pages they visited

 * https://support.google.com/analytics/answer/6004245

 * Type: 3rd Party

 * Duration: _utma: 2 years, _utmb: Session, _utmc: Session + 30 min, _utmz: 6
   months

Cookie Type: Website Session ID

 * Name: PHPSESSID

 * Purpose: To maintain information about each visit to the website and enable
   core site functionality. This cookie does not contain any personal
   information and only lasts for the duration of your visit.

 * Type: 1st Party

 * Duration: Expires at end of session

 * Cookie Type: Cookie Policy Acknowledgement

 * Name: viewed_cookie_policy

 * Purpose: This allows us to hide the cookie policy pop up once you have
   acknowledge it.

 * Type: 1st Party

 * Duration: 1 Year

Cookie Type: Facebook

 * Name: fr

 * Purpose: This Cookie is placed by Facebook. It enables us to measure,
   optimize and build audiences for advertising campaigns served on Facebook. In
   particular it enables us to see how our users move between devices when
   accessing our website and Facebook, to ensure that our Facebook advertising
   is seen by our users most likely to be interested in such advertising by
   analysing which content a user has viewed and interacted with on our website.

 * https://apps.ghostery.com/en/apps/facebook_custom_audience

 * Type: 3rd Party

 * Duration: 1 Year

 * Cookie Type: Advertising

 * Name: TDCPM, TDID

 * Purpose: Registers a unique ID that identifies a returning user’s device. The
   ID is used for targeted ads from adsrvr.org

 * Type: 3rd Party

 * Duration: 1 Year

Cookie Type: Marketo_Advertising

 * Name: _mkto_trk

 * Purpose: This cookie is associated with an email marketing service provided
   by Marketo. This tracking cookie allows a website to link visitor behaviour
   to the recipient of an email marketing campaign, to measure campaign
   effectiveness.

 * Type: 3rd Party

 * Duration: 2 Years

Our websites may use 3rd party vendor re-marketing tracking cookies, including
the Google AdWords & Facebook Pixel tracking cookie. This means we will continue
to show ads to you across the internet, specifically on the Google Content
Network (GCN) and Facebook. As always we respect your privacy and are not
collecting any identifiable information through the use of Google’s or any other
3rd party remarketing system.

The third party vendors, including Google & Facebook, whose services we use –
will place cookies on web browsers in order to serve ads based on past visits to
our website. Third party vendors, including Google, use cookies to serve ads
based on a user’s prior visits to your website. This allows us to make special
offers and continue to market our services to those who have shown interest in
our service.

9. Changes to Our Privacy Notice

We may change this privacy notice from time to time (for example, if the law
changes). Any changes will be immediately posted on our site. We recommend you
check the privacy notice regularly to remain up to date.

This privacy notice was last updated in August 2018




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