Privacy Notice
Privacy Notice
This Privacy Notice applies to the collection, use, and management of your personal data when you use our Website or order our Products. It sets out the legal relationship between you and us.
Please read this Privacy Notice carefully. By using our Website or ordering our Products, you agree to this Privacy Notice, which explains how we handle your personal data. If you do not agree with this Privacy Notice, please refrain from using our Website or ordering our Products.
1. Who We Are
1.1 We are Cloudpillo B.V. trading as Cloudpillo (we, us, our). We are a company registered in the Netherlands under company number 80589855 at the Dutch Chamber of Commerce, and our registered office is at: Reitscheweg 1, 5232 BX, 's-Hertogenbosch, the Netherlands.
1.2 We are committed to protecting the privacy and security of your personal data.
1.3 This Privacy Notice describes how we collect, use and look after your personal data when you order our Products or visit our website www.cloudpillo.co.uk (our Website) (regardless of where you visit it from). It also tells you about your rights and how the law protects you.
2. Important Information
2.1 This Privacy Notice supplements the other notices and terms published on our Website (including our website terms of use (Terms)) and is not intended to override them.
2.2 We are the controller of, and are responsible for, your personal data.
2.3 To assist you further in understanding this Privacy Notice, we have set out in the Schedule a glossary of terms used in this Privacy Notice, examples of types of personal data we collect, how we use it, the lawful basis for processing such data and further details of your rights.
2.4 Our Website may include links to third-party websites, plug-ins and applications. By clicking on these links or enabling connections you may be allowing third parties to collect or share your personal data. We have no control over these third-party websites, plug-ins or applications and are not responsible for their privacy notices, therefore you should read their privacy notices to understand what personal data they collect about you and how they use it.
3. Contact Us
3.1 If you have any questions about this Privacy Notice, including any requests to exercise your legal rights, please contact us in writing, either by:
-Email: support@cloudpillo.co.uk
-Post: Reitscheweg 1, 5232 BX, 's-Hertogenbosch, the Netherlands.
-3.2 You have the right to make a complaint at any time to the ICO at www.ico.org.uk. We would, however, appreciate the chance to deal with your concerns before you approach the ICO, so please contact us in the first instance.
-3.3 It is important that the data we hold about you is accurate and current, therefore please keep us informed of any changes to your personal data.
4. The Data We Collect About You
4.1 We may collect, use, store and transfer the types of personal data about you listed in Part 1 of the Schedule.
4.2 We also collect, use and share aggregated data. However, if we combine aggregated data with your personal data so that it can directly or indirectly identify you, we treat this as your personal data.
4.3 Our Website is not intended for children and we do not knowingly collect data relating to children.
4.4 We do not collect any special categories of personal data or any information about criminal convictions and offences.
4.5 If we are required by law, or under the terms of a contract we have with you, to collect your personal data and you fail to provide it:
-We may not be able to enter into or perform the contract with you; and/or
-We may have to cancel the supply of Products to you and/or the contract (as applicable).
-4.6 We will notify you of this at the relevant time.
5. How Personal Data Is Collected
5.1 We collect personal data in the following ways:
-Direct interactions: You may provide personal data when you complete our online enquiry form, register for an account, order Products from our Website, or correspond with us (by post, phone, or email). We may also contact you to ask you to leave a review of our Products.
-Automated technology: We automatically collect personal data (technical and usage) when you browse or interact with our Website, using cookies, server logs, and similar technologies. We may also receive technical data about you if you visit other websites that use our cookies. Please see our Cookies Policy [LINK] for further details.
-Publicly available sources: We may collect personal data from publicly available sources such as the Electoral Register and credit reference agencies based inside the UK.
-Third parties: We may receive personal data from:
- Analytics providers based outside the UK, such as Google
- Advertising networks
- Search information providers
- Our suppliers, such as website support and maintenance providers
6. How We Use Your Personal Data
6.1 We will only use your personal data when the law allows us to. Most commonly, we will use your personal data:
-To perform the contract we are to enter into or have entered into with you for the sale and supply of Products;
-To comply with a legal obligation; or
-Where it is necessary to carry out our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
-6.2 Part 2 of the Schedule sets out the lawful basis we will rely on to process your personal data.
-6.3 Please note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your information.
7. Change of Purpose
7.1 We will only use your personal data for the purpose that we originally collected it for, unless:
-We reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose; or
-We have a lawful basis to change the purpose.
-7.2 If we need to use your personal data for an unrelated purpose, we will notify you and explain the legal basis that allows us to use your personal data in this manner.
-7.3 We may process your personal data (without your knowledge or consent) where this is required or permitted by law.
8. Marketing
8.1 You will only receive marketing communications from us if you have:
-Purchased Products from us; or
-Provided your consent to receive marketing communications and have not opted out of receiving marketing communications.
-8.2 We may ask you as part of our follow-up process to leave a review of our Products.
-8.3 We will not share your personal data with third parties for their marketing purposes.
-8.4 How to Opt Out:
-You can opt out of electronic marketing by clicking the unsubscribe button within the particular marketing communication.
-You can also withdraw your consent to receive marketing communications and ask to be removed from our mailing list at any time by contacting us.
-8.5 Even if you opt out of receiving marketing communications, we may still use your personal data for other purposes provided we have a lawful basis to do so.
9. Disclosure of Your Personal Data
9.1 We will only share your personal data with the Third Parties set out in Part 4 of the Schedule.
9.2 We require all Third Parties to respect the security of your personal data and to treat it in accordance with the law. Such Third Parties can only process your personal data for specified purposes and in accordance with our instructions.
9.3 We are based outside of the UK, and some Third Parties may be based outside of the UK, therefore your personal data may be transferred outside of the UK.
9.4 Whenever we transfer your personal data out of the UK, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:
-We will only transfer personal data to countries that have been deemed to provide an adequate level of protection for personal data; or
-We use specific contracts which give personal data the same protection it has in the UK with our services providers.
10. Data Security
10.1 We operate appropriate security measures to prevent personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed.
10.2 Access to personal data is restricted to individuals who:
-Have a business need to know it;
-Are under confidentiality obligations; and
-Can only process it on our instructions.
-10.3 We have procedures in place to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.
11. Data Retention
11.1 We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.
11.2 We may update our data retention practices from time to time, and you can request details by contacting us.
11.3 We are legally required to keep basic information about our customers (including contact, identity, financial, and transaction data) for six years after the end of the tax year in which they cease being customers, for tax purposes.
11.4 We may anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes. We can use anonymised information indefinitely without further notice to you.
12. Your Legal Rights
12.1 Your legal rights in relation to your personal data are set out in full in Part 3 of the Schedule.
12.2 If you wish to exercise any of your rights, please contact us.
12.3 You will not have to pay a fee to exercise your rights unless your request is:
-Clearly unfounded, repetitive, or excessive, in which case we may charge a reasonable fee or refuse to comply with your request.
-12.4 We may ask you to provide further information to help us confirm your identity. This is a security measure to ensure that personal data is not disclosed to any person who does not have the right to receive it.
-12.5 We aim to respond to all legitimate requests within one month. If your request is particularly complex or you have made a number of requests, it may take us longer to respond. In this case, we will notify you and keep you updated.
13. Updates to This Privacy Notice
13.1 We may change this Privacy Notice from time to time by updating this page.
13.2 Please check it regularly to ensure that you are aware of any changes.
13.3 This Privacy Notice was last updated in December 2024.
Schedule
Types of personal data
| Data Type | Details |
|---|---|
| Contact Data | Billing address, delivery address, email address, and telephone number. |
| Financial Data | Bank account and payment card details. |
| Identity Data | First name, maiden name, last name, username or similar identifier, marital status, title, date of birth, and gender. |
| Marketing and Communication Data | Your preferences in receiving marketing from us and our third parties, and your communication preferences. |
| Profile Data | Your username and password, purchases or orders made by you, your interests, preferences, feedback, and survey responses. |
| Technical Data | Internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, and other technology on the devices you use to access our Website. |
| Transaction Data | Details about payments to and from you and other details of products you have purchased from us. |
| Usage Data | Information about how you use our Website and Products. |
Lawful basis for processing and processing activities
The lawful basis upon which we may rely on to process your personal data are:
| Basis for Processing | Details |
|---|---|
| Consent | You have given your express consent for us to process your personal data for a specific purpose. |
| Contract | The processing is necessary for us to perform our contractual obligations with you under our contract, or because you have asked us to take specific steps before entering into a contract with you. |
| Legal Obligation | The processing is necessary for us to comply with a legal or regulatory obligation. |
| Legitimate Interests | The processing is necessary for our or a third party’s legitimate interest, e.g., to provide the best service to you via our Website. Before we process your personal data on this basis, we ensure we consider and balance any potential impact on you, and we will not use your personal data on this basis where such impact outweighs our interest. |
Set out below are specific details of the processing activities we undertake with your personal data and the lawful basis for doing this.
| Purpose/Activity | Type of Data | Lawful Basis for Processing |
|---|---|---|
| To register you as a new customer. | Contact and identity | To perform our contract with you. |
| To process and deliver your order, manage payments, fees and charges, and recover debts. | Contact, financial, identity, marketing and communications, transaction | (i) To perform our contract with you. (ii) As necessary for our legitimate interest in recovering debts due to us. |
| To manage our relationship with you and notify you of changes to our Terms or Privacy Notice. | Contact, identity, profile, marketing and communications | (i) To perform our contract with you. (ii) As necessary to comply with a legal obligation. (iii) As necessary for our legitimate interests in keeping our records updated and analyzing how customers use our products. |
| To administer and protect our business and this Website (including troubleshooting, data analysis, testing, system maintenance, support, reporting, and hosting of data). | Contact, identity, technical | (i) As necessary for our legitimate interests in running our business, providing administration and IT services, ensuring network security, preventing fraud, and in the context of a business reorganization. (ii) As necessary to comply with legal obligations. |
| To deliver relevant website content/advertisements to you and measure or understand the effectiveness of our advertising. | Contact, identity, profile, marketing, communications, technical, and usage | As necessary for our legitimate interests in studying how customers use our products, developing them, growing our business, and informing our marketing strategy. |
| To use data analytics to improve our Website, products, marketing, customer relationships, and experiences. | Technical and usage | As necessary for our legitimate interests to define types of customers for our products, keep our Website updated and relevant, develop our business, and inform our marketing strategy. |
Your legal rights
You have the following legal rights in relation to your personal data:
| Right | Details |
|---|---|
| Access your data | You can ask for access to and a copy of your personal data and check we are lawfully processing it. |
| Correction | You can ask us to correct any incomplete or inaccurate personal data we hold about you. |
| Erasure | You can ask us to delete or remove your personal data where:
We may not always be able to comply with your request for specific legal reasons, which will be notified to you at the time of your request. |
| Object | You can object to the processing of your personal data where:
In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms and, in such circumstances, we can continue to process your personal data for such purposes. |
| Restrict processing | You can ask us to suspend or restrict the processing of your personal data, if:
|
| Request a transfer | You can request a transfer of your personal data which is held in an automated manner and in relation to which you provided your consent for us to process such personal data or which we need to process to perform our contract with you, to you or a third party. We will provide your personal data in a structured, commonly used, machine-readable format. |
| Withdraw your consent | You can withdraw your consent at any time (where we are relying on consent to process your personal data). This does not affect the lawfulness of any processing carried out before you withdraw your consent. |
Third Parties
| Category | Details |
|---|---|
| Service Providers |
|
| Payment Gateway Providers |
|
| Professional Advisors | Acting as processors or controllers, including lawyers, bankers, auditors, and insurers who provide consultancy, banking, legal, insurance, and accounting services. |
| HM Revenue & Customs, Regulators, and Other Authorities | Acting as processors or controllers who require reporting of processing activities in certain circumstances. |
| Other Third Parties | Such third parties whom we may choose to sell, transfer, or merge parts of our business or our assets with. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, the new owners may use your personal data in the same way as set out in this Privacy Notice. |
Glossary
| Term | Definition |
|---|---|
| Aggregated Data | Information such as statistical or demographic data which may be derived from personal data but which cannot by itself identify a data subject. |
| Controller | A body that determines the purposes and means of processing personal data. |
| Data Subject | An individual living person identified by personal data (which will generally be you). |
| ICO | Information Commissioner’s Office, the UK supervisory authority for data protection issues. |
| Personal Data | Information identifying a data subject from that data alone or with other data we may hold, but it does not include anonymized or aggregated data. |
| Processor | A body that is responsible for processing personal data on behalf of a controller. |
| Special Categories of Personal Data | Information about race, ethnicity, political opinions, religious or philosophical beliefs, trade union membership, health, genetic, biometric data, sex life, and sexual orientation. |