Cooper Davis Associates Limited
Data Controller
Document Version 3.1
Data Audit: 23 January 2024
ICO REGISTRATION NO: ZA 023390
ONLINE PRIVACY NOTICE
COOPER DAVIS ASSOCIATES LIMITED
Registered Member of the GDPR Check & Verify Register
1 Company Contact Details
1.1 Cooper Davis Associates Limited, trading as:
1.1.1 Hold Everything
1.1.2 London Office
1.2 3rd Floor, 207 Regent Street, London W1B 3HH hereinafter ‘the Company’, We, Us and Our.
1.3 Our email address is: richard@hold-everything.com
1.4 Our contact telephone number is: 0207 580 4242
1.5 We are a Data Controller under the provisions of the UK GDPR and the Data Protection Act
2018 and have registered with the UK Information Commissioners office:
ICO Registration Number – Hold Everything: ZA 023390
ICO Registration Number – London Office: ZB 294110
2 Status of key personnel
2.1 We have designated Mr Richard Cooper as Data Protection Manager for the business.
2.2 We are not required to formally designate a Data Protection Officer (DPO) Because we are not
engaged in any of the following activities:
2.2.1 We are not a public authority.
2.2.2 We are not an organisation that carries out the regular and systematic monitoring of
individuals on a large scale.
2.2.3 We are not an organisation that carries out the large scale processing of special
categories of data, such as health records, or information about criminal convictions.
2.3 We do not believe it is necessary to appoint a DPO voluntarily but if this policy changes, or such
a change is made or planned to be made, we will complete a Data Protection Impact
Assessment and update this policy statement accordingly.
3 Introduction and Overview
3.1 The Company is committed to the highest standards of information security and treats
confidentiality and data security extremely seriously.
3.2 This policy document has been prepared in view of the Retained Regulation (EU) 2016/679,
which is now assimilated law in the UK, in accordance with section 5 of the Retained EU Law
(Revocation and Reform) Act 2023.
3.3 Pursuant to the UK General Data Protection Regulation (UK GDPR) and the Data Protection
Act 2018 (DPA) the Company must:
3.3.1 use technical or organisational measures to ensure personal data is kept secure,
including protection against unauthorised or unlawful processing and against
accidental loss, destruction or damage;
3.3.2 implement appropriate technical and organisational measures to demonstrate that it
has considered and integrated data compliance measures into the Company’s data
processing activities; and be able to demonstrate that it has used or implemented such
measures and complied with the data protection principles.
3.3.3 The Company maintains records of its own actions and our interactions with other Data
Controllers and our Data Processors to ensure we can suitably demonstrate adherence
to the data protection principles. Specifically, we ensure data is processed:
(a) Fairly, Lawfully and Transparently.
(b) for limited purposes.
(c) in a manner which is adequate, relevant and not excessive.
(d) in a manner which is accurate and not kept for longer than necessary.
(e) in accordance with the prescribed rights.
(f) for no longer than necessary.
(g) in a manner which is secure and not transferred to countries outside the UK,
without appropriate safeguards.
(h) 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.
3.4 This Online Privacy Notice is a precis of our written policies held at our business premises.
4 Scope of this Privacy Notice
4.1 This Privacy Notice applies to Personal Data we process when you visit or use our website.
Further Privacy Policy statements and documents may apply offline and these are available, if
relevant, on request.
4.2 We are committed to protecting your personal data privacy and, in accordance with relevant
data protection laws, we uphold strict security procedures for the collection, storage, use and
disclosure of your personal information.
4.3 We have described below the personal information we may gather about you, the purposes we
will hold it for and the limited categories of people to whom we may disclose it.
5 What information do we collect and how do we use it?
5.1 During your visit to our site, we will only collect personal information that you choose to provide.
If, for example, you contact us with an enquiry or request us to provide you with further
information.
5.2 If you share other people’s data with us, for example if you refer business to us on behalf of
another, you will need to check you have lawful authority to do so. E.G. The other party has
consented to you providing us with their information. In such a case you are responsible for
ensuring the transmission to us of the information is lawful and we may ask you for documentary
evidence of this.
6 Consequences of failing to provide Personal Data
6.1 In general if you fail or refuse to provide us with your Personal Data we will not be able to deal
with your enquiry or do business with you. The following explains the consequences for each
Lawful Basis of processing.
(a) Consent: It is your decision to provide your information by consent. We protect
your data as described in this document but we cannot proceed with an enquiry
without, for example your contact details to receive a reply.
(b) Contract: We cannot contract with you for goods or services in business unless
you provide us with, at least some of your details. We adhere to the principle
of Data Minimisation and only collect enough data to complete the task at hand.
(c) Legal Obligation: If we have a legal obligation to process your data, failure to
provide the necessary information may have adverse consequences for you.
If this is the case we will tell you.
(d) Public Task: If we are required to process your personal data in the public
interest or the exercise of official authority we will inform you. Failure to provide
data under these circumstances will mean we cannot include you in the
processing activity.
(e) Vital Interests: If data processing is required to protect the vital interests of a
natural person then it is likely we will be in possession of the data before the
need arises. If you have not provided us with your data this situation cannot
apply to you.
(f) Legitimate Interests: Where data processing occurs and has been deemed to
be in our legitimate interests this will be based on a written assessment of
need. There is usually no need for the data subject to provide their data for this
purpose, although you do have the right to object to its use under certain
circumstances but you usually must provide some identification data to make
such an objection.
7 Using your data
7.1 We may use the information you provide us with in the following ways
(a) To administer any account you have with us.
(b) To perform our contractual obligations to you.
(c) To respond to your queries and requests.
(d) To communicate with you.
(e) To ensure that the content of our site is presented in the most effective manner.
(f) To provide you with any information, products and/or services requested from
us.
(g) To provide you with helpful information about our products or services.
(h) To make improvements to the service we provide you.
(i) We also reserve the right to disclose your personal information where we are
required to do so by law, such as to assist in any disputes, claims or
investigations relating to your account or contracts with us and to detect and
prevent fraudulent transactions.
(j) E-mail correspondence with us via our website and email addresses
accessible through or obtained from this site may be recorded and/or
monitored.
8 How do we store and protect your data?
8.1 Data we receive and process is held by us in secure electronic devices and separate back up
devices and servers.
8.2 Personal Data may also be held in encrypted 3rd party ‘Cloud’ Servers.
8.3 Further encrypted back ups of data may be held securely in offsite locations which are also
subject to physical security at their location.
8.4 We will not sell, rent or otherwise disclose the personal information you provide to us through
the site to third parties (other than as listed below) unless we are required to do so by law.
8.5 The Main Establishment for all of our Data Processing is the UK. We do not generally operate
or transfer Personal Data outside of the United Kingdom.
8.6 Due to the operation of the Internet and other computer based applications Personal Data under
our control may transit countries outside of the UK.
8.7 We will only transfer data outside the UK if adequate safeguards are in place in the destination
country.
8.8 Where Personal Data is transferred to a third country or an international organisation we will
ensure that an adequacy decision or similar authority exists between the UK and the relevant
country or area.
8.9 Where no adequacy decision exists and we rely on the provisions of Standard Contractual
Clauses or Binding Corporate Rules evidence of the safeguards provided thereby will be
available upon request.
9 Types and Categories of Personal Data
9.1 Identity data: name, username, title, date of birth. Contact data: billing and delivery address,
email address, phone number.
9.2 Financial data: payment card details (processed by a third-party payment services provider
and not stored by us).
9.3 Transaction data: details of products purchased, amounts, dates etc.
9.4 Technical data: IP address, login data, browser type and version, time zone setting and
location, browser plug-in types and versions, operating system and platform based on your
Cookie preference choices.
9.5 Profile data: username and password, purchases or orders made by users.
9.6 Usage data: information about how users use our website, products and services.
9.7 Marketing and communications data: record of Website users preferences in receiving
marketing from us about the products we sell.
10 Personal Data under our control
10.1 The following is a chart of the personal data under our control.
12 Lawful bases for processing data
12.1 We hold and process your data by lawfully allowed means, these include:
(a) Your Consent: Consent is usually given by yourself when you contact us via
this Website or personally when we discuss products or advice with you.
(b) Contractual obligations: This occurs when you purchase products or
services from us.
(c) Legal Obligation: When the processing is necessary for us to comply with the
Law.
(d) Vital Interests: When the processing is necessary to protect someone’s life.
(e) Public Task: When the processing is necessary for us to perform a task in the
public interest or for an official function and the task or function has a clear
basis in Law.
(f) Legitimate Interests: When the processing is necessary for our legitimate
interests or the legitimate interests of a third party unless there is a good reason
to protect the individual’s personal data which overrides those legitimate
interests.
(i) N.B. Legitimate Interests can only be used following the application of
the prescribed three part Legitimate Interests Assessment Test and
then only when a positive outcome is indicated by the conclusions of
the test. All Legitimate Interests Assessment Tests will be
documented, recorded and retained.
13 Types and Categories of Personal Data
(a) Identity data: name, username, title, date of birth. Contact data: billing and
delivery address, email address, phone number.
(b) Financial data: payment card details (processed by a third-party payment
services provider and not stored by us).
(c) Transaction data: details of products purchased, amounts, dates etc.
(d) Technical data: IP address, login data, browser type and version, time zone
setting and location, browser plug-in types and versions, operating system and
platform based on your Cookie preference choices.
(e) Profile data: username and password, purchases or orders made by users.
(f) Usage data: information about how users use our website, products and
services.
(g) Marketing and communications data: record of Website users preferences
in receiving marketing from us about the products we sell.
14 Your Personal Data Rights
14.1 Under the UK General Data Protection Regulation (UK GDPR) and The Data Protection Act
2018 (DPA) you have a number of rights with regard to your personal data. To exercise any of
your rights contact our Data Manager using the details given above.
14.2 We protect the individual’s rights provided by the UK GDPR and Data Protection Act 2018 as
being the following:
(a) The right to be informed (Confirmation processing is taking place or not.)
(b) The right of access
(c) The right to rectification
(d) The right to erasure
(e) The right to restrict processing
(f) The right to data portability
(g) The right to object
(h) The right not to be subject to automated decision making, including profiling.
14.3 You have the right to request from us access to and rectification or erasure of your personal
data; the right to restrict processing; the right to object to processing as well as in certain
circumstances the right to data portability as below.
14.4 In the event that you provide your data directly to us for the purpose of a contract, or in
circumstances where you have provided your data by consent, you have the right to be provided
with your data in a structured, machine-readable format. This is known as Data Portability.
14.5 Following a request relating to Data Portability we will transmit the relevant personal data to the
data subject or their nominated data controller where it is possible and technically feasible for
us to do so.
14.6 Where you have provided your data voluntarily by Consent you have the right to withdraw your
Consent at any time. However, withdrawal of Consent does not affect the lawfulness of any
processing of your data based on your Consent prior to its withdrawal.
14.7 Where we need to process data for the purposes of entering into a Contract with you, if you fail
to provide such data it may mean that we cannot establish legal relations between us and the
contract may not be able to go ahead. We will inform you if this happens.
14.8 Automated decision making and profiling means making decisions without human intervention,
usually with the use of a computer program or software. We may use automated decision
making about you if it is necessary for entering into or performing a Contract with you or where
you Consent to the actions.
14.9 Please note we will retain and use your personal information as necessary to comply with our
legal obligations, resolve disputes, and enforce our agreements. If we need to use your data
for a reason it was not collected and you are not aware of this, we will inform you and in
appropriate cases obtain your further consent to such use.
14.10 If we process data about you but we have not obtained the data personally from you, we must
provide you with the information described in this Privacy Notice and some additional
information.
14.11 The additional information will be provided to you at least by the time we contact you and in
any event within the space of one month after we obtain it.
14.12 If the processing is based on Legitimate Interests, you are entitled to know what and whose
Legitimate Interests they are.
14.13 You are entitled to know the purpose of the processing, whether we or someone else is
processing it and the categories of Personal Data involved.
14.14 You are entitled to know the source of the information and whether the source is publicly
accessible.
14.15 There are some exceptions to this additional information rule. If we obtain your Personal Data
from a source other than yourself, the additional information rules will apply unless:-
(a) You already have the information regarding our processing; or
(b) it would take a disproportionate effort or be impossible to provide you with it;
or
(c) you are already legally protected under separate provisions; or
(d) we have a legal duty not to disclose it.
14.16 We use the lawful basis of Legitimate Interests for processing data in the following
circumstances:
(a) When processing data using Video Conferencing software.
(b) When processing data from our CCTV equipment.
(c) When processing data under the PECR Regulations for the ‘Soft opt in’.
(d) When processing data using Dashcam equipment.
14.17 Our Specific Legitimate Interests are:
14.17.1 Video Conferencing
(a) To facilitate efficient business video and telecommunications.
(b) To protect the safety of our employees and participants on the call from
unnecessary real world travelling.
(c) To support our primary business objectives.
14.18 You have the right to complain to the Data Regulator at the Information Commissioners Office
on 0303 123 1113 or through their website www.ico.org.uk.
15 Children’s data
15.1 Our site is not directed at children and should not be accessed by them.
15.2 We will not knowingly collect information from persons under 13 years of age without their
parent’s or guardian’s consent.
15.3 If a Parent or Guardian of a person under 13 years of age discovers their child has engaged
with our Website without their consent, please inform us immediately using the contact email
provided above.
15.4 We have considered the elements of the AADC (Children’s code) in relation to our Online
activity and concluded that we are not a relevant Information Society Service which is likely to
be accessed by children.
15.5 There is nothing on our Website which could be damaging to children who view the pages or
the pictures.
15.6 The products on our Website are only available and relevant to adults over the age of 18 years.
15.7 We protect the rights of the child in accordance with the UNCRC and the AADC by trading only
with adults AND using self-certifying Age Gate Technology on pages where payments can be
made.
16 Third Party Websites
16.1 From time to time our site may contain links to and from the websites of our suppliers or other
third party sites.
16.2 If you visit any of these sites you should confirm they have their own privacy policies and you
should check these before submitting any personal data on their site. We cannot accept any
responsibility or liability for the policies on any other Websites.
17 Data Access
17.1 You have rights of access to the data we hold about you. Should you wish to exercise these
rights please contact our Data Manager whose details are given above.
17.2 There is usually no charge for the Data Access service. As soon as we are satisfied as to your
identity, we will send you, without delay and in any case within one Month, the Personal Data
we hold relating to you, which we are legally obliged to provide.
17.3 We may need to request specific information from you to help us confirm your identity and
ensure your right to access the information (or to exercise any of your other rights). This is
another appropriate security measure to ensure that your Personal Data is not disclosed to
anyone who has no right to receive it.
17.4 In the event we need more time to gather the requested information we will let you know without
delay and in any event within one month.
17.5 A fee may be payable for Data Access services if the request(s) are manifestly unfounded or
excessive or repetitive in nature. Alternatively, we may choose to ignore this type of request. In
these cases we will inform you of our decision and if applicable any fee that may be required.
17.6 Please contact us if you believe that any personal data or information which we hold about you
is incorrect or incomplete. Any information or data which is found to be incorrect will be
corrected as soon as practicable.
17.7 Please contact us if you wish to have your personal data removed entirely from our systems.
As soon as we are satisfied as to your identity and the data is not required to be kept for any
other lawful reason or purpose it will be removed from our systems forthwith.
17.8 If you so wish, your Data will be provided to you electronically in a commonly used format such
as email.
17.9 If you are unhappy with any of the responses given to you by us you may complain about us to
the regulator at the Information Commissioners Office on 0303 123 1113 or through their
website www.ico.org.uk.
18 Business Transfer or Sale
18.1 In the event our business, or part of it, is taken over, bought or merged with another business
we may need to disclose any personal data we are holding about you to the other Company so
they can continue to provide services to you in accordance with this Privacy Policy.
18.2 It may be necessary to transfer your data to a Company that is negotiating with us for the
purchase of our business but only where it is necessary to evaluate the business purchase
transaction.
18.3 In the case of a pre-sale transfer of personal data, the data would be kept safe during the
negotiations and destroyed by the third party if the sale or merger did not go ahead.
19 Changes to this policy.
19.1 There may be developments in how we use your data according to changes in the Law.
19.2 We reserve the right to make changes to this Data Protection and Privacy Policy at any time
without notice and it is your responsibility to revisit this page from time to time to re-read this
policy including any and each time you visit our website.
19.3 Any revised terms shall take effect as at the date of posting.
19.4 If you don’t find your concern addressed here, feel free to contact us by e-mailing our Data
Manager at the contact details given above.
