We respect your privacy and we are committed to protecting your personal data. This privacy statement will inform you how we use and look after your personal data when you are a customer or you:
This statement does not apply to you if you work for us or are applying to work for us, in which case you will be provided with separate privacy statements setting out that relationship with you. For example, if you use our job application forms via the links on our site.
This statement also tells you about your privacy rights and how the law protects you.
When we say “we”, “us”, or “Ceuta Holdings” that means the company Ceuta Holdings Limited. This privacy statement is issued on behalf of Ceuta Holdings. If your communications with us relate to other Ceuta Group companies then we will pass your personal data to them so they can handle your enquiry. Their privacy statement will also apply to how they process your data.
Where we collect information about you, if that information is about you, or can be used by us or organisations with which we work, to find out about you, it is known as “personal data”.
The law says that we have to tell you what types of personal data we have about you, what we use it for, why we are allowed to use it in that way, and what your legal rights are. That is what this document – called a “privacy statement” – is for. We also have to tell you some other things – those are all covered in this statement.
The rules about personal data are detailed and can be difficult to understand. If you need help understanding anything in this policy, please contact us at dataprotection@ceutagroup.com.
The simple version is this:
If you want to ask us to do any of these things, or you have any questions or worries, you can contact us at dataprotection@ceutagroup.com. You can also contact the organisation in charge of making sure we do the right things with your personal data – the Information Commissioner’s Office – by clicking here.
This policy is addressed to individuals who visit the websites or pages on social media platforms operated by Ceuta Holdings Limited (Ceuta Holdings, we, our or us) or our customers, and other individuals that may deal with us, including individuals at our suppliers. In this policy we collectively refer to these categories of individuals as “you”.
If you are applying for a job or you are one of our staff members or workers a different policy will apply, which will be provided to you.
Our privacy statement is provided in a layered format so you can click through the links below to take you to the specific sections set out below. Alternatively, you can contact us to ask for a copy.
Purpose of this privacy statement
This privacy statement aims to give you information on how Ceuta Holdings collects and processes your personal data when you are a customer or you:
It does not apply to you if you work for us or are applying to work for us, in which case you will be provided with separate privacy statements setting out that relationship with you. For example, if you use our job application forms via the links on our site.
This website is not intended for children and we do not knowingly collect data relating to children.
It is important that you read this privacy statement together with any other data protection or privacy statement that we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. This privacy statement supplements other notices and privacy policies and is not intended to override them.
Ceuta Holdings Limited (registered company number 08528478) with its registered head offices at Hill House, 41 Richmond Hill, Bournemouth, Dorset, BH2 6HS is the controller and responsible for your personal data (referred to as “Ceuta Holdings”, “we”, “us” or “our” in this privacy statement).
The Ceuta Group of Companies is made up of different companies, details of which can be found here. This privacy statement is issued on behalf of Ceuta Holdings. If your communications with us relate to other Ceuta Group companies then we will pass your personal data to them so they can handle your enquiry. Their privacy statement will apply to how they process your personal data.
If you have any questions about this privacy statement, including any requests to exercise your legal rights, please contact the Data Privacy Manager using our contact details below.
If you have any questions about this privacy statement or our privacy practices, please contact our Data Privacy Manager in the following ways:
Full name of legal entity: Ceuta Holdings Limited
Email address: dataprotection@ceutagroup.com
Postal address: 41 Richmond Hill, BH2 6HS, Bournemouth, UK
Telephone number: 01202 449781
You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so we would encourage you to contact us in the first instance to discuss these.
Any changes that we make to this policy in the future will be posted on this page and, where appropriate, notified to you by email. Please check back frequently to see any updates or changes to our privacy policy.
It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.
This website, and information that we may post on our website or via the pages on social media platforms which we operate (our sites) may include links to third-party websites, plug-ins and applications, for your convenience and information. Clicking on those links or enabling those connections means you may leave our sites and may allow third parties to collect or share data about you.
We do not control these third-party websites, the social media platforms themselves, or third party, social media accounts or apps and are not responsible, or liable, for how they process your personal data or for their privacy statements. For example, they may send their own cookies to users, collect data or solicit personal data from you. When you leave our sites, we encourage you to read the privacy statement of every website, app and social media account that you use or visit.
If you are applying for a job with us, you may be asked to complete an online application form. This form is provided by a recruitment software provider. All personal data that you provide via that form is stored on our systems, and is not accessed or otherwise processed by that provider.
When you contact us through our sites, or communicate with us, or visit our premises, you may provide us with personal data about you.
Personal data means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).
We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:
We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data could be derived from your personal data but is not considered personal data in law as this data will not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy statement.
Where we need to collect personal data by law, or under the terms of a contract we have with you, or we are processing your personal data to fulfil a request you have made, and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with goods or services) or we may not be able to otherwise comply with your request. In this case, we may have to cancel a product or service you have with us but we will use reasonable efforts to notify you if this is the case at the time.
We use different methods to collect data from and about you including through:
We will only use your personal data when the law allows us to do so. Most commonly, we will use your personal data in the following circumstances:
To find out more about the types of lawful basis that we will rely on to process your personal data, refer to the Glossary at the end of this document.
Generally, we do not rely on consent as a legal basis for processing your personal data although we will get your consent before sending third party direct marketing communications to you via email or text message. You have the right to withdraw consent to marketing at any time by contacting us.
We have set out below, in a table format, a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.
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 data. Please contact us if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below.
| Purpose/activity | Type of data | Legal basis for processing including legitimate interest basis) |
|---|---|---|
| To register you as a new customer | (a) Identity (b) Contact |
Performance of a contract with you |
| To manage our relationship with you which will include: (a) Responding to an enquiry or complaint (b) Notifying you about changes to our terms or privacy statement (c) Asking you to leave a review or take a survey |
(a) Identity (b) Contact (c) Marketing (d) Communications (f) Social Media |
(a) Performance of a contract with you (b) Necessary to comply with a legal obligation (c) Necessary for our legitimate interests (to keep our records updated) |
| To administer and protect our business, this website and pages on social media platforms operated by us (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data) | (a) Identity (b) Contact (c) Technical (d) Communications Data (e) Social Media Data |
(a) Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise) (b) Necessary to comply with a legal obligation |
| To use data analytics to improve our sites, products/services, marketing, customer relationships and experiences | (a) Technical (b) Usage |
Necessary for our legitimate interests (to define types of customers for our products and services, to keep our sites updated and relevant, to develop our business and to inform our marketing strategy) |
| To make suggestions and recommendations to you about goods or services that may be of interest to you | (a) Identity (b) Contact (c) Technical (d) Usage (e) Marketing (f) Communications (g) Social Media Data |
Necessary for our legitimate interests (to develop our products/services and grow our business) |
| CCTV | CCTV data | Legitimate interest – to manage security of our premises, to manage health and safety at our premises, and to allow us to manage insurance claims |
| To complete accident or incident reports which are reported to us | (a) Identity Data (b) Contact Data (c) Accident and Incident Data |
Legitimate interest Legal Obligation |
Promotional offers from us
You will receive marketing communications from us if you have requested information from us or purchased goods or services from us and you have not opted out of receiving that marketing.
Third-party marketing
Our site is designed to provide information about our Ceuta Group companies. If you make an enquiry with us we will pass your enquiry to the appropriate group company so that they can contact you directly, including for their own marketing purposes. We do not otherwise share your personal data with any third party for marketing purposes.
Opting out
You can ask us to stop sending you marketing messages at any time by checking or unchecking relevant boxes to adjust your marketing preferences. You can also follow the opt-out links on any marketing message sent to you in our emails, or unsubscribe from our pages on social media platforms operated by us, or contact us at any time.
Cookies
You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of our website may become inaccessible or not function properly. For more information about the cookies we use, please see our Cookie Policy.
Change of purpose
We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose.
If you would like to understand more about any of our purposes or, you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.
If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.
Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.
We may share your personal data with the parties set out below for the purposes set out in the table Purposes for which we will use your personal data above.
We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.
We do not transfer your personal data outside the United Kingdom or the European Economic Area (EEA), unless your enquiry relates to one of our Ceuta Group companies which is based outside the UK or the EEA – see here for details on where our group companies are located, or where you contact us from outside the UK or EEA.
Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the UK or the EEA.
Please note that we have no control over the routes emails take, and even emails exchanged between two people in the UK could appear on equipment in countries outside the UK or the EEA, where they may not be protected by strong privacy or data protection laws.
We have a strong commitment to data security.
We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed.
In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.
We take appropriate steps to communicate and train our staff in relation to applicable data protection law.
We have put in place procedures 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.
Unfortunately, the transmission of information via the Internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted to or via our sites or via any social media platforms; any transmission is at your own risk.
Use of CCTV data is subject to additional specific rules and protections, as described more fully in our CCTV Policy, which is available on request.
If you would like to know more about our data security measures please contact us.
We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.
To determine the appropriate retention period for personal data, we consider the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements.
Details of retention periods for different aspects of your personal data are available in our retention policy which you can request from us by contacting us.
By law we have to keep basic information about our customers (including Contact, Identity, Financial and Transaction Data) for six years after they cease being customers for tax purposes.
In some circumstances you can ask us to delete your data: see your legal rights below for further information.
In some circumstances we will anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes, in which case we may use this information indefinitely without further notice to you.
Under certain circumstances, you have rights under data protection laws in relation to your personal data which we process as a controller.
These rights are subject to specific requirements and limitations set out in the applicable data protection legislation and are summarised below:
If you wish to exercise any of the rights set out above, please contact us.
You also have the right to complain to the Information Commissioner’s Office about our processing or our response to your requests and objections – ICO or 0303 123 1113.
No fee usually required
You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee, or refuse your request, if your request is clearly unfounded, repetitive or excessive.
What we may need from you
We may need to request proportionate information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.
Time limit to respond
We try to respond to all legitimate requests within one month. Occasionally it could take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.
Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give you the best service/product and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us.
Performance of Contract means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.
Comply with a legal obligation means processing your personal data where it is necessary for compliance with a legal obligation that we are subject to.
Internal Third Parties
Other companies in the Ceuta Group such as those based in the UK, Ireland, The Netherlands, USA, Singapore, Thailand and Australasia, which provide various products and services as well as internal IT and system administration services and leadership reporting.
External Third Parties
