PRIVACY POLICY

Educational Art and Craft Supplies Ltd Privacy Policy  Introduction Educational Art and Craft Supplies Ltd (also known by our brand name Essdee) are a manufacturer of art and craft material, and offer a range of Scraperboard, etching tools, block printing tools and materials.  We are committed to protecting and respecting your privacy. Everyone has rights with regard to the way in which their personal information is handled.  During the course of our activities we will collect, store and process personal information about our customers, suppliers and other third parties, and we recognise that the correct and lawful treatment of this data will maintain confidence in the organisation and will provide for successful business operation. This policy sets out the basis on which any personal information we collect from you, or that you provide to us, will be processed by us.  Please read the following carefully to understand our views and practices regarding your personal data and how we will treat it. Becoming a customer or your provision of any information to us constitutes your acknowledgement of the terms of this privacy policy.  Please do not send us any of your information if you do not want it to be used in the ways described in this privacy notice. 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. You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), which is the UK supervisory authority for data protection issues.  We would however appreciate the chance to deal with your concerns before you approach the ICO, so please contact us in the first instance. For the purpose of UK data protection laws, the data controller is Educational Art and Craft Supplies Ltd of Frederick Road, Hoo Farm Industrial Estate, Kidderminster, Worcestershire, DY11 7RA. We can be contacted on 01562 60787 and info@essdee.co.uk. The data we collect about you ‘Personal Data’ is any information about an individual from which that person can be identified. It does not include anonymised data where identifying characteristics have been removed. We may collect, use, store and transfer different kinds of personal data about you which we have grouped together follows:

• Identity Data which may include your name, username or similar identifier, title, job title and gender
• Contact Data which may include address, billing address and details, email addresses and telephone numbers
• Financial Data which may include bank account and payment card details
• Transaction Data which may include details about payments to and from you and other details of products you have purchased from us
• Technical Data which may include internet protocol (IP) addresses, 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
• Profile Data which may include your username and password, purchases or orders made by you, your interests, preferences and any feedback and survey responses
• Usage Data which may include information about how you use our website and products
• Marketing and Communications Data which may include your preferences in receiving marketing from us and your communication preferences

We also may collect, use and share what is known as ‘Aggregated Data’ (such as statistical or demographic data) for any purpose.  Aggregated Data may be derived from your personal data but is not considered personal data in law as this data does 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 notice. We do not collect any Special Categories of Personal Data about you or parties associated with you.  These categories of data include details about race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data. Where we need to collect personal data by law, or under the terms of a contract we have with you 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). In this case, we may have to cancel a product you have purchased from us but we will notify you if this is the case at the time. How we collect your personal data We may use different methods to collect data from and about you.  These include: Direct interactions You may provide us with personal data for example when you:

• visit our website
• purchase our products
• request marketing information to be sent to you
• complete a survey or give us some feedback
• meet with us in our office, at events or elsewhere
• log onto the wi-fi network in our offices
• fill in forms on our website
• give us your business card
• enter a competition, promotion or survey organised by us
• correspond with us by phone, email, letter or otherwise

Automated technologies or interactions When you visit our website, we may automatically collect technical data about your equipment, browsing actions and patterns.  We may collect this personal data by using cookies, server logs and similar technologies. Third parties or publicly available sources Examples of this might include:

• analytics providers or search information providers/engines
• advertising networks
• data brokers or aggregators
• providers of technical, payment and delivery services
• Companies House
• by conducting searches of publicly available databases or social media sites, such as Facebook, Twitter, LinkedIn

How we use your personal data We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:

• Where we need it to perform a contract we are about to enter into or have entered into with you
• Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests
• Where we need to comply with a legal or regulatory obligation
• Where you have given us consent

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 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. Purposes for which we will use your personal data 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.

Purpose/Activity	Type of data	Lawful basis for processing including basis of legitimate interest
To register or subscribe you as a new customer	(a) Identity (b) Contact	Performance of a contract with you
To process and deliver products to you, including: (a) Manage payments, fees and charges (b) Collect and recover money owed to us	(a) Identity (b) Contact (c) Financial (d) Transaction (e) Marketing and Communications	(a) Performance of a contract with you (b) Necessary for our legitimate interests
To manage our relationship with you which will include: (a) Notifying you about changes to our terms or privacy policy (b) Asking you to leave a review or take a survey	(a) Identity (b) Contact (c) Profile (d) Marketing and Communications	(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 and to study how customers use our products)
To administer and protect our business and our website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)	(a) Identity (b) Contact (c) Technical	(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 deliver relevant website content to you and measure or understand the effectiveness of our communications with you	(a) Identity (b) Contact (c) Profile (d) Usage (e) Marketing and Communications (f) Technical	Necessary for our legitimate interests (to study how customers use our products, to develop them, to grow our business and to inform our marketing strategy)
To use data analytics to improve our website, products, marketing, customer relationships and experiences	(a) Technical (b) Usage	Necessary for our legitimate interests (to define types of customers for our products, to keep our website updated and relevant, to develop our business and to inform our marketing strategy)
To make suggestions and recommendations to you about goods that may be of interest to you	(a) Identity (b) Contact (c) Technical (d) Usage (e) Profile	Necessary for our legitimate interests (to develop our products and grow our business)
To provide you with information about special offers and other products we provide that are similar to those that you have already received from us and to provide you with updates	(a) Identity (b) Contact (c) Profile (d) Usage (e) Marketing and Communications (f) Technical	Necessary for our legitimate interests (to ensure you continue to receive communications that you have previously agreed to receive and to ensure that we provide you with the communications that you have requested)
To enable you to participate in a prize draw or competition	(a) Identity (b) Contact (c) Profile (d) Usage (e) Marketing and Communications (f) Technical	Necessary for our legitimate interests (to study how customers and prospective customers use our products, to develop them and help grow our business)

Marketing We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising. We may use your Identity, Contact, Technical, Usage and Profile Data as described above to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which products and offers may be relevant for you. You will receive marketing communications from us if you have requested information from us or purchased services from us or if you provided us with your details when you registered for a promotion and, in each case, you have not opted out of receiving that marketing. We will not share your personal data with any other company for marketing purposes. Opting Out You can ask us to stop sending you marketing messages at any time by contacting us or by selecting the ‘unsubscribe’ option which is include with each such communication to you. Where you opt out of receiving marketing messages, this will not apply to personal data provided to us as a result of the purchase of a product. Cookies Like many other websites, the Educational Art and Craft Supplies Ltd website uses cookies. A cookie is a small file which asks permission to be placed on your computer’s hard drive. Once you agree, the file is added and the cookie helps analyse web traffic or lets you know when you visit a particular site. Cookies allow web applications to respond to you as an individual. The web application can tailor its operations to your needs, likes and dislikes by gathering and remembering information about your preferences. 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. We use traffic log cookies to identify which pages are being used. This helps us analyse data about web page traffic and improve our website in order to tailor it to customer needs. We only use this information for statistical analysis purposes and then the data is removed from the system. Overall, cookies help us provide you with a better website, by enabling us to monitor which pages you find useful and which you do not. A cookie in no way gives us access to your computer or any information about you, other than the data you choose to share with us. Below is a list of the main cookies used on our website, you can view the full list here. Google Analytics 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 For more information on Google Analytic’s privacy policy visit here - http://www.google.com/analytics/learn/privacy.html Google Maps These are Google Maps third party cookies, which are unique identifiers to allow traffic analysis to Google Maps. Our website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy notice of every website you visit. Our website may contain links to other websites run by other organisations. This privacy policy applies only to our website‚ so we encourage you to read the privacy statements on the other websites you visit. We cannot be responsible for the privacy policies and practices of other sites even if you access them using links from our website. In addition, if you linked to our website from a third party site, we cannot be responsible for the privacy policies and practices of the owners and operators of that third party site and recommend that you check the policy of that third party site. Disclosures of your personal data Any third party joint data controllers or third party data processors we engage in the normal course of our business are required by us to respect the security of your personal data and to treat it in accordance with the law.  They are only permitted to process your personal data for specified purposes and in accordance with our instructions. We may share your personal data with our business partners which include, but are not limited to:

• Our outsourced IT services provider, together with the providers of wi-fi, IT and system administration services to our business and on-line cloud and data-room providers
• Analytics and search engine providers that assist us in the improvement and optimisation of our website
• Transport providers such as logistics companies and freight forwarders
• Payment solutions such as card providers, banks and other payment service providers
• E-commerce platform
• Marketing providers who assist in the promotion of our products (such as Mailchimp)

However, when we use third party service providers, we disclose only the personal information that is necessary to deliver the service and we have a contract in place that requires them to keep your information secure and not to use it for their own direct marketing purposes. Please be reassured that we will not release your information to third parties beyond the company for them to use for their own direct marketing purposes, unless you have requested us to do so, or we are required to do so by law, for example, by a court order or for the purposes of prevention of fraud or other crime. Transferring data outside of the EEA We do not currently transfer your data outside of the EEA, except in the case of our use of a marketing automation platform (currently Mailchimp) which we use to transmit emails on our behalf.  As part of our commitment to protecting your data we strive at all times to ensure that full and GDPR-compliant arrangements between Educational Arts and Craft Supplies Ltd and our chosen automation platform provider are in place. Data Security We strive to maintain 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. Ways in which data is protected include having in place a Data Protection Policy, adhering to Data Retention Protocols, restricting access to data to only those staff who need to access it as part of their duties, using password protection, applying firewall protection and encryption technology, using disposing of paper documents containing personal data by shredding, using lockable filing cabinets and training staff in the importance of data security. We have put in place procedures to deal with any suspected personal data breach and will notify you and the ICO 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 information, we cannot guarantee the security of your data transmitted to our website; any transmission is at your own risk.  Once we have received your information, we will use strict procedures and security features to try to prevent unauthorised access. Data Retention 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. The length of time that we will store your data will depend on the ‘legal basis’ for why we are using the data, as follows:

Legal Basis	Length of Time
Where we use/store your data because it is necessary for the performance of the contract between you and us	We will use/store your data for as long as necessary for the performance of the contract between you and us
Where we use/store your data because it is necessary for us to comply with a legal obligation to which we are subject	We will use/store your data for a long as necessary for us to comply with our legal obligations
Where we use/store your data because it is necessary for our legitimate business interests	We will use/store your data for as long as it is necessary for our legitimate business interests, or such earlier time as you ask us to stop.  However, if we can demonstrate the reason why we are using/storing your data is more important than your interests, rights and freedoms, then we will be allowed to continue to use/store your data for as long as it is necessary for our legitimate business interests
Where we use/store your data because you have given us your specific, informed and unambiguous consent	We will use/store your data until you ask us to stop

To determine the appropriate retention period for personal information, we consider the amount, nature and sensitive personal information, the potential of harm from unauthorized use or disclosure of your personal information, the purposes for which we process your personal information and whether we can achieve those purposes through other means, and the applicable legal requirements. In some circumstances you can ask us to delete your data.  This is explained in the section about your legal rights below. In some circumstances we may anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes.  In this case we may use this information indefinitely without further notice to you. Your Legal Rights Under certain circumstances, you have rights under data protection laws in relation to your personal data.  If you wish to exercise any of the rights set out below you should contact us. 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 if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances. We may need to request specific information from you to help us to confirm your identity and to 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. We will endeavour to respond to all legitimate requests within one month. Occasionally it may 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. You have a right to:

• Request access to your personal data (commonly known as a “data subject access request”). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
• Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
• Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
• Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
• Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios: (a) if you want us to establish the data’s accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
• Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
• Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products to you. We will advise you if this is the case at the time you withdraw your consent. 

Updated March 2021