The Cowan Group takes your privacy seriously. This privacy statement describes what personal data we collect, how we use it and your rights and options.
This statement aims to give you information on how we collect and process any personal data you may provide to us, through this website or otherwise. It is important that you read this privacy statement together with any other privacy statement or fair processing notice 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 our website terms and other notices we may give and is not intended to override them.
1 Data Controller
The Cowan Group is responsible for your personal data.
The Group has appointed a Data Protection Officer and they can be contacted by email at firstname.lastname@example.org. Your personal data will be controlled by the relevant Group entity that you have instructed or that is providing services or communication to you in your region.
2 Your consent
As a general principle, you will provide us with your personal data entirely voluntarily; there are generally no detrimental effects for you if you choose not to consent or to provide your personal data. However, there are circumstances in which the Group cannot take action without certain personal data. An example would be because personal data is required to process your instructions or provide a service. In these cases, it will unfortunately not be possible for us to provide you with what you request without the relevant personal data and we will notify you accordingly.
Your use of this website signifies your consent to us collecting and using personal data about you as specified below in accordance with this privacy statement. Should we choose to change these terms for any reason, the changes will be posted here so that you are always kept informed about the collection and use of your personal information, and when we disclose it.
3 Data security
3.1 We have put in place appropriate security measures to prevent the unauthorised collection of personal data, your personal data from being accidentally lost, erased, used or accessed in an unauthorised way, copied, altered or disclosed. In addition, we limit access to your personal data to those employees, professional advisers and service providers 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 and contractual terms to comply with applicable data protection legislation. In other cases, data is anonymous, so that you cannot be identified.
3.2 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.
3.3 We will store all the personal data you provide on our secure password and firewall protected servers or in paper files.
3.4 You acknowledge that the transmission of information over the internet is inherently insecure and we cannot guarantee the security of personal data sent over the internet.
4 The data we collect about you
Personal data means any information about an individual from which that person can be identified. We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:
4.1 Identity data includes first name, maiden name, last name, position, organisation’s name, telephone number, email address, username or similar identifier, marital status, title and gender;
4.2 Contact data includes an individual’s billing address, delivery address, email address and telephone numbers;
4.3 Financial data includes (in the case of an individual) invoices raised for services supplied to you, your bank account and payment details;
4.4 Technical data includes 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 this website
4.5 Profile data includes orders made by you (in the case of an individual), your location, how you heard about us;
4.6 Usage data includes information about how you (in the case of an individual) use our website, products and services; and
4.7 Marketing and communications data includes your preferences in receiving marketing from us and our third parties and your communication preferences.
5 How do we collect personal information about you and how is it used?
We use different methods to collect data from and about you including through:
5.1 Direct interactions. You may give us your identity, contact and financial data by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide by:
5.1.1 applying for our services;
5.1.2 requesting that information about us is sent to you;
5.1.3 enter a competition, promotion or survey; or
5.1.4 giving us some feedback.
5.1.5 through automated technologies or interactions. As you interact with our website, we may automatically collect technical data about your equipment, browsing actions and patterns. We collect this personal data by using cookies, and other similar technologies. We may also receive technical data about you if you visit other websites employing our cookies.
5.1.6 through third parties or publicly available sources. This includes:
220.127.116.11 Technical data from parties based inside or outside the European Economic Area (EEA):
18.104.22.168.1 analytics providers such as Google;
22.214.171.124.2 advertising networks; and
126.96.36.199.3 search information providers;
188.8.131.52 Contact, financial and transaction data from providers of technical, payment and delivery services ;.
184.108.40.206 Identity and contact data from data brokers or aggregators;
220.127.116.11 Identity and contact data from publicly availably sources.
6 How we use your personal data
6.1 We will only use your personal data when the data protection legislation allows us to do so. Most commonly, we will use your personal data in the following circumstances:
6.1.1 Where we need to perform the contract we are about to enter into or have entered into with you;
6.1.2 Where it is necessary for our legitimate interests and your interests and fundamental rights do not override those interests;
6.1.3 Where we need to comply with a legal or regulatory obligation; and
6.1.4 Where you have provided clear consent for the processing of your personal data either to the Group as Data Controller, or to a third-party Data Controller for which the Group acts as a Data Processor.
7 Purposes for which we will use your personal data
7.1 We may use your personal data to:
7.1.1. enable your use of the services available on the website;
7.1.2. process client orders, including sending goods and supplying services, and the management of payments;
7.1.3 manage our relationship with you which will include:
18.104.22.168. notifying you about changes to our terms or privacy statement;
22.214.171.124 improving your browsing experience by personalising the website;
126.96.36.199 sending to you general (non-marketing) commercial communications;
188.8.131.52 sending to you email notifications, sales enquiries, proposals and quotations which you have specifically requested;
184.108.40.206 dealing with enquiries and complaints made by or about you relating to the website;
220.127.116.11 keeping the website secure and to prevent fraud;
18.104.22.168 verifying compliance with the terms and conditions governing the use of the website;
22.214.171.124. inviting you to training, networking and exhibition events we feel may be of interest to you;
126.96.36.199. asking you to leave a review or take a survey;
7.1.4. enable you to partake in a competition or complete a survey;
7.1.5. administer and protect our business and this website;
7.1.6. deliver relevant website content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you;
7.1.7 use data analytics to improve our website, products/services, marketing, customer relationships and experiences;
7.1.8. make suggestions and recommendations to you about goods or services that may be of interest to you.
7.2 We may provide aggregate statistics about sales, customers, traffic patterns and information to third parties, but these statistics will not include any information that identifies you.
7.3 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.
7.4 Marketing – We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising.
7.5 Promotional offers from us
7.5.1 We may use your Identity, Contact, Technical, Usage and Profile Data 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, services and offers may be relevant for you.
7.5.2 You will receive marketing communications from us if you have requested information from us and have not opted out of receiving that marketing.
7.6 Third-party marketing
7.6.1 Where the website contains links to other websites. We are not responsible for the privacy policies or practices of third party websites.
7.7 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 wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.
7.8 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.
7.9 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 applicable legislation.
8 Disclosure of your personal data
8.1 We may have to share your personal data with
8.1.1 service providers who provide IT and system administration services;
8.1.2 professional advisers;
8.1.3 regulators and other authorities in the jurisdictions in which we operate who require reporting of processing activities in certain circumstances.
8.2 The personal data disclosed to service providers may:
- relate to performance of our contract with you;
- be necessary for our legitimate interests or to comply with a legal obligation.
8.3 Where we decide to sell, transfer, or merge parts of our business or our assets we may disclose personal data. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy statement.
8.4 We require all service providers and others to respect the security of your personal data and to treat it in accordance with applicable data protection legislation. We do not allow our 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.
9 International transfers
The Group operates in multiple jurisdictions. We may transfer your personal data abroad if required for the permitted purposes as described above. This may include countries which do not provide the same level of protection as your home country.
All Group offices will ensure a level of data protection at least as protective as that required in the jurisdictions in which we operate. We will also require our agents, consultants and sub-contractors to whom we transfer your personal data to ensure a similar level of data protection.
Where necessary explicit consent will be obtained from you prior to the transfer of your personal data.
10 What are cookies and how do we deal with them?
We use a number of different cookies on our site. If you do not know what cookies are, or how to control or delete them, then we recommend you visit http://www.aboutcookies.org for detailed guidance. The following describes the cookies we use on this site and what we use them for.
10.1 We use both “session” cookies and “persistent” cookies on the website. Session cookies will be deleted from your computer when you close your browser. Persistent cookies will remain stored on your computer until deleted, or until they reach a specified expiry date.
10.2 We will use the session cookies to: keep track of you whilst you navigate the website; prevent fraud and increase website security; and enhance your user experience. We will use the persistent cookies to: enable our website to recognise you when you visit; keep track of your preferences in relation to your use of our website; and remember your login details
10.4 Social Buttons: These enable users to share or bookmark the web pages. In order to implement these buttons, and connect them to the relevant social networks and external sites, there are scripts from domains outside of this site. You should be aware that these sites are likely to be collecting information about what you are doing all around the internet, including on this site. So if you click on any of these buttons, these sites will be registering that action and may use that information. In some cases these sites will be registering the fact that you are visiting Cowan.com, and the specific pages you are on, even if you don’t click on the button if you are logged into their services. You should check the respective policies of each of these sites to see how exactly they use your information and to find out how to opt out, or delete, such information.
10.4 We do not currently feature advertisers or payment services. However, if we should add these in the future, our advertisers and/or payment services providers may also send you cookies.
10.5 You can change your browser settings to disable cookies if you have privacy concerns. Disabling cookies for all sites is not recommended as it may interfere with your use of some sites. The best option is to disable or enable cookies on a per-site basis. Consult your browser documentation for instructions on how to block cookies and other tracking mechanisms.
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 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 requirements.
11.3 In some circumstances you can ask us to delete your personal data. See section 12 of this privacy statement for further information.
11.4 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 which case we may use this information indefinitely without further notice to you.
12 Your legal rights
You have rights under data protection legislation in relation to your personal data. 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 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.
Subject to certain legal conditions, you have the right to:
12.1 Request access to your personal data. This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
12.2 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.
12.3 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.
12.4 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.
12.5 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 cases:
12.5.1 if you want us to establish the data’s accuracy;
12.5.2 where our use of the data is unlawful but you do not want us to erase it;
12.5.3 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
12.5.4 you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
12.6 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.
12.7 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 or services to you. We will advise you if this is the case at the time you withdraw your consent. If you wish to exercise any of the above rights, please send an email to email@example.com. We will consider any requests and complaints which we receive and provide you with a response in a timely manner. If you are not satisfied with our response, you may take your complaint to the relevant regulator.
Updates to this Privacy Statement
We reserve the right to update and change this privacy statement from time to time in order to reflect any changes to the way in which we process your personal data or changing legal requirements. In case of any such changes, we will post the changed privacy statement on our website. The changes will take effect as soon as they are posted on this website.