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Welcome

Cookie Data Privacy Notice

Sales and Services Privacy Notice
Rude Oil – Sales and Services
This privacy notice was last updated on 24th May 2018.

1. What is the purpose of this Privacy Notice?
Your ‘personal data’ or ‘personal information’ is any piece of information that would allow us to identify you as an individual. The processing of personal data is governed by the EU General Data Protection Regulation (the “GDPR”) and national laws that implement the GDPR in each European Economic Area (“EEA”) country.

We take your privacy very seriously, and this document sets out what personal information we collect from you in relation to this service, how we intend to use it and what your rights in respect of that information are. By entering into a contract (or trying to) with us, you are accepting and consenting to the practices described in this Privacy Notice.

It is important that you read this Privacy Notice (together with any other privacy notice or fair processing notice we may provide you with on specific occasions when we are collecting or processing personal data about you) and we encourage you to keep copies of all such notices for your records.

Our products and/or services are not intended for children and we do not knowingly collect data relating to children.

2. Who controls your personal information, and how do you get in touch?
The controller of your personal information is Cuts Ice Limited, a company incorporated and registered in England and Wales under company number 07512911 (“we”, “us”, “our”). Cuts Ice Limited is a member of the Cuts Ice group comprising many different legal entities. This Privacy Notice is issued on behalf of Rude Oil in the Cuts Ice group, and you will interact with the brand via:



Should you have any query in respect of this Privacy Notice (including details of the group companies) or your personal information, you can contact us at the following:

Data controller

Cuts Ice Limited

Website

http://www.cutsice.com/

Address

Unit 2 Origin Business Park, Rainsford Road, Park Royal
London, NW10 7FW

Telephone

+44 208 960 6974

Email

privacy@cutsice.com


3. What information do we collect about you, and for what purpose?
If you contact us then we may collect, use, store and/or transfer information about your identity and contact details to be able to service your requirements, including:

  • Representatives’ Names;
  • Representatives’ business addresses;
  • Representatives’ telephone numbers (mobile or landline);
  • Representatives’ email addresses.

If you do business with us then we may collect, use, store and/or transfer information about your identity, contact details and financial and/or transaction data to be able to trade with you, for example:

  • Representatives’ Names;
  • Representatives’ business addresses;
  • Representatives’ telephone numbers (mobile or landline);
  • Representatives’ email addresses;
  • You may also share bank details if we are setting up direct debits or standing orders or need to refer to a credit reference agency.

If we are given your contact details or you have made them public and we need to contact you, we may collect, use, store and/or transfer information such as:

  • Representatives’ Names;
  • Representatives’ business addresses;
  • Representatives’ telephone numbers (mobile or landline);
  • Representatives’ email addresses.

We may also collect, use and share aggregated data such as statistical or demographic data for any purpose if you (or your representatives) cannot be identified in any way. 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. However, if we combine or connect aggregated data with your personal information 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 your representatives (this includes details about your 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). Nor do we collect any information about criminal convictions and offences.

4. How do we collect and use your personal information?
We collect your personal information through different methods, including:

  • Information you give us. You may give us information about your identity, contact details, financial and/or transaction data if you do business with us.
  • Information we receive from other sources. We may receive personal data about you from various third parties and public sources. For example, we may collect contact data from your website or from selected business partners.

We may purchase lists of data from organisations, from time to time, that can provide data privacy records showing your consent for the use of this data by us.  There may be instances where we are provided your information in relation to a contract with another party.  If this is the case then we will endeavour to contact you within thirty (30) days to let you know this has happened, and you can ask us to stop processing your data at this point.  We may also use your information if you have made this public, on your website, via Linked-in or other public means.

5. What is our legal basis for collecting and using your personal information?
We will use your personal information in the following ways and for the purposes set out below. We have identified our legitimate interests where appropriate.


Your information

Purpose

Legal basis

Your contact details.

These are processed for you to be able to take out a contract for our services.  These are then processed to enable us to provide payment terms and discuss matters with relevant personnel to be able to fulfil the contracted services agreed.  These will then need to be used for billing purposes.

We need this information to be able to be able to enter into a contract with you, and to be able to fulfil our obligations under it.

It is also necessary for our legitimate interests (to recover any debts due to us, manage our relationship with you and keep our records updated).

The data you share as part of our contract e.g. contact details and financial and/or transaction data.

To allow access to data exchanged between the disclosing and receiving parties to fulfil contractual obligations between the parties.

We need this information to be able to fulfil the contract that you have engaged us to perform.

It is also necessary for our legitimate interests (to run our business, recover any debts due to us, manage our relationship with you and keep our records updated).

If your data has been shared with us, but is outside of contract or if you have made your data public and we contact you.

To allow us to contact if we have been provided your information in relation to our services or you have made your data public and we have an interest in contact you in relation to our services.

We have a legitimate interest in contacting you in relation to our services (to develop our business)


6. What if you do not want to provide your personal information?
You do not have to provide your personal information to us. However, where we need to collect personal data by law or under the terms of a contract we have with you (e.g. if you try to buy anything from us) and you fail to provide it when requested, we may not be able to perform the contract we have or are trying to enter into with you and may have to cancel the product and/or service you have with us (but we will notify you at the time if this is the case).

7. How is your personal information protected?
We maintain strong physical, electronic and procedural safeguards to protect the confidentiality, integrity and availability of your personal information. We have taken appropriate security measures against illegal and/or unauthorised access to your personal information, and against the accidental loss of, or damage to, it.

8. Do we share your personal information with anyone?
Data is shared as part of the provision of these services with several parties outside of Cuts Ice that allow us to process your data.  These parties, and the purposes for sharing the data, are set out below:


Microsoft and IT solution companies

To be able to provide these services to you we need to have appropriate IT solutions in place.  We purchase these from both Microsoft and other companies as needed to fulfil our obligations to you.  Where feasible and technically possible we will encrypt the data so that the provider does not have access to it.

Credit reference agencies

If you are a sole trader then your details may be provided directly, otherwise it will be that data of your organisation.  This allows us to check the credit worthiness of your organisation for us to be able to provide payment terms.  These companies will not have access to any report information as this is held under non-disclosure agreements between us.

Our bank

To be able to collect payments by direct debit or standing order if this has been agreed with us.  If you have provided bank details then this will need to be shared with our bank to be able to process payments.  These companies will not have access to any report information as this is held under non-disclosure agreements between us.

Payment service provider / Bank

If you purchase something from one of our e-liquid brand sites then to process your payment we will need to share information with our partners to process this payment.

Address / Age verification service

As our services are aimed at over 18’s we have a requirement to verify your address and age.  We will share information with our provider to ensure that you are eligible to purchase our products.

Mail and courier companies

If you buy something from us we will need to post / deliver this to you so we need to share information with these companies to fulfil your request.


We may also need to share your personal information with the following in limited circumstances:

  • IT security providers;
  • Insurers;
  • External advisors (for example solicitors or auditors); and
  • Public authorities or law enforcement.

If we sell or buy (or plan to sell or buy) any business or assets or seek investment from a third-party investor, we may disclose your personal data to the investor or prospective seller or buyer of such business or assets. 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 Notice.

Any time we provide access to your personal information to someone else, we will ensure that it is adequately secured to protect your privacy and that they comply with the requirements of the applicable data protection legislation.

9. Will your personal information be transferred outside of the EEA?
If you are a resident of a country in the EEA, we may need to transfer your personal information outside of the EEA, for example where our data storage facilities or processing locations are in another country. 
Whenever we transfer your personal data outside of the EEA, we ensure a similar degree of protection is afforded to it by putting adequate, legally-approved safeguards in place, including at least one of the following:

  • we will only transfer your personal information to countries that have been deemed to provide an adequate level of protection for personal data by the European Commission;
  • where we use certain service providers, we may use specific contracts approved by the European Commission which give personal data the same protection it has in Europe; and
  • where we use providers based in the US, we may transfer data to them if they are part of the Privacy Shield which requires them to provide similar protection to personal data shared between Europe and the US.

If you would like more information about our safeguards, please contact us using the details inserted in Section two (2) above.

10. How long do we keep your personal information?
We will only retain your personal data for as long as necessary to fulfil the purposes we hold it for, including for the purposes of satisfying any legal, accounting or reporting requirements. In general, we will need to keep the information that we collect from you for the following periods of time:


Your information

Retention Period

Your contact details.

This will be retained for the lifetime of the contract between us and if possible, this will be removed at the end of the contract.  However, if this is part of product information that has been provided to you or us this will be retained for the lifetime of the contract plus six years to be able to defend any insurance claims against us.

The data you share as part of our contract.

This will be retained for the lifetime of the contract between us plus six years to be able to defend any insurance claims against us.

If your data has been shared with us, but is outside of contract or if you have made your data public and we contact you.

This will be retained while we have a legitimate interest in the data, or until:

  • We form a contact between us;
  • Or you have asked us not to process your data.

We may sometimes need to keep a copy of your personal information for a longer period, for example in the event of an incident, to investigate a data breach or to comply with legal requirements. We will never keep your personal information for longer than we consider necessary.
In all cases, your personal information will be securely destroyed once the retention periods described above expire.

11. What are your rights in respect of your personal information?
You have rights in respect of the personal information we hold on you, including the right to ask us to:

  • inform you on how we collect and use it (this Privacy Notice is designed to do that);
  • rectify it if you believe that it is incorrect;
  • provide you with a copy of any information we hold on you in a portable data format that we agree;
  • request the transfer of it to you or a third party;
  • tell you about automated decision-making solutions that we use; and
  • restrict the processing of it e.g. stop processing or using it temporarily.

You can also object to our use of your personal information for our legitimate purposes at any time.


Should you want to exercise any of those rights, please contact us using the details set out in Section 2 above. We try 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 several requests. In this case, we will notify you and keep you updated.

Out partners use automated decision making for the following reasons:

  • To review if we can give you credit facilities;
  • To decide if you are over 18 and able to purchase our products;
  • To process your payment card for your purchase to be approved.

Cuts Ice does not handle these processes directly and they are provided to us.  If you would like to know more about these processes and which companies to contact to find out how this data is processed then please contact us using the details set out in Section 2 above.

12. Will we do anything else with your information in the future?
Where we need to use your personal data for another reason, other than for the purpose for which we collected it, we will only use your personal data where that reason is compatible with the original purpose.

Should it be necessary to use your personal data for a new, unrelated purpose, we will endeavour notify you and communicate the legal basis which allows us to do so before starting any new processing.

The exception to this is where use of the personal information is required or permitted by law e.g. to a recall of any of our products, updated allergy advice or for another legal reason that may require us to contact you. In this case, we may process your personal information without your knowledge or consent.

13. You have the right to complain to us or our supervisory authority
You also have the right to lodge a complaint with our supervisory authority, the Information Commissioner’s Office, which can be contacted at the following:


Supervisory Authority

UK Information Commissioner’s Office

Website

https://ico.org.uk/concerns/

Address

Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF, United Kingdom

Telephone

0303 123 1113

Email

https://ico.org.uk/global/contact-us/email/


14. Changes to this Privacy Notice
We may need to make changes to this Privacy Notice in the future (for example, to comply with new legal requirements).

Where that is the case, we will provide you with a revised Privacy Notice on our website, which you will be able to access. If required by law, we will seek your prior approval before revising this Privacy Notice.

It is important that the personal information we hold about you is accurate and current. Please keep us informed if your personal information changes during your relationship with us.