COP Security Privacy Statement

Introduction
COP Security respects your privacy and is committed to protecting your personal data. This privacy notice explains how we look after your personal data and informs you about your privacy rights and how the law protects you. COP Security is a trading division of Weststone Limited and is referred to as "COP", "we", "us" or "our" in this privacy notice.
1. Important information and who we are
Purpose of this privacy notice
This privacy notice informs you about how COP collects and processes your personal data when you interact with us, including any data you may provide through our website, when you sign up to our marketing information, or purchase a product or service. 
It is important that you read this privacy notice together with our terms and conditions and any other privacy notice 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 notice supplements the other notices and is not intended to override them. 

Controller 
COP is the controller and responsible for your personal data. 

If you think that we have not used your data in the right way or you are not satisfied with our response to any request you have made concerning your data, 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 whose contact details can be found at https://ico.org.uk/concerns. 

Changes to the privacy notice and your duty to inform us of changes 
We may need to update our Privacy Policy from time to time. You can check it at any time on our website. We will inform you of any significant changes. 

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. 

Third-party links 
Our website and emails 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 content or privacy statements. We encourage you to read the privacy notice of every website you visit.
2. The data we collect about you
Personal data, or personal information, means any information about an individual from which that person can be identified.
Our website, products and services are not intended for children and we do not knowingly collect data relating to children.
We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:
  • Identity Data includes first name, maiden name, last name, username or similar identifier, marital status, title, date of birth and gender.
  • Contact Data includes billing address, delivery address, email address and telephone numbers.
  • Financial Data includes bank account and payment card details.
  • Transaction Data includes details about payments to and from you and other details of products and services you have purchased from us.
  • Technical Data includes internet protocol (IP) address, your login data, [other identifying technical data from services,] 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 and services.
  • Profile Data includes your username and password, purchases or orders made by you, your interests, preferences, feedback and survey responses.
  • Usage Data includes information about how you use our products, services and website.
  • Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.
  • Recording of your image via CCTV camera when you visit our offices.
  • Recording of all telephone conversations (incoming & outgoing) for training and quality purposes.

  • We also collect, use and share 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 service feature.

    We do not collect any Special Categories of Personal Data about you (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.

    If you fail to provide personal 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 or services). In this case, we may have to cancel a product or service you have with us but we will notify you if this is the case at the time.
    3. How is your personal data collected?
    We use different methods to collect data from and about you including through:
    • Direct interactions You may give us your Identity, Contact, Technical and Financial Data by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you
    • apply for our products or services;
    • create an account on our website or by phone;
    • subscribe to our service or publications;
    • request marketing to be sent to you;
    • contact by telephone;
    • visit to our offices;
    • enter a competition, promotion or survey; or
    • give us some feedback.
    • Automated technologies or interactions As you interact with our services and website, we may automatically collect Technical Data about your equipment, service usage, browsing actions and patterns. We collect this personal data by using cookies, server logs and other similar technologies
    • Third parties or publicly available sources We may receive personal data about you from various third parties and public sources as set out below
    • Technical Data from analytics providers such as Google based outside the EU.
    • Contact, Financial and Transaction Data from providers of technical, payment and delivery services such as credit reference agencies based inside the EU.
    • Identity and Contact Data from publicly availably sources such as Companies House and the Electoral Register based inside the EU
    4. 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 which are permitted by data protection laws:
    • Where we need to perform the contract we are about to enter into or have entered into with you.
    • Where it is necessary for our legitimate interests in conducting and managing our business (or those of a third party). Legitimate Interest means the interest of our company in conducting and managing our business to enable us to give you the best service. We balance this with any potential impact on you (both positive and negative) and your rights. We do not use your personal data where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law.
    • Where we need to comply with a legal or regulatory obligation.
    Generally we do not rely on consent as a legal basis for processing your personal data other than in relation to 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 at admin@cop-eu.com.

    Purposes for which we will use your personal data
    We have set out below 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 Lawful Basis for Processing
    To register you as a new customer (a) Identity
    (b) Contact
    Performance of a contract with you
    To process and deliver your order 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
    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/services)
    To enable you to partake in a prize draw, competition or complete a survey (a) Identity
    (b) Contact
    (c) Profile
    (d) Usage
    (e) Marketing and Communications
    (a) Performance of a contract with you
    (b) Necessary for our legitimate interests (to study how customers use our products/services, to develop them and grow our business)
    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
    (d) Financial
    (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 and advertisements to you and measure or understand the effectiveness of the advertising we serve to 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/services, to develop them, to grow our business and to inform our marketing strategy)
    To use data analytics to improve our website, 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 website 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) Profile
    Necessary for our legitimate interests (to develop our products/services and grow our business)
    You have choices regarding certain personal data uses, particularly around marketing and advertising.

    Promotional offers from us
    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.
    You will receive marketing communications from us if you have requested information from us or purchased goods or services from us or if you provided us with your details when you entered a competition or registered for a promotion and, in each case, you have not opted out of receiving that marketing.

    Third-party marketing
    We must obtain your express consent before we share your personal data outside COP for marketing purposes.

    Opting out
    You can make choices about your marketing preferences or ask us or third parties to stop sending you marketing messages at any time by following the opt-out links on any marketing message sent to you or by contacting us.

    Where you opt out of receiving these marketing messages, we will stop sending them but we may still retain personal data provided to us as a result of a product/service purchase, warranty registration, product/service experience or other transactions.

    Cookies
    A cookie is a text file that is placed on your hard disk by a web page server. This allows the Cop Security website to function correctly and enables the web server to identify a returning customer allowing a user to log into the site.
    We use cookies in the following ways:
    • Essential cookies which are strictly necessary to ensure functionality of our website. These cookies allow you to move around our site, using the features, searches and order placement it offers.
    • Gathering information about how you use our site, for example pages most visited, error messages displayed etc.
    • Traffic monitoring showing IP addresses accessing our site.
    • Analytical/statistical information in relation to repeat visits.
    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 this website may become inaccessible or not function properly.

    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 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.
    5. Disclosures of your personal data
    In order to carry out the purposes set out in the table above, we may have to share your personal data with the following parties:
    • Service providers acting as processors based in the UK who provide IT and system administration services.
    • Professional advisers acting as processors or joint controllers including lawyers, bankers, auditors and insurers based in the United Kingdom who provide consultancy, banking, legal, insurance and accounting services.
    • HM Revenue & Customs, regulators and other authorities acting as processors or joint controllers based in the United Kingdom who require reporting of processing activities in certain circumstances.
    • Third parties to whom we may choose to sell, transfer, or merge parts of our business or our 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.
    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.
    6. International transfers
    We do not transfer your personal data outside the European Economic Area (EEA).
    7. 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.

    All transactional areas of our website are protected using ‘https’ technology. 

    Access to your account is password-protected, and financial data (such as payment card information) is secured by SSL encryption.

    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.
    8. Data retention
    We will only retain your personal data for as long as necessary for the purposes for which we collected it, including for the purposes of satisfying any legal, accounting, or reporting requirements.

    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

    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 'Request Erasure' below for further information.

    At the end of the retention period we will either delete your personal data or we may anonymise it (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.
    9. Your legal rights
    Under certain circumstances, you have rights under data protection laws in relation to your personal data. These are the right to:
    • 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.
    • Request correction of your personal data. This enables you to have any incomplete or inaccurate data we hold about you corrected.
    • 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 have 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 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 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.
    • Right to withdraw consent 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 rights set out above, please contact admin@cop-eu.com.

    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 if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.

    What we may need from you
    We may need to request 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 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.