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Data Protection / GDPR Policy

Data Protection / GDPR Policy

Data Protection / GDPR Policy

This Data Protection & Privacy Policy is to help you understand what data we collect at Camber & Kernz (including our third-party providers), why we collect it, how we protect it and what we do with it, to comply with the General Data Protection Act (and future UK Data Protection Bill) which will be launched 25th May 2018.

We; Camber & Kernz, keep the following personal data from yourselves when you make a purchase from us:

• Name, Address, and Email

This information is kept on a spreadsheet which is password protected on a PC. We do not use this information for anything else apart from our legal obligations to provide you with an effective purchase transaction, and should you have any queries about anything we have a way to contact you.

When you register with us, the ‘Welcome’ email message clearly states that you are consenting to be signed up to our mailing list for offers and updates on any of our policies / procedures. This said, (apart from a legal update correspondence) there is always an ‘unsubscribe’ option available and you can withdraw your consent at any time.

Our retention for the above information, is reviewed annually with our customers and should they wish to unsubscribe, that option is available, and they will subsequently be removed off our spreadsheet. Due to our legal obligation for fulfilling your order we cannot grant any right to erasure until the transaction is completed.

To provide you with an effective online e-commerce service at Camber & Kernz, we use additional third party providers / data processors to make a great shopping experience.

We use two companies that help us to process your data:

• BigCommerce – e-commerce platform the website is built upon

• Stripe – processes payments when using credit or debit cards

We encourage you to read the Data Protection Policy on the website carefully and take the time to get to know all practices, through using the links available. Below, for transparency we have included the current policies / procedures from our third party processors to give you piece of mind, however please use the appropriate links for the most current and up to date version.

Cookies

The Privacy and Electronic Communications Regulations 2003 cover the use of cookies and similar technologies for storing information, and accessing information stored, on a user's equipment such as their computer or mobile. On the 25th May 2011 amendments were made to these regulations, which require businesses and organisations running websites in the UK to get consent from visitors to their website in order to store cookies on users' computers. When someone visits our website we collect visitor statistics using BigCommerce Analytics which places cookies on your computer.

We do this to find out things such as the number of visitors to the various parts of the site and how we can improve it. This information is collected in a way which does not personally identify anyone. We do not make any attempt to find out the identities of visitors to our website. We will not associate any data gathered from this site with any personally identifying information from any source. Cookies are small text files that are placed on your computer by websites that you visit.

They are widely used in order to make websites work, work more efficiently, or enhance user experience as well as to provide information to the owners of the site. If the settings in your web browser are set to accept cookies it means that you consent to us using cookies for the above purpose. If cookies aren't enabled on your computer, it will mean that your shopping experience on our website will be limited to browsing and you won't be able to add products to your basket and buy them.

We do not use cookies to pass information to any third party or collect any personal information, such as name, address and credit/debit card details.

Camber & Kernz uses BigCommerce (www.bigcommerce.com) as there website ecommerce platform, they process your data within the e-commerce platform. These privacy practices apply to the Camber & Kernz website and related BigCommerce websites, pages, applications, and mobile applications (collectively, the "Site").

BigCommerce – Data Processor Ultimately, the GDPR specifies that every business is responsible for maintaining compliance. Our commitment to merchants is that we will provide the means to integrate securely and help you make an informed decision. BigCommerce participates in the EU - U.S Privacy Shield framework, as all there servers are based in the United States. To learn more about the EU - US Privacy Shield program, and to view BigCommerce’s certification, please visit the U.S. Department of Commerce sit at https://www.privacyshield.gov/.

Information BigCommerce Collects BigCommerce collects information to provide a more efficient service to all our users. We collect information in the following ways: Information you give us. For example, when you interact with our Site by making a purchase or subscribing to an email list, we can ask for information including the following; personal information, like your first and last name, company name, email address, postal address, phone number, and credit card number.

We also collect passwords, password hints, and similar security information used for authentication and account access. Information BigCommerce gets from your use of our services BigCommerce collects data about how you and your device interact with BigCommerce and our services.

For example, we collect:

• Product use data. We collect data about the features you use, the items you purchase, and the web pages you visit.

• Device data. We collect data about your device and the network you use to connect to our products. It includes data about the operating systems and other software installed on your device. It may include IP address, device identifiers (such as the IMEI number for phones), regional and language settings.

• Error reports and performance data. We collect data regarding the performance of the products and any problems you experience with them. This data helps to diagnose problems in the services you use, and to improve our service and provide solutions.

• Depending on your service and settings, error reports can include data such as the type or severity of the problem, details of the software or hardware related to an error, contents of files you were using when an error occurred, and data about other software on your device.

• Support Data. When you engage BigCommerce for support, we collect data about you and your hardware, software, and other details related to the support incident. Such data includes contact or authentication data, the content of your chats and other communications with BigCommerce support.

The Purpose for which Information is collected BigCommerce uses the data we collect for two basic purposes, described in more detail below:

(1) to operate our business and provide (including improving and personalizing) the services we offer,

(2) to send communications, including promotional communications. Providing and Improving Our Services. We use data to carry out your transaction and to provide our services to you.

We also use data to diagnose service problems, troubleshoot issues, and provide other customer care and support services. We use data collected to continually improve our services, including adding new features or capabilities, such as using error reports to improve security features and determining what new features to prioritize.

Data is also used to develop aggregate analysis and business intelligence that enable us to operate, protect, make informed decisions, and report on the performance of our business. Communications. We use data we collect to deliver and personalize our communications with you. For example, we may contact you by email or other means to inform you when a subscription is ending, let you know when security updates are available, remind you about items left in your online shopping cart, update you or inquire about a service or repair request, invite you to participate in a survey, or tell you that you need to take action to keep your account active.

Additionally, you can sign up for email subscriptions and choose whether you wish to receive promotional communications from BigCommerce by email, SMS, physical mail, and telephone. For information about managing email subscriptions and promotional communications, please visit the http://grow.bigcommerce.com/manage-youremail-preferences.html.

Reasons we share personal data, we may share your personal data with your consent or as necessary to provide our services. When you provide payment data to make a purchase, we will share payment data with banks and other entities that process payment transactions or provide other financial services, and for fraud prevention and credit risk reduction.

In addition, we share personal data among BigCommerce-controlled affiliates and subsidiaries. BigCommerce may use from time to time a limited number of third-party service providers, contractors, and other businesses to assist us in providing our solutions to our customers or for the purposes described in this statement. In such cases, these companies must abide by our data privacy and security requirements and are not allowed to use personal data they receive from us for any other purpose. We may also disclose personal data as part of a corporate transaction such as a merger or sale of assets. Compliance; Protection.

We will access, transfer, disclose, and preserve personal data, including your content when we have a good faith belief that doing so is necessary to:

1. comply with applicable law or respond to valid legal process, including from law enforcement or other government agencies;

2. protect our customers, for example to prevent spam or attempts to defraud users of our products, or to help prevent the loss of life or serious injury of anyone;

3. operate and maintain the security of our products, including to prevent or stop an attack on our computer systems or networks;

4. protect the rights or property of BigCommerce, including enforcing the terms governing the use of the services.

Accountability for Onward Transfer If BigCommerce discloses Personal Data covered by this Policy to a non-agent third party, it will do so consistent with any notice provided to data subjects and any choice they have exercised regarding such disclosure. BigCommerce will only disclose Personal Data to third party agents that have given us contractual assurances that they will provide at least the same level of privacy protection as is required by the principles underlying the Privacy Shield (the “Principles”) and that they will process Personal Data for limited and specific purposes consistent with any consent provided by the individual.

If BigCommerce has knowledge that a third party to which it has disclosed Personal Data covered by this Policy is processing such Personal Data in a way that is contrary to this Policy and/or the Principles, BigCommerce will take reasonable steps to prevent or stop such processing. In such case, the third-party is liable for damages unless it is proven that BigCommerce is responsible for the event giving rise to the violation. Accessing and Updating Your Personal Information Whenever you use our services, we aim to provide you with access to your personal information. If that information is wrong, we strive to give you ways to update it quickly or to delete it — unless we have to keep that information for legitimate business or legal purposes. When updating your personal information, we may ask you to verify your identity before we can act on your request.

We may reject requests that are unreasonably repetitive, require disproportionate technical effort (for example, developing a new system or fundamentally changing an existing practice), risk the privacy of others, or would be extremely impractical (for instance, requests concerning information residing on backup systems).

We aim to maintain our services in a manner that protects information from accidental or malicious destruction. Because of this, after you delete information from our services, we may not immediately delete residual copies from our active servers and may not remove information from our backup systems. Transparency and Choice People have different privacy concerns. Our goal is to be clear about what information we collect, so that you can make meaningful choices about how it is used.

For example, our customers can:

• Review and control certain types of information tied to your BigCommerce Account by using the BigCommerce control panel.

• Control who you share information with through your BigCommerce Account.

• Take information associated with your BigCommerce Account out of many of our services.

You may also set your browser to block all cookies, including cookies associated with our services, or to indicate when a cookie is being set by us. Security of Personal Data BigCommerce is committed to protecting the security of your personal data. We use a variety of security technologies and procedures to help protect your personal data from unauthorized access, use or disclosure. When we transmit highly confidential data (such as a credit card number or password) over the Internet, we protect it through the use of encryption.

Enforcement; Recourse Inquiries and complaints relating to BigCommerce treatment of Personal Data and its compliance with the Principles may be directed to: privacy@bigcommerce.com or BigCommerce, Inc. 11305 Four Points Austin, TX 78726

Attention: General Counsel BigCommerce will respond to any such inquiries or complaints within forty-five (45) days. If BigCommerce fails to respond or its response is insufficient or does not address the concern, BigCommerce has registered with the Direct Marketing Association to provide independent third party dispute resolution at no cost to the complaining party. To contact Direct Marketing Association and/or learn more about the company’s dispute resolution services, including instructions for submitting a complaint, please visit https://thedma.org/shield-complaint-form/ or www.thedma.org/privacy-shield-safe-harbor-forconsumers/.

Complaining parties may also, in absence of a resolution by BigCommerce and Direct Marketing Association, seek to engage in binding arbitration through the Privacy Shield Panel. DMA Contact Information: Privacy Shield Line Direct Marketing Association 1333 Broadway, Suite 301 New York, New York 10018 BigCommerce also commits to periodically reviewing and verifying the accuracy of this Policy and the company’s compliance with the Principles, and remedying issues identified. All employees of BigCommerce that have access to Personal Data covered by this Policy in the U.S. are responsible for conducting themselves in accordance with this Policy. Failure of a BigCommerce employee to comply with this Policy may result in disciplinary action. BigCommerce is subject to the investigatory and enforcement powers of the Federal Trade Commission (FTC).

To provide our customers at Camber & Kernz with an effective credit or debit card service, we use Stripe as our service provider. To ensure transparency, we have provided you with the current privacy policy from Stripe below;

Welcome to Stripe! Privacy Policy — Worldwide Last updated: October 12, 2017

Privacy and online safety are important to Stripe. We offer a software platform and services for helping run an internet business. We collect data about businesses and their customers (“Data”) when they use the platform, the services, and our websites (collectively, “Services”). This privacy policy describes how we collect, use and disclose Data. In this privacy policy, we sometimes refer to “You”. “You” may be a visitor to one of our websites, a user of one or more of our Services (“User”), or a customer of a User (“Customer”). We’ll do our best to clarify who we are referring to at various points in the policy.

This policy does not apply to third-party websites, products, or services even if they link to our Services, and You should consider the privacy practices of those third-parties carefully. If You disagree with the practices described in this policy, You should (a) take the necessary steps to remove cookies from Your computer after leaving our website, and (b) discontinue Your use of our Services.

Finally, we have also put together a Cookie Policy that describes in detail how we use cookies and similar technologies.

1. Overview The Data we collect depends on how our Services are used. Sometimes we receive Data directly, such as when a Stripe account is created, test transactions are submitted through our website, the Stripe Checkout form is used, or we receive an email. Other times, we get Data by recording interactions with our Services by, for example, using technologies like cookies and web beacons. We also get Data from third parties, like our financial partners or identity verification services. The collection and use of data from a variety of sources is essential to our ability to provide our Services – and to help keep the Services safe. Data is critical in helping us to increase the safety of Your online payments, and reduce the risk of fraud, money laundering and other harmful activity.

2. Data We Collect a. Personal Data. We call Data that identifies, or that could reasonably be used to identify, You as an individual as “Personal Data”. We collect Personal Data in different ways. For example, we collect Personal Data when a business registers for a Stripe account, a Customer makes payments or conducts transactions through a User’s website or application, a person responds to Stripe emails or surveys, or when a Customer uses the “Remember Me” feature of Stripe Checkout. We also receive Personal Data from other sources, such as our partners, financial service providers, identity verification services, and publicly available sources. Personal Data does not include Data that has been aggregated or made anonymous such that it can no longer be reasonably associated with a specific person.

The Personal Data that we may collect includes:

• Contact details, such as name, postal address, telephone number, email address;

• Financial and transaction Data, such as credit or debit card number, and bank account information; and

• Other Personal Data, such as date of birth, SSN or EIN. b. Other Data. We call Data other than Personal Data “Other Data”. We collect Other Data through a variety of sources. One of our sources for Other Data is cookies and other technologies that record Data about the use of our websites, websites that implement our Services, and the use of our Services generally. Other Data that we may collect include:

• Browser and device data, such as IP address, device type, operating system and Internet browser type, screen resolution, operating system name and version, device manufacturer and model, language, plug-ins, add-ons and the version of the Services You are using;

• Transaction data, such as purchases, purchase amount, date of purchase, and payment method;

• Cookie and tracking technology data, such as time spent on the Services, pages visited, language preferences, and other anonymous traffic data; and

• Company data, such as a company’s legal structure, product and service offerings, jurisdiction, company records, and information submitted through the Stripe Atlas service.

3. How We Use Data a. Personal Data. We and our service providers use Personal Data to:

(i) provide the Services;

(ii) detect and prevent fraud;

(iii) mitigate financial loss or other harm to Users, Customers, and Stripe; and

(iv) promote, analyze and improve our products, systems, and tools. Examples of how we may use Personal Data include:

• To verify an identity for compliance purposes;

• To evaluate an application to use our Services;

• To conduct manual or systematic monitoring for fraud and other harmful activity;

• To respond to inquiries, send service notices and provide customer support;

• To process a payment with Stripe Checkout, communicate regarding a payment, and provide related customer service;

• For audits, regulatory purposes, and compliance with industry standards;

• To develop new products;

• To send marketing communications;

• To improve or modify our Services; and

• To conduct aggregate analysis and develop business intelligence that enable us to operate, protect, make informed decisions, and report on the performance of, our business. b. Other Data. We may use Other Data for a range of different purposes, provided we comply with applicable law and our contractual commitments. In some countries (for example, European Economic Area countries), local legal regimes may require us to treat some or all of Other Data as “personal data” under applicable data protection laws. Where this is the case, we will process Other Data only for the same purposes as Personal Data under this privacy policy.

4. How We Disclose Data Stripe does not sell or rent Personal Data to marketers or unaffiliated third parties. We share Your Personal Data with trusted third parties, including: a. To Stripe Affiliates. We share Data with entities worldwide that we control, are controlled by us, or are under our common control, to provide our Services. Stripe, Inc. is the party responsible for overall management and use of the Data by these affiliated parties; b. To Stripe Service Providers. We share Data with service providers who help us provide the Services. Service providers help us with things like payment processing (i.e., banks, credit bureaus, payment method providers), website hosting, data analysis, information technology and related infrastructure, customer service, email delivery, Stripe Atlas, and auditing; c. To Our Users. We share Data with Users (such as merchants and application providers) as necessary to process payments or provide the Services. For example, we share Data with Users about purchases made by their Customers through the Stripe payment processing services; d. To Authorized Third Parties. We share data with parties directly authorized by a User to receive Data, such as when a User authorizes a third party application provider to access the User’s Stripe account using Stripe Connect. The use of Data by an authorized third party is subject to the third party’s privacy policy; e. To Third Parties. We will share Data with third parties in the event of any reorganization, merger, sale, joint venture, assignment, transfer or other disposition of all or any portion of our business, assets or stock (including in connection with any bankruptcy or similar proceedings); and f. Safety, Legal Purposes and Law Enforcement. We use and disclose Data as we believe necessary: (i) under applicable law, or payment method rules; (ii) to enforce our terms and conditions; (iii) to protect our rights, privacy, safety or property, and/or that of our affiliates, You or others; and (iv) to respond to requests from courts, law enforcement agencies, regulatory agencies, and other public and government authorities, which may include authorities outside Your country of residence.

5. Security We use reasonable organisational, technical and administrative measures to protect Personal Data within our organisation. Unfortunately, no data transmission or storage system can be guaranteed to be 100% secure. If You have reason to believe that Your interaction with us is no longer secure (for example, if You feel that the security of Your account has been compromised), please contact us immediately.

6. Advertising We may use third-party advertising companies to serve advertisements regarding goods and services that may be of interest to You when You access our websites, based on Data relating to Your access to and use of our websites on any of Your devices, as well as Data received from third parties. To do so, these companies may place or recognize a unique cookie, or similar tracking technology, on Your browser (including the use of pixel tags). They may also use these technologies, along with data they collect about Your online use, to recognize You across the devices You use, such as a mobile phone and a laptop, and to make decisions about the advertisements You see. If You would like more information about this practice, and to learn how to opt out of behavioural advertising delivered by Network Advertising Initiative member companies in desktop and mobile browsers on the particular device on which You are accessing this Privacy Policy, please visit the Network Advertising Initiative and Digital Advertising Alliance. You may download the AppChoices app to opt out in mobile apps. In order to understand and improve the effectiveness of our advertising, we may also use web beacons, cookies, and other technologies to identify the fact that You have visited our website or seen one of our advertisements, and we may provide that Data to one or more third party advertising networks. The Data we provide may include the time and date of Your visit to our website, pages viewed, links clicked and other information that does not disclose Your ‘real world’ identity. Those advertising networks may recognize the web beacon or cookie associated with Your visit to our website when You visit other websites on which they serve advertising, and they may make decisions about the advertisements You see based on it. We may choose to work with Google AdWords, Doubleclick, AdRoll or other advertising networks. Each of these companies has its own privacy policy, which we encourage You to review. For more information about advertising and tracking online, visit the Network Advertising Initiative. This website allows consumers to “opt out” of the behavioural advertising delivered by member companies. To learn more about the cookies that may be served through our Services, and how You can control our use of cookies, please see our Cookie Policy. At present, there is no industry standard for recognizing Do Not Track browser signals, so we do not respond to them.

7. Choice and Access You have choices regarding our use and disclosure of Your Personal Data: a. Opting out of receiving electronic communications from us. If You no longer want to receive marketing-related emails from us on a going-forward basis, You may opt-out via the unsubscribe link included in such emails. We will try to comply with Your request(s) as soon as reasonably practicable. Please note that if You opt-out of receiving marketing-related emails from us, we may still send You important administrative messages that are required to provide You with our Services. b. How You can access or change Your Personal Data. If You would like to review, correct, or update Personal Data that You have previously disclosed to us, You may do so by signing in to Your Stripe account or by contacting us. If emailing us Your request, please make clear in the email what Personal Data You would like to have changed. For Your protection, we may only implement requests with respect to the Personal Data associated with the particular email address that You use to send us Your request, and we may need to verify Your identity before implementing Your request. We will try to comply with Your request as soon as reasonably practicable.

8. Retention Period We will retain Personal Data for the period necessary to fulfil the purposes outlined in this Privacy Policy unless a longer retention period is required or permitted by law. Please note that we have a variety of obligations to retain the Data that You provide to us, including to ensure that transactions can be appropriately processed, settled, refunded or charged-back, to help identify fraud and to comply with anti-money laundering and other laws and rules that apply to us and to our financial service providers. Accordingly, even if You close Your Stripe Account, we will retain certain Data to meet our obligations. There may also be residual Data that will remain within our databases and other records, which will not be removed.

9. Use of Services by Minors The Services are not directed to individuals under the age of thirteen (13), and we request that they not provide Personal Data through the Services.

10. Jurisdiction and Cross-Border Transfer Our services are global and Data (including Personal Data) may be stored and processed in any country where we have operations or where we engage service providers, and we may transfer Data to countries outside of Your country of residence, including the United States, which may have data protection rules that are different from those of Your country. However, we will take measures to ensure that any such transfers comply with applicable data protection laws and that Your Data remains protected to the standards described in this privacy policy. In certain circumstances, courts, law enforcement agencies, regulatory agencies or security authorities in those other countries may be entitled to access Your Personal Data.

11. Privacy Shield Certification If You are located in the EEA or Switzerland, we comply with applicable laws to provide an adequate level of data protection for the transfer of Personal Data. Stripe is certified under the EU-U.S. and the Swiss-U.S. Privacy Shield Framework. For more, see Stripe’s Privacy Shield Policy.

12. Stripe as a Data Processor We may collect, use and disclose certain Personal Data about Customers when acting as the User’s service provider. Our Users are responsible for making sure that the Customer’s privacy rights are respected, including ensuring appropriate disclosures about third party data collection and use. To the extent that we are acting as a User’s data processor, we will process Personal Data in accordance with the terms of our agreement with the User and the User’s lawful instructions.

13. Updates to this Privacy Policy and Notifications We may change this Privacy Policy. The “Last updated” legend at the top of this Privacy Policy indicates when this Privacy Policy was last revised. Any changes are effective when we post the revised Privacy Policy on the Services. We may provide You with disclosures and alerts regarding the Privacy Policy or Personal Data collected by posting them on our website and, if You are a User, by contacting You through your Stripe Dashboard, email address and/or the physical address listed in Your Stripe account. You agree that electronic disclosures and notices have the same meaning and effect as if we had provided You with hard copy disclosures. Disclosures and notices in relation to this Privacy Policy or Personal Data shall be considered to be received by You within 24 hours of the time they are posted to our website or, in the case of Users, sent to through one of means listed in this paragraph.

14.Contact Us If You have any questions about this Privacy Policy, please contact us at privacy@stripe.com or at: Stripe, Inc. 185 Berry Street, Suite 550 San Francisco, CA 94107 Attention: Stripe Legal For EU individuals: The entity that provides Services in Europe is Stripe Payments Europe, Ltd., 1 Grand Canal Street Lower, Grand Canal Dock, Dublin. Sensitive Information. Because email communications are not always secure, please do not include credit card or other sensitive Data (such as racial or ethnic origin, political opinions, religion, health, or the like) in Your emails to us.

If you have any concerns with regards to the Privacy Policy from Stripe or have any further questions with regards to the service they provide and what they do with your personal data, then please do not hesitate to contact them directly on https://stripe.com/contact, as Camber & Kernz do not hold any financial or transactional information.

Please Contact Us, should you have any questions or queries about our Data Protection & Privacy Policy, and we shall try to help.

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