Website Privacy and Cookies Policy December 2023

Wholesale Gifts Tomorrow
How We Use Your Information:
Website Privacy & Cookies Policy Business-to-Business
December 2023

Background:
The www.wholesalegiftstomorrow.co.uk Site is owned and operated by CKB Ltd ®. CKB Ltd ® and its group brands including Lanyards Tomorrow ®, Gifts Tomorrow ™ and Bar Amigos ® understand that your privacy is important to you and that you care about how your personal data is used and shared online. We respect and value the privacy of everyone who visits Our Site and will only collect and use personal data in ways that are described here, and in a manner that is consistent with Our obligations and individual’s rights under the law.

Please read this Website Privacy and Cookies Policy: Business-to-Business carefully and ensure that you understand it. If you do not accept and agree with this Policy, you must stop using Our Site immediately.

1. Definitions and Interpretation
In this Policy, the following terms shall have the following meanings:

2. Information About Us
Our Site, www.wholesalegiftstomorrow.co.uk, is owned and operated by CKB Ltd ®, a limited company registered in England under 07123102, whose registered address is St. Christopher's House, Ridge Road, Letchworth Garden City, Hertfordshire, SG6 1PT, England and whose main trading address is Unit 5, Business Centre East, Fifth Avenue, Letchworth Garden City, Hertfordshire, SG6 2TS. We also operate under our group company brands of Gifts Tomorrow™ on www.giftstomorrow.co.uk and Lanyards Tomorrow ® on www.lanyardstomorrow.co.uk In addition, we operate under our CKB Ltd ® and Bar Amigos ® brands. www.ckbltd.com acts as a portal only for access to our associated company transactional websites of www.giftstomorrow.co.uk and www.lanyardstomorrow.co.uk
2.1 Our VAT number is 991324508.
2.2 Our Data Protection Officer is the position holder of Company Secretary, and can be contacted at Unit 5, Business Centre East, Fifth Avenue, Letchworth Garden City, Hertfordshire, SG6 2TS.
2.3 If you are in the European Union, you may address privacy-related inquiries to our EU Representative pursuant to Article 27 EU-GDPR:

EU-REP.Global GmbH
www.eu-rep.global
Attn: CKB Ltd.
Hopfenstr. 1d, 24114 Kiel, Germany
[email protected]

3. What Does This Policy Cover?
3.1 This Policy applies only to your use of Our Site and subsequent completion of a company registration form for Goods ordering purposes, for which you are required to confirm that you are at least 18 years of age. Our Site may contain links to other websites. Please note that We have no control over how your data is collected, stored, or used by other websites and We advise you to check the privacy policies of any such websites before providing any data to them.

4. Data Subject Rights
4.1 Data subjects have the following rights under the UK-GDPR, which this Policy and Our use of personal data have been designed to uphold. This also relates to an individual in business where they are personally identifiable:
4.1.1 The right to be informed about Our collection and use of personal data;
4.1.2 The right of access to the personal data We hold about you (see Part 12);
4.1.3 The right to rectification if any personal data We hold about you is inaccurate or incomplete (please contact Us using the details in Part 14);
4.1.4 The right to be forgotten – i.e. the right to ask Us to delete any personal data We hold about you (We only hold your personal data for a certain time period, as explained in Part 6 but if you would like Us to delete it sooner, please contact Us using the details in Part 14);
4.1.5 The right to restrict (i.e. prevent) the processing of your personal data;
4.1.6 The right to data portability (obtaining a copy of your personal data to re-use with another service or organisation);
4.1.7 The right to object to Us using your personal data for particular purposes including in sending you direct marketing;
4.1.8 The right to withdraw consent. This means that if the Company is relying on your consent as the legal basis for using your personal data, you are free to withdraw that consent at any time; and
4.1.9 Rights with respect to automated decision making and profiling (including your right to object to this).
Please note that the Company may undertake marketing activity to promote products on a business to business basis based on Our legitimate interests and in accordance with Our marketing strategy. Such marketing strategy is not specifically based on your use of Our Site. You may also have consented to us contacting you in this way via a company registration form.

Any profiling activity undertaken by the Company is done to analyse visitor behaviour on Our Site which may help inform Our marketing strategy. This is done using an IP address which provides details of where a visitor has come from on the internet and how long a visitor spends on each of the Company web pages. Cookie preferences can be altered at any time to cease profiling activity. For more information, please refer to the Company Data Protection Policy located on Our Site.

4.2 If you have any cause for complaint about Our use of your personal data, please contact Us using the details provided in Part 14 and We will do Our best to solve the problem for you. If We are unable to help, you also have the right to lodge a complaint with the UK’s supervisory authority, the Information Commissioner’s Office.
4.3 For further information about your rights, please contact the Information Commissioner’s Office or your local Citizens Advice Bureau.

5. What Data Do We Collect?
Depending upon your use of Our Site, We may collect some or all of the following personal and non-personal data (please also see Part 13 on Our use of Cookies and similar technologies):
5.1 name*;
5.2 business/ company name*;
5.3 contact information such as email addresses, postal addresses and telephone numbers*; and
5.4 IP address;

*on a company registration form provided separate to Our Site following access to Our Site

6 How Do We Use Your Data?
6.1 All personal data is processed and stored securely, for no longer than is necessary in light of the reason(s) for which it was first collected. We will comply with Our obligations and safeguard your rights under the UK-GDPR at all times. For more details on security see Part 7, below.
6.2 Our use of personal data will always have a lawful basis, which will be because you have consented to Our use of your personal data, or because it is contractual/ legally required, or in Our legitimate interests. Specifically, We may use your data for the following purposes:
6.2.1 Providing and managing your registration following you accessing Our electronic Goods catalogue available on Our Site (consent);
6.2.2 Providing and managing your access to Our Site (legitimate interests);
6.2.3 Personalising and tailoring your experience on Our Site (legitimate interests/ consent options);
6.2.4 Supplying Our products to you once you place an Order following accessing Our electronic Goods catalogue available on Our Site – i.e. fulfilling an order (please note that We require certain data in order to enter into a contract with you) (contractual);
6.2.5 Personalising and tailoring Our products for you including for the purpose of order fulfilment – for example, to fulfil a personalised order such as for lanyards. This may include you dealing directly with a third-party supplier for a product proof and delivery of your order (contractual);
6.2.6 Replying to emails and communications from you (contractual);
6.2.7 Analysing your use of Our Site to enable Us to continually improve Our Site and your user experience (including personalising and tailoring Our product adverts on social media, for example and providing functionality to enable users to share/ like product updates on social media) (legitimate interests/ consent options); and
6.2.8 As is required under the law for financial accounting purposes, for example (financial/ legally required).
Some of the aforementioned may be managed separate to Our Site; for example when We use third party suppliers for Our Site functionality.
6.3 If We have your contact details, We may from time to time send you important notices by email based on contractual necessity or our legitimate business interests.  Such notices may relate to matters including, but not limited to service changes, changes to our Terms of Use: Business-to-Business, and changes to Our Terms of Sale: Business-to-Business. We will never send marketing communications of any kind to a named individual without express consent. Such marketing communications would relate to new product offerings.  If you do give consent, you may opt out at any time.  The Company may issue marketing communications to promote products to businesses based on Our legitimate interests and in accordance with Our marketing strategy.
6.4 Third parties may be utilised by the Company including social media platforms. Such third parties may engage in what is known as “behavioural advertising”; advertising which is tailored to your preferences, based on your activity. Your activity is monitored using Cookies, as detailed below in Part 13. You can control and limit your data used in this way by adjusting your web browser’s privacy settings. Please note that We do not control the activities of such advertisers, nor the information they collect and use which is based on the third party’s filters. Limiting the use of your data in this way will not necessarily remove the advertising, but it may make it less relevant to your interests and activities.
6.5 Third parties content may appear on Our Site. Such parties may use third party Cookies, as detailed below in Part 13. Please refer to Part 13 for more information on controlling Cookies. Please note that We do not control the activities of such third parties, nor the data they collect and use and advise you to check the privacy policies of any such third parties.
6.6 You have the right to withdraw your consent to Us using your personal data at any time, and to request that We delete it.
6.7 We do not keep your personal data for any longer than is necessary in light of the reason(s) for which it was first collected. Data will therefore be retained for the following periods (or its retention will be determined on the following bases):
6.7.1 For the time period required for legal and financial accounting purposes; and/ or
6.7.2 Because you have consented to Our use of your personal data (e.g. by completing a company registration form). We will retain your data until you unsubscribe. Should you decide you no longer wish to be registered with us, please e-mail [email protected] confirming this and arrangements will be made for registration removal.

7 How and Where Do We Store Your Data?
7.1 We only keep your personal data for as long as We need to and/ or are required to and/ or have your permission to in order to use it as described above in Part 6.
7.2 The UK has issued regulations confirming that a country ensures an adequate level of protection (referred to as ‘adequacy decisions’ or ‘adequacy regulations’) in respect of data transfers outside of the UK following Brexit. Since 1st January 2021, transfers of personal data from the UK to the European Economic Area (“the EEA”) (the EEA consists of all EU member states, plus Norway, Iceland, and Liechtenstein) continue to be permitted. Pre-existing EU Commission adequacy decisions in effect pre-Brexit as at 31/12/2020 are also recognised, subject to ongoing review by the UK Government.
7.3 Some or all of your data may be stored outside of the EEA. You are deemed to accept and agree to this by using Our Site and submitting information to Us. If We do store data outside the EEA, We will take all reasonable steps to ensure that your data is treated as safely and securely as it would be within the UK and under data protection regulations including:
7.3.1 Approaching any relevant partner/ supplier organisations for confirmation that their data storage processes are acceptable (see Part 8); and
7.3.2 putting in place suitable physical, electronic and managerial procedures to safeguard and secure data collected through Our Site.
7.4 Data security is very important to Us, and to protect your data We have taken suitable measures to safeguard and secure data collected through our transactional sites including Secure Sockets Layer Software (SSL) Certificate to protect your personal information. The www.wholesalegiftstomorrow.co.uk site is non transactional and any orders are placed separately.
7.5 Notwithstanding the security measures that We take, it is important to remember that the transmission of data via the internet may not be completely secure and that you are advised to take suitable precautions when transmitting to Us data via the internet.

8 Do We Share Your Data?
8.1 We may share your data within our Company group of brands which includes CKB Ltd ®, Gifts Tomorrow ™, Lanyards Tomorrow ®, and Bar Amigos ®.
8.2 We may contract with third parties to supply services to you on Our behalf. These include delivery of goods and may include suppliers for personalised orders (e.g. proof approval)
8.3 In some cases, the third parties may require access to some or all of your data. Where any of your data is required for such a purpose, We will take all reasonable steps to ensure that your data will be handled safely, securely, and in accordance with your rights, Our obligations, and the obligations of the third party under the law.
8.4 We may compile statistics about the use of Our Site. All such data will be anonymised and will not include any personally identifying data, or any anonymised data that can be combined with other data and used to identify you. We may from time to time share such data with third parties such as prospective investors, affiliates, partners, and advertisers. Data will only be shared and used within the bounds of the law.
8.5 We may sometimes use third party data processors that are located outside of the European Economic Area (“the EEA”) (The EEA consists of all EU member states, plus Norway, Iceland, and Liechtenstein). Where any personal data is transferred outside the EEA, We will take all reasonable steps to ensure that your data is treated as safely and securely as it would be within the UK and under the data protection regulations including:
8.5.1 Approaching any relevant partner/ supplier organisations for confirmation that their data storage and processing activities are acceptable.
8.6 In certain circumstances, We may be legally required to share certain data held by Us, which may include your personal data, for example, where We are involved in legal proceedings, where We are complying with legal requirements, a court order, or a governmental authority. We do not require any further consent from you in order to share your data in such circumstances and will comply as required with any legally binding request that is made of Us.

9 What Happens If Our Business Changes Hands?
9.1 We may, from time to time, expand or reduce Our business and this may involve the sale and/or the transfer of control of all or part of Our business. Any personal data that you have provided will, where it is relevant to any part of Our business that is being transferred, be transferred along with that part and the new owner or newly controlling party will, under the terms of this Policy, be permitted to use that data only for the same purposes for which it was originally collected by Us.
9.2 In the event that any of your data is to be transferred in such a manner, you will be contacted in advance and informed of the changes if you have consented to receiving information communications or if we deem this a necessary communication under Our legitimate interests.

10 How Can You Control Your Data?
10.1 In addition to your rights under the UK-GDPR, set out in Part 4, when you submit personal data via Our Site, you will be given options to restrict Our use of your data (e.g. via accessing the Cookie consent function).

11 Your Right to Withhold Information
11.1 You may access certain areas of Our Site without providing any data at all subject to Parts 13.1 and 13.9.
11.2 You may restrict Our use of Cookies. For more information, see Part 13.

12 How Can You Access Your Data?
12.1 You have the right to ask for a copy of any of your personal data held by Us (where such data is held). Under the UK-GDPR, no fee is payable, and We will provide any and all information in response to your request free of charge. Please contact Us for more details using the contact details below in Part 14.

13 Our Use of Cookies
13.1 A cookie is a small file, typically of letters and numbers, downloaded on to a device when the user accesses certain websites. Cookies allow a website to recognise a user’s device and provide enhanced website functionality for the user as a result. Cookies are generated when you first visit Our Site. You can decline consent for such cookies once on our Site. However, prior to this, acceptance of such cookies is deemed to occur via implied consent as you visited Our Site and the consent option is presented to you once on Our Site (for those landing cookies). We also consider We have a legitimate interest to gather this landing data to inform the success of our investment in online advertising, for example, as a small family run business.
13.2 Cookies can be session cookies or persistent cookies. Session cookies only last for the duration of your online session and disappear from your device when you close your browser. Persistent cookies, however, stay on your device after the browser has been closed and last for the period of time specified in the cookie. Furthermore, persistent cookies are activated each time you visit the site that the cookie was generated by.
13.3 Use of Our Site may place Cookies on your computer or device.
13.4 By using Our Site you may receive certain third party Cookies on your computer or device. Third party Cookies are those placed by websites, services, and/or parties other than Us. Third party Cookies are used on Our Site for the cookie consent function tool, for example. For more details, please refer to Part 6, above, and to Part 13.6 below. These Cookies are not integral to the functioning of Our Site and your use and experience of Our Site will not be impaired by refusing consent to them.
13.5 All Cookies used by and on Our Site are used in accordance with current Cookie Law.
13.6 Before Cookies are placed on your computer or device, you will be shown a message requesting your consent to set those Cookies (apart from the landing cookies as outlined in 13.1). By giving your consent to the placing of Cookies you are enabling Us to provide the best possible experience and service to you. You may, if you wish, deny consent to the placing of Cookies. You may also later go back into the Cookie consent options after initially consenting and change your consent preferences.
13.7 No features of Our Site depend on Cookies to function and, as such, there are no “strictly necessary” Cookies. There are also no “functional” Cookies.
13.8 The following third-party Cookies may be placed on your computer or device:

13.9 In addition to the controls that We provide which are accessed via the Cookie consent function, you can choose to enable or disable Cookies in your internet browser. Most internet browsers also enable you to choose whether you wish to disable all cookies or only third party Cookies. For further details, please consult the help menu in your internet browser or the documentation that came with your device.
13.10 You can choose to delete Cookies on your computer or device at any time, however you may lose any information that enables you to access Our Site more quickly and efficiently.
13.11 Our Site currently primarily functions as a portal for accessing Our electronic Goods catalogue and is non transactional.
13.12 It is recommended that you keep your internet browser and operating system up-to-date and that you consult the help and guidance provided by the developer of your internet browser and manufacturer of your computer or device if you are unsure about adjusting your privacy settings.

14. Contacting Us
14.1 If you have any questions about Our Site, please contact Us by email at [email protected], by telephone on +44 (0)1462 682020, or by post at Unit 5, Business Centre East, Fifth Avenue, Letchworth Garden City, Hertfordshire, SG6 2TS. Please ensure that your query is clear, particularly if it is a request for information about the data We hold about you (as under Part 12, above).
14.2 For business-to-business sales related queries please contact us by e-mail at [email protected] , by telephone on +44 (0) 1446 731246, or by post at CKB Ltd (Gifts Tomorrow), Cardiff House, Cardiff Road, Vale of Glamorgan, CF63 2AW.

15. Changes to Our Website Privacy and Cookies Policy
15.1 We may change this Policy from time to time (for example, if the law changes). Any changes will be immediately posted on Our Site and you will be deemed to have accepted the terms of the Policy on your first use of Our Site following the alterations. We recommend that you check this page regularly to keep up-to-date.

16. Implementation of Policy
16.1 This Policy shall be deemed effective as of 1st December 2023. No part of this policy shall have retroactive effect and shall thus apply only to matters occurring on or after this date.

V13 Wholesale Gifts Tomorrow Website Privacy & Cookies Policy (B2B) - effective date 1st December 2023