1. Definitions and Interpretation

In this Policy the following terms shall have the following meanings:

2. Scope of this Policy

This Policy applies only to the actions of Castle Creativity and Users with respect to this Website.  It does not extend to any websites that can be accessed from this Website including, but not limited to, any links provided to social media websites.

Collected Data

Without limitation, any of the following Data may be collected by this Website on occasion:

• [name;]
• [date of birth;]
• [gender;]
• [job title;]
• [profession;]
• [contact information such as email addresses and telephone numbers;]
• [demographic information such as post code, preferences and interests;]
• [financial information such as credit / debit card numbers;]
• [IP address (automatically collected);]
• [web browser type and version (automatically collected);]
• [operating system (automatically collected);]
• [a list of URLs starting with a referring site, your activity on this Website, and the site you exit to (automatically collected); and]

4. Data Use
   • Any personal Data you submit can be retained by Castle Creativity for six months.
   • Unless we are obliged or permitted by law to do so, and subject to Clause 5, your Data will not be disclosed to third parties. This [includes] OR [does not include]our affiliates and / or other companies.
   • All personal Data is stored securely in accordance with the principles of the GDPR.
   • Any or all of the above Data may be required by us from time to time in order to provide you with the best possible service and experience when using our Website. Specifically, Data may be used by us for the following reasons:
     • [internal record keeping;]
     • [improvement of our products / services;]
     • [transmission by email of promotional materials that may be of interest to you;]
     • [contact for market research purposes which may be done using email, telephone, fax or mail. Such information may be used to customise or update the Website.]

5. Third Party Websites and Services
   • Castle Creativity may, from time to time, employ the services of other parties for dealing with matters that may include, but are not limited to, payment processing, delivery of purchased items, search engine facilities, advertising and marketing. The providers of such services [do not]have access to certain personal Data provided by Users of this Website.
   • [Any Data used by such parties is used only to the extent required by them to perform the services that Castle Creativity requests. Any use for other purposes is strictly prohibited.  Furthermore, any Data that is processed by third parties shall be processed within the terms of this Policy and in accordance with the GDPR.]
6. Links to Other Websites

This Website may, from time to time, provide links to other websites.  Castle Creativity has no control over such websites and is in no way responsible for the content thereof.  This Policy does not extend to your use of such websites.  Users are advised to read the privacy policy or statement of other websites prior to using them.

7. Changes of Business Ownership and Control
   • Castle Creativity 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 Castle Creativity. Data provided by Users will, where it is relevant to any part of our business so 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 the Data for the purposes for which it was originally supplied to us.
   • In the event that any Data submitted by Users is to be transferred in such a manner, you will [not]be contacted in advance and informed of the changes. [When contacted you will [not]be given the choice to have your Data deleted or withheld from the new owner or controller.]
8. Controlling Use of Your Data
   • Wherever you are required to submit Data, you will be given options to restrict our use of that Data. This may include the following:
     • use of Data for direct marketing purposes; and
     • sharing Data with third parties.

9. Your Right to Withhold Information
   • You may access [certain areas of]the Website without providing any Data at all. [However, to use all features and functions available on the Website you may be required to submit certain Data.]
   • You may restrict your internet browser’s use of Cookies. For more information see Clause 12.

Accessing your own Data
You have the right to ask for a copy of any of your personal Data held by Castle Creativity (where such data is held) on payment of a small fee which will not exceed £50.

11. Security
    • Data security is of great importance to Castle Creativity and to protect your Data we have put in place suitable physical, electronic and managerial procedures to safeguard and secure Data collected via this Website.
12. Cookies
    • This Website may place and access certain Cookies on your computer. Castle Creativity uses Cookies to improve your experience of using the Website and to improve our range of [products]AND/OR[services].  Castle Creativity has carefully chosen these Cookies and has taken steps to ensure that your privacy is protected and respected at all times.
    • All Cookies used by this Website are used in accordance with current UK and EU Cookie Law.
    • Before the Website places [any]Cookies on your computer, subject to [sub-Clause 12.4] AND/OR [sub-Clause 12.7], you will be presented with a message bar requesting your consent to set those Cookies. By giving your consent to the placing of Cookies you are enabling Castle Creativity to provide the best possible experience and service to you.  You may, if you wish, deny consent to the placing of Cookies; however certain features of the Website may not function fully or as intended.
    • [Certain features of the Website depend upon Cookies to function. UK and EU Cookie Law deems these Cookies to be “strictly necessary”.  These Cookies are shown below.  Your consent will not be sought to place these Cookies.  You may still block these cookies by changing your internet browser’s settings as detailed below.]
    • This Website places the following Cookies:

Do we need to list the cookies used? Google Analytucs uses the _ga cookie. This stores one valuable piece of information: your Client ID. For a full breakdown of cookies collected by Google Analytics please follow this link: https://developers.google.com/analytics/devguides/collection/analyticsjs/cookie-usage

• This Website uses analytics services provided by Google Analytics. Website analytics refers to a set of tools used to collect and analyse usage statistics, enabling us to better understand how Users use the Website.  This, in turn, enables us to improve the Website and the [products]AND/OR[services]offered through it.  You do not have to allow us to use these Cookies, as detailed below, however whilst our use of them does not pose any risk to your privacy or your safe use of the Website it does enable us to continually improve our business.
• The analytics services used by this Website use Cookies to gather the required information. [Certain of these Cookies may be placed immediately when you decide to visit the Website and it may not be possible to obtain your prior consent.  You may remove these Cookies and prevent future use of them by following the steps set out below.]
• The analytics services used by this Website use the following Cookies:

• 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.  By default, most internet browsers accept Cookies but this can be changed.  For further details, please consult the help menu in your internet browser.
• You can choose to delete Cookies at any time however you may lose any information that enables you to access the Website more quickly and efficiently including, but not limited to, personalisation settings.
• It is recommended that you ensure that your internet browser is up-to-date and that you consult the help and guidance provided by the developer of your internet browser if you are unsure about adjusting your privacy settings.

13. Changes to this Policy

Castle Creativity reserves the right to change this Policy as we may deem necessary from time to time or as may be required by law.  Any changes will be immediately posted on the Website and you are deemed to have accepted the terms of the Policy on your first use of the Website following the alterations.