Last modified: 3rd March 2020
Porcupine Collective C.I.C. respects your privacy and is committed to protecting it through its compliance with this policy. This policy describes the types of information we may collect from you or that you may provide when you visit www.porcupinecollective.com (including any content, functionality, digital products and services offered on or through the website, whether as a guest or a registered user), and our practices for collecting, using, maintaining, protecting and disclosing that information. As used herein, “Porcupine Collective” shall refer to the aforementioned website.
If you are not happy with any aspect of how we collect and use your data, you have the right to complain to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk).
It is important that the information we hold about you is accurate and up to date. Please let us know if at any time your personal information changes by emailing us at email@example.com.
2. What data do we collect about you, for what purpose and on what ground we process it
Personal data means any information capable of identifying an individual. It does not include anonymised data.
We may process certain types of personal data about you as follows:
· Communication Data that includes any communication that you send to us whether that be through the contact form on our website, through email, text, social media messaging, social media posting or any other communication that you send us. We process this data for the purposes of communicating with you, for record keeping and for the establishment, pursuance or defence of legal claims. Our lawful ground for this processing is our legitimate interests which in this case are to reply to communications sent to us, to keep records and to establish, pursue or defend legal claims.
· Customer Data that includes data relating to any purchases of goods and/or services such as your name, title, billing address, delivery address email address, phone number, contact details, purchase details and your card details. We process this data to supply the goods and/or services you have purchased and to keep records of such transactions. Our lawful ground for this processing is the performance of a contract between you and us and/or taking steps at your request to enter into such a contract.
· User Data that includes data about how you use Porcupine Collectiveand any online services or digital products together with any data that you post for publication on our website or through other online services. We process this data to operate Porcupine Collective and ensure relevant content is provided to you, to ensure the security of our website, to maintain back- ups of our website and/or databases and to enable publication and administration of our website, other online services and business. Our lawful ground for this processing is our legitimate interests which in this case are to enable us to properly administer our website and our community interest company.
· Technical Data that includes data about your use of Porcupine Collectiveand online services and digital products such as your IP address, your login data, details about your browser, length of visit to pages on our website, page views and navigation paths, details about the number of times you use our website, time zone settings and other technology on the devices you use to access our website. The source of this data is from our analytics tracking system. We process this data to analyse your use of Porcupine Collective and other online services, to administer and protect our business and websites, to deliver relevant website content and advertisements to you and to understand the effectiveness of our advertising. Our lawful ground for this processing is our legitimate interests which in this case are to enable us to properly administer our websites and our community interest company and to grow our community interest company and to decide our marketing strategy.
· Marketing Data that includes data about your preferences in receiving marketing from us and our third parties and your communication preferences. We process this data to enable you to partake in our promotions such as competitions, prize draws and free give-aways, to deliver relevant website content and advertisements to you and measure or understand the effectiveness of this advertising. Our lawful ground for this processing is our legitimate interests which in this case are to study how customers use our products/services, to develop them, to grow our community interest company and to decide our marketing strategy.
· We may use Customer Data, User Data, Technical Data and Marketing Data to deliver relevant website content and advertisements to you (including Facebook adverts or other display advertisements) and to measure or understand the effectiveness of the advertising we serve you. Our lawful ground for this processing is legitimate interests which is to grow our community interest company. We may also use such data to send other marketing communications to you. Our lawful ground for this processing is either consent or legitimate interests (namely to grow our community interest company).
We may also process Aggregated Data from your personal data but this data does not reveal your identity and as such in itself is not personal data. An example of this is where we review your Usage Data to work out the percentage of website users using a specific feature of our site. If we link the Aggregated Data with your personal data so that you can be identified from it, then it is treated as personal data.
We do not collect sensitive data from you. Sensitive data refers to data that 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. We do not collect any information about criminal convictions and offences.
3. How we collect your personal data
We collect data about you through a variety of different methods including:
Web Beacons. Emails and newsletters sent electronically, as well as Pages of Porcupine Collective, may contain small electronic files known as web beacons (also referred to as clear gifs. pixel tags and single-pixel gifs) that permit Porcupine Collective, for example, to count users who have visited those pages or opened an e-mail and for other related Porcupine Collective statistics (for example, recording the popularity of certain website content and verifying system and server integrity).
If you visit Porcupine Collective with an open ID (such as Facebook), you may also be sharing and integrating data with third-party social media sites, and we may track aggregate data about the number of visits to this site with an open ID, the number of items “liked” on this site, or items on this site that you choose to share with a third-party social media site.
4. How we use your personal data
We will only use your personal data when legally permitted. The most common uses of your personal data are:
Generally, we do not rely on consent as a legal ground for processing your personal data, other than in relation to sending marketing communications to you via email, text message or instant message. You have the right to withdraw consent to marketing at any time by emailing us at firstname.lastname@example.org.
Purposes for Processing Your Personal Data
Set out below is a description of the ways we intend to use your personal data and the legal grounds on which we will process such data. We have also explained what our legitimate interests are where relevant.
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 email us at email@example.com 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.
Type of data
Lawful basis for processing
To register you as a new customer
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
(e) Marketing and Communications
(a) Performance of a contract with you
(b) Necessary for our legitimate interests to recover debts owed to us
To manage our relationship with you which will include:
(b) Asking you to leave a review or take a survey
(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
(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 community interest company
To administer and protect our community interest company and Porcupine Collective (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data
(a) Necessary for our legitimate interests for running our community interest company, 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 content and advertisements to you and measure and understand the effectiveness of our advertising
(e) Marketing and Communications
Necessary for our legitimate interests to study how customers use our products/services, to develop them, to grow our community interest company and to inform our marketing strategy
To use data analytics to improve our website, products/services, marketing, customer relationships and experiences
Necessary for our legitimate interests to define types of customers for our products/services, to develop them, to grow our community interest company and to inform our marketing strategy
To make suggestions and recommendations to you about goods or services that may be of interest to you
Necessary for our legitimate interests to develop our products/services and grow our community interest company
Our lawful ground of processing your personal data to send you marketing communications is your consent.
Under the Privacy and Electronic Communications Regulations, we may send you marketing communications from us if:
Before we share your personal data with any third party for their own marketing purposes we will get your express consent.
You can 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 emailing us at firstname.lastname@example.org at any time.
Where you opt out of receiving our marketing communications, this will not apply to personal data provided to us as a result of a product/service purchase, warranty registration, product/service experience or other transactions.
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 find out more about how the processing for the new purpose is compatible with the original purpose, please email us at email@example.com.
If we need to use your personal data for a purpose unrelated to the purpose for which we collected the data, we will notify you and we will explain the legal ground of processing.
We may process your personal data without your knowledge or consent where this is required or permitted by law.
5. Disclosures of your personal data
We may have to share your personal data with the parties set out below for the purposes set out in the table in paragraph 4 above:
We require all third parties to whom we transfer your data to respect the security of your personal data and to treat it in accordance with the law. We only allow such third parties to process your personal data for specified purposes and in accordance with our instructions.
6. International Transfers
Countries outside of the European Economic Area (EEA) do not always offer the same levels of protection to your personal data, so European law has prohibited transfers of personal data outside of the EEA unless the transfer meets certain criteria.
Many of our third parties service providers are based outside the European Economic Area (EEA) so their processing of your personal data will involve a transfer of data outside the EEA.
Whenever we transfer your personal data out of the EEA, we do our best to ensure a similar degree of security of data by ensuring at least one of the following safeguards is implemented:
If none of the above safeguards is available, we may request your explicit consent to the specific transfer. You will have the right to withdraw this consent at any time.
7. Data Security
Porcupine Collective has implemented measures designed to secure your personal information from accidental loss and from unauthorised access, use, alteration and disclosure. All information you provide to us is stored in a technically and physically secure environment. Any payment transactions will be encrypted using SSL technology.
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 such data. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.
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.
The safety and security of your information also depends on you. Where we have given you (or where you have chosen) a username and/or password for access to certain parts of Porcupine Collective, you are responsible for keeping this username and/or password confidential. We ask you not to share your username or password with anyone.
Unfortunately, the transmission of information via the internet is not completely secure. Although we take reasonable measures to protect your information, we cannot guarantee the security of your personal information transmitted to Porcupine Collective. Any transmission of personal information is at your own risk. We are not responsible for circumvention of any privacy settings or security measures contained on Porcupine Collective.
8. Data Retention
We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, 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 below for further information.
In some circumstances we may anonymise your personal data (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 data protection laws you have rights in relation to your personal data that include the right to request access, correction, erasure, restriction, transfer, to object to processing, to portability of data and (where the lawful ground of processing is consent) to withdraw consent.
You can see more about these rights at:
If you wish to exercise any of the rights set out above, please email us at firstname.lastname@example.org.
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 or refuse to comply with your request in these circumstances.
We may need to request specific 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.
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.
If you are not happy with any aspect of how we collect and use your data, you have the right to complain to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk). We should be grateful if you would contact us first if you do have a complaint so that we can try to resolve it for you.
10. Third-Party Links
Porcupine Collective 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 privacy statements. When you leave our website, we encourage you to read the privacy notice of every website you visit.
11. Children Under Eighteen
Porcupine Collective does not knowingly collect personally identifiable information from children under the age of eighteen. If you are under the age of eighteen, you must ask your parent or guardian for permission to use this website.
Porcupine Collective is not intended for children under 18 years of age. No one under age 18 may provide any information to or on Porcupine Collective. We do not knowingly collect personal information from children under 18. If you are under 18, do not use or provide any information on Porcupine Collective, make any purchases through Porcupine Collective, or provide any information about yourself to us, including your name, address, telephone number, e-mail address or any screen name or user name you may use. If we learn we have collected or received personal information from a child under 18 without verification of parental consent, we will delete that information. If you believe we might have any information from or about a child under 18, please email us at email@example.com.
12. Contact Information
Chapel House, Coombe, St. Austell, PL26 7LN