Privacy Policy

This privacy policy applies between you, the User of this Website, and Charlton Gray Limited, the owner and provider of this Website. Charlton Gray Limited takes the privacy of your information very seriously. This privacy policy applies to our use of any and all Data collected by us or provided by you in relation to your use of the Website. Please read this privacy policy carefully.

Definitions and interpretation

1. In this privacy policy, the following definitions are used:

Term	Definition
Data	collectively all information that you submit to Charlton Gray Limited via the Website. This definition incorporates, where applicable, the definitions provided in the Data Protection Laws
Data Protection Laws	any applicable law relating to the processing of personal Data, including but not limited to the GDPR, and any national implementing and supplementary laws, regulations and secondary legislation
GDPR	the UK General Data Protection Regulation
Charlton Gray Limited, we or us	Charlton Gray Limited, a company incorporated in England and Wales with registered number 13696633 whose registered office is at Star Lodge, Montpellier Drive, Cheltenham, Gloucestershire, GL50 1TY
User or you	any third party that accesses the Website and is not either (i) employed by Charlton Gray Limited and acting in the course of their employment or (ii) engaged as a consultant or otherwise providing services to Charlton Gray Limited and accessing the Website in connection with the provision of such services
Website	the website that you are currently using, www.charlton-gray.co.uk, and any sub-domains of this site unless expressly excluded by their own terms and conditions

2. In this privacy policy, unless the context requires a different interpretation:

• the singular includes the plural and vice versa;
• references to sub-clauses, clauses, schedules or appendices are to sub-clauses, clauses, schedules or appendices of this privacy policy;
• a reference to a person includes firms, companies, government entities, trusts and partnerships;
• “including” is understood to mean “including without limitation”;
• reference to any statutory provision includes any modification or amendment of it;
• the headings and sub-headings do not form part of this privacy policy.

Scope of this privacy policy

3. This privacy policy applies only to the actions of Charlton Gray Limited 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 we may provide to social media websites.
4. For purposes of the applicable Data Protection Laws, Charlton Gray Limited is the “data controller”. This means that Charlton Gray Limited determines the purposes for which, and the manner in which, your Data is processed.

Data collected

5. We may collect the following Data, which includes personal Data, from you:

• name;
• contact Information such as email addresses and telephone numbers;

in each case, in accordance with this privacy policy.

How we collect Data

6. We collect Data in the following ways:

• data is given to us by you; and
• data is collected automatically.

Data that is given to us by you

7. Charlton Gray Limited will collect your Data in a number of ways, for example:

• when you contact us through the Website, by telephone, post, e-mail or through any other means;
• when you use our services;

in each case, in accordance with this privacy policy.

Data that is collected automatically

8. To the extent that you access the Website, we will collect your Data automatically, for example: we automatically collect some information about your visit to the Website. This information helps us to make improvements to Website content and navigation, and includes your IP address, the date, times and frequency with which you access the Website and the way you use and interact with its content.

Our use of Data

9. 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; transmission by email of marketing materials that may be of interest to you; in each case, in accordance with this privacy policy.
10. We may use your Data for the above purposes if we deem it necessary to do so for our legitimate interests. If you are not satisfied with this, you have the right to object in certain circumstances (see the section headed “Your rights” below).
11. For the delivery of direct marketing to you via e-mail, we’ll need your consent, whether via an opt-in or soft-opt-in: soft opt-in consent is a specific type of consent which applies when you have previously engaged with us (for example, you contact us to ask us for more details about a particular product/service, and we are marketing similar products/services). Under “soft opt-in” consent, we will take your consent as given unless you opt-out. For other types of e-marketing, we are required to obtain your explicit consent; that is, you need to take positive and affirmative action when consenting by, for example, checking a tick box that we’ll provide. If you are not satisfied with our approach to marketing, you have the right to withdraw consent at any time. To find out how to withdraw your consent, see the section headed “Your rights” below.

Who we share Data with

12. We may share your Data with the following groups of people for the following reasons: our employees, agents and/or professional advisors – to obtain advice from relevant professional advisers if required; in each case, in accordance with this privacy policy.

Keeping Data secure

13. We will use technical and organisational measures to safeguard your Data, for example: access to your account is controlled by a password and a user name that is unique to you; we store your Data on secure servers.
14. Technical and organisational measures include measures to deal with any suspected data breach. If you suspect any misuse or loss or unauthorised access to your Data, please let us know immediately by contacting us via this e-mail address: jane@charlton-gray.co.uk.
15. If you want detailed information from Get Safe Online on how to protect your information and your computers and devices against fraud, identity theft, viruses and many other online problems, please visit www.getsafeonline.org. Get Safe Online is supported by HM Government and leading businesses.

Data retention

16. Unless a longer retention period is required or permitted by law, we will only hold your Data on our systems for the period necessary to fulfil the purposes outlined in this privacy policy or until you request that the Data be deleted.
17. Even if we delete your Data, it may persist on backup or archival media for legal, tax or regulatory purposes.

Your Rights

18. You have the following rights regarding your Data:

• Right to Access: You have the right to request access to copies of the information we hold about you or request modifications, updates, or deletions. We will not charge you for access unless the request is manifestly unfounded or excessive, and we may refuse the request if legally permitted. If we refuse, we will provide the reasons why.
• Right to Rectification: You have the right to have your Data corrected if it is inaccurate or incomplete.
• Right to Erasure: You have the right to request that we delete or remove your Data from our systems.
• Right to Restrict Processing: You have the right to block us from using your Data or limit the way in which we can use it.
• Right to Data Portability: You have the right to request that we move, copy, or transfer your Data.
• Right to Object: You have the right to object to our use of your Data, including where we use it for our legitimate interests.

19. To make enquiries, exercise any of your rights set out above, or withdraw your consent to the processing of your Data (where consent is our legal basis for processing your Data), please contact us via this e-mail address: jane@charltongray.co.uk.
20. If you are not satisfied with the way a complaint you make in relation to your Data is handled by us, you may be able to refer your complaint to the relevant data protection authority. For the UK, this is the Information Commissioner’s Office (ICO). The ICO’s contact details can be found on their website at https://ico.org.uk/.
21. It is important that the Data we hold about you is accurate and current. Please keep us informed if your Data changes during the period for which we hold it.

Links to Other Websites

22. This Website may, from time to time, provide links to other websites. We have no control over such websites and are not responsible for the content of these websites. This privacy policy does not extend to your use of such websites. You are advised to read the privacy policy or statement of other websites prior to using them.

Changes of Business Ownership and Control

23. Charlton Gray Limited may, from time to time, expand or reduce our business, and this may involve the sale and/or transfer of control of all or part of Charlton Gray Limited. 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 privacy policy, be permitted to use the Data for the purposes for which it was originally supplied to us.
24. We may also disclose Data to a prospective purchaser of our business or any part of it.
25. In the above instances, we will take steps with the aim of ensuring your privacy is protected.

General

26. You may not transfer any of your rights under this privacy policy to any other person. We may transfer our rights under this privacy policy where we reasonably believe your rights will not be affected.
27. If any court or competent authority finds that any provision of this privacy policy (or part of any provision) is invalid, illegal, or unenforceable, that provision or part-provision will, to the extent required, be deemed to be deleted, and the validity and enforceability of the other provisions of this privacy policy will not be affected.
28. Unless otherwise agreed, no delay, act, or omission by a party in exercising any right or remedy will be deemed a waiver of that, or any other, right or remedy.
29. This Agreement will be governed by and interpreted according to the law of England and Wales. All disputes arising under the Agreement will be subject to the exclusive jurisdiction of the English and Welsh courts.

Changes to this privacy policy

30. We reserve the right to modify this privacy policy at any time, so please review it frequently. Changes and clarifications will take effect immediately upon their posting on the website. If we make material changes to this policy, we will notify you here that it has been updated, so that you are aware of what information we collect, how we use it, and under what circumstances, if any, we use and/or disclose it.

You are deemed to have accepted the terms of the privacy policy on your first use of the Website following the alterations. If you do not agree to the terms of this privacy policy, as amended from time to time, in whole or in part, please do not use our Website.

Contact us

If you have any questions about this privacy policy, or if you wish to exercise any of your rights set out above, please contact us via this email address: jane@charltongray.co.uk.

Attribution

31. This privacy policy was created using a document from Rocket Lawyer (https://www.rocketlawyer.com/gb/en). This policy was created on 13 March 2023 and updated on [date of latest update].