PROTECTING YOUR PRIVACY

CAMBEE LIMITED

This privacy & cookies policy explains in detail the types of personal data Cambee may collect about you when you interact with us and how we manage it.

We hope the following sections will answer any questions but if not, please get in touch with us.

1. What is Cambee?

Cambee Limited (for simplicity, we use ‘we’ and ‘us’ below to mean Cambee and its brands) is a company active in the business of campervan conversions. We carry out full and partial conversions of vans (in particular, VW Transporter vans) into campervans, and also sell component parts to customers wishing to convert vans independently.

For the purposes of the conversion process, we carry out a number of activities, including: designing and fitting beds and wooden kitchen and storage units, both of which we also sell as kits for self-conversions; fitting seats, windows and pop-up roofs; fixing into place insulation, lining and flooring; and installing appliances and related fittings.

2. What are the legal bases that we rely on?

The law on data protection sets out a number of different reasons for which a company may collect and process your personal data, including:

Consent

In specific situations, we may collect and process your data with your consent (for example, when you tick a box to receive marketing emails). We will only collect the personal data necessary to perform the service.

Contractual obligations

In certain circumstances, we need your personal data to comply with our contractual obligations. For example, if you order an item from us for home delivery, we’ll collect your address details to deliver your purchase, and pass them to our courier.

Legal compliance

If the law requires us to, we may need to collect and process your data. For example, we are required to pass on details of people involved in fraud or other criminal activity affecting us to law enforcement.

Legitimate interest

In specific situations, we require your data to pursue our legitimate interests in a way which might reasonably be expected as part of running our campervan conversion business and which does not materially affect your rights, freedom or interests. For example:

• We may use your purchase history to send you or make available personalised offers.

• We may combine the shopping history of many customers to identify trends and ensure we can keep up with demand, or develop new products or services.

• We may use your contact details to email you direct marketing information, telling you about products and services that we think might interest you.

3. When do we collect your personal data?

We collect your personal data when you:

• Create a website account with us.

• Visit our website, and use your account to buy products and services.

• Visit our website and buy products and services using a guest account (in which case we just collect transaction-based data).

• Purchase a product or service at our premises or by phone but don’t have (or don’t use) an account.

• Redeem vouchers from us on the phone, at our premises or online Engage with us on social media.

• Contact us by any means with queries, complaints etc.

• Fill in any forms. For example, we may require you to provide your contact details on a form to enter prize draws or competitions that we hold at motorhome shows.

• Book any kind of appointment with us, for example to view any of our converted stock campervans.

• Choose to complete any surveys we send you.

• Comment on or review our products and services.

• Have given a third party permission to share with us the information they hold about you.

• Have given your consent to share information that is publicly available (such as information held by the Land Registry) or is made public as a matter of law.

• Use our car park, which has a CCTV system operated for the security of both customers and our staff. This system may record your image during your visit.

4. What sort of personal data do we collect?

• If you have a web account with us: your name, billing/delivery address, order details, email and telephone number.

• Necessary contact details in order to respond to your queries, or contact you regarding quotes or ongoing orders.

• Details of your interactions with us at our premises, over the phone or online. For example, we collect notes from our conversations with you, details of any complaints or comments you make, and details of your purchases.

• Copies of documents you provide to prove your age or identity (including your passport and driver's licence), but only in specific circumstances where the law requires this.

• Details of your visits to our website, and which site you came from to ours.

• Information gathered by the use of cookies in your web browser. For example, to deliver the best possible web experience, we collect technical information about your internet connection and browser as well as the country and telephone code where your computer is located, the web pages viewed during your visit, the advertisements you clicked on, and any search terms you entered. You can learn more about how we use cookies below.

• Payment card information.

• Your comments and product reviews.

• Your image may be recorded on CCTV when you visit our premises.

• Your social media username, if you interact with us through social media, to help us respond to your comments, questions or feedback.

5. How and why do we use your personal data?

• To process any orders that you make by using our website or at our premises. If we don’t collect your personal data during checkout, we won’t be able to process your order and comply with our legal obligations.

For example, your details may need to be passed to a third party to supply or deliver a product that you ordered, and we may keep your details for a reasonable period afterwards in order to fulfil any contractual obligations, such as refunds and warranties.

• To better respond to your queries, refund requests and complaints. We may also keep a record of these to inform any future communication with us and to demonstrate how we communicated with you throughout. We do this on the basis of our contractual obligations to you, our legal obligations and our legitimate interests in providing you with the best service and understanding how we can improve our service based on your experience.

• To protect our business and your account from fraud and other illegal activities. This includes using your personal data to maintain, update and safeguard your account. We’ll also monitor your browsing activity with us (for example, checking your password when you login and using automated monitoring of IP addresses to identify possible fraudulent log-ins from unexpected locations), to quickly identify and resolve any problems and protect the integrity of our website. We do this on the basis of our legitimate business interests.

• To protect our customers, premises, assets, employees and partners from crime, we operate a CCTV system at our premises, which records images for security. We do this on the basis of our legitimate business interests.

• To process payments and to prevent fraudulent transactions. We do this on the basis of our legitimate business interests. This also helps to protect our customers from fraud.

• If we discover any criminal activity or alleged criminal activity through our use of CCTV, fraud monitoring and suspicious transaction monitoring, we will process this data for the purposes of preventing or detecting unlawful acts. Our aim is to protect the individuals we interact with from criminal activities.

• With your consent, we will use your personal data, preferences and details of your transactions to keep you informed about relevant products and services including tailored special offers, discounts, promotions, events, competitions and so on.

Of course, you are free to opt out of hearing from us at any time.

• To send you communications required by law or which are necessary to inform you about our changes to the services we provide you. For example, we will send you details of any major changes we make to this policy, product recall notices, and legally required information relating to your orders. These service messages will not include any promotional content and do not require prior consent when sent by email or text message. If we do not use your personal data for these purposes, we would be unable to comply with our legal obligations.

• To display the most interesting content to you on our website, we may use data we hold about your favourite products. We will do so on the basis of your consent to our website placing cookies or similar technology on your device.

For example, we may display a list of items you’ve recently looked at, or offer you recommendations based on your purchase history and any other data you’ve shared with us.

• To administer any of our prize draws or competitions which you enter, based on your consent given at the time of entering.

• To comply with our contractual or legal obligations to share data with law enforcement.

• To send you survey and feedback requests to help improve our services. These messages will not include any promotional content and do not require prior consent when sent by email or text message. We have a legitimate interest to do so as this helps make our products or services more relevant to you.

Of course, you are free to opt out of receiving these requests from us at any time.

• To process your bookings and appointments. Sometimes, we’ll need to share your details with a third party who is providing a service (such as delivery couriers). We do so to maintain our appointments with you. Without sharing your personal data, we might be unable to fulfil your request.

If you wish to change how we use your data, you’ll find details in the “What are your rights over your personal data?” section below.

Remember, if you choose not to share your personal data with us, or refuse certain contact permissions, we might not be able to provide some products or services you’ve requested. For example, if you’ve asked us to let you know when an item comes back into stock, we can’t do that if you’ve withdrawn your general consent to hear from us.

6. How will we protect your personal data?

We know how much data security matters to all our customers. With this in mind we will treat your data with the utmost care and take all appropriate steps to protect it.

We secure access to all transactional areas of our website using ‘https’ technology.

Access to your personal data is password-protected, and sensitive data (such as payment card information) is secured by SSL encryption.

7. How long will we keep your personal data?

Whenever we collect or process your personal data, we’ll only keep it for as long as is necessary for the purpose for which it was collected.

At the end of that retention period, your data will either be deleted completely or anonymised, for example by aggregation with other data so that it can be used in a non-identifiable way for statistical analysis and business planning.

The following are examples of customer data retention periods:

Orders

When you place an order, we’ll keep the personal data you give us for five years so we can comply with our legal and contractual obligations. In the case of conversions carried out at our premises, and certain other products and services we provide, we’ll keep the data for 10 years.

Warranties

If your order included a warranty, the associated personal data will be kept until the end of the warranty period.

8. Who do we share your personal data with?

We may sometimes share your personal data with trusted third parties such as delivery couriers, for fraud management, to handle complaints, to help us personalise our offers to you and so on. In all cases, we will provide only the information they need to perform their specific services.

For fraud management, we may share information about fraudulent or potentially fraudulent activity in our premises or systems. This may include sharing data about individuals with law enforcement bodies.

We may also be required to disclose your personal data to the police or other enforcement, regulatory or government bodies, in your country of origin or elsewhere, upon a valid request to do so. These requests are assessed on a case-by-case basis and take the privacy of our customers into consideration.

We may, from time to time, expand, reduce or sell Cambee and this may involve the transfer of part of the company or the whole business to new owners. If this happens, your personal data will, where relevant, be transferred to the new owners under the terms of this policy.

9. Where might your personal data be processed?

In certain circumstances, we may need to share your personal data with third parties and suppliers outside the European Economic Area (which includes all EU member countries as well as Iceland, Liechtenstein and Norway), such as the USA.

For example, this might be required in order to fulfil your order, process your payment details or provide support services.

Any transfer of your personal data will follow applicable laws and we will treat the information under the guiding principles of this policy.

10. What are your rights over your personal data?

An overview of your different rights

You have the right to request that we:

• Allow access to the personal data we hold about you, free of charge in most cases.

• Correct your personal data when incorrect, out of date or incomplete – for example, when you withdraw consent, or object and we have no legitimate overriding interest, or once the purpose for which we hold the data has come to an end (such as the end of a warranty).

• Stop using your personal data for direct marketing (either through specific channels, or all channels).

• Stop any consent-based processing of your personal data after you withdraw that consent.

You also have the right to request a copy of any information about you that we hold at any time, and also to have that information corrected if it is inaccurate. To get a copy of your information or to ask for your information to be amended, please email office@cambee.co.uk or call us on 01626 57 22 22.

Your right to withdraw consent

Whenever you have given us your consent to use your personal data, you have the right to change your mind at any time and withdraw that consent.

Where we rely on our legitimate interest

In cases where we are processing your personal data on the basis of our legitimate interest, you can ask us to stop for reasons connected to your individual situation. We must then do so unless we believe we have a legitimate overriding reason to continue processing your personal data.

Direct marketing

You have the right to stop the use of your personal data for direct marketing activity through all channels, or selected channels. We must always comply with your request.

Checking your identity

To protect the confidentiality of your information, we will ask you to verify your identity before proceeding with any request you make under this policy. If you have authorised a third party to submit a request on your behalf, we will ask them to prove they have your permission to act.

11. How can you stop the use of your personal data for direct marketing?

You can stop direct marketing communications from us by clicking the ‘unsubscribe’ link in any email communication that we send you. We will then stop any further emails.

Please note that you may continue to receive communications for a short period after changing your preferences while our systems are fully updated.

12. How can you make a complaint?

If you feel that your data has not been handled correctly, or you are unhappy with our response to any requests you have made to us regarding the use of your personal data, you have the right to lodge a complaint with the Information Commissioner’s Office.

You can contact them by calling 0303 123 1113 or go online to www.ico.org.uk/concerns (please note we can't be responsible for the content of external websites).

If you are based outside the UK, you have the right to lodge your complaint with the relevant data protection regulator in your country of residence.

13. How does this policy apply if you live outside the UK?

By using our services or providing your personal data to us, you expressly consent to the processing of your personal data by us or on our behalf. Of course, you still have the right to ask us not to process your data in certain ways, and if you do so, we will respect your wishes.

Sometimes we’ll need to transfer your personal data between countries to enable us to supply the goods or services you’ve requested. In the ordinary course of business, we may transfer your personal data from your country of residence to ourselves and to third parties located in the UK.

By dealing with us, you are giving your consent to this overseas use, transfer and disclosure of your personal data outside your country of residence for our ordinary business purposes.

This may occur because our information technology storage facilities and servers are located outside your country of residence, and could include storage of your personal data on servers in the UK.

We’ll ensure that reasonable steps are taken to prevent third parties outside your country of residence using your personal data in any way that’s not set out in this policy. We’ll also make sure we adequately protect the confidentiality and privacy of your personal data.

14. What is our cookies policy?

Our website uses cookies. By using the website and agreeing to this policy, you consent to our use of cookies in accordance with the terms of this policy.

What are cookies?

Cookies are files sent by web servers to web browsers, and stored by the web browsers. The information is then sent back to the server each time the browser requests a page from the server. This enables a web server to identify and track web browsers.

We use the information to compile reports that help us improve our website. This information is in an anonymous form, and includes the number of visitors to our website, where visitors linked to the site from and the pages visited.

There are two main kinds of cookies: “session” cookies and “persistent” cookies. Session cookies are deleted from your computer when you close your browser, whereas persistent cookies remain stored on your computer until deleted, or until they reach their expiry date.

We use both session and persistent cookies on our website.

What cookies do we use on our website?

Google Analytics

We use Google Analytics to analyse the use of our website. Google Analytics generates statistical and other information about website use by means of cookies, which are stored on users' computers. We use the information generated to create reports about the use of the website.

We use the following Google Analytics cookies on our website, for the following purposes:

__utma – this is a persistent cookie which keeps track of the number of times a visitor has been to our site, as well as the time of the first visit and the last visit. It expires after two years.

__utmb and __utmc – these session cookies work in tandem to calculate the length of a user’s visit. The __utmb cookie logs the time a web session begins while the __utmc cookie logs the time the session ends. The __utmb expires when the user leaves the page. The __utmc cookie expires a short time after the user’s visit ends.

__utmt – this is a persistent cookie used to throttle the request rate for the website service, limiting the collection of data on high traffic sites. This cookie expires after 10 minutes.

__utmz – this is a persistent cookie which keeps track of where a visitor came from, the search engine they used, what link they clicked on, the keyword they used, and from where in the world they accessed our website. This cookie expires after six months.

For more information on Google Analytics cookies, please see the Google privacy information.

You can opt out of Google Analytics tracking by installing a browser plug-in from Google.

Google AdSense

We publish Google AdSense interest-based advertisements on this website. These are tailored by Google to reflect your interests. To determine your interests, Google will track your behaviour across the web using cookies. You can view, delete or add interest categories associated with your browser using Google's Ads Preference Manager, available at: http://www.google.com/ads/preferences/. You can opt-out of the AdSense partner network cookie at:http://www.google.com/privacy_ads.html. However, this opt-out mechanism uses a cookie, and if you clear the cookies from your browser your opt-out will not be maintained. To ensure that an opt-out is maintained in respect of a particular browser, you should use the Google browser plug-in available at: http://www.google.com/ads/preferences/plugin.

Blocking or deleting cookies

Most browsers allow you to block cookies. For example, in Chrome (version 66), you can block cookies by opening Chrome and then the “Customise and control Google Chrome” menu in the top right. Then click “Settings”, “Advanced” (at the bottom of the page) and “Content settings” (under “Privacy and security”). This takes you to the “Cookies” page, where you can select your blocking preferences.

Most browsers also allow you to delete cookies already stored on your computer. For example, in Chrome, you can delete all cookies by opening the “Advanced” settings page as above and clicking “Clear browsing data” (under “Privacy and security”), then ticking “Cookies and other site data” and clicking “Clear data”.

Note that if you block or delete cookies you will not be able to use some of the features of our website.

15. Any questions?

We hope this policy has been helpful in setting out the way we handle your personal data and your rights to control it.

If you have any questions that haven’t been covered, please contact Cambee by:

• emailing us at office@cambee.co.uk; or

• writing to us at Cambee Ltd, Unit 2, Greenhill Industrial Estate, Greenhill Road, Kingsteignton, Newton Abbot, Devon TQ12 3BD.