We may process personal data about you in different ways and different situations, depending on if you are a representative of a client, customer, vendor, or a job applicant. We may also process personal data about visitors to our website(s), depending on how you chose to interact with us. Regardless of situation, we promise to never sell, commercialise, or use your personal data in violation of applicable data protection laws.
Data protection officer: email@example.com
Cigar Club LDN LIMITED has a responsibility to ensure appropriate and proportionate security of the personal data we process. We must report any personal data breach to the supervisory authority unless the personal data breach is “unlikely to result in a risk for the rights and freedoms of individuals”. Where a personal data breach is likely to result in a high risk to the rights and freedoms of individuals, we are also required to inform the data subject concerned, without undue delay.
Why have we access to and process your data?
The processing of you or your company’s personal data is necessary for us to enter into and/or to fulfil the agreement we have with yourself or your company. We may also process personal data about visitors to our website(s) or physical locations, depending on how you choose to interact with us.
We will only process your personal data if we have legal grounds to do so. This means that the processing must be necessary for the performance of a contract to which you or the company you represent is party to or is necessary to comply with your requests prior to entering into a contract with your company.
We have a legitimate interest to process your data to form and manage client and business relationships, for marketing purposes, and to ensure the safety of Cigar Club LDN LIMITED employees and assets. In accordance with our legitimate interests, we may also use your data to provide you with information about our services, performance updates, events and training which is likely to be of interest to you or to execute necessary or desired tasks expected by the business relationship you represent.
We have a legal obligation to provide your personal data when we are audited by the authorities and to prevent, monitor and evidence fraud, anti-money laundering and other criminal activities to comply with statutory legislation.
Your data will be held securely in compliance with data protection law.
What personal data are you processing about me and why?
We hold only the necessary information for the management of the contractual or business relationship. To be able to communicate with you we need your name, job title, and contact details such as address, land line telephone number, mobile number and email address.
Unless otherwise agreed with you or is necessary for the establishment, exercise or defence of legal claims, we will not include special categories of personal information (often known as ‘sensitive personal data’ such as data revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, trade-union membership, biometric data and the processing of data concerning health or sex life).
Will you share my personal data with others?
We may share your personal data with our suppliers that facilitate and/or provide parts of our services, e.g. print and mail services, legal representatives. We may also share your personal data with our clients if you are representing a vendor which is part of the services, we provide to them and regulatory / governmental authorities.
Our employees will have access to the personal data. In such a case, access will be granted only if necessary, for the purposes described and only if the employee is bound by an obligation of confidentiality.
Will my personal data be transferred to another country?
We may transfer your data to another country to and from the European Economic Area (EEA). If we do so, we will ensure there are suitable safeguards in place to comply with EU General Data Protection Regulation (GDPR). Generally, your personal data will not be transferred outside of the European Economic Area (EEA). We also use third-party service providers to store or who may access your data, which may be located outside of the EEA, including, but not limited to the United States. We will never transfer your personal data outside of the EEA without ensuring the safety and protection of your personal data. Therefore, we make sure that any recipients have signed the EU Standard Model Clauses, to justify the transfer, or that the country can guarantee adequate protection under data protection law. We may disclose information outside of these groups to help prevent fraud, or if required to do so by law.
How long do you store my personal data?
We will retain your data as long as required for the lawful purpose for which it was obtained, as long as we have legitimate interest to keep it e.g. until termination of our agreement and to be able to defend ourselves against legal claims. We are also legally obliged to keep your personal data for a period of time to prevent and detect fraud, detect and evidence anti-money laundering and for financial audits.
As far as our backups are concerned, we will also delete your data in our backups, but only when the backup tape comes up for destruction, according to our backup policy. When the backup comes up for deletion as per our back up policy, we will fully delete your data.
Will I be subject to automated decision-making?
We will not use your personal data for automated decision-making and/or profiling.
What rights do I have?
It is important you understand that it is your personal data that we process and that we want you to be comfortable with us doing so.
Right to access
You may request information on how we process your personal data, including information on:
Why we process your personal data
What categories of personal data we process
Who we share your personal data with
How long we store your personal data or the criteria for determining this period
What rights you have
From where we have received your personal data (if we have not received it from you)
If the processing includes automatic decision making (so-called profiling)
If your personal data has been transferred to a country outside of the EEA, how we ensure the protection of your personal data.
Right to correction
It is important that we have the right information about you, and we encourage you to let us know if any of your personal data is incorrect, e.g. if you or the company you represent have changed name or moved address.
Right to be forgotten
If we process your personal data in an unlawful way, you may ask us to delete this information. The right is not absolute and only applies in certain circumstances, for example ‘the personal data is no longer necessary for the purpose which you originally collected or processed it for’ etc. Given the context of our agreement, it is, however unlikely, that we will be able to comply with this right.
Right to restriction
From the time you have requested we correct your personal data or if you have objected to the processing and until we have been able to investigate the issue or confirm the accuracy of your personal data (or changed it in accordance with your instructions), you are entitled to the restriction of processing. This means that we (except for storing the personal data) may process your personal data only in accordance with your consent, if necessary, with reference to legal claims, to protect someone else’s rights or if there is an important public interest in the processing.
You may also request that we restrict the processing of your personal data if the processing is unlawful, but you do not want us to delete the personal data. This right is not absolute and only applies in certain circumstances. For example, contesting the accuracy of your personal data and we are verifying the accuracy of the data. Given the context of our agreement, it is, however unlikely, that we will be able to comply with this right.
Right to objection
If you believe that we do not have the right to process your personal data, you may object to our processing. In such cases, we may continue processing only if we can show compelling justifying reasons that out-weigh your interests, rights and freedoms. However, we may always process your personal data if it is required for the determination, exercise or defence of legal claims. (Note that this only provides you with the right to raise your objections, not a blanket right to have any and all processing ceased). Given the context of our agreement, it is, however unlikely, that we will be able to comply with this right.
Withdrawal of consent
Cigar Club LDN LIMITED does not base its processing upon consent. However, given that some processing activities may be based on consent, you are in your right to withdraw it and we will (where our legitimate interest does not override this right) consequently stop the processing. We will also notify others we may have shared your personal data with of your request(s).
How to complain about the use of your data or exercise my rights?
If you wish to raise a complaint about how we handle your personal data, including in relation to any of the rights outlined above, you can contact our Data protection officer: firstname.lastname@example.org
If you are not satisfied with our response, or believe we are processing your data unfairly or unlawfully, you can complain to the Data Inspectorate. You can find further information about the Data Inspectorate and their complaints procedure here: https://ico.org.uk/.
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The website http://www.allaboutcookies.org/ provides useful general information on cookies.
We embed videos from our official YouTube channel using YouTube’s privacy-enhanced mode. This mode may set cookies on your computer once you click on the YouTube video player, but YouTube will not store personally-identifiable cookie information for playbacks of embedded videos using the privacy-enhanced mode. Read more at YouTube’s embedding videos information page.
Vimeo and Other Embedded Videos Via Other Video Hosting Sites
We may embed videos from other video hosting sites and where possible use a privacy-enhanced mode to align with our policy of protecting our visitors information. This mode and content may set cookies on your computer once you click on videos embedded onto the site. Video content via online hosting sites will not store personally-identifiable cookie information for playbacks of embedded videos.
How do I change my cookie settings?
Many web browsers allow some control of most cookies through the browser settings. To find out more about cookies, including how to see what cookies have been set, visit www.aboutcookies.org or www.allaboutcookies.org.
Find out how to manage cookies on popular browsers:
Microsoft Internet Explorer
To find information relating to other browsers, visit the browser developer’s website.
Matthew Balman, email@example.com
Text last updated: 2022 Jan 30
Terms & conditions
The information contained within this web site, and those of all Cigar Club LDN LIMITED linked hereto is provided purely for informational purposes regarding Cigar Club LDN LIMITED, its subsidiaries and partners and the services that they offer. It does not constitute an offer to sell any securities and must not be relied upon in connection with any investment decision.
Information on this web site is provided “as is” without warranty or term of any kind, either express or implied, including, but not limited to, any implied warranties or terms of merchantability, fitness for a particular purpose, or non-infringement. All such implied terms and warranties are hereby excluded.
By accessing this web site you agree that Cigar Club LDN LIMITED will not be liable for any direct, indirect or consequential loss arising from the use of the information and material contained in this web site, or any other hyperlinked website, including, without limitation, any lost profits, business interruption, loss of programs or other, even if we are expressly advised of the possibility of such damages.
Other sites that may be listed or linked in this web site are not under the control of Cigar Club LDN LIMITED. Accordingly, Cigar Club LDN LIMITED can make no representation concerning the content of these sites to you, nor can the fact that Cigar Club LDN LIMITED has given you this listing serve as an endorsement by Cigar Club LDN LIMITED of any of these sites. Cigar Club LDN LIMITED is providing links to these as a convenience to you.
Permission is granted to download and print materials from this web site for the purpose of viewing, reading, and retaining for reference. Any other copying, distribution, or modification of materials on this site, whether in electronic or hard copy form, without the express prior written permission from Cigar Club LDN LIMITED is strictly prohibited.
The above exclusions and limitations apply only to the extent permitted by law.
Cookies – When you visit our web site, we may send “cookies” to your computer. A cookie is a small text file or piece of data that a web site that you visit can place or save onto your computer. Cookies do not themselves contain any personally identifiable information. There are two types of cookies. One saves a file for a longer period of time onto your computer, and it can remain on your computer after you shut it off. Such cookie could, for example, be used to remember the visitors settings on her last visit to that web site. The second type of cookie is called “session cookie.” While you are visiting a website, session cookies are temporarily stored in your computer’s memory. Session cookies are not stored for a long period of time on your computer, since they disappear when you close your web browser. The Cigar Club LDN LIMITED web site does use both Session and Persistent cookies.
Personally identifiable information
We will not collect your personally identifiable information without your knowledge and permission, nor will we sell or rent any such data. In order to provide you with a specific product, service, or information or to process a transaction, we may request your personally identifiable information. This information may for example include your name, title, shipping address, billing address, e-mail address, telephone numbers, and/or telefax numbers. Personally identifiable information is only collected when necessary to provide a product, service, or information, process a transaction, or if you submit it to us for other purposes, for instance if applying for employment.