Cinch Storage 2020

Privacy Policy

Your Personal Information
    1. This privacy policy explains how we collect and process your personal data, what your rights are and how the law protects you.
    2. Personal data, or personal information, means any information about an individual person from which that individual person can be identified. 
    3. We do not knowingly collect any personal data relating to children.
Who we are and how you can contact us 
    1. We are UK STORAGE CONSULTANCY LIMITED. Our registered office is at 18a Rockley Road, London, England, W14 0DA.  
    2. You can contact us by email at hello@cinchstorage.co.uk.  
    3. Our representative for all queries in relation to this policy and your data protection rights is Joshua Nimmo.  
    4. When we refer to our website, we mean our website at https://cinchstorage.co.uk/ and any further related website(s) and/or related mobile application published by us from time to time.
Where we collect your personal information from 

We may collect personal information about you in the following ways: 

Data you give to us:

      1. Data you give to us when you register to use our services
      2. When you talk to us in person at one of our storage locations
      3. When you use our website
      4. When you talk to us on the phone (please note, phone calls may be recorded)
      5. In emails or letters to us
      6. When you give us feedback, including reporting any issues
      7. CCTV footage from when you attend one of our storage locations

Data we collect when you use our services

      1. Payment and transaction data 
      2. Profile and usage data, including data we gather from the devices you use to connect to our website services such as computers and mobile phones, using cookies and other internet tracking software  (please see our separate Cookie Policy)

Data from third parties we work with

      1. Data (including that referred to above) from each of our storage locations (which are separate legal entities) 
      2. Reports generated from third-party data analytics service providers
      3. Companies that introduce you to us
      4. Credit reference agencies
      5. Public information sources, such as Companies House
      6. Government and law enforcement agencies
The types of personal data we collect 
    1. We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:
      1. Identity data – name, username, title 
      2. Contact data – billing and correspondence addresses, email address, telephone number(s), social media channels
      3. Financial data – bank account and payment card details
      4. Transaction data – details about payments to and from you, details of products and services you have purchased from us, details of storage locations used and the reasons behind your requirement for storage 
      5. Technical data – internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access our website
      6. Profile and behavioural data – your username and password, orders made by you, your interests, offer preferences and feedback
      7. Usage data – information about how you use our website, products and services, CCTV footage (from our storage locations)
      8. Marketing and communications data – your preferences in receiving marketing from us and our third parties and your communication preferences 
    2. We may also collect, use and share aggregated data such as statistical or demographic data for any purpose. Aggregated data may be derived from your personal data but is not considered personal data in law as this data does not directly or indirectly reveal your identity. For example, we may aggregate your usage data to calculate the percentage of users accessing a specific website feature or taking up a particular offer. However, if we combine or connect aggregated data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy policy.
    3. We do not collect any special categories of personal data about you.  This includes details about 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). Nor do we collect any information about criminal convictions and offences.
How we use your personal information 
    1. Your privacy is protected by law. 
    2. We are only allowed to use personal information about you if we have a legal basis to do so, and we are required to tell you what that legal basis is.  We have set out in the table below: the personal information which we collect from you, how we use it, and the legal ground on which we rely when we use the personal information.  
    3. In some circumstances we can use your personal information if it is in our legitimate interest to do so, provided that we have told you what that legitimate interest is.  A legitimate interest is when we have a business or commercial reason to use your information which, when balanced against your rights, is justifiable.  If we are relying on our legitimate interests, we have set that out in the table below.
What we use your personal information for What personal information we collect Our legal grounds for processing Our legitimate interests (if applicable)
To register you as a new customer Identify data, data contact, technical data profile and behavioural data Necessary for the performance of a contract with you To ensure we able to operate our business, effectively and efficiently
To process and deliver your order of products and services Identity data, contact data, technical data, profile and behavioural data, financial data, transaction data Necessary for the performance of a contract with you
To manage payments or collect and recover money owed to us Contact data, financial data, transactional data Necessary for the performance/enforcement of a contract with you To ensure we are paid for the products and services provided to you
To manage our relationship with you, including notifying you about changes to our terms or policies Identity data, contact data, profile and behavioural data, marketing and communications data Necessary for the performance of a contract with you To ensure our terms and policies are kept up-to-date and that those updates are communicated to our customers in order to ensure such policies are enforceable and uniformly applicable across our business. 
To notify you of new products and services that may be of interest to you, to enable you to partake in a prize draw, competition or to complete a survey Identity data, contact data, profile and behavioural data, marketing and communications data Consent To generate repeat business where we have identified that you are likely to be interested in the communication (and you have not withdrawn your consent to receive such notifications).
To administer and protect our business and our website Technical data, profile and behavioural data, usage data To operate our business, to protect our customers’ personal data and to ensure our storage locations and website are secure and can be trusted by our customers. 
To deliver relevant website content and online advertisements to you and measure or understand the effectiveness of the advertising we serve to you Technical data, profile and behavioural data, usage data Consent (to cookies and/or to marketing) To improve our commercial offering, to be able to better serve our customers’ needs
To use data analytics to improve our website, products / services, marketing, customer relationships and experiences Technical data, profile and behavioural data, usage data To improve our commercial offering, to be able to better serve our customers’ needs, to improve order conversion rates by doing so
  • What we use your personal information for:
    To register you as a new customer
    What personal information we collect:
    Identify data, data contact, technical data profile and behavioural data
    Our legal grounds for processing:
    Necessary for the performance of a contract with you
    Our legitimate interests (if applicable):
    To ensure we able to operate our business, effectively and efficiently
  • What we use your personal information for:
    To process and deliver your order of products and services
    What personal information we collect:
    Identity data, contact data, technical data, profile and behavioural data, financial data, transaction data
    Our legal grounds for processing:
    Necessary for the performance of a contract with you
    Our legitimate interests (if applicable):
  • What we use your personal information for:
    To manage payments or collect and recover money owed to us
    What personal information we collect:
    Contact data, financial data, transactional data
    Our legal grounds for processing:
    Necessary for the performance/enforcement of a contract with you
    Our legitimate interests (if applicable):
    To ensure we are paid for the products and services provided to you
  • What we use your personal information for:
    To manage our relationship with you, including notifying you about changes to our terms or policies
    What personal information we collect:
    Identity data, contact data, profile and behavioural data, marketing and communications data
    Our legal grounds for processing:
    Necessary for the performance of a contract with you
    Our legitimate interests (if applicable):
    To ensure our terms and policies are kept up-to-date and that those updates are communicated to our customers in order to ensure such policies are enforceable and uniformly applicable across our business.
  • What we use your personal information for:
    To notify you of new products and services that may be of interest to you, to enable you to partake in a prize draw, competition or to complete a survey
    What personal information we collect:
    Identity data, contact data, profile and behavioural data, marketing and communications data
    Our legal grounds for processing: Consent
    Our legitimate interests (if applicable):
    To generate repeat business where we have identified that you are likely to be interested in the communication (and you have not withdrawn your consent to receive such notifications).
  • What we use your personal information for:
    To administer and protect our business and our website
    What personal information we collect:
    Technical data, profile and behavioural data, usage data
    Our legal grounds for processing:
    Our legitimate interests (if applicable):
    To operate our business, to protect our customers’ personal data and to ensure our storage locations and website are secure and can be trusted by our customers
  • What we use your personal information for:
    To deliver relevant website content and online advertisements to you and measure or understand the effectiveness of the advertising we serve to you
    What personal information we collect:
    Technical data, profile and behavioural data, usage data
    Our legal grounds for processing:
    Consent (to cookies and/or to marketing)
    Our legitimate interests (if applicable):
    To improve our commercial offering, to be able to better serve our customers’ needs
  • What we use your personal information for:
    To use data analytics to improve our website, products / services, marketing, customer relationships and experiences
    What personal information we collect:
    Technical data, profile and behavioural data, usage data
    Our legal grounds for processing:
    Our legitimate interests (if applicable):
    To improve our commercial offering, to be able to better serve our customers’ needs, to improve order conversion rates by doing so
Who we share your personal information with 
    1. We may share (or allow access to) your personal information with any of the following organisations, in connection with our provision of the products and services which you have requested from us:  
Third Party Server Location (where applicable) Further Details
Our physical storage locations UK Our storage locations are independent entities to which we provide supervisory, management, operational and administrative services.
SiteLink US To manage our storage operations, to generate and record communications with customers, to store records of transactions and agreements, to process financial/payment data.
Google Various We use Analytics, Adwords, Optimise and Tag Manager.
ActiveCampaign US To identify customers and selectively trigger communications across multiple channels (including email, website, social media and telephone)
Incsub, LLC UK We use WPMU DEV services in connection with our website
CookiePro (One Trust) EU To store customer preferences and optimise website performance
RapidStor US on Google Cloud To process online quotes and reservations, to process financial data for the purpose of processing payments and to generate communications based on this activity.
HotJar Ireland (Citation) To analyse website performance and customer behaviour, to improve our commercial offering.
Social Intents LLC Various Web chat service
Microsoft We use Microsoft Teams (and may do for client meetings from time to time)
CCTV providers (various) Various To monitor activity in and around the premises.
Telephone provider Various To monitor calls for audit and training purposes.
Payment processor Various To process payments.
Professional advisers that we use from time to time UK Where context reasonably requires.
Credit reference agencies UK Where we deem it necessary.
  • Third Party:
    Our physical storage locations
    Server Location (where applicable):
    UK
    Further Details:
    Our storage locations are independent entities to which we provide supervisory, management, operational and administrative services.
  • Third Party:
    SiteLink
    Server Location (where applicable):
    US
    Further Details:
    To manage our storage operations, to generate and record communications with customers, to store records of transactions and agreements, to process financial/payment data.
  • Third Party:
    Google
    Server Location (where applicable):
    Various
    Further Details:
    We use Analytics, Adwords, Optimise and Tag Manager.
  • Third Party:
    ActiveCampaign
    Server Location (where applicable):
    US
    Further Details:
    To identify customers and selectively trigger communications across multiple channels (including email, website, social media and telephone)
  • Third Party:
    Incsub, LLC
    Server Location (where applicable):
    UK
    Further Details:
    We use WPMU DEV services in connection with our website
  • Third Party:
    CookiePro (One Trust)
    Server Location (where applicable):
    EU
    Further Details:
    To store customer preferences and optimise website performance
  • Third Party:
    RapidStor
    Server Location (where applicable):
    US on Google Cloud
    Further Details:
    To process online quotes and reservations, to process financial data for the purpose of processing payments and to generate communications based on this activity.
  • Third Party:
    HotJar
    Server Location (where applicable):
    Ireland (Citation)
    Further Details:
    To analyse website performance and customer behaviour, to improve our commercial offering.
  • Third Party:
    Social Intents LLC
    Server Location (where applicable):
    Various
    Further Details:
    Web chat service
  • Third Party:
    Microsoft
    Server Location (where applicable):
    Further Details:
    We use Microsoft Teams (and may do for client meetings from time to time)
  • Third Party:
    CCTV providers (various)
    Server Location (where applicable):
    Various
    Further Details:
    To monitor activity in and around the premises.
  • Third Party:
    Telephone provider
    Server Location (where applicable):
    Various
    Further Details:
    To monitor calls for audit and training purposes.
  • Third Party:
    Payment processor
    Server Location (where applicable):
    Various
    Further Details:
    To process payments.
  • Third Party:
    Professional advisers that we use from time to time
    Server Location (where applicable):
    UK
    Further Details:
    Where context reasonably requires.
  • Third Party:
    Credit reference agencies
    Server Location (where applicable):
    UK
    Further Details:
    Where we deem it necessary.
  1. You can find details of how these third parties use your personal information by looking at their privacy policies, all of which should be available on the relevant websites, or on request. Our storage locations will treat your personal information in accordance with this privacy policy and we shall be responsible to you for any failure on the part of our storage locations to do so.
  2. We require all organisations who we share your data with to respect the security of your personal data and to treat it in accordance with the law. We do not allow any of our service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes (in accordance with the uses set out in the table at paragraph 5) and in accordance with our instructions.
Failing to provide personal data 
    1. Where we need to collect personal data by law, or under the terms of a contract we have with you and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with the products and/or services that you require). In this case, we may have to cancel the provision of such products and/or services to you but we will notify you if this is the case at the time.
Third party links
    1. Our website 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 policy of every website you visit.
Transferring your personal information outside the EEA
    1. The EEA is the European Economic Area, which consists of the EU Members States, Iceland, Liechtenstein and Norway. If we transfer your personal information outside the EEA we have to tell you.  
    2.  We may send your data outside the EEA where we consider it reasonably necessary to do so in connection with the provision of our products and services to you (for example, where a third-party identified at paragraph 6.1 needs us to do so in order to be able to provide us with services related to our use of your data in accordance with the table in paragraph  5). Please refer to the server locations stated at paragraph 6.1.
    3. If we do transfer your personal information outside the EEA, we will make sure that it is treated with an equivalent level of protection as if it was being processed or stored in the EEA and that your rights in respect of such data are unaffected.
Data security
    1. We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. 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. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.
    2. We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator (including the ICO) of a breach where we are legally required to do so.
How long do we keep your personal information 
    1. We will keep your personal information for as long as you are our customer. 
    2. In the event you haven’t ordered any of our products and/or services for a period of 2 years, we may keep the following elements of your personal information for up to a further 2 years (in each case, unless you have requested that we do not do so  in accordance with paragraph 13.6): 
      1. Identity, contact and profile data: to simplify the process of re-ordering our products and services (this reflects the often relatively long gaps between our repeat customers’ orders for our products and services)
      2. Transaction data: to maintain our records and be able to respond to any complaints or queries
      3. Marketing and communications data: to be able to provide you with details of our products and services, in line with your communications preferences.
      4. Any other personal data: to comply with laws applicable to us from time to time.
Marketing 
    1. We may use your personal information to tell you about relevant products and services and any upcoming offers.  
    2. We can only use your personal information to send you marketing messages if we have either your consent or a legitimate interest to do so.  
    3. You can ask us to stop sending you marketing messages at any time – you just need to contact us, or use the opt-out links on any marketing message sent to you. 
    4. We will get your express opt-in consent before we share your personal data with any company outside our group of companies for marketing purposes.  You can ask a third-party company to stop sending you marketing messages at any time, by adjusting your marketing preferences in relation to that company or by using the opt-out links on any marketing message sent to you.
    5. Where you opt out of receiving marketing messages, this will not apply to personal data provided to us as a result of purchasing our products and/or services or any other transaction between you and us. 
Your rights 
    1. You have certain rights which are set out in the law relating to your personal information.  The most important rights are set out below. 

Getting a copy of the information we hold 

    1. You can ask us for a copy of the personal information which we hold about you, by writing to us at hello@cinchstorage.co.uk. This is known as a data subject access request. 
    2. You will not have to pay a fee to access your personal data, unless we believe that your request is clearly unfounded, repetitive or excessive. In such circumstances we can charge a reasonable fee or refuse to comply with your request. 
    3. We will try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month and in that case we will notify you and keep you updated. 

Telling us if information we hold is incorrect 

    1. You have the right to question any information we hold about you that you think is wrong or incomplete.  Please contact us at hello@cinchstorage.co.uk. if you want to do this and we will take reasonable steps to check its accuracy and, where inaccurate, correct it. 

Telling us if you want us to stop using your personal information

    1. You have the right to: 
      1. object to our use of your personal information (known as the right to object); or
      2. ask us to delete the personal information (known as the right to erasure); or 
      3. request the restriction of processing; or
      4. ask us to stop using it if there is no need for us to use it (known as the right to be forgotten). 
    2. There may be legal reasons why we need to keep or use your data, which we will tell you if you contact us in connection with one of the above rights. 

Where we rely on our legitimate interest

    1. 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.

Withdrawing consent

    1. You can withdraw your consent to us using your personal information at any time.  Please contact us at hello@cinchstorage.co.uk if you want to withdraw your consent. If you withdraw your consent, we may not be able to provide you with (or contact you in respect of) our products or services. 

Request a transfer of data 

You may, in certain circumstances, ask us to transfer your personal information to a third party. Please contact us at hello@cinchstorage.co.uk if you would like us to transfer your personal information to a third party and we will let you know whether your circumstances give rise to this right (and/or whether it will be possible for us to do so even if you do not strictly have this right).

Making a complaint 
    1. Please let us know if you are unhappy with how we have used your personal information by contacting us at hello@cinchstorage.co.uk
    2. You also have a right to complain to the Information Commissioner’s Office.  You can find their contact details at www.ico.org.uk.  We would be grateful for the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.