Introduction
Cavello Group Limited ("Cavello Group", "we", "our" or "us") respects your privacy and is committed to the protection of your personal information.
This privacy policy tells you how we look after your personal data when you visit our website, regardless of where you visit it from, what your rights are in relation to your personal data and how the law protects you.
Controller
Cavello Group is made up of different legal entities, details of which can be found here. This privacy policy is issued on behalf of the Cavello Group Group so when we mention "Cavello Group", "we", "us" or "our" in this privacy policy, we are referring to the relevant company in the Cavello Group Group responsible for processing your data. We will let you know which entity will be the controller for your data when you purchase a product or service with us. Cavello Group UK Limited (Registered Number 12325782) of Cavello Group House, Lamport Drive, Heartlands Business Park, Daventry, Northamptonshire, NN11 8YH is the controller and responsible for this website.
We have appointed a data privacy manager who is responsible for overseeing questions in relation to this privacy policy. If you have any questions about this privacy policy, including any requests to exercise your rights please contact our data privacy manager using the details below.
Purpose of this privacy policy
This privacy policy sets out the basis by which any personal information we collect from you, or that you provide to us (including through this website or when you purchase a product or service), will be processed by us in our capacity as controller, why we use such information, who we share it with and the rights to which you may be entitled. Please read the following carefully to understand our views and practices regarding your personal information and how we will treat it.
This website is not intended for children and we do not knowingly collect data relating to children.
It is important that you read this privacy policy together with any other privacy policy or fair processing policy we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. This privacy policy supplements other notices and privacy policies and is not intended to override them.
Contact Details
Questions, comments and requests regarding this privacy policy or our privacy practices can be directed to the data privacy manager in the following ways:
Email: enquires@cavellogroup.com
Postal Address: Data Privacy Manager, Cavello Group UK, Cavello Group House, Lamport
Drive,
Heartlands Business Park, Daventry, Northamptonshire, NN11 8YH.
Complaints
You have the right to make a complaint at any time to the Information Commissioner's Office (ICO), the UK regulator for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO, so in the first instance please email enquires@cavellogroup.com
Changes to this privacy policy and your duty to inform us of changes
We keep our privacy policy under regular review. If we change anything important about this policy (the information we collect, how we use it or why) we will highlight those changes at the top of the policy and provide a prominent link to it for a reasonable length of time following the change. This version was last updated in May 2022.
It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.
Changes to this privacy policy and your duty to inform us of changes
We keep our privacy policy under regular review. If we change anything important about this policy (the information we collect, how we use it or why) we will highlight those changes at the top of the policy and provide a prominent link to it for a reasonable length of time following the change. This version was last updated in May 2022.
It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.
Third Party Links
This 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.
Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).
We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:
- Identity Data includes first name, last name, username or similar identifier, marital status, title, date of birth, gender any relevant registration details.
- Contact Data includes address, email address and telephone numbers.
- Financial Data includes bank account and payment card details.
- Transaction Data includes details about payments to and from you and other details of products and services you have purchased from us including your property details and any claims details.
- Technical Data includes 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 this website.
- Profile Data includes purchases or orders made by you, your interests, preferences, feedback and survey responses.
- Usage Data includes information about how you use our website, products and services.
- Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.
- Vulnerability data – information about health, life events, resilience and capability that helps us identify if you might be a vulnerable person so that we can better meet your needs.
We may also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data could be derived from your personal data but is not considered personal data in law as this data will 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. 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.
If you fail to provide personal data
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 goods or services). In this case, we may have to cancel a product or service you have with us but we will notify you if this is the case at the time.
How is your personal data collected?
We use different methods to collect data from and about you including through:
- Direct interactions. You may give us your Identity, Contact Details by filling in
forms or by corresponding with us by post, phone, email or otherwise. This includes personal data
you provide when you:
- apply for our products or services;
- You register for, enquire about or enrol on any of our events or exhibitions;
- create an account on our website or manage your preferences through our website;
- subscribe to our newsletters or other publications;
- request marketing to be sent to you;
- enter a competition, promotion or survey; or
- give us feedback or contact us.
- Automated technologies or interactions. As you interact with our website, we will automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies, server logs and other similar technologies. Please see our information on cookies for further details.
- Third parties or publicly available sources. We may on occasion receive personal
data about you from various third parties and public sources as set out below:
- Technical Data from the following parties:
- analytics providers such as Google based outside the UK;
- advertising networks; and
- search information providers.
- Identity, Contact and Transaction Data from providers of building warranty and insurance providers
- Identity Data from third party providers of identity verification services for anti-fraud and anti-money laundering screening.
- Contact, Financial and Transaction Data from providers of technical, payment and delivery services.
- Identity and Contact Data from publicly available sources such as Companies House and the Electoral Register based inside the UK.
- Technical Data from the following parties:
We collect and use your personal information for a variety of reasons. However, rest assured we will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:
- Where we need some information to enter into and perform our contract with you – for example your Transaction Data in connection with claims under our Buildmark products, Identity, Contact and Financial Data for builders and developers.
- Some information processing is required to comply with our legal obligations due to our anti-fraud and anti-money laundering screening obligations or in the public interest such as making sure we verify our customers' identities. We are also required to process certain data in order to comply with the legal requirements placed upon us by the Insurance Distribution Directive ((EU) 2016/97). Your personal information may also be processed if it is necessary on reasonable request by a law enforcement or regulatory authority, body or agency, to enforce or apply the terms of any contract or legal obligation with us or in the defence of a legal claim. We will not delete personal information if relevant to an investigation or a dispute. It will continue to be stored until those issues are fully resolved.
- Other information we collect because we have legitimate business interests. Our legitimate
business interests include:
- Registering you for, and communicating with you about, our events and exhibitions
- providing you with up-to-date technical information
- keeping you updated with regard to our fees and charges
- ensuring that our regulatory and legal obligations are complied with
- telling you about the various products and services that we provide
- making sure our records are up-to-date
- operating incentive programmes to encourage excellence
- making sure our products and services are paid for promptly and in full
- understanding how you use our products, services, training and materials
- obtaining and distributing feedback relating to quality of goods or services provided
- understanding and responding to your feedback
- providing communications relating to market and industry issues
- analysing the services our customers want
- improving our services
- receiving information from other entities in the Cavello Group Group about shared customers
Generally, we do not rely on consent as a legal basis for processing your personal data although we will get your consent before sharing your personal information with third party organisations for their marketing purposes, where you give us your consent, this consent can be withdrawn at any time through the Cavello Group Preference Centre which can be accessed via a link on our emails or manually by emailing enquires@cavellogroup.com.
Purposes for which we will use your personal data
We use your personal information to conduct our business, to provide access to our on-line portals, to enable you to set up and operate an account with us, to enable you to access, use and/or purchase our services and products, to undertake surveys and for the purposes set out in more detail in this section.
We have set out below, in a table format, a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.
Please note that 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 contact us 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.
Purpose/Activity | Type of data | Lawful basis for processing including basis of legitimate interest |
---|---|---|
To register you as a new customer | (a) Identity (b) Contact |
To process and deliver our products or services to you |
To process and deliver our products or services to you including: (a) Manage payments, fees and charges (b) Collect and recover money owed to us (c) administer claims under any warranty or guarantee including through BuildMark |
(a) Identity (b) Contact (c) Financial (d) Transaction (e) Marketing and Communications |
(a) Performance of a contract with you (b) Necessary for our legitimate interests (to recover debts due to us) |
To manage our relationship with you which will include: (a) Notifying you about changes to our terms or privacy policy (b) Asking you to leave a review, take a survey or provide other feedback |
(a) Identity (b) Contact (c) Profile (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 | (a) Identity (b) Contact (c) Profile (d) Usage (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 business) |
To administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data) | (a) Identity (b) Contact (c) Technical |
(a) Necessary for our legitimate interests (for running our business, 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 website content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you | (a) Identity (b) Contact (c) Profile (d) Usage (e) Marketing and Communications (f) Technical |
Necessary for our legitimate interests (to study how customers use our products/services, to develop them, to grow our business and to inform our marketing strategy) |
To use data analytics to improve our website, products/services, marketing, customer relationships and experiences | (a) Technical (b) Usage |
Necessary for our legitimate interests (to define types of customers for our products and services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy) |
To make suggestions and recommendations to you about goods or services that may be of interest to you | (a) Identity (b) Contact (c) Technical (d) Usage (e) Profile (f) Marketing and Communications |
Necessary for our legitimate interests (to develop our products/services and grow our business) |
To administer our contract with you where you are a supplier or developer providing products
or services to us (a) Manage payments, fees and charges (b) Ensure quality of service |
(a) Identity (b) Contract (c) Financial |
(a) Performance of a contract with you (b) Necessary for our legitimate interests (to ensure we are provided with a quality service and to administer our relationship with our service providers) |
To register you for our events and exhibitions and to communicate with you about the events and exhibitions which you have registered for | (a) Identity (b) Contact (c) Vulnerability (if provided) |
(a) Necessary for our legitimate interests (to enable us to run effective events and
exhibitions); (b) Explicit Consent (only where you provide us with your Vulnerability data so that we can better meet your needs in relation to that exhibition or event). |
Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give you the best service/product and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us.
We will only document any vulnerabilities you have declared where you consent to us doing so and then only so as to enable us to help better meet your needs and to comply with regulatory requirements about how we treat vulnerable people.
Third-party marketing
We will get your express opt-in consent before we share your personal data with any third party for marketing purposes.
Opting out
You can ask us or third parties to stop sending you marketing messages at any time by logging into the Cavello Group Preference Centre which can be accessed via a link on our emails or manually by emailing enquires@cavellogroup.com.
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 get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.
If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.
Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.
How long will you use my personal data for?
We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal data for a longer period in the event of a complaint, warranty claim or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.
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, regulatory, tax, accounting or other requirements.
Details of retention periods for different aspects of your personal data are available in our retention policy which you can request from us by contacting us.
In some circumstances you can ask us to delete your data: see your rights below for further information.
In some circumstances we will 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.
We will take all reasonable care to keep your data secure and prevent unauthorised access to it. We have put in place appropriate security measures to prevent your personal data from being accidentally lose, used or accessed in an unauthorised way, altered or disclosed. All information you provide to us is stored on our secure servers. 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 process your personal data on our instructions and they are subject to a duty of confidentiality.
Where we have given you (or where you have chosen) a password which enables you to access certain parts of our website, you are responsible for keeping this password confidential. We ask you not to share a password with anyone.
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.
Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your data, we cannot guarantee the security of your data transmitted to our website; any transmission is at your own risk. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorised access.
We may share your personal data with the parties set out below for the purposes set out in the table Purposes for which we will use your personal data above.
- Other companies in the Cavello Group Group and who are based in the UK so that we can provide the best service across the Cavello Group Group in accordance with the legitimate interests of the Cavello Group Group.
- We may also disclose your personal data to third parties in the following circumstances:
- if Cavello Group or substantially all of its assets are acquired by a third party, in which case personal data held by it about its customers will be one of the transferred assets
- if we seek to acquire other businesses or merge with them.
- if we are defending a legal claim your personal data may be transferred as required in connection with defending such claim
- if we are under a duty to disclose or share your personal data in order to comply with any legal obligations, and other agreements; or to protect the rights, property, or safety of Cavello Group, our customers or others.
- if necessary to our service providers acting as processors based in the UK who provide warranty support, [IT and system administration services].
- where required by our professional advisers acting as processors or joint controllers including lawyers, bankers, auditors and insurers based in the UK who provide consultancy, banking, legal, insurance and accounting services.
- if required by HM Revenue & Customs, regulators and other authorities based in the UK who require reporting of processing activities in certain circumstances.
- for the purposes of ensuring fraud prevention and meeting our legal obligations to fraud prevention agencies and anti-money laundering screening providers.
We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.
Your personal data may be shared if it is made anonymous and aggregated, as in such circumstances the information will cease to be personal data.
International Transfers
We will only transfer data to jurisdictions outside the UK where there are appropriate safeguards in place to provide an adequate level of protection for your information.
Some of the external third parties referenced above may be based outside the UK so their processing of your personal data will involve a transfer of data outside the UK.
Whenever we transfer your personal data out of the UK, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:
- We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data.
- Where we use certain service providers, we may use specific contracts approved for use in the UK which give personal data the same protection it has in the UK.
Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the UK.
We set out below the rights you have over your information and how you can exercise those rights.
Some of the rights listed below will only apply in certain circumstances as explained below
You have the right to:
Our Site is directed to people residing in the United Kingdom. We do not represent that content available on or through our Site is appropriate for use or available in other locations.