When you provide personally identifiable information to Cornwall Trade and Investment, we may use it to provide you with ongoing information about Cornwall Trade and Investment products and services. Cornwall Trade and Investment will not rent, sell or lease this personally identifiable information to other companies or individuals. You have a right to access, rectify, modify and delete any data referring to you. In order to exercise this right please contact us info@cornwallti.com
Please be aware that we do use tracking code on our website, we’re not using this information for anything other than to simply monitor the traffic on our site to try and improve the user experience. As part of this, using our website means that a temporary cookie will be used to track your visit whilst on our website.
We also use some tracking software which helps identify who’s visiting our site, so from time to time we’ll pick up the phone and make sure you’ve found everything you’re looking for on our website.
Cookies are essential small files which store information regarding your visit, it’ll collect data on how you’ve interacted with our site and allows us to view how users in turn interact with our site, our primary aim is to use this data to help improve our site and the content which users are looking for.
Cornwall Trade and Investment (Cornwall Trade and Investment) is part of Cornwall Development Company (CDC), an arms-length economic development provision of Cornwall Council and part of the Corserv Ltd group of companies. Cornwall Trade and Investment is funded by the European Regional Development Fund (ERDF) contract with the Ministry for Housing, Communities and Local Government (MHCLG) under Funding Agreement Reference Project Number: O5R1P00003 and Cornwall Council.
Cornwall Trade and Investment’s existence is twofold; firstly to help and encourage companies and investors without a presence in Cornwall and the Isles of Scilly (C&IoS) to establish small and medium-sized enterprises (SMEs) within the region; providing relevant information, making introductions, and providing advice on the financial assistance available. Secondly, the aim is to promote C&IoS as a business destination of choice through raising the profile of Cornwall as a location for ‘next generation’ businesses – enhancing the national and international image of the region.
This website is part of the commercial service we provide you under our contractual agreement with MHCLG and you; the data you provide us is for the purpose of accessing the Cornwall Trade and Investment programme.
Cornwall Trade and Investment respects your privacy and is committed to protecting your personal data. This privacy notice will inform you as to how we look after your personal data when you visit our website (regardless of where you visit it from) and tell you about your privacy rights and how the law protects you.
This privacy notice aims to give you information on how Cornwall Trade and Investment collects and processes your personal data through your use of this website, including any data you may provide through this website when you sign up to a newsletter, registering or completion and submission of any application.
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 notice together with any other privacy notice or fair processing notice 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 notice supplements the other notices and is not intended to override them.
We have appointed a Data Protection Officer (DPO), Richard Zmuda, CORSERV Ltd Group Company Secretary, to oversee compliance with this privacy notice and the data protection legislation in general.
The Data Control Officer (DCO) is Nicky Pooley, CDC. If you have any questions about this privacy notice, or how we handle your personal information, please contact the DCO initially. You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK supervisory authority 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 please contact us in the first instance.
Our full details are:
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.
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 notice 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 follows:
Identity Data includes first name, maiden name, last name, username or similar identifier, marital status, title, date of birth and gender.
Contact Data includes address, email address and telephone numbers.
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 your username and password, your interests, preferences, feedback and survey responses.
Usage Data includes information about how you use our website and services.
Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.
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. 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 notice.
We only collect anonymised Special Categories of Personal Data about your company employees confined to ethnicity, age and disability with the option to choose “prefer not to say”. This is a requirement from the contract we have with MHCLG in delivering this programme. Nor do we collect any information about criminal convictions and offences.
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.
We use different methods to collect data from and about you including through:
Direct interactions. You may give us your Identity and/or Contact Data by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:
Automated technologies or interactions. As you interact with our website, we may automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies and Google Analytics.
Google Analytics. When someone visits this site we use a third party service, Google Analytics, to collect standard internet log information and details of visitor behaviour patterns. We do this to find out things such as the number of visitors to the various parts of the site. This information is only processed in a way which does not identify anyone. We do not make, and do not allow Google to make, any attempt to find out the identities of those visiting our website. For more information on Google Analytics cookies, see the official Google Analytics page.
Cookies. Cookies are small text files that are placed on your computer by websites that you visit. For more information on the cookies used on this site, read our Cookies Policy.
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 to perform the contract we are about to enter into or have entered into with you.
Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
Where we need to comply with a legal or regulatory obligation.
Information you supply using any electronic forms on this website will only be used for the purpose(s) stated on the form.
Information you provide in emails to us will only be used for the purpose (which we reasonably believe) that you give it to us for.
Information you provide us with may be used for statistical research but will not be used in any way (beyond its original purpose) which enables you to be identified.
Generally we do not rely on consent as a legal basis for processing your personal data other than in relation, if applicable, to sending third party direct marketing communications to you via email or text message or for the purposes of providing you with our newsletter. You have the right to withdraw consent to marketing at any time by contacting us.
We collect, use, hold and share where necessary, information for the following purposes:
It applies to information we collect about:
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.
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 | (a) Performance of a contract with you and in accordance with our contractual requirements with MHCLG (b) Necessary for our legitimate interests (to study how customers use our products/services, to develop them and grow our business) |
If you register for a newsletter | (a) Identity (b) Contact | (a) Performance of a contract with you and in accordance with our contractual requirements with MHCLG (b) Necessary for our legitimate interests (to study how customers use our products/services, to develop them and grow our business) |
To enable you to provide information to complete any application for our services | (a) Identity (b) Contact (c) Profile (d) Personal credit check where a company credit check cannot be obtained (e) Anonymised ethnicity, age and disability | (a) Performance of a contract with you and in accordance with our contractual requirements with MHCLG (b) Necessary for our legitimate interests (to study how customers use our products/services, to develop them and grow our business) |
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 or take a survey | (a) Identity (b) Contact (c) Profile (d) Marketing and Communications | (a) Performance of a contract with you and in accordance with our contractual requirements with MHCLG (b) Necessary for our legitimate interests (to study how customers use our products/services, to develop them and grow our business) (c) Necessary to comply with a legal obligation |
To enable you to complete a survey | a) Identity (b) Contact (c) Profile (d) Usage (e) Marketing and Communications | (a) Performance of a contract with you and in accordance with our contractual requirements with MHCLG (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 use data analytics to improve our website, 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 services that may be of interest to you | (a) Identity (b) Contact (c) Technical (d) Usage (e) Profile | Necessary for our legitimate interests (to develop our products/services and grow our business) |
We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising of other programmes offered by CDC or selected Third Parties which we think might be of benefit to you commercially. You have the right to opt out or unsubscribe to these at any point.
You can ask us or third parties to stop sending you marketing messages at any time by logging into the website and checking or unchecking relevant boxes to adjust your marketing preferences or by following the opt-out links on any marketing message sent to you or by contacting us at any time.
Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of the services we have provided you.
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.
We may have to share your personal data with the parties set out below for the purposes set out in the table in paragraph 4 above.
Your data may be shared with the following third parties:
Your identity and contact details may be shared within CDC only for the purposes of making you aware of other services that might be of interest to you. Specific information provided as part of an application process will not be shared without your written agreement.
CORSERV or Cornwall Council or accessed by their appointed auditors as a consequence of our funding requirements.
Cornwall and Isles of Scilly Growth Hub and other Service providers acting as processors based in the UK who provide business/commercial support activities as this reduces the need to repeat your information.
MHCLG and associated auditors. This forms part of our contractual agreement with MHCLG.
HM Revenue & Customs, regulators and other authorities acting as processors or joint controllers based in the United Kingdom who require reporting of processing activities in certain circumstances.
Department of International Trade (DIT) if you are located outside the United Kingdom.
Your information may be provided to other companies who provide administration services on our behalf, for example a mailing house or email marketing provider but solely for the purpose of providing you with the information you have requested and not for marketing purposes by anyone other than Cornwall Trade and Investment.
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.
We do not transfer your personal data outside the European Economic Area (EEA).
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.
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.
We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.
Information that is not related to an application and associated services will be held until the end of the Cornwall Trade and Investment programme 30 September 2021. The information will be destroyed within 3 months thereafter.
Information collected and stored directly associated with the grant application and associated services will be held until 31 December 2033 in accordance with our contract with MHCLG. The information will be destroyed within 3 months thereafter.
Under certain circumstances, you have rights under data protection laws in relation to your personal data.
You have the right to:
If you wish to exercise any of the rights set out above, please contact us.
When we receive a complaint from a person we make up a file, manual or electronic, containing the details of the complaint and associated investigation. This normally contains the identity of the complainant and any other individuals involved in the complaint.
We will only use the personal information we collect to process the complaint and to check on the level of service we provide. We may compile and publish statistics highlighting information such as the number of complaints we receive and time taken to resolve, but not in a form which identifies anyone.
We usually have to disclose the complainant’s identity to the department/service/programme/project which the complaint is about, including third parties such as contractors, in order to fully understand and resolve an issue. If a complainant doesn’t want information identifying him or her to be disclosed, we will try to respect that. However, it may not be possible to handle a complaint on an anonymous basis.
We will keep personal information contained in complaint files in line with our retention policy. Local Government Ombudsmen complaints are retained for ten years from closure. Complaint files are retained in a secure environment and access to it will be restricted according to the ‘need to know’ principle.
Similarly, where enquiries are submitted to us we will only use the information supplied to us to deal with the enquiry and any subsequent issues and to check on the level of service we provide.
You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.
We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.
We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.
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.
Performance of Contract means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.
Comply with a legal or regulatory obligation means processing your personal data where it is necessary for compliance with a legal or regulatory obligation that we are subject to.
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