The Legal Stuff
Last Update May 2021
CPM United Kingdom Limited, CPM Group including shopt, Axis and Hyphen (“we”, “us” or “our”) respect your privacy. We are committed to safeguarding your privacy and protecting your information against unauthorized use.
1. Who processes your personal information?
This Policy applies to the processing of personal data by CPM India, Axis or any other CPM Group of Companies outside of the EU and the UK. Please see our separate GDPR policy which applies to the processing of personal data by CPM Group in the European Union (EU) and the UK and other jurisdictions where our companies operate.
2. Purpose of this policy
This Policy explains our approach to any personal information that we might collect from you using this website (the “Site”) and any personal information about you we might collect/process in other situations or interactions with us, and the purposes for which we process your personal information.
This Policy will inform you of the nature of the personal information about you that is processed by us and how you can exercise your rights. This Policy is intended to assist you in making informed decisions when using the Site or otherwise providing personal information to us or in other situations where we may process your personal information.
3. How to contact us?
• sending an e-mail to: [firstname.lastname@example.org]; or
• calling us on: +44  20 3481 1020
• sending a letter addressed to: Bankside 3, 90-100 Southwark Street, London SE1 0SW
4. Type of personal data we collect/process
When we talk about personal data we mean any information which relates to an identified or identifiable living individual. Individuals might be identified by reference to a name, an identification number, location data, an online identifier (such as an IP address) or to other factors that are specific to them, such as their physical appearance. Categories of personal data we may collect and process about you include:
• contact information (e.g. name, physical address, telephone number, email address);
• your date of birth;
• information about your employment or education history;
• information for hiring talent and human resources (e.g. work eligibility status, financial account information, government-issued identification information or dietary requirements);
• any additional data that may identify you which you submit to us.
5. How we use personal data?
Our primary goal in collecting personal information from you is to:
• verify your identity;
• help us improve our products and services and develop and market new products and services;
• carry out requests made by you on the Site;
• investigate or settle inquiries or disputes;
• comply with any applicable law, court order, other judicial process, or the requirements of a regulator;
• enforce our agreements with you;
• protect the rights, property or safety of us or third parties, including our other clients and users of the Site;
• provide support for the provision of our Services; and
• use as otherwise required or permitted by law.
We set out in more detail below the specific ways in which we may use your personal data
All Service Enquiries. For more information click here
Our Site uses various user interfaces to allow you to request information about our products and services: these include printed and electronic enquiry forms and a telephone enquiry service. Contact information may be requested in each case, together with details of other personal information that is relevant to your enquiry. This information is used in order to enable us to respond to your requests.
Client Administration. For more information click here
We may collect personal data about our client and potential client contacts to enable us to respond to client requests, to administer client accounts with us, to conduct credit checks (if permitted by applicable law), and to verify and carry out financial transactions for payments made to us.
Recruitment. For more information click here
If individuals apply for a job with us or otherwise express an interest in working for us, we will collect contact details and CV or resume information from the individual. We use such personal data for the following purposes: a) to assess the individual’s suitability for any position for which they applied (or future positions for which we think the individual may be suitable) including employment or freelancer positions, summer placements or internships and also any business support or services role whether such application has been received by us online, via email or by hard copy or in person application; b) to take any steps necessary to enter into any contract of employment (or otherwise) with the individual; c) to comply with any regulatory or legal obligations in relation to any such application; and d) to review our equal opportunity profile in accordance with applicable legislation. We do not discriminate on the grounds of gender, race, ethnic origin, age, religion, sexual orientation, disability or any other basis covered by local legislation.
Marketing communications. For more information click here
We may carry out marketing activities using an individual’s personal data. In particular, we may use personal data to form a view on what we think the individual may want or need, or what may be of interest to the individual. We may use that information to provide individuals with marketing information about our events and services we feel may be of interest. We may also provide individuals with information about media and public relations events.
Contact Databases click here
We collect and maintain data bases containing information about retailers, SME businesses, on-trade premise and consumers which we use to help our clients increase and manage distribution of their products. We may collect this information independently or as data processors acting on behalf of our clients. Such information may include an individual’s name and personal contact information, or business contact details. The type of personal data that we collect may vary depending on the services we are providing to our client. Data collected will only always be specific and not excessive to fulfil the data processing task. This information may be information that is purchased by our client or our business, voluntarily supplied to us by those individuals through our Site, during a face to face meeting, or in other situations such as a phone call to our contact centre or email contact via a client website.
Business administration and legal compliance. For more information click here
We may use an individual’s personal data for the following business administration and legal compliance purposes:
• to facilitate the operation or effective management of our group of businesses;
• to enforce or protect our legal rights;
• to deal with complaints;
• to protect the rights of third parties (including where health or security of an individual is endangered (e.g. a fire); and
• in connection with a business transition or sale such as a merger, re-organisation, acquisition by another company, or sale of all or a portion of our assets.
Visiting our premises. For more information click here
If an individual visits any of our premises we may collect contact information as part of our sign in process. We may also capture their image on our surveillance camera or CCTV.
6. Sharing your personal data
Please note, the types of third parties we share your personal data with set out above is non-exhaustive and there may be circumstances where we need to share personal information with other third parties in order to operate our Sites and to provide our services.
We may share your personal information with any of our group affiliates, or with our agents, partners, clients, contractors, professional advisors or government or regulatory bodies for the following purposes: (a) provide our services to clients or otherwise receive assistance in processing transactions; (b) fulfilment of requests for information, receiving and sending communications, updating marketing lists, analysing data; (c) provision of IT and other support services; (d) to facilitate the operation and effective management of our group of businesses; (e) comply with a legal obligation or in connection with a legal claim or dispute or to otherwise protect our legal rights; (f) assistance in other ancillary to the operation of tasks, from time to time. Our agents, partners and contractors will use your information to the extent necessary to perform their functions.
We will not sell your personal information to other companies and we will not share it with other companies for them to use without your consent, except in the circumstances listed above or in connection with the sale or merger of CPM or the division or office responsible for the services.
We will notify you of any other circumstances where we would share your information on a case by case basis.
7. How do we obtain your consent?
Where our use of your personal information requires your consent, you can provide such consent:
• at the time we collect your personal information following the instructions provided; or
Where our use of your personal information requires your consent, you can provide such consent:
Every time a user visits our Site, web analytics software provided by a third party generates an anonymous analytical cookie. These cookies can tell us whether or not you have visited the Site before. Your browser will tell us if you have these cookies, and if you don’t, we generate new ones. This allows us to track how many individual unique users we have, and how often they visit the Site. Unless you have previously downloaded content or subscribed to one of our newsletters on our Site, these cookies cannot be used to identify individuals, they are used for statistical purposes only. If you have previously subscribed or downloaded content from our site, we will know the details you gave us for this, such as name and email address.
Cookies used include:
The expiration date is varying on different analytics tools between 1 and 3 years
User data tied to cookies and advertising IDs is also used to detect and prevent ad fraud and ensure that users don’t see ads that they’ve blocked in the past. In these cases, or in cases where Google stores this data on behalf of its customers (e.g. in Google Analytics), data may be stored for periods longer than those specified above.
SOCIAL MEDIA COOKIES
Social Media providers use electronic tools including ‘Cookies’, ‘Social Plugins’ and ‘Tracking Pixels’ to track your browsing habits, likes and social interactions across the internet in order to build up a profile about you. We enable these on our site to facilitate social sharing.
The expiry date for Twitter and LinkedIn cookies is 30 days and 90 days for Facebook cookies.
9. Access choice and means
We provide you with reasonable access to the personal information maintained about you. We also provide you with a reasonable opportunity to correct, amend or delete the information where it is inaccurate. We may limit or deny access to personal information where the burden or expense of providing access would be disproportionate to the risks to your privacy in the case in question, or where the rights of third persons would be violated.
We generally offer you the opportunity to choose whether your personal information may be (a) disclosed to third-party controllers or (b) used for a purpose that is materially different from the purposes for which the information was originally collected or subsequently authorized by you.
10. Opt out and unwanted communications
To opt-out of any future promotional or marketing communications or any other commercial communications from us, you should send a request to us at the contact information in the section entitled contact details.
11. Third party links and services
Your browsing and interaction on any other websites, or your dealings with any other third-party service provider, is subject to that website’s or third-party service provider’s own rules and policies.
We do not monitor, control, or endorse the privacy practices of any third parties.
We encourage you to become familiar with the privacy practices of every website you visit or third party service provider that you deal with and to contact them if you have any questions about their respective privacy policies and practices.
12. How long do we keep your personal information for?
We hold your personal information only as long as we have a valid legal reason to do so, which includes providing you with the services you have requested, meeting our legal and regulatory obligations, resolving disputes and enforcing our agreements.
The length of time for which we keep different types of personal information can vary, depending on why we originally obtained them, the reason we process them and the legal requirements that apply to them.
If any personal data is only useful for a short period (e.g. for a specific marketing campaign or in relation to recruitment), we will delete it at the end of that period. Please note that if you are an unsuccessful candidate we may keep your information for a short period.
If you have opted out of receiving marketing communications from us, we will need to retain certain personal data on a suppression list so that we know not to send you further marketing communications in the future.
13. Confidentiality and security of your personal information
We are committed to keeping the personal information you provide to us secure and we will take reasonable precautions to protect your personal information from loss, misuse or alteration. For more information click here
We have implemented information security policies, rules and technical measures to protect the personal information that we have under our control from:
• unauthorised access;
• improper use or disclosure;
• unauthorised modification; and
• unlawful destruction or accidental loss.
All of our employees and data processors (i.e. those who process your personal information on our behalf, for the purposes listed above), who have access to, and are associated with the processing of personal information, are obliged to respect the confidentiality of the personal information of all users of our Services.