Privacy Policy

Your personal data – what is it?

“Personal data” is any information about a living individual which allows them to be identified from that data (for example a name, photographs, videos, email address, or address). Identification can be directly using the data itself or by combining it with other information which helps to identify a living individual. The processing of personal data is governed by legislation relating to personal data which applies in the United Kingdom including the General Data Protection Regulation (the “GDPR) and other legislation relating to personal data and rights such as the Human Rights Act.

Who are we?

This Privacy Notice is provided to you by GOLD & CIRCLE, which is the data controller for your data.

Other data controllers the company works with:

  • Suppliers 

  • Contractors 


We may need to share your personal data we hold with them so that they can carry out their responsibilities to the company. If we and the other data controllers listed above are processing your data jointly for the same purposes, then the company and the other data controllers may be “joint data controllers” which means we are all collectively responsible to you for your data. Where each of the parties listed above are processing your data for their own independent purposes then each of us will be independently responsible to you and if you have any questions, wish to exercise any of your rights (see below) or wish to raise a complaint, you should do so directly to the relevant data controller. 
A description of what personal data the company processes and for what purposes is set out in this Privacy Notice. 


The company will process some or all of the following personal data where necessary to perform its tasks:

  • Names, title
  • Contact details such as telephone numbers, addresses, and email addresses; 
correspondences over email in the cases where you have contacted us
  • Where you pay for activities or services, financial identifiers such as credit/debit card numbers, payment/transaction identifiers in addition to your purchase history
  • Records of you entering competitions with us
  • Marketing options such as completing surveys, newsletter subscription and account registration.
  • Device Information using the following technologies:
    - “Cookies” are data files that are placed on your device or computer and often include an anonymous unique identifier. For more information about cookies, and how to disable cookies, visit http://www.allaboutcookies.org.
    - “Log files” track actions occurring on the Site, and collect data including your IP address, browser type, Internet service provider, referring/exit pages, and date/time stamps.
    - “Web beacons”, “tags”, and “pixels” are electronic files used to record information about how you browse the Site.
  • When you visit the Site, we automatically collect certain information about your device, including information about your web browser, IP address, time zone, and some of the cookies that are installed on your device. Additionally, as you browse the Site, we collect information including but not limited to the individual web pages or products that you view, what websites or search terms referred you to the Site, and information about how you interact with the Site. We refer to this automatically-collected information as “Device Information”.
  • Data about you from third parties including but not limited to content you viewed, adverts you have seen.

The company will comply with the General Data Protection Regulation 2018. This says that the personal data we hold about you must be:

  • Used lawfully, fairly and in a transparent way. 

  • Collected only for valid purposes that we have clearly explained to you and not used in any way 
that is incompatible with those purposes. 

  • Relevant to the purposes we have told you about and limited only to those purposes. 

  • Accurate and kept up to date. 

  • Kept only as long as necessary for the purposes we have told you about. 

  • Kept and destroyed securely including ensuring that appropriate technical and security measures 
are in place to protect your personal data from loss, misuse, unauthorized access and disclosure. 


We use your personal data for some or all of the following purposes:

  • To deliver services like fulfilling your orders
, sending out newsletters, processing competition information
  • To understand your needs to provide the services that you request and to understand what we can 
do for you and inform you of other relevant services;
  • To confirm your identity 

  • To contact you by post, email, social media, phone/SMS
  • To help us build up a picture of how we are performing
  • To enable us to meet all legal and statutory obligations and powers 

  • To carry out comprehensive safeguarding procedures (including due diligence, complaints 
handling, security incidents and misrepresentation, legal purposes) in accordance with best practices
  • To maintain our own accounts and records; 

  • To seek your views, opinions or comments; 

  • To send you communications which you have requested and that may be of interest to you. These may include information about new products or initiatives and we will use relevant technologies to help us follow up on their effectiveness.
  • To allow the statistical analysis of data so we can plan the provision of services.

  • To place tracking technologies ("Cookies") in order to present you with ore customized content

What is the legal basis for processing your personal data?

  • The company has certain powers and obligations. Most of your personal data is processed for compliance with a legal obligation which includes the discharge of the company’s statutory functions and powers. We will always take into account your interests and rights. This Privacy Notice sets out your rights and the company’s obligations to you. 
We may process personal data if it is necessary for the performance of a contract with you, or to take steps to enter into a contract. 
Sometimes the use of your personal data requires your consent. We will first obtain your consent to that use. 


Sharing your personal data

This section provides information about the trusted third parties with whom the company may share your personal data. These third parties have an obligation to put in place appropriate security measures and will be responsible to you directly for the manner in which they process and protect your personal data. It is likely that we will need to share your data with some or all of the following (but only where necessary): 


  • The data controllers listed above under the heading “Other data controllers thecompany works with”;
  • Our agents, suppliers and contractors. For example, we may ask a commercial provider to publish or distribute newsletters on our behalf, to maintain our database software; to assist with marketing and social media tasks or performance-related analytics.
  • On occasion, other companies with which we are carrying out joint ventures

How long do we keep your personal data?

We will keep some records permanently if we are legally required to do so. We may keep some other records for an extended period of time. For example, it is currently best practice to keep financial records for a minimum period of 8 years to support HMRC audits or provide tax information. We may have legal obligations to retain some data in connection with our statutory obligations. The company is permitted to retain data in order to defend or pursue claims. In some cases the law imposes a time limit for such claims (for example 6 years for contract claims). We will retain some personal data for this purpose as long as we believe it is necessary to be able to defend or pursue a claim. In general, we will endeavour to keep data only for as long as we need it. This means that we will delete it when it is no longer needed.

Your rights and your personal data

You have the following rights with respect to your personal data: 
When exercising any of the rights listed below, in order to process your request, we may need to verify your identity for your security. In such cases we will need you to respond with proof of your identity before you can exercise these rights. 


1) The right to access personal data we hold on you

At any point you can contact us to request the personal data we hold on you as well as why we have that personal data, who has access to the personal data and where we obtained the personal data from. Once we have received your request we will respond within 30 days. 


There are no fees or charges for the first request but additional requests for the same personal data or requests which are manifestly unfounded or excessive may be subject to an administrative fee. 


2) The right to correct and update the personal data we hold on you

If the data we hold on you is out of date, incomplete or incorrect, you can inform us and your data will be updated.

3) The right to have your personal data erased

If you feel that we should no longer be using your personal data or that we are unlawfully using your personal data, you can request that we erase the personal data we hold.

When we receive your request we will confirm whether the personal data has been deleted or the reason why it cannot be deleted (for example because we need it for to comply with a legal obligation).

4) The right to object to processing of your personal data or to restrict it to certain purposes only

You have the right to request that we stop processing your personal data or ask us to restrict processing. Upon receiving the request we will contact you and let you know if we are able to comply or if we have a legal obligation to continue to process your data.

5) The right to data portability

You have the right to request that we transfer some of your data to another controller. We will comply with your request, where it is feasible to do so, within 30 days of receiving your request.

6) The right to withdraw your consent to the processing at any time for any processing of data to which consent was obtained

7) The right to lodge a complaint with the Information Commissioner’s Office.

You can contact the Information Commissioners Office on 0303 123 1113 or via email https://ico.org.uk/global/contact-us/email/ or at the Information Commissioner's Office, Wycliffe House, Water Lane, Wilmslow, Cheshire SK9 5AF.

Transfer of Data Abroad

Any personal data transferred to countries or territories outside the European Economic Area (“EEA”) will only be placed on systems complying with measures giving equivalent protection of personal rights either through international agreements or contracts approved by the European Union.

Further processing

If we wish to use your personal data for a new purpose, not covered by this Privacy Notice, then we will provide you with a new notice explaining this new use prior to commencing the processing and setting out the relevant purposes and processing conditions. Where and whenever necessary, we will seek your prior consent to the new processing.

Changes to this notice

We keep this Privacy Notice under regular review and we will place any updates on goldandcircle.com. This Notice was last updated in September 2018.

Contact Details

Please contact us if you have any questions about this Privacy Notice or the personal data we hold about you or to exercise all relevant rights, queries or complaints at hello@goldandcircle.com