GDPR / Privacy Policy - Penwithian Cash and Carry
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GDPR / Privacy Policy


June 2018

Penwithian Wholesalers Ltd GDPR Privacy Policy



At Penwithian Wholesalers Ltd, we are committed to protecting and respecting your privacy. Throughout Penwithian’s years of operation, we have developed relationships with our customers and suppliers based on respect and integrity.


This policy explains when and why we collect personal information about you, how we use it, how we keep it safe and secure and your rights and choices in relation to your information.


In this policy ‘Penwithian Wholesalers Ltd’, ‘we’, ‘us’ or ‘our’ means:

Penwithian Wholesalers Ltd, Company Reg No: 688425 Registered address: Eastern Green, Penzance, Cornwall TR18 3AS.


How do we collect information from you?

We obtain information about you in the following ways:


Information you give to us directly.

We may obtain information about you when you register at our business and when you purchase products, place an order, or communicate with us through our website, by telephone, email, mail or fax. We may also collect personal information through face to face meetings and also with sales reps.


Why we need your personal data.

We need to know your basic personal data in order to provide our goods and services to you, process your orders, and to tell you about our products and services. We will not collect any personal data from you that we do not need to provide and oversee these services to you. This information is not shared with third parties and you can unsubscribe at any time via telephone 01736 366422 or email


Where we keep your personal data.

Penwithian Wholesalers Ltd is based in the UK. We are committed to protecting the security of your personal information and take precautionary measures to help prevent loss, theft, misuse and unauthorised access, disclosure, alteration and destruction. We store personal data on our computer system that has limited access and is password protected. Other paper records are also stored at the premises which is alarmed when closed.


Social Media.

When you interact with us on social media platforms such as Facebook and Twitter, we may obtain information about you (e.g. when you publicly tag us in a photo). The information we receive will depend on the privacy preferences you have set on those types of platforms.


What type of information is collected and held by Penwithian Wholesalers Ltd?

The personal information we collect, store and use might include:

  • your name and contact details (including business and personal postal address, email address and telephone number);
  • your date of birth;
  • your debit/credit card details. If you make a purchase and pay over the telephone, your card information is not held by us, it is collected by us to process the payment and then the details are shredded.
  • Information on past transactions (including copies of invoices)
  • any other personal information shared with us, and all other necessary information for the establishment of a trading relationship.
  • we keep a secure record of Supplier bank details so we can make payment by BACS.
  • CCTV footage is kept for security purposes.

Data protection laws recognise certain categories of personal information as sensitive and therefore requiring greater protection, for example information about your health, ethnicity and religion.

We do not collect sensitive data about you.


How and why is your information used?

We may use your information for several different purposes, which may include:

  • providing you with the services, products or information you asked for.
  • processing orders that you have submitted;
  • carrying out our obligations under any contracts entered into between you and us;
  • keeping a record of your relationship with us;
  • conducting analysis and market research to better understand how we can improve our services, products or information;
  • seeking your views or comments on the services we provide;
  • notifying you of changes to our services;
  • sending you communications which you have requested and that may be of interest to you. These may include information about promotions of goods and services;


How long is your information kept for?

We keep your information for no longer than is necessary for the purposes it was collected for. The length of time we retain your personal information for is determined by operational and legal considerations. For example, we are legally required to hold some types of information to fulfil our statutory and regulatory obligations (e.g. health/safety and tax/accounting purposes).

Who has access to your information?

We do not sell or rent your information to third parties.

We do not share your information with third parties for marketing purposes.

Lawful Processing

Data protection law requires us to rely on one or more lawful grounds to process your personal information. We consider the following grounds to be relevant:



Specific Consent

Where you have provided specific consent to us using your personal information in a certain way, such as to send you email, text and/or telephone marketing

Performance of a contract

Where we are entering into a contract with you or performing our obligations under it, like when you buy Penwithian Wholesalers Ltd products and services.


Vital interests

Where it is necessary to protect life or health (for example in the case of medical emergency suffered by an individual/employee at our business location).

Legitimate interests

Where it is reasonably necessary to achieve our or others’ legitimate interests (as long as what the information is used for is fair and does not duly impact your rights).

We consider our legitimate interests to be running Penwithian Wholesalers Ltd as a Wholesale Cash & Carry organisation in pursuit of our aims and ideals. For example, to:

  • send postal communications which we think will be of interest to you;
  • conduct research to better understand our customers;
  • determine the effectiveness of our services, promotional campaigns and advertising;
  • monitor who we deal with to protect the business against fraud, money laundering and other risks;
  • enhance, modify, personalise or otherwise improve our services /communications for the benefit of our customers;


When we legitimately process your personal information in this way, we consider and balance any potential impact on you (both positive and negative), and your rights under data protection laws. We will not use your personal information where our interests are overridden by the impact on you, for example, where use would be excessively intrusive (unless, for instance, we are otherwise required or permitted to by law).

When we use sensitive personal information, we require an additional legal basis to do so under data protection laws, so will either do so on the basis of your explicit consent or another route available to us at law (for example, if we need to process it for employment, social security or social protection purposes, your vital interests, or, in some cases, if it is in the public interest for us to do so).


We may send you marketing and promotions by post unless you have told us that you would prefer not to hear from us.

Your choices

You have a choice about whether or not you wish to receive information from us. If you do not want to receive direct marketing communications from us about the products and services you can buy, then you can select your choices by contacting us.

We’re committed to putting you in control of your data so you’re free to change your marketing preferences (including to tell us that you don’t want to be contacted for marketing purposes) at any time using: or by telephone: 01736 366422, or post: Penwithian Wholesalers Ltd, Eastern Green, Penzance, Cornwall TR18 3AS.

We will not use your personal information for marketing purposes if you have indicated that you do not wish to be contacted and will retain your details on a suppression list to help ensure that we do not continue to contact you. However, we may still need to contact you for administrative purposes like where we are processing a payment.


Your Rights

Under UK data protection law, you have certain rights over the personal information that we hold about you. Here is a summary of the rights that we think apply:


Right of access

You have a right to request access to the personal data that we hold about you.

You also have the right to request a copy of the information we hold about you, and we will provide you with this unless legal exceptions apply.

If you want to access your information, please send a description of the information you would like to see and proof of your identity by post to the address provided below

Right to have your inaccurate personal information corrected

You have the right to have inaccurate or incomplete information we hold about you corrected. The accuracy of your information is important to us. If you change email address, or if you believe any of the other information we hold is inaccurate or out of date, please contact us via email or post (see below). Alternatively, you can telephone 01736 366422



Right to restrict use

You have a right to ask us to restrict the processing of some or all of your personal information if there is a disagreement about its accuracy, or we’re not lawfully allowed to use it.

Right of erasure

You may ask us to delete some or all of your personal information and in certain cases, and subject to certain exceptions; we will do so as far as we are required to.

Right to object

You have the right to object to processing where we are using your personal information (1) based on legitimate interests, or (2) for direct marketing/promotions.

If you want to exercise any of the above rights, please email us at or write to Penwithian Wholesalers Ltd, Eastern Green, Penzance, Cornwall TR18 3AS. We may be required to ask for further information and/or evidence of identity. We will endeavour to respond fully to all requests within one month of receipt of your request, however if we are unable to do so we will contact you with reasons for the delay.

Please note that exceptions apply to a number of these rights, and not all rights will be applicable in all circumstances. For more details we recommend you consult the guidance published by the UK’s Information Commissioner’s Office.


Keeping your information safe

When you give us personal information, we take steps to ensure that appropriate technical and company controls are in place to protect it.

Any sensitive information (such as credit or debit card details) is written down, processed for payment and once payment is authorised, the details are shredded.

Non-sensitive details (your email address etc.) are transmitted normally over the internet, and this can never be guaranteed to be 100% secure. As a result, while we strive to protect your personal information, we cannot guarantee the security of any information you transmit to us, and you do so at your own risk. Once we receive your information, we make our best effort to ensure its security on our systems.


Keeping your information up to date

We take reasonable steps to ensure your information is accurate and up to date.

We really appreciate it if you let us know when your contact details change.


Use of ‘cookies’

Like many other websites, Penwithian’s website uses cookies. ‘Cookies’ are small pieces of information sent by an organisation to your computer and stored on your hard drive to allow that website to recognise you when you visit.

It is possible to switch off cookies by setting your browser preferences.


Links to other websites

Our website may contain links to other websites run by other organisations. This policy applies only to our website‚ so we encourage you to read the privacy statements on the other websites you visit. We cannot be responsible for the privacy policies and practices of other websites even if you access those using links from our website.

In addition, if you linked to our website from a third party site, we cannot be responsible for the privacy policies and practices of the owners and operators of that third party site and recommend that you check the privacy policy of that third party site.


16 or Under

We are concerned to protect the privacy of children aged 16 or under. If you are aged 16 or under‚ please get your parent/guardian’s permission beforehand whenever you provide us with personal information.





Changes to this policy

Any changes we may make to this policy in the future will be posted on our website so please check our page occasionally to ensure that you’re happy with any changes. If we make any significant changes we’ll make this clear on our website.


Review of this Policy

We keep this policy under regular review. This policy was last updated in June 2018.