Last Updated: 24th May 2018

Your privacy is very important to us at CTI Materials LLC (“CTI”, “us” or “we”), and we want to be upfront about how and when we use your personal details.

We collect personal information mainly to make your experience with us as excellent as possible, and we’ll never share your data with third parties or use it without your permission, except where it is part of providing a service to you, or for the purposes of user research. The privacy policy below, together with the terms of use and terms and conditions of supply, explains in more detail exactly what kind of information we may collect and how we use it. We’ve tried to simplify it as much as possible, but if you have any questions, please contact us at privacy@ctimaterials.com.

1. Information we may collect about you

   We may collect and process the following information about you:

   1. Identity Data, including username or similar identifier and an encrypted version of your login/password;
   2. Profile Data, including your user-generated content (on your profile page or in your comments and creations), preferences, feedback and survey responses, as well as any profile data which we have added (for example, using analytics and profiling);
   3. Technical Data, including internet protocol (IP) address, browser type and version, time zone setting and city-level location, operating system and platform and other technology on the devices you use to access our services;
   4. Usage Data, including information about how you use our website, products and services;
   5. Tracking Data, including information we or third party providers collect about you from cookies;
   6. Marketing and Communications Data, including your preferences in receiving direct marketing from us, and records of your emails or calls to us;
   7. We also collect, use and share Aggregated Datasuch 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 visiting a specific product page. In some instances we may combine Aggregated Data with your personal data, in which case we treat the combined data as personal data in accordance with this privacy policy;
   8. We do not collect any Categories of Personal Dataabout you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data). Nor do we collect any information about criminal convictions and offences.

2. Cookies

   Like many websites, we may use cookies to help us provide you with the best possible web experience.

   Cookies are small text files which a website may put on your computer or mobile device when you first visit a site or page. The cookie will help the Website, or another website, to recognise your device the next time you visit. We use the term “cookies” in this policy to refer to all files that collect information in this way.

   There are many functions cookies serve. For example, they can help us to remember your username and preferences, analyse how well the Website is performing, or even allow us to recommend content we believe will be most relevant to you.

   Certain cookies contain personal information – for example, if you click to “remember me” when logging in, a cookie will store your username. Most cookies will not collect information that identifies you, but will instead collect more general information such as how users arrive at and use the Website.

   Generally, our cookies perform up to three different functions:

   1. Essential Cookies

      Some cookies are essential for the operation of the Website. If you opt to disable these cookies, you will not be able to access or use all of the features that the Website incorporates.

   2. Performance Cookies

      We use other cookies to help us understand how our visitors use the website, and help us monitor and improve performance. For example, we might use performance cookies to keep track of which pages are most popular or figure out why some pages are displaying error messages.

   3. Functionality Cookies

      We use functionality cookies to allow us to remember your preferences. For example, cookies save you the trouble of typing in your username every time you use the Website, and recall your customisation preferences such as geographical location.

   Does anyone else use cookies on the Website?

   We do use or allow third parties to serve cookies that fall into the three categories above. For example, like many companies, we use Google Analytics to help us monitor our traffic. We may also use third party cookies to help us with market research, revenue tracking, improving site functionality and monitoring compliance with our terms and conditions.

   We sometimes advertise on third party websites, and we may allow our trusted advertising partners to place targeting cookies so that we can provide more interesting content.

   Can you block cookies?

   As we have explained above, cookies help you to get the most out of the Website.

   However, if you do wish to disable cookies then you can do so by amending the settings within your browser or mobile device.

   Please remember that if you do choose to disable cookies, you may find that certain sections of the Website do not work properly.

3. Lawful basis and purposes of processing your personal information

   We collect information about you so that we can:

   1. provide you with the services you signed up for;
   2. improve the Website and our products and services;
   3. maintain our IT systems and manage hosting of our data;
   4. notify you about changes to our service;
   5. comply with our regulatory obligations.

4. Storage of your personal information

   The data we collect from you is stored in the EU or under the EU-U.S. Privacy Shield but may be transferred to and stored at a destination outside of these, but only where the organisation receiving your data has provided adequate safeguards. It may also be processed by staff operating outside of the EEA.

   Sensitive information between your browser and the Website is transferred in encrypted form using Secure Socket Layer (“SSL”). When transmitting sensitive information, you should always make sure that your browser can validate the Website’s certificate.

   It is your responsibility to keep your password secure. Unfortunately, the transmission of information via the internet is not completely secure. Although Cheap Tubes will do its best to protect your personal data, we cannot guarantee the security of your data transmitted to the Website, any transmission is at your own risk.

   Once we have received your information, we will use strict procedures and security features to try and prevent any unauthorised access. In the unlikely ever of a suspected data security breach, we will notify you and any applicable regulator where we are legally required to do so.

5. Retention periods

   We will only retain your personal information for as long as necessary to fulfil the purposes we collected it for, including for the purposes of responding to any problems you might have, or for satisfying any legal, accounting or reporting requirements. 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 requirements.

   In some circumstances, we may anonymise your personal information so that it can no longer be associated with you, in which case we may use such information without further notice to you. Once you are no longer our user, we will retain or securely destroy your personal information in accordance with applicable laws and regulations.

6. Disclosure of your information

   We may disclose your personal information to any partner of CTI Materials and/or a member of our group, which means our subsidiaries, our ultimate holding company and its subsidiaries, as defined in section 1159 of the UK Companies Act 2006.

   We may disclose your personal information to third parties:

   1. in the event that we sell or buy any business or assets;
   2. if Kano or substantially all of its assets are acquired by a third party; or
   3. if we are under a duty to disclose or share your personal data in order to comply with any legal obligation or to protect the rights, property, or safety of CTI Materials, our customers and users, or others.

7. Your rights

   Under certain circumstances, by law, you have the right to:

   1. Request accessto your personal information (commonly known as a “data subject access request”). This enables you to receive a confirmation from us as to whether we process any of your personal information or not, and if this is the case, to receive a copy of such personal information and to check that we are lawfully processing it;
   2. Request correctionof the personal information that we hold about you. This enables you to have any incomplete or inaccurate information we hold about you corrected;
   3. Request erasureof your personal information (often referred to as “the right to be forgotten”). This enables you to ask us to delete or remove personal information where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal information where you have exercised your right to object to processing (see below);
   4. Object to processingof your personal information where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground;
   5. Request the restriction of processingof your personal information. This enables you to ask us to suspend the processing of personal information about you, for example, if you want us to establish its accuracy or the reason for processing it, or if we no longer need your data for our legitimate interests but we need to hold some of it for the purpose of legal proceedings.

   Please note that if you request erasure, object to our processing of your personal data or request the restriction of our processing of your personal data we may not be able to provide our services and we may need to deactivate your account.

   You also have the right to ask us not to process your personal data for marketing purposes. You can exercise your right to prevent such processing by checking certain boxes on the forms we use to collect your data. You can always unsubscribe from our email communications at any time by following the unsubscribe link in our email communications.

   If you wish to exercise any of the rights set out above, please email us at privacy@ctimaterials.com and let us know the details of your request, for example by specifying the personal data you want to access, the information that is incorrect and the information with which it should be replaced. 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 or refuse to comply with your request if it is clearly unfounded, repetitive or excessive.

   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.

8. Changes to this policy

   We will update this page to reflect any changes in our privacy policy. Any changes we make to our privacy policy in the future will be posted on this page, so be sure to check in and have read every now and then.

9. Contact

   To contact CTI Materials about Data Privacy, please email privacy@ctimaterials.com or write to us with you