Privacy Policy

Privacy Policy

 

Last updated: October 2025

Half Moon Bay Ltd (“we”, “us”, “our”) respects your privacy and is committed to protecting personal data.
This notice explains how we collect, use, and protect personal information in line with the UK General Data Protection Regulation (UK GDPR) and the Data Protection Act 2018.

1. Who we are

Data Controller: Half Moon Bay Ltd
Company Number: 3129562
Registered Address: Unit 9 Hercules Way, Bowerhill Trading Estate, Melksham, SN12 6TS
Email for privacy queries: sales@halfmoonbay.co.uk

We are a UK-based wholesale B2B supplier of gifts and licensed merchandise.

2. What information we collect

We may collect and process the following personal data:

• Contact details (name, email, phone number, job title, business address)
• Trade account details (account history, purchases, invoices, credit references)
• Marketing preferences and newsletter subscriptions
• Website use data (IP address, browser type, pages visited, cookies and analytics information)
• Employment and applicant data (CV, references, contact details, employment history, and where required special category data such as health information)

3. How we collect information

We collect personal data directly from you — for example, when you:

• Visit our website or create an account
• Place an order or request a brochure
• Subscribe to our mailing list
• Apply for employment
• Contact us via email or social media

We may also receive information from:

• Credit reference agencies (if you open a trade account)
• Couriers or delivery partners regarding orders
• Public sources (e.g. Companies House)

4. How we use your information and lawful bases for processing

Purpose	Example data used	Lawful basis
Managing orders and trade accounts	Contact details, payment and delivery info	Contract – to fulfil orders and manage your account
Meeting legal and tax obligations	Financial records, invoices	Legal obligation – HMRC and record-keeping requirements
Business relationship management and marketing to existing customers	Contact details, purchase history	Legitimate interests – to maintain and grow business relationships (you can object at any time)
Email marketing and newsletters	Name, email, preferences	Consent – you choose to opt in and can unsubscribe any time
Recruitment and employment administration	CV, application forms, references	Contract / Legal obligation (for employment rights and health & safety)
Website analytics and cookies	Device and usage data	Consent – non-essential cookies used only with your permission

5. Sharing your information

We only share data when necessary to run our business or comply with the law.
We may share personal data with:

• IT hosting and support providers
• Email and marketing platforms (e.g. Klaviyo)
• Website analytics providers (e.g. Google Analytics)
• Delivery and logistics partners
• Payment processors and accountants
• Professional advisers (lawyers, auditors)
• Credit reference agencies (for trade accounts)

We never sell personal data.

6. International transfers

Some service providers (e.g. Google, Klaviyo, Hootsuite) process data outside the UK or EEA.
Where this happens we use appropriate safeguards such as the UK-US data bridge or UK Standard Contractual Clauses (SCCs) approved by the ICO.
Copies of these safeguards are available on request.

7. Data retention

We keep personal data only as long as necessary for our business purposes and legal requirements.

Type of data	Retention period
Trade account and order records	6 years after account closure (for tax and contract purposes)
Marketing contacts	Until you unsubscribe or withdraw consent
Job applicant data	6 months after recruitment decision (unless you agree to longer retention)
Employee records	For the duration of employment plus legal record-keeping periods (usually 6 years)

8. Cookies and website analytics

Our website uses cookies to make it work and to understand how visitors use it.
Non-essential cookies (analytics, marketing) are used only with your consent via our cookie banner.
You can change your preferences at any time under Cookie Settings.
See our separate Cookie Notice for details of each cookie used and its expiry.

9. Data security

We use appropriate technical and organisational measures to protect personal data, including:

• Secure servers and encrypted connections (SSL/TLS)
• Role-based access controls
• Employee training on data protection and confidentiality
• Regular review of IT security and third-party contracts

10. Your rights under data protection law

You have the right to:

• Access your personal data (a copy of what we hold)
• Rectify inaccurate or incomplete data
• Erase data (“the right to be forgotten”) in certain cases
• Restrict processing of your data
• Object to processing based on legitimate interests or to direct marketing
• Data portability – receive your data in a machine-readable format
• Withdraw consent for any processing based on consent

To exercise these rights, contact us at sales@halfmoonbay.co.uk.
We may need to verify your identity and will respond within one month.

11. Children’s data

We do not target or knowingly collect personal data from children under 16.

12. Automated decision-making

We do not use automated decision-making that produces legal or similarly significant effects on individuals.

13. Complaints

If you are unhappy with how we handle your data, please contact us first.
You also have the right to complain to the Information Commissioner’s Office (ICO):
📞 0303 123 1113 🌐 www.ico.org.uk

14. Changes to this privacy notice

We may update this policy periodically to reflect changes in our processing or legal requirements.
The latest version will always be available on our website.