Privacy Policy


James Clay (“We”, “Our” or “Us”) respect your privacy and appreciate your personal data is valuable. Our privacy policy summarises the information We might collect from you and how it will be used in compliance with the General Data Protection Regulation (GDPR) 2018.

The policy applies to all personal data (PD) We collect whether that’s in person, by telephone or through online locations such as Our website. Use of Our website ( and any other sites that We operate is subject to your agreement with this policy unless a separate privacy policy has been provided.

What information do We collect about you?

We collect information about you when you register for an account with us or place an order for products or services. We also collect information when you voluntarily complete customer surveys, provide feedback and participate in competitions. Anonymous website usage information is also collected using Google Analytics.

The data we collect about you

Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).

We may collect, use, store and transfer different kinds of personal data about you as follows:

  • Personally identifiable data including your name, username or similar identifier, title, date of birth.
  • Contact data including billing address, delivery address, email address and telephone numbers.
  • Financial data including bank and payment details.
  • Transaction data including details about payments to and from you and other details of products and services you have purchased from Us.
  • Technical data including internet protocol (IP) addresses, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access Our websites.
  • Profile data including purchases or orders made by you, your interests, preferences, feedback and any survey responses.
  • Usage data including information about how you use Our website, products and services.
  • Marketing and communications data including your preferences in receiving marketing from us and our third parties and your communication preferences.

How is your personal data collected?

We use different methods to collect data from and about you including through:

  • Direct interactions. You may give Us your personal data by filling in forms or by corresponding with Us by post, phone, email or otherwise. This includes personal data you provide when you:
  • request information to be sent to you;
  • interact with Us about business activities; or
  • provide Us with feedback.
  • Automated technologies or interactions. As you interact with our website, we may automatically collect technical data about your equipment, browsing actions and patterns. We collect this personal data by using cookies, server logs and other similar technologies.
  • Third parties or publicly available sources. We may receive personal data about you from various third parties as set out below: Technical data from search engines and analytics providers, survey platforms.
  • Contact, financial and transaction data from providers of technical, payment and delivery services.
  • Identity and contact data from publicly availably sources.
  • Information from Our customers.

How will we use the information about you?

We collect information about you to process your order, manage your account and, if you agree, email, telephone or contact you by post about other products and services we think may be of interest to you. If you do become a customer it may be necessary to share your data with other organisations for the purposes of satisfying your order, e.g. logistics and delivery companies.

The bases for processing any personal data we hold about you are as follows:

  • Where We need to fulfil a contract We are about to enter into or have entered into with you.
  • Where it is necessary for our legitimate interests (or those of a third party), by which We mean in the interest of Our business to enable Us to give you the best service and most secure experience.
  • Where We need to comply with a legal or regulatory obligation that We are subject to.

Generally We do not rely on consent as a legal basis for processing your personal data other than in relation to sending direct marketing communications to you electronically (see ‘Marketing’ below).

We may share your information with credit reference agencies and other companies for use in credit decisions, for fraud prevention and to pursue debtors. Beyond this, we will not disclose any information to any company outside Broom House Investments Limited T/A James Clay and Sons except to prevent fraud or if required to do so by law.


We would like to send you information about products and services which may be of interest to you. If you have consented to receive marketing, you may opt out at a later date. You have a right at any time to stop Us from contacting you for marketing purposes.


We will only retain your personal data for as long as necessary to fulfil the purposes We collected it for, including for the purposes of 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 data (so that it can no longer be associated with you) for research or statistical purposes in which case We may use this information indefinitely without further notice to you.

Access to your information and correction

You have the right to request a copy of the information that We hold about you. If you would like a copy of some or all of your personal information, please email or write to us at the following address.

Broom House Investments Limited T/A James Clay and Sons
Unit 1 River Street
West Yorkshire

You will not have to pay a fee to access your personal data. However, We may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, We may refuse to comply with your request in these circumstances.

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 but comply in any event within 3 months of receiving your request (or any further information requested from you).

We want to make sure that your personal information is accurate and up to date. You may ask us to correct or remove information you think is inaccurate.

You have the following additional rights in relation to any personal data we hold:

  • Request correction of the personal data that We hold about you. This enables you to have any incomplete or inaccurate data We hold about you corrected, though We may need to verify the accuracy of the new data you provide to us.
  • Request erasure of your personal data. This enables you to ask Us to delete or remove personal data 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 data where you have successfully exercised your right to object to processing (see below), where We may have processed your information unlawfully or where We are required to erase your personal data to comply with local law. Note, however, that We may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
  • Object to processing of your personal data 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 as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where We are processing your personal data for direct marketing purposes. In some cases, We may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
  • Request restriction of processing of your personal data. This enables you to ask Us to suspend the processing of your personal data in the following scenarios: (a) if you want Us to establish the data's accuracy; (b) where Our use of the data is unlawful but you do not want Us to erase it; (c) where you need Us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to Our use of your data but We need to verify whether we have overriding legitimate grounds to use it.
  • Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for Us to use or where We used the information to perform a contract with you.
  • Withdraw consent at any time where We are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, We may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.

    If you wish to exercise any of the rights set out above, please contact us.

Changes to our privacy policy

We keep our privacy policy under regular review and we will place any updates on this web page. This privacy policy was last updated on 07/09/2021.


Our cookie policy is applicable to all websites and services that we operate.

Cookies anonymously track use of our website and may enable specific features to enhance your browsing experience. You can refuse to accept cookies by activating the setting on your browser which allows you to block the setting of cookies. However, if you select this setting you may be unable use certain features of our website.

We use cookies to collect specific types of information including:

  • the date and time of your visit;
  • the pages you visit; and
  • the address of the web site from which you linked to us (if applicable).

This is solely statistical data that enables us to analyse customer trends and does not identify personally identifiable information.

For further information about cookies, you may like to visit

The following cookies are used on our websites

Google Analytics

  • _ga this is included in each page request in a site and used to calculate visitor, session and campaign data for the site’s user reports. It's stored for 2 years.
  • _gat queues requests sent to Google Analytics and is valid for 60 seconds only.
  • _gid holds a unique value to distinguish between users and is valid for 24 hours.

Details of Google's Privacy Policy can be found here.

Our website platform

Our Content Management System (CMS) is called Craft CMS which requires cookies to function. It uses the following cookies.

Craft relies on PHP sessions to maintain sessions across web requests. That is done via the PHP session cookie called CraftSessionId. This cookie expires as soon as the visitors browsing session expires.

A cookie named CRAFT_CSRF_TOKEN will be created to facilitate protection against cross-site request forgeries. This helps to safeguard data as it is submitted through forms on the website.

For GDPR purposes, please note that Craft's default cookies do not collect any personal or sensitive information. Craft's default cookies do not collect IP addresses, and neither does the information they store get passed to any 3rd parties.

Craft's cookies are only used to communicate with the Craft installation for the purposes of user authentication, form validation/security, and basic web application operations.

Our website hosting

Our website is hosted by Digital Ocean within a London based data centre. All website traffic is encrypted and delivered over https, with our SSL certificate stating our company name in the browser address bar.

Digital Ocean is a US based company and are a third party data processor.

Third Party Data Processors

We may store your data on servers provided by third party vendors, or through services who process personal data on our behalf. These third parties may be based outside the UK and we are satisfied that their own privacy policies meet the requirements of GDPR.

Specific services can include:

  • Our server environments
  • Our email communication platforms
  • Digital marketing tools such as website analytics

Named third party providers and their respective privacy policies are: