- We take privacy and the protection of personal information seriously. This privacy notice sets out details about how we gather, use and share personal information and about individual privacy rights. How we use personal information depends upon the context in which it is made available to us.
- Our Data Protection Officer (DPO) provides help and guidance to make sure we apply good practice standards to protecting personal information. Our DPO can be reached by email at firstname.lastname@example.org if you have any questions about how we use personal information.
What kinds of personal information we use
- We use a variety of personal information depending on the circumstances under which personal information is made available to us.
- We may use personal information in the following circumstances:
- where you are purchasing products or services from us, we will collect the names, dates of birth, contact information and personal addresses of the participants. We may also need to conduct credit checks against the person or entity paying for the products or services.
- we collect names, email addresses, phone numbers, CV's and any other information provided to us by job applicants applying for a role with us;
- we hold the names, job titles, employer details and professional contact details for various business contacts, including client contacts and supplier contacts; and
- we may use names, phone numbers, postal addresses and email addresses for marketing purposes.
How we use your personal information
We may use your personal information for the following purposes:
- to perform our contract with you to deliver the products or services you have ordered from us and process your payment;
- to allow us to process your trade credit application and to provide you (or the business you represent) with products and services;
- to allow us to ask for your feedback, assess customer satisfaction and to improve our overall operations;
- to communicate with you by sending you information about our products and services that we think may be of interest to you. We will not send you marketing communications if you have not given us your consent to do this, or if you have given us your consent and then changed your mind and unsubscribed;
- to validate your information to check that the data we hold about our customers is accurate, consistent and up to date; and
- to comply with any legal or regulatory obligations to which we are subject.
Our legal basis for using your personal information
- We will only use your personal information where it is permitted by law and where:
- we need to use your personal information to perform a contract with you (e.g. where you are a consumer or where you are a sole trader representing yourself);
- we need to use your personal information to comply with our legal or regulatory obligations;
- you have given us consent to use your personal information (if consent is needed we will ask for this from you separately); and
- it is in our legitimate business interests to be able to comply with our obligations and exercise our rights under our contract with the corporate entity you represent, and there is no disadvantage to you or risk to your personal information.
- If you do not provide us with the personal information we request from you, or if you do not allow us to process your personal information that we may obtain from other sources (such as credit reference agencies), we may not be able to offer you our products or services, or continue to administer any services that you have with us.
Who we share your personal information with
- We may share your personal information with:
- our service providers who process and store data on our behalf (such as our IT service providers);
- our professional advisers;
- our insurers;
- any guarantor to a credit agreement with us;
- credit reference agencies;
- law enforcement, taxation and legal authorities;
- claims handling agencies; and
- debt recovery agencies.
- We may also share your personal information with third parties in the event that:
- our business or substantially all of its assets are acquired by a third party;
- if we are under a duty to disclose or share your personal information;
- in order to comply with any legal or regulatory obligation;
- in order to enforce or apply any contract with you (or the business you represent); or
- to protect our rights, property, or the safety of our employees, customers or others.
How long we keep your personal information
We keep your personal information for as long as we need to for the purposes we have set out above. Usually, we will retain your information for 5 or 6 years after the termination of our contract with us as may be required by law, unless there is an exceptional business purpose in which this time period needs to be extended.
Information security measures
We will treat all of your personal information in strict confidence and we will take all reasonable steps to keep your personal information secure once it has been transferred to our systems. We adopt appropriate data collection, storage and processing practices and security measures to protect against unauthorised access, alteration, disclosure or destruction of your personal information.
Transferring data outside of Europe
We may transfer your personal data outside of the European Economic Area to 10,000 Feet (in the USA) or entities we have specified that we share your information with as outlined above.
Your Privacy Rights
- Data protection laws give you a number of rights as set out below. If you would like to exercise any of your rights, please contact our DPO in writing.
- Access: you may request access to a copy of your personal information.
- Withdraw Consent: where our processing of your personal information is based on your consent, you can withdraw your consent at any time.
- Rectification: you may ask us to rectify any inaccurate information we hold about you.
- Erasure: you may ask us to delete the personal information we hold about you, where there is no reason for us to continue to hold your information.
- Portability: you may ask us to provide you with the personal information that we hold about you in a structured, commonly used, machine readable format, or you can ask us to send your information in this format to another controller.
- Object: you may object to our processing of your personal information.
- Restriction: you can ask us to restrict the personal information we use about you where you have asked for it to be erased or where you have objected to our use of it.
- If you are not happy with the way in which we process your personal information, or the way in which we handle any request by you to exercise your privacy rights, you may make a compliant to the ICO by visiting their website at https://ico.org.uk/concerns/ or on 0303 123 1113.
Changes to this notice
We may modify this notice from time to time, so please review it regularly. We will let you know if we make any material changes to this notice by means of an announcement on our website homepage or, if appropriate, by contacting you directly.