2. WHO WE ARE
3. COMPANIES AND WEBSITES WITHIN SCOPE
4. COLLECTION OF PERSONAL DATA
We collect personal data from you for one or more of the following purposes:
- To fulfil a contract that we have entered into with you or with the entity (or organisation) that you represent. In these circumstances it may be your entity (or organisation), rather than yourself, that has provided us with your personal data.
- To initiate and complete commercial transactions with you, or the entity (or organisation) that you represent, for the purchase of products and/or services.
- To deliver products you have purchased directly or indirectly from us.
- To communicate with suppliers of goods and services.
- Keeping accounts and other business records.
- To carry out marketing, electronic or otherwise.
- Complying with legal or regulatory requirements.
- To manage existing and past employees.
- To manage job applicants.
- Dealing with queries from our current employees, past employees, and job applicants.
- Dealing with complaints or queries from our customers and our suppliers.
- Dealing with queries from our shareholders and other stakeholders.
- Generating data analytics to monitor and improve the performance of our website.
- To ensure the security and safe operation of our websites and underlying business infrastructure.
- Technical information, including the IP (Internet Protocol) address used to connect your device to the Internet.
- Your login information, browser type and version, time zone setting, browser plug-in types and versions.
- Operating system and platform.
- Information about your visit, including the URL (Uniform Resource Locators) clickstream to, through and from our site.
5. LAWFUL BASIS FOR THE PROCESSING OF PERSONAL DATA
We believe that it is in our legitimate interests, or is necessary for the performance of a contract, to collect and use personal information to operate our business and to provide a service that you have requested. In some cases, we may be under a legal duty to use or disclose personal information, for example to comply with a request from an official body. When we process on the lawful basis of legitimate interest, we apply the following test to determine whether it is appropriate:
6. SHARING YOUR PERSONAL INFORMATION
We may share your personal information, but this will be done on a ‘need to know’ basis and only where it is necessary to do so or where we are required to share information. Such as our professional advisors and service providers including:
- Legal counsel.
- Payment providers.
- Payroll providers.
- Pension providers.
- Information technology and communications service providers.
- Logistics and transport services.
We may also share personal information:
- With any competent law enforcement or regulator as required by law.
- When we buy or sell and business or assets.
7. INTERNATIONAL TRANSFER
We are a global organisation and use third parties located in other countries to help us run our business. This includes countries outside the European Union (“EU”) and to countries that do not have laws that provide specific protection for personal data. We have taken steps to ensure all personal data is provided with adequate protection and that all transfers of personal data outside the EU are done lawfully. Where we transfer personal data outside of the EU to a country not determined by the European Commission as providing an adequate level of protection for personal data, the transfers will be under an agreement which covers the EU requirements for the transfer of personal data outside the EU.
8. HOW LONG DO WE KEEP YOUR PERSONAL INFORMATION?
We will take steps to keep your information for only as long as is necessary for our business needs and in compliance with any legal or regulatory duties to retain personal information for a particular period. However long we retain personal information for, we will make sure it is subject to appropriate security.
9. SECURITY MEASURES
We have what we believe are appropriate security controls in place to protect personal data. Risk assessment, including assessing risks to the rights and freedoms of data subjects, is at the heart of our Information Security Management System. We do not, however, have any control over what happens between your device and the boundary of our information infrastructure. You should be aware of the many information security risks that exist and take appropriate steps to safeguard your own information. We accept no liability in respect of breaches that occur beyond our sphere of control.
10. YOUR RIGHTS AS A DATA SUBJECT
As a data subject whose personal information we hold, you have certain rights. If you wish to exercise any of these rights, please email firstname.lastname@example.org or use the information supplied in the Contact Us section below. To process your request, we will ask you to provide a valid form of identification for verification purposes. Your rights are as follows:
- The right of access You may request a copy of the personal data we hold about you free of charge. Once we have verified your identity and, if relevant, the authority of any third-party requestor, we will provide access to the personal data we hold about you as well as the following information:
- provided by the data subject to the company,
- is processed automatically
- The right to rectification When you believe we hold inaccurate or incomplete personal information about you, you may exercise your right to correct or complete this data. This may be used with the right to restrict processing to make sure that incorrect / incomplete information is not processed until it is corrected.
- The right to erasure (the ‘right to be forgotten’) Where no overriding legal basis or legitimate reason continues to exist for processing personal data, you may request that we delete the personal data. This includes personal data that may have been unlawfully processed. We will take all reasonable steps to ensure erasure.
- The right to restrict processing You may ask us to stop processing your personal data. We will still hold the data but will not process it any further. This right is an alternative to the right to erasure. If one of the following conditions applies you may exercise the right to restrict processing:
- The right to data portability
- The right to object
11. DO YOU HAVE TO PROVIDE YOUR PERSONAL INFORMATION TO US?
12. AUTOMATED DECISION-MAKING
13. DO WE USE YOUR PERSONAL INFORMATION FOR MARKETING?