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Privacy Policy (UK)

1. WHAT IS THE PURPOSE OF THIS DOCUMENT?

AQUALISA PRODUCTS LIMITED is committed to protecting the privacy and security of your personal information.

This privacy notice describes how we collect and use personal information about you during and after your contractual relationship with us, in accordance with the General Data Protection Regulation (GDPR).

It applies to all customers of AQUALISA PRODUCTS LIMITED.

1.1          AQUALISA PRODUCTS LIMITED (company registration number 01281596) is a “data controller”. This means that we are responsible for deciding how we hold and use personal information about you. We are required under data protection legislation to notify you of the information contained in this privacy notice.

1.2          This notice applies to current and former customers.  This notice does not form part of any contract we may have with you.  We may update this notice at any time.

1.3          It is important that you read this notice, together with any other privacy notice we may provide on specific occasions when we are collecting or processing personal information about you, so that you are aware of how and why we are using such information.

 

2. DATA PROTECTION PRINCIPLES

We will comply with data protection law. This says that the personal information we hold about you must be:

1.   Used lawfully, fairly and in a transparent way.

2.   Collected only for valid purposes that we have clearly explained to you and not used in any way that is incompatible with those purposes.

3.   Relevant to the purposes we have told you about and limited only to those purposes.

4.   Accurate and kept up to date.

5.   Kept only as long as necessary for the purposes we have told you about.

6.   Kept securely.

 

3. THE KIND OF INFORMATION WE HOLD 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).

There are “special categories” of more sensitive personal data which require a higher level of protection

3.1          We will collect, store, and use the following categories of personal information about you:

  • Personal contact details such as name, title, addresses, telephone numbers, and personal email addresses (Identity Data).

  • Data captured by the use of CCTV (Image Data).

  • Data captured during recorded telephone calls (Phone Call Data).

  • Details about payments to and from you and about the products and services that you have purchased from us (Purchase Data).

  • Your bank account details (Financial Data).

  • Information about your use of our website www.aqualisa.co.uk (Usage Data).

  • Technical data such as your internet protocol (IP) address, your login data, 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 website (Technical Data).

  • Information about your marketing and communication preferences (Communications Data).

  • Information given by you to us in feedback and survey responses (Profile Data).

We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data could be derived from your personal data but is not considered personal data in law as this data will not directly or indirectly reveal your identity. For example, we may aggregate your data about your use of our website to calculate the percentage of users accessing a specific website feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy policy.

3.2          In addition to the above personal information, where you apply for finance, we will collect, store, and use the following categories of personal information about you (Finance Data):

  • Date of birth.

  • Gender

  • Marital status

  • Salary information

  • Employment status

3.3          We may also collect, store and use the following “special categories” of more sensitive personal information:

  • Information about your health, including any medical condition (Special Category Data).

 

4. HOW IS YOUR PERSONAL INFORMATION COLLECTED?

4.1      We collect personal information about our customers in the following ways:

1.   Direct interactions. You may give us your Identity Data, Phone Call Data, Purchase Data, Financial Data, Usage Data, Communications Data, Profile Data, Finance Data and Special Category Data by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:

  • submit an order to purchase goods from us;

  • apply for finance;

  • create an account on our website;

  • subscribe to our service or publications;

  • request marketing to be sent to you;

  • enter a competition, promotion or survey; or

  • give us feedback or contact us.

2.   Attendance on site.  When you visit our premises we capture your Image Data through the use of CCTV.

3.   Automated technologies or interactions. As you interact with our website, we will automatically collect Technical Data and / or Usage Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies, server logs and other similar technologies. We may also receive Technical Data about you if you visit other websites employing our cookies. Please see our cookie policy for further details.

4.   Third parties or publicly available sources.  We collect personal data about our customers from third party sources in the following ways:

 

Categories of personal data we collect from third party sources

Source of the personal data

Identity Data, Purchase Data (details of our products and services that you have purchased via third parties), Financial Data, Communications Data, Profile Data and Finance Data

Third party sellers of our products / services.

Identity Data

Publicly available sources such as Companies House and the Electoral Register based inside and / or outside the EU.

Technical Data

  1. Analytics providers such as Google based inside and / or outside the EU;

  2. Advertising networks based inside and / or outside the EU.

Identity Data, Purchase Data and Financial Data

Providers of technical, payment and delivery services based inside and/ or outside the EU.

Identity Data

Data aggregators based inside and / or outside the EU.


4.2          We may collect additional personal information in the course of contract related activities throughout the period of our contractual relationship.

 

 5. HOW WE WILL USE INFORMATION ABOUT YOU  

We will only use your personal information when the law allows us to. Most commonly, we will use your personal information in the following circumstances:

1. Where we need to perform the contract, we have entered into with you.

2. Where we need to comply with a legal obligation.

3. Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.

We may also use your personal information in the following situations, which are likely to be rare:

1. Where we need to protect your interests (or someone else’s interests).

2. Where it is needed in the public interest.

3. With your express consent.

5.1        Situations in which we will use your personal information

5.1.1      We need all the categories of information in the list above (see paragraphs 3.1 and 3.2 and 3.3) primarily to allow us to perform our contract with you and to enable us to comply with legal obligations. In some cases we may use your personal information to pursue legitimate interests of our own or those of third parties, provided your interests and fundamental rights do not override those interests. The situations in which we will process your personal information are listed below. We have indicated the purpose or purposes for which we are processing or will process your personal information, as well as indicating which categories of data are involved:

 

Situations in which we will process your personal information:

Categories of data involved:

Purpose(s) / Legal Bases of processing:

To process and deliver an order and generally administer the contract we have entered into.

(a) Identity Data

(b) Phone Call Data

(c) Purchase Data

(d) Financial Data

(e) Communications Data

(f) Profile Data

(g) Special Category Data*

1. Processing is necessary for the performance of the contract with you.

 

2. Processing is necessary for our legitimate interests:

  • To deliver goods / services to you where the contract we have entered into is not with you directly; and / or

  • For training and monitoring purposes; and/or

  • To recover debts due to us.

 

3. * We will use your Special Category Data where you give us this information to enable us to provide a service to you.  In this situation we rely on your express verbal consent to use your Special Category Data.

To facilitate a credit application that you / your company may wish to make (the credit agreement is not with us but a third party)

(a) Identity Data

(b) Phone Call Data

(c) Purchase Data

(d) Financial Data

(e) Finance Data

(f) Communications Data

(g) Profile Data

(h) Special Category Data*

1. Processing is necessary for the performance of the contract with you.

 

2. Processing is necessary for our legitimate interests:

  • To enable us to deliver goods / services to you where the contract we have entered into is not with you directly; and / or

  • To assist you / your company in making a credit application to a third party; and/or

  • For training and monitoring purposes.

 

3. To comply with a legal obligation.

 

4. * We will use your Special Category Data in this situation where you give us this information as part of an application for credit.  In this situation we rely on your express verbal consent to use your Special Category Data.

 

IMPORTANT NOTE: nothing within this privacy notice affects the third party to whom you are making an application for credit.  You should read their privacy notice for details of how they use your personal data.

To manage our relationship with you which will include:

(a) Notifying you about changes to our terms or privacy policy;

(b) Asking you to leave a review or take a survey

(a) Identity Data

(b) Phone Call Data

(c) Purchase Data

(d) Usage Data

(e) Communications Data

(f) Profile Data

1. Processing is necessary for the performance of the contract with you.

 

2. Processing is necessary for our legitimate interests:

  • Processing is necessary for the performance of a contract with a third party; and / or

  • To keep our records updated and to study how customers use our products/services; and/or

  • For training and monitoring purposes.

 

3. Processing is necessary to comply with a legal obligation.

To administer and protect our business and our website (including: business planning and complying with accounting and auditing obligations; preventing fraud; and troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data).

a) Identity Data

(b) Phone Call Data

(c) Purchase Data

(d) Financial Data

(e) Usage Data

(f) Technical Data

(g) Communications Data

(h) Profile Data

(i) Special Category Data*

1. Processing is necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud, for training and monitoring purposes and in the context of a business reorganisation or group restructuring exercise).

 

2. Processing is necessary to comply with a legal obligation.

 

3. * We will use your Special Category Data where you give us this information to enable us to provide a service to you.  In this situation we rely on your express verbal consent to use your Special Category Data.

To enable you to partake in a prize draw, competition or complete a survey

1. Identity Data

2. Usage Data

3. Profile Data

4. Communications Data

5. Technical Data

1. Processing is necessary for the performance of a contract with you.

 

2. Processing is necessary for our legitimate interests (to study how customers use our products/services, to develop them and grow our business).

Dealing with legal disputes involving you.

1. Identity Data

2. Image Data

3. Phone Call Data

4. Purchase Data

5. Financial Data

6. Usage Data

7. Technical Data

8. Communications Data

9. Profile Data

10. Finance Data

11. Special Category Data

1. Processing is necessary to comply with a legal obligation.

 

2. Processing is necessary for the purpose of, or in connection with, legal proceedings (including prospective legal proceedings), including obtaining legal advice.

Protecting our business premises and assets

1. Image Data

Processing is necessary for our legitimate interests (to protect our business premises and security of persons on site)

To provide and administer the product warranties

1. Identity Data

2. Phone Call Data

3. Purchase Data

4. Financial Data

5. Communications Data

6. Profile Data

7. Finance Data

1. Processing is necessary for the performance of our contract with you;

 

2. Processing is necessary for our / third party legitimate interests:

  • To provide cover under a warranty, where the contract entered into is not with you directly; and / or

  • To enable our third party  extended warranty providers to contact you regarding potential extended warranty cover.

 

3.Processing is necessary to comply with a legal obligation.

To make suggestions and recommendations to you about similar goods or services that may be of interest to you

1. Identity Data

2. Phone Call Data

3. Purchase Data

4. Communications Data

5. Profile Data

Processing is necessary for our legitimate interests to develop our products/services and grow our business.

 

5.1.2      Some of the above grounds for processing will overlap and there may be several grounds which justify our use of your personal information.  If you have any questions regarding this, please contact us using the information set out below

5.2         Marketing

5.2.1     We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising.

5.2.2      Promotional offers from us

We may use your Identity Data, Phone Call Data, Purchase Data, Usage Data, Technical Data, Communication Data and Profile Data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which products, services and offers may be relevant for you (we call this marketing).

You may receive marketing communications from us if you have requested information from us or purchased similar goods / services from us and you have not opted out of receiving that marketing.  Sometimes we may ask you for consent to send you marketing communications.

You have the right to object to our processing of your personal data for direct marketing purposes at any time. To exercise this right, please contact the Compliance Officer using the contact details set out at paragraph 10.2.2 below.

5.2.3      Third-party marketing

Unless the law allows us to share your personal data without your express consent, we will get your express opt-in consent before we share your personal data with any third party for their own marketing purposes

5.2.4      Opting out

You can ask us to stop sending you marketing messages at any time by logging into the website and checking or unchecking relevant boxes to adjust your marketing preferences or by following the opt-out links / instructions on any marketing message sent to you or by contacting us on the details set out below at any time.

Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of a goods/service purchase, service experience or other transactions.

5.2.5      Cookies

You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of this website may become inaccessible or not function properly.

5.3         If you fail to provide personal information

If you fail to provide certain information when requested, we may not be able to perform the contract we have entered into with you (such as delivering goods or services to you), or we may be prevented from complying with our legal obligations (such as to ensure the health and safety of our customers).

5.4         Change of purpose

5.4.1      We will only use your personal information for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If we need to use your personal information for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.

5.4.2      Please note that we may process your personal information without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

 

6. HOW WE USE PARTICULARLY SENSITIVE PERSONAL INFORMATION

"Special categories” of particularly sensitive personal information require higher levels of protection. We need to have further justification for collecting, storing and using this type of personal information. We have in place an appropriate policy document and safeguards which we are required by law to maintain when processing such data. We may process special categories of personal information in the following circumstances:

1.  In limited circumstances, with your explicit verbal consent.

Less commonly, we may process this type of information where it is needed in relation to legal claims or where you have already made the information public.

6.1         Our obligations

We will use your particularly sensitive personal information in the following ways: 

  • We will use information about your physical or mental health, or disability status, to ensure your call / query is dealt with appropriately and to ensure that any installation services we provide to you take account of your particular personal circumstances.

6.2         Do we need your consent?

We do not need your consent if we use special categories of your personal information to carry out our legal obligations or exercise specific rights. Where we do need consent, we will usually ask you to provide us with your explicit verbal consent (after having told you the reason why we need your special category information so that you can carefully consider whether you wish to consent).  In limited circumstances, we may approach you for your written consent to allow us to process certain particularly sensitive data. If we do so, we will provide you with full details of the information that we would like and the reason we need it, so that you can carefully consider whether you wish to consent. You should be aware that it is not a condition of your contract with us that you agree to any request for consent from us.

 

7. DATA SHARING

We may have to share your data with third parties, including third-party service providers and other entities in the group of companies to which we belong.

We (Aqualisa Products Limited) do not transfer your personal information outside the EU.

7.1         Why might you share my personal information with third parties?

We will share your personal information with third parties where required by law, where it is necessary to administer the working relationship with you or where we have another legitimate interest in doing so.

”Third parties” includes independent data controllers, third-party service providers (including contractors and designated agents) and other entities within our group.

7.2         Which third-party service providers process my personal information on your behalf?

The following categories of third-party service providers may process personal information about you for the following purposes:

  • Service providers who provide website, IT and system administration services to us;

  • Service providers who provide business administration services to us.

7.3         How secure is my information with third-party service providers and other entities in your group?

All our third-party service providers and other entities in the group are required to take appropriate security measures to protect your personal information in line with our policies. We do not allow our third-party service providers to use your personal data for their own purposes. We only permit them to process your personal data for specified purposes and in accordance with our instructions.

7.4         When might you share my personal information with other entities in your group?

We will share your personal information with other entities in our group as part of our regular reporting activities on company performance, in the context of a business reorganisation or group restructuring exercise, for system maintenance support and hosting of data.

7.5         What about other third parties?

We may share your personal information with other third parties, for example in the context of the possible sale or restructuring of the business. We may also need to share your personal information with a regulator or to otherwise comply with the law.

Typically, we will share your personal data with the following third parties who act as independent data controllers:

  • organisations who deliver to you the products that have been ordered;

  • organisations who provide extended warranties for the products you have purchased from us;

  • organisations that provide finance to you to enable you to purchase products / services from us;

  • organisations that process your payments made over the phone or online;

  • third party sellers of our products;

  • organisations who provide services for credit risk reduction and other fraud and crime prevention purposes and organisations providing similar services, including financial institutions, credit reference agencies and regulatory bodies with whom such personal data is shared;

  • professional advisers including lawyers, bankers, auditors and insurers who provide consultancy, banking, legal, insurance and accounting services;

  • HM Revenue & Customs, regulators and other authorities.

 

8. DATA SECURITY

We have put in place measures to protect the security of your information.

Our third-party service providers will only process your personal information on our instructions and where they have agreed to treat the information confidentially and to keep it secure.

8.1          We have put in place appropriate security measures to prevent your personal information from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal information to those employees, agents, contractors and other third parties who have a business need to know. Our third-party service providers will only process your personal information on our instructions, and they are subject to a duty of confidentiality.

8.2          We have put in place procedures to deal with any suspected data security breach and will notify you and any applicable regulator of a suspected breach where we are legally required to do so.

 

9. DATA RETENTION

9.1         How long will you use my information for?

9.1.1      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 satisfying any legal, accounting, or reporting requirements.

9.1.2      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.

9.1.3      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.  

9.1.4      We will retain and securely destroy your personal information in accordance with applicable laws and regulations.

9.1.5      In some circumstances you can ask us to delete your data (see below).

 

10. RIGHTS OF ACCESS, CORRECTION, ERASURE, AND RESTRICTION

10.1      Your duty to inform us of changes

It is important that the personal information we hold about you is accurate and current. Please keep us informed if your personal information changes during your contractual relationship with us.

10.2       Your rights in connection with personal information

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

 

 

Legal Right

Description:

1

Request access to your personal data (commonly known as a "data subject access request").

This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.

2

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.

3

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.

4

Object to processing of your personal data

You may object 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.

5

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:

  • If you want us to establish the data's accuracy.
  • Where our use of the data is unlawful but you do not want us to erase it.
  • 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.
  • You have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.

6

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.

7

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.


10.2.2    If you want to review, verify, correct or request erasure of your personal information, object to the processing of your personal data, or request that we transfer a copy of your personal information to another party, please contact the Compliance Officer using the following contact details:

Telephone number:           01959 560010

Email address:                    [email protected]

Postal address:                   Aqualisa Products Limited, The Flyer's Way, Westerham, Kent TN16 1DE

10.3       No fee usually required

You will not have to pay a fee to access your personal information (or to exercise any of the other rights). However, we may charge a reasonable fee if your request for access is clearly unfounded or excessive. Alternatively, we may refuse to comply with the request in such circumstances.

10.4       What we may need from you

 

11. RIGHT TO WITHDRAW CONSENT

11.1       In the limited circumstances where you may have provided your consent to the collection, processing and transfer of your personal information for a specific purpose, you have the right to withdraw your consent for that specific processing at any time. To withdraw your consent, please contact the Compliance Officer using the contact details set out at paragraph 10.2.2 above.

11.2       Once we have received notification that you have withdrawn your consent, we will no longer process your information for the purpose or purposes you originally agreed to, unless we have another legitimate basis for doing so in law

 

12. DATA PROTECTION MANAGER

Our Compliance Officer is responsible for overseeing compliance with this privacy notice. If you have any questions about this privacy notice or how we handle your personal information, please contact the Compliance Officer.

You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues.  You may find out more about how to contact the ICO by going to the following website: https://ico.org.uk/global/contact-us/

 

13. CHANGES TO THIS PRIVACY NOTICE

We reserve the right to update this privacy notice at any time. In the event we make substantial updates, we will make available our updated privacy notice on our website.  We may also notify you in other ways from time to time about the processing of your personal information.

 

If you have any questions about this privacy notice, please contact our Compliance Officer using the contact details set out at paragraph 10.2.2.

 

We may need to request specific information from you to help us confirm your identity and ensure your right to access the information (or to exercise any of your other rights). This is another appropriate security measure to ensure that personal information is not disclosed to any person who has no right to receive it.

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