INTRODUCTION AND TERMS
subsequent laws “Data Protection Laws”.
WHO WE ARE AND HOW TO CONTACT US
FAO: Privacy Officer
Baker Tom Limited, 15 Wilson Way, Pool, Redruth, Cornwall, TR15 3RT
Email: [email protected]
Telephone: 01209 218989 and ask to speak to the Privacy Officer
THE DATA WE COLLECT ABOUT YOU
We collect and process Personal Data. We collect, use, store and transfer different kinds of personal data about you which we have grouped together follows:
Identity Data includes first name, last name, and company name
Contact Data includes billing address, email address and telephone numbers.
Financial Data includes bank account and payment card details.
Technical Data includes 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 the website.
Usage Data includes information about how you use our website, products and services.
Marketing and Communications Data includes your preferences in receiving marketing from us.
We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data may be derived from your personal data but is not considered personal data in law as this data does not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data 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 notice.
We do not collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data). Nor do we collect any information about criminal convictions and offences.
IF YOU FAIL TO PROVIDE PERSONAL DATA
Where we need to collect personal data by law, or under the terms of a contract we have with you and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with goods or services). In this case, we may have to cancel a product or service you have with us but we will notify you if this is the case at the time.
HOW YOUR DATA WILL BE USED
We use information held about you to:
carry out our obligations arising from any contracts entered into between you and us;
provide you with information, products or services that you request from us or which we feel may interest you (where you have consented to be contacted for such purposes or where we have identified a Legitimate Interest);
to comply with a legal or regulatory obligation; and notify you about changes to our services we also embrace the use of social media and may wish to process any comments made public by you.
PURPOSES FOR WHICH WE WILL USE YOUR PERSONAL DATA
We have set out below, a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.
Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out below.
We will keep your information within the organisation except where disclosure is required or permitted by law or when we use third-party service providers (data processors) to supply and support our services to you. We have contracts in place with our data processors. This means that they cannot do anything with your personal data unless we have instructed them to do so. They will not share your personal data with any organisation apart from us. They will hold it securely and retain it for the period we instruct.
Please see below the list which sets out the categories of recipients of personal data.
IT Support Services
Email Service Platform provider
Cloud Based Back-Up Services
Secure document disposal service
Cloud Based CRM provider
Internal HR systems provider
Banking & Card Payment Processing
Accountants & Accounting Software
In addition, third parties may provide us with Personal Data and they should only do so where the law allows them to.
This website may include links to third-party websites, plug-ins, and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy notice of every website you visit.
WHERE YOUR DATA IS HELD
We store any Personal Data in the UK, EEA or in a country where an adequacy decision has been made by Article 29 Working Party (e.g. EU-US Privacy Shield).
We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.
We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.
Where we use Legitimate Interests we will record our decision and our method on making this decision.
APPLICATIONS TO WORK FOR US
If you apply to work for us (directly or indirectly) in any role (including volunteers) we may receive data about you from third parties. In addition, we will keep the details of your application and any additional information provided to us by you or others for 90 days. If you do not wish for us to keep your details for this reason, please let us know by contacting us using the details provided in this policy.
Our data retention policy is dictated by the Data Protection Laws and is available for inspection by submitting a written request using the contact details provided in this policy.
Under the Data Protection Laws your rights are:
Access – You are entitled to find out what details we may hold about you and why. We strive to be as open as we can be in terms of giving people access to their personal data. Individuals can find out if we hold any of their Personal Data by making a formal request under the Data Protection Laws. Such requests should be in writing to the contact details provided in this policy. In the instance that we do not hold information about you, we will confirm this in writing at the earliest opportunity. If we do hold your personal data we will respond in writing within one calendar month of your request (where that request was submitted in accordance with this policy). The information we supply will:(a) confirm that your data is being processed;
(b) verify the lawfulness and the purpose of the processing;
(c) confirm the categories of personal data being processed;
(d) confirm the type of recipient to whom the personal data have been or will be disclosed; and
(e) let you have a copy of the data in an intelligible form.
Rectification – We are obliged to correct or update your details. We will correct or update your data without delay provided you make the request in writing to the contact details provided in this policy, clearly specifying which data is incorrect or out of date.
Erasure – This is also known as the request to be forgotten. Under Data Protection Laws you have the right to erasure under specific circumstances. A request for your personal data to be deleted will be decided on a case by case basis and should be submitted in writing to the contact details provided in this policy.
Restrict processing – You have the right to ‘block’ or suppress the processing by us of your personal data.
Portability – You have the right to obtain and reuse your personal data that you have provided to us.
Object – You have the right to object to us processing your data in relation to direct marketing and or profiling.
Rights in relation to automated decision making and profiling – We do not use automatic decision making or profiling.
Please note that you may need to provide identification in order to prove who you are if you wish to invoke any of your rights as provided by the Data Protection Laws and as summarised above.
If you agree, we will try to deal with your request informally, for example by providing you with the specific information you need over the telephone.
You have the right to complain about the processing of your personal data. Please contact us using the details provided above. If you are still unsatisfied you have the right to complain to the Information Commissioners Office. We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.
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Data security and protection
We ensure the security of any personal information we hold by using secure data storage technologies and precise procedures in how we store, access and manage that information. Our methods meet the GDPR compliance requirement.
Email marketing messages & subscription
Under the GDPR we use the consent lawful basis for anyone subscribing to our newsletter or marketing mailing list. We only collect certain data about you, as detailed in the “Processing of your personal date” above. Any email marketing messages we send are done so through an EMS, email marketing service provider. An EMS is a third party service provider of software / applications that allows marketers to send out email marketing campaigns to a list of users.
Email marketing messages that we send may contain tracking beacons / tracked clickable links or similar server technologies in order to track subscriber activity within email marketing messages. Where used, such marketing messages may record a range of data such as; times, dates, I.P addresses, opens, clicks, forwards, geographic and demographic data. Such data, within its limitations will show the activity each subscriber made for that email campaign.
Any email marketing messages we send are in accordance with the GDPR and the PECR. We provide you with an easy method to withdraw your consent (unsubscribe) or manage your preferences / the information we hold about you at any time. See any marketing messages for instructions on how to unsubscribe or manage your preferences, you can also unsubscribe from all MailChimp lists, by following this link, otherwise contact the EMS provider.
Our EMS provider is Mail Chimp. We hold the following information about you within our EMS system;
We would never share your data with third parties and only use it for emails regarding Baker Tom offers, news and events.