Eltro (GB) Limited respects your privacy and we are committed to protecting your personal data. This privacy notice informs you how we look after your personal data when you do business with us, if you make enquiries or seeks quotations from us or visit our website (regardless of where you visit it from) and to tell you about your privacy rights and how the law protects you.
1. Important information and who we are
Purpose of this privacy notice
This privacy notice aims to give you information on how we collect and process your personal data including any data you may provide through our website when you sign up to receive any information, request a call back, quotation or referral, purchase a product or service, request to go on our mailing list or ask to receive any newsletter. Our website is not intended for children and we do not knowingly collect data relating to children nor do we act for children in the course of providing legal services.
It is important that you read this privacy notice together with any other privacy notice or fair processing notice we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. This privacy notice supplements any previous privacy notices and is not intended to override them. We reserve the right to update this privacy notice from time to time and you can check for the latest version on our website www.eltro.co.uk
Eltro (GB) Limited is the controller and responsible for your personal data (collectively referred to as “we”, “us” or “our”) in this privacy notice.
We have appointed a data protection manager who is responsible for overseeing questions in relation to this privacy notice. If you have any questions about this privacy notice, including any requests to exercise your legal rights, please contact the data protection manager using the details set out below.
The Data Protection Manager
Unit B4 Armstrong Mall
Southwood Business Park
Farnborough GU14 0NR
Telephone: 01252 523000
You have the right at any time to make a complaint to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.
Changes to the privacy notice and your duty to inform us of changes
This version has of the privacy notice has been prepared following changes in the data protection law on 25th May 2018. It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.
Our 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.
2. 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 which we have grouped together as follows:
- Identity Data includes first name, maiden name, last name, username or similar identifier, marital status, title, date of birth and gender.
- Contact Data includes billing address, delivery address, email address and telephone numbers.
- Financial Data includes bank account and payment card details.
- Transaction Data includes data relevant to any matter that you instruct us to undertake on your behalf including data provided by you or obtained in accordance with your instructions from other parties including where relevant to your matter sensitive personal information, details about payments to and from you and other details relating to services you have asked us to provide to you.
- 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 this website.
- Profile Data if contacting us through our website this may include your username and password, services requested by you, your interests, preferences, feedback and survey responses.
- Usage Data includes information about how you use our website and services.
- Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.
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.
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). This may also include medical information or reports from third parties that you have provided or authorised us to obtain in connection with your instructions to us. We do not collect this data or data relating to Criminal Convictions from you unless this information is specifically provided by you as relevant to a specific legal matter that you have instructed us to undertake on your behalf. Any such Special Categories of data or data relating to criminal convictions will only be retained and securely stored for the purpose of the specific matter for which it has been provided to us by you.
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.
3. 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 Identity, Contact and Financial Data by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:
- apply for information about our services directly or via our website
- seek a quotation or estimate of costs from us
- make an appointment to receive advice
- instruct us to do work for you
- subscribe to our website, articles, newsletters or other services or publications;
- request information or marketing to be sent to you;
- enter a competition, promotion or survey;
- provide feedback to us
- Automated technologies or interactions. If 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, and other similar technologies.
- Third parties or publicly available sources. We may receive personal data about you from various third parties and public sources as set out below:
- Contact, Financial and Transaction Data from providers of technical, payment and delivery services within the United Kingdom.
- Identity and Contact Data from publicly availably sources such as Companies House and the Electoral Register based inside the United Kingdom.
- Service providers acting as processors who provide design services, IT and system administration services in the United Kingdom.
- Professional advisers acting as processors including lawyers, bankers, auditors and insurers who provide consultancy, banking, legal, insurance and accounting services within the United Kingdom.
- Other parties to a transaction or matter in which you instruct us such as other parties to a transaction, other parties representatives, lawyers, accountants, insurers, agents, the courts or tribunals.
- HM Revenue & Customs, regulators and other authorities acting as processors or joint controllers based in the United Kingdom who require reporting of processing activities in certain circumstances.
4. How we use your personal data
We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:
- Where we need to perform the contract we are about to enter into or have entered into with you for the provision of goods or services.
- 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.
- Where we need to comply with a legal, statutory or regulatory obligation.
Generally we do not rely on consent as a legal basis for processing your personal data other than in relation to sending third party direct marketing communications to you via email or text message. You have the right to withdraw consent to marketing at any time by contacting the data protection manager/
Purposes for which we will use your personal data
We have set out below, in a table format, 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 the data protection manager 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 in the table below.
The lawful basis for using your personal data
Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give you the best possible service and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us.
Performance of Contract means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract in connection with the goods and services that we provide.
Comply with a legal or regulatory obligation means processing your personal data where it is necessary for compliance with any statutory or regulatory obligation that we may be subject to.
|Purpose/Activity||Type of data||Lawful basis for processing including basis of legitimate interest|
|To register you as a customer or to update identification documents.||(a) Identity
|Performance of a contract with you to enable the provision of goods and/or services to you|
|To comply with anti-money laundering, anti-terrorism; anti-bribery or other legislation designating required proof of identity||(a) Identity
|Performance of contract
Comply with legal obligations
|To process and deliver our goods and services including:
(a) Manage payments, fees and charges
|Performance of a contract
Legitimate interests (to recover debts due to us).
|To manage our relationship with you which will include:
| Performance of a contract with you
To comply with a legal obligation
For our legitimate interests (to keep our records updated and to study how customers use our products/services)
|To administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)||(a) Identity
|For our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise)
To comply with a legal obligation
|To deliver relevant website content and information to you and measure or understand the effectiveness of the advertising we serve to you||(a) Identity
|For our legitimate interests (to study how customers use our products/services, to develop them, to grow our business and to inform our strategy)|
|To use data analytics to improve our website, products/services, customer relationships and experiences||(a) Technical
|For our legitimate interests (to define types of customers for our products and services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy)|
|To make suggestions and recommendations to you about goods or services that may be of interest to you||(a) Identity
|Necessary for our legitimate interests (to develop our products/services and grow our business)|
We strive to provide you with choices regarding certain personal data uses, particularly around any marketing and advertising.
Promotional offers from us
We may use your Identity, Contact, Technical, Usage 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 will receive marketing communications from us if you have requested information from us or purchased goods or services from us or registered for a promotion and, in each case, you have not opted out of receiving that marketing.
We will not share your personal date with any third party company without your express consent.
Disclosures of your personal data
We may have to share your personal data with the parties set out below for the purposes set out in the table above:
External Third Parties
Third Parties detailed in clause 4 in the table above.
Third parties to whom we may choose to sell, transfer, or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy notice.
We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.
5. International transfers
We do not transfer your personal data outside the European Economic Area except where you instruct us to to so or it becomes necessary to do so in the course of providing goods or service to you which may require us to deal with another party on your behalf what is located outside of the EEA. In those circumstances we would not transfer any personal date without ensuring the safety and security of your personal data or without your express consent for this purpose.
6. Data Security
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. Further information regarding this can be obtained from us upon request.
7. Data retention
How long will you use my personal data for?
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. It will then be securely and permanently destroyed. We have strict policies and procedures in place for this purpose. Upon request we will provide you with a copy of our Data Retention Policy.
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, as well as the applicable statutory requirements.
Details of retention periods for different aspects of your personal data in order to comply with our statutory obligations are available by contacting the Data Privacy Manager.
By law we have to keep basic information about our clients for specific periods for example, in respect of legislative obligations or to comply with tax and accounting rules and any instruction from our insurers. We will not store your personal data for longer than we are required to.
In some circumstances you can ask us to delete your data: see section 9 below for further information.
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.
8. Your legal rights
Under certain circumstances, you have rights under data protection laws. These are as follows:
- 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.
- 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.If you make data subject access request:
- Time limit to respond – 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.
- No fee usually required – You will not have to pay a fee to access your personal data (or to exercise any of the other rights). 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.
- What we may need from you – 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.