Introduction

Welcome to the Company’s Privacy Notice.

The Company respects your privacy and is committed to protecting your personal data. This Privacy Notice will inform you as to how we look after your personal data when you interact with us and it will tell you about your privacy rights and how the law protects you.

We know that there is a lot of information here, but we want you to be fully informed about your rights. Please also use the Glossary to understand the meaning of some of the terms used in this Privacy Notice.

1. IMPORTANT INFORMATION AND WHO WE ARE

2. THE DATA WE COLLECT ABOUT YOU

3. HOW IS YOUR PERSONAL DATA COLLECTED

4. HOW WE USE YOUR PERSONAL DATA

5. DISCLOSURES OF YOUR PERSONAL DATA

6. INTERNATIONAL TRANSFERS

7. DATA SECURITY

8. DATA RETENTION

9. YOUR LEGAL RIGHTS

10. GLOSSARY

1. Important information and who we are

This Privacy Notice explains how the Company collects and processes your personal data when you interact with us, including any data you may provide through our website when you sign up for our newsletter or purchase a service. It also explains how we’ll store and handle that data, and keep it safe.

Our website is not intended for children and we do not knowingly collect data relating to children.

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 the other notices and is not intended to override them.

Controller:

The Company Limited is the controller and responsible for your personal data (referred to also as “we”,”us” or “our” in this Privacy Notice).

We have appointed a Data Protection Officer 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 us using the details set out below.

Contact details:

You can:

• email us: info@optimum-safety.co.uk

• write to us: Chris Owen, Optimum Safety Management, Greetwell Place, Lime Kiln Way, Lincoln, LN2 4US

• call us: 01522 527544

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 (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 was last updated in November 2019. It’s likely that we’ll need to update this Privacy Notice from time to time. We’ll notify you of any significant changes, but you’re welcome to come back and check it whenever you wish.

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.

Third-party links

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.

– 1 – 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 follows:

• Identity Data includes first name, maiden name, last name, username or similar identifier, marital status, title, date of birth and gender. If you provide a passport or driving licence to prove your identity, the data will also include your place of birth, facial image and nationality. Your image may also be recorded on CCTV when you visit our premises.
• Contact Data includes billing address, delivery address, email address and telephone numbers.
• Financial Data includes bank account and payment card details.
• Transaction Data includes details about payments to and from you and other details of products and services you have purchased from us.
• 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.
• 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 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.

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 service you have with us but we will notify you if this is the case at the time.

– 2 – When and how we collect your personal data

We use different methods to collect data from and about you including through:

• Direct interactions. You may give us your Identity, Contact, Financial, Marketing and Communications 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 or buy our services online, over the phone or at our premises;

• visit and/or create an account on our website;

• subscribe to our newsletter;

• book any kind of appointment with us or book to attend an event;

• enter a competition, promotion or survey;

• give us some feedback;

• fill in any forms – for example, if an accident happens at our premises, we may need to collect your personal data; or

• use our car park and premises which usually have CCTV systems operated for security purposes.

• 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, server logs and other similar technologies. We may also receive Technical Data about you if you visit other websites employing our cookies.

• Third parties or publicly available sources. We may receive personal data about you from various third parties and public sources.

– 3 – 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 a contract we have entered into with you.

• 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 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 direct marketing communications to you. You have the right to withdraw consent to marketing at any time by contacting us.

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 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 in the table below.

Marketing 

We strive to provide you with choices regarding certain personal data uses, particularly around 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 expressly consented to receive such communications, or purchased goods or services from us or if you provided us

with your details when you entered a competition or registered for a promotion and, in each case, you have not opted out of receiving that marketing. 

Third-party marketing 

We will get your express opt-in consent before we share your personal data with any other company for marketing purposes. 

Opting out 

You can ask us or third parties to stop sending you marketing communications at any time by logging into the website and checking or unchecking relevant boxes to adjust your marketing preferences, or by contacting us at any time. 

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

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. 

Change of purpose 

We will only use your personal data 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 you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us. 

If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so. 

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

– 4 – Disclosures of your personal data 

We may have to share your personal data with third parties. Examples include the following:- 

i) Delivery couriers acting as processors. 

ii) Professional advisors acting as processors or joint controllers, lawyers, bankers, auditors and insurers. 

iii) Fraud prevention agencies. 

iv) HM Revenue and Customs, regulators and other authorities acting as processors or joint controllers who require reporting of processing activities and certain circumstances. 

v) Google/Facebook to show new products that might interest you whilst you are browsing the internet. This is based on either your marketing consent or your acceptance of cookies on our website. 

vi) Service providers acting as processors who provide IT and system administration services/support. 

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 

Some of these third parties are either based outside the European Economic Area (EEA) or data is sent or stored outside the EEA so their processing of your personal data will involve a transfer of data outside the EEA. 

If we do this, we have procedures in place to ensure your data receives the same protection as if it were being processed inside the EEA. For example, our contracts with third parties stipulate the standards they must follow at all times. If you wish for more information about these contracts please contact us. 

Any transfer of your personal data will follow applicable laws and we will treat the information under the guiding principles of this Privacy Notice. 

– 6 – Data security

We know how much data security matters to all our customers. With this in mind, we will treat your data with the utmost care and take all appropriate steps to protect it. 

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. For example, we secure access to all

transactional areas of our websites using ‘https’ technology and secure sensitive data (such as payment card information) by SSL encryption. 

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. 

– 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. 

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. 

For example, when you place an order, we’ll keep the personal data you give us for six years so we can comply with our legal and contractual obligations. If your order includes a warranty, the associated personal data will be kept until the end of the warranty period. 

Full details of retention periods for different aspects of your personal data are available in our Data Retention Policy which can be made available upon request. 

In some circumstances you can ask us to delete your data: see Your legal rights 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 in relation to your personal data as set out below: 

• Access to the personal data we hold about you, free of charge in most cases. 
• Correction of your personal data when incorrect, out of date or incomplete. 
• Erasure of your personal data for example, when you withdraw consent or object and we have no legitimate overriding interest, or once the purpose for which we hold the data has come to an end (such as the end of a warranty).
• That we stop using your personal data for direct marketing (either through specific channels, or all channels). 
• That we stop any consent-based processing of your personal data after you withdraw that consent. Whenever you have given us your consent to use your personal data, you have the right to change your mind at any time and withdraw that consent. 
• That we restrict the way we process 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. 
• That we transfer your personal data to a third party by providing 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. 
• Review of any decision made based solely on automatic processing of your data (i.e. where no human has yet reviewed the outcome and criteria for the decision)

If you wish to exercise any of the rights set out above, please contact us.

No fee is 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. 

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. 

– 9 – Glossary

LAWFUL BASIS 

Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give you the best service/product 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. 

Complying with a legal or regulatory obligation means processing your personal data where it is necessary for compliance with a legal or regulatory obligation that we are subject to.