This Privacy Notice explains in detail the types of personal data we may collect about you when you interact with us. It also explains how we will store and handle that data and keep it safe. We appreciate that this document contains a lot of information but we want you to be fully informed about your rights and how we use your data. We trust that this document will answer any questions you may have but if not, please do contact us. As we may need to update this Privacy Notice please feel free to revisit the document from time to time.
2. Explaining the legal bases we rely on
The law on data protection sets out a number of different reasons for which a company may collect and process your personal data, including:
In specific situations, we can collect and process your data with your consent. For example, when you tick a box to receive email newsletters or details of offers When collecting your personal data, we will always make clear to you which data is necessary in connection with a particular service.
In certain circumstances, we need your personal data to comply with our contractual obligations. For example, if you order requires delivery we will use your designated delivery address information for this purpose and pass them on to our courier / haulage company.
If the law requires us to, we may need to collect and process your data. For example, we can pass on details of people involved in fraud or other criminal activity affecting Grilles & Architectural Products Limited to the relevant law enforcement bodies.
In specific situations, we require your data to pursue our legitimate interests in a way which might reasonably be expected as part of running our business and which does not materially impact your rights, freedom or interests. For example, we will use your purchase history to contact you prior to peak production runs / shutdown periods to make you aware of any offers or pending interruptions to production. We will also combine your order history to identify trends to ensure that we can maintain market demands and customer expectations.
3. When do we collect your personal data?
1. When you visit any of our websites. 2. When you purchase a product by phone/email or fax but do not have (or do not use) an account. 3. When you engage with us on social media. 4. When you contact us by any means with queries, complaints etc. 5. When you ask one of our employees to email you information about a product or service. 6. When you comment on or review our products and services. Any individual may access personal data related to them, including opinions. So if your comment or review includes information about the employee who provided that service, it may be passed on to them if requested. 7. When you fill in any forms. For example, if an accident happens on site, an employee may collect your personal data. 8. When you have given a third party permission to share with us the information they hold about you. 9. We collect data from publicly available sources (such as Land Registry) when you have given your consent to share information or where the information is made public as a matter of law. 10. When you enter our premises which usually have CCTV systems operated for the security of both customers and employees. These systems may record your image during your visit.
4. What sort of personal data do we collect?
If you have an account with us your name, billing/delivery address, orders and receipts, email and telephone number. Details of your interactions with us through our sales office, customer services team or online through our websites or social media, For example, we collect notes from our conversations with you, details of any complaints or comments you make, details of purchases you made, items that may be of interest to you and how/when you contact us.
1. Your comments and product reviews. 2. Your image may be recorded on CCTV when you visit our premises. 3. Your social media username, if you interact with us through those channels, to help us respond to your comments, questions or feedback.
5. How and why do we use your personal data?
We want to provide you with the best possible customer service and delivery. One way to achieve this is to get the fullest overall picture we can of who you are by amalgamating the data we have about you. We can these uses this to promote products and services that are most likely to interest you. The data privacy law allows this as part of our legitimate interest in understanding our customers and providing the highest levels of service. However, if you wish to change how we use your data, you will find details in the ‘What are my rights?’ section below. Remember, if you choose not to share your personal data with us, or refuse certain contact permissions, we may not be able to provide some of the services you have asked for.
For example, if you have asked us to let you know when there is a particular shortage of a stock item, we cannot do that if you have withdrawn your general consent to hear from us. Here’s how we’ll use your personal data and why:
1. To process any orders that you make by telephone, email, verbally or by fax. If we do not collect your personal data during the order processing, we will not be able to process your order and comply with our legal obligations. For example, your details may need to be passed to a third party during our manufacturing, supply or delivery process and we may keep your details for a reasonable period afterwards in order to fulfil any contractual obligations such as refunds, guarantees and so on.
2. To respond to your queries, refund requests and complaints. Handling the information, you sent enables us to respond. We may also keep a record of this information for any future communication with us and to illustrate our communication with you throughout each process. We do this on the basis of our contractual obligations to you, our legal obligations and our legitimate interests in providing you with the best service and understanding how we can improve our service based on your experience.
3. To protect our business and your account from fraud and other illegal activities. This includes using your personal data to maintain, update and safeguard your account. We will do all of this as part of our legitimate interest. For example, when an order is placed and a 3rd party collects the product from our premises.
4. To protect our customers, premises, assets and Employees from crime, we operate CCTV systems on our premises which record images for security. We do this on the basis of our legitimate business interests.
5. To process payments and to prevent fraudulent transactions. We do this on the basis of our legitimate business interests. This also helps to protect our customers from fraud.
If we discover any criminal activity or alleged criminal activity through our use of CCTV, fraud monitoring and suspicious transaction monitoring, we will process this data for the purposes of preventing or detecting unlawful acts. We aim to protect the individuals we interact with from criminal activities.
With your consent, we will use your personal data, preferences and details of your transactions to keep you informed by email, web, text, telephone and through our sales offices about relevant products and services. Of course, you are free to opt out of hearing from us by any of these channels at any time.
1. To send you relevant, personalised communications by post in relation to updates, offers, services and products. We’ll do this on the basis of our legitimate business interest. You are free to opt out of hearing from us by post at any time.
2. To send you communications required by law or which are necessary to inform you about our changes to the services we provide you. For example, updates to this Privacy Notice, product recall notices, and legally required information relating to your orders. These service messages will not include any promotional content and do not require prior consent when sent by email or text message. If we do not use your personal data for these purposes, we would be unable to comply with our legal obligations.
3. To develop, test and improve the systems, services and products we provide to you. We’ll do this on the basis of our legitimate business interests.
4. To comply with our contractual or legal obligations to share data with law enforcement. For example, when a court order is submitted to share data with law enforcement agencies or a court of law.
5. To send you survey and feedback requests to help improve our services. These messages will not include any promotional content and do not require prior consent when sent by email or text message. We have a legitimate interest to do so as this helps make our products or services more relevant to you.
Of course, you are free to opt out of receiving these requests from us at any time by by updating your preferences in your online account. Sometimes, we will need to share your details with a third party who is providing a service (such as delivery couriers). We do so to maintain our appointment with you. Without sharing your personal data, we would be unable to fulfil your request.
6. Combining your data for personalised direct marketing
We want to bring you offers and promotions that are most relevant to your interests at particular times. To help us form a better, overall understanding of you as a customer, we combine your personal data gathered across the Company as described above, for example your purchase history.
7. How we protect your personal data
1. 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. 2. We allow no incoming ports open on our up to date router, Only specific staff are allowed onto our secured WPA wifi network, which is separated from the company network. 3. All our client machines are running the latest operating systems with the latest updates, and are connected via ethernet cable. 4. Each machine is running Eset Nod32 antivirus and are maintained twice yearly to check for Adware/Malware. 5. We run no embedded systems that may be insecure. 6. All our machines are secure with a logon password. 7. We secure access to all transactional areas over port443 using ‘https’ technology. 8. Access to your personal data is password-protected and we are PCI compliant and as such do not support. 9. Protocols TLS1.0, TLS1.1, SSL2.0 SSL3.0 and weak Cypher encryption suites.
We regularly monitor our system for possible vulnerabilities and attacks, and we carry out penetration testing to identify ways to further strengthen security. https://www.microsoft.com/en-us/trustcenter/privacy/gdpr/solutions
8. How long will we keep your personal data?
Whenever we collect or process your personal data, we’ll only keep it for as long as is necessary for the purpose for which it was collected. At the end of that retention period, your data will either be deleted completely or anonymised, for example by aggregation with other data so that it can be used in a non-identifiable way for statistical analysis and business planning. Some examples of customer data retention periods:
Orders. When you place an order, we will keep the personal data you give us for ten years so we can comply with our legal and contractual obligations.
Inactive accounts. If you have not used your account for more than five years, it will be flagged as inactive and we will contact you to ask whether you want to keep it open. Unless you reply to say ‘yes’, we’ll close the account and delete or anonymise the personal data associated with it.
9. Who do we share your personal data with?
We sometimes share your personal data with trusted third parties. For example, delivery couriers, for fraud management, to handle complaints. Here’s the policy we apply to those organisations to keep your data safe and protect your privacy:
1. We provide only the information they need to perform their specific services. 2. They may only use your data for the exact purposes we specify in our contract with them. 3. We work closely with them to ensure that your privacy is respected and protected at all times. 4. If we stop using their services, any of your data held by them will either be deleted or rendered anonymous. Examples of the kind of third parties we work with are:
A. IT companies who support our business systems.
B. Operational companies such as delivery couriers.
Sharing your data with third parties for their own purposes: We will only do this in very specific circumstances, for example:
For fraud management, we may share information about fraudulent or potentially fraudulent activity in our premises or systems. This may include sharing data about individuals with law enforcement bodies.
We may also be required to disclose your personal data to the police or other enforcement, regulatory or Government body, in your country of origin or elsewhere, upon a valid request to do so. These requests are assessed on a case-by-case basis and take the privacy of our customers into consideration. For further information please contact our Data Protection Officer.
10. Where your personal data may be processed
Sometimes we will need to share your personal data with third parties and suppliers outside the European Economic Area (EEA).
International orders. If you are based outside the UK and place an order with us, we will transfer the personal data that we collect from you to the Company in the UK.
Protecting your data outside the EEA. The EEA includes all EU Member countries as well as Iceland, Liechtenstein and Norway. We may transfer personal data that we collect from you to third-party data processors in countries that are outside the EEA such as Australia or the USA.
For example, this might be required for shipping purposes, processing your payments or providing support services.
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 our Data Protection Officer. Any transfer of your personal data will follow applicable laws and we will treat the information under the guiding principles of this Privacy Notice.
11. What are your rights over your personal data?
An overview of your different rights
You have the right to request:
1. Access to the personal data we hold about you, free of charge in most cases. 2. The correction of your personal data when incorrect, out of date or incomplete. 3. That we stop using your personal data for direct marketing (either through specific channels, or all channels). 4. That we stop any consent-based processing of your personal data after you withdraw that consent. 5. Review by an Employee 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).
You can contact us to request to exercise these rights at any time as follows: To ask for your information please contact The Data Protection Officer, Grilles & Architectural Products Limited, Ava House, 1 Hill Court, Aurillac Way, Hallcroft Industrial Estate, Retford, Nottinghamshire. DN22 7PX. To ask for your information to be amended contact our sales team by email firstname.lastname@example.org
If we choose not to action your request we will explain to you the reasons for our refusal.
Your right to withdraw 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.
Where we rely on our legitimate interest. In cases where we are processing your personal data on the basis of our legitimate interest, you can ask us to stop for reasons connected to your individual situation. We must then do so unless we believe we have a legitimate overriding reason to continue processing your personal data.
Direct marketing. You have the right to stop the use of your personal data for direct marketing activity through all channels, or selected channels. We must always comply with your request.
Checking your identity. To protect the confidentiality of your information, we will ask you to verify your identity before proceeding with any request you make under this Privacy Notice. If you have authorised a third party to submit a request on your behalf, we will ask them to prove they have your permission to act.
12. How can you stop the use of your personal data for direct marketing?
There are several ways you can stop direct marketing communications from us:
Click the ‘unsubscribe’ link in any email communication that we send you. We will then stop any further emails from Grilles & Architectural Products Limited. Write to The Data Protection Officer, Grilles & Architectural Products Limited, Ava House, 1 Hill Court, Aurillac Way, Hallcroft Industrial Estate, Retford, Nottinghamshire. DN22 7PX Please note that you may continue to receive communications for a short period after changing your preferences while our systems are fully updated.
13. Contacting the Regulator
If you feel that your data has not been handled correctly, or you are unhappy with our response to any requests you have made to us regarding the use of your personal data, you have the right to lodge a complaint with the Information Commissioner’s Office. You can contact them by calling 0303 123 1113.
Or go online to www.ico.org.uk/concerns (opens in a new window; please note we cannot be responsible for the content of external websites) If you are based outside the UK, you have the right to lodge your complaint with the relevant data protection regulator in your country of residence. Details can be found in Section 16.
14. If you live outside the UK
For all non-UK customers
This Privacy Notice will only be available in English.
By using our services or providing your personal data to us, you expressly consent to the processing of your personal data by us or on our behalf. Of course, you still have the right to ask us not to process your data in certain ways, and if you do so, we will respect your wishes.
Sometimes we will need to transfer your personal data between countries to enable us to supply the goods you have requested. In the ordinary course of business, we may transfer your personal data from your country of residence to ourselves and to third parties located in the UK.
By dealing with us, you are giving your consent to this overseas use, transfer and disclosure of your personal data outside your country of residence for our ordinary business purposes. This may occur because our information technology storage facilities and servers are located outside your country of residence, and could include storage of your personal data on servers in the UK. We will ensure that reasonable steps are taken to prevent third parties outside your country of residence using your personal data in any way that is not set out in this Privacy Notice. We will also make sure we adequately protect the confidentiality and privacy of your personal data.
We will ensure that any third parties process your personal data only in accordance with their legitimate interests. These third parties may be subject to different laws from those which apply in your country of residence. Please note that we do not take active steps to ensure that any overseas recipient of your personal data complies with the laws which apply in your country.
15. Any questions?
We hope this Privacy Notice has been helpful in setting out the way we handle your personal data and your rights to control it. If you have any questions that have not been covered, please contact us, or write to our Data Protection Officer who will be pleased to help you: Write to us, at:
Data Protection Officer
Grilles & Architectural Products Limited
1 Hill Court
Hallcroft Industrial Estate