Privacy Notice Revision: 14/09/18

Spooner Industries Limited 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 visit our website (regardless of where you visit it from) or after we have received it in any email correspondence. It will tell you about your privacy rights and how the law protects you.

We have appointed a Data Privacy Administrator 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 Privacy Administrator using the details set out below.

Contact details
Spooner Industries Limited
Accounts – GDPR
Moorland Engineering Works
Lower Railway Road
Ilkley, LS29 8JB
Tel: 01943 609505
Email: dataprotection@spooner.co.uk

What personal information do we collect and why do we collect it?

We may collect and process the following personal information about you through our Website or otherwise when conducting our general business activity, this includes activity as a client, a supplier or as a contractor. We collect data as follows:

• Information that you provide by filling in forms on our website. This includes information provided at the time of submitting forms, posting material or requesting contact or services. We may also ask you for information when you report a problem with our website;
• Information concerning your visits to our website (including but not limited to traffic data) and the resources that you access.
• Information received during general e-mail and telephone correspondence to and from us
• Information received in other correspondence that you send to us;
• If you provide us with your business card or other details at meetings, exhibitions, conferences or via other media.
• If you are an existing or prospective client of ours, from that relationship.
• If you are a customer or business partner of one of our existing or prospective clients, and for whom we are undertaking work.
• Indirectly, through one of our people, a client or a third party; and
• If you are involved in a business activity which utilises our core technologies and expertise.

The way we process your information varies depending on our relationship with you.
Your personal information will only be used for the fulfilment of any contracts between us or to provide you with information on products or services that you request from us or which we feel may interest you.
We will use some of the personal information supplied by you to ensure that content from our website is presented in the most effective manner for you and your computer, to keep a record of the services you have subscribed to, to deliver services you may have requested, to notify you about changes to our services, to contact you in response to applications made by you, to contact you in order to promote our services, to inform you of sector developments that may affect you or to inform you of new products, services or events which we think may be of interest to you.

If you have provided us with your contact details, we may contact you by telephone, post or by email. We will not contact you for direct marketing purposes if you have indicated that you do not wish us to use your personal information for this purpose when we collected the information. We will not pass on your personal data to third parties in order for them to market to you unless you have expressly agreed that we may do so.

We will retain your personal information for so long as is reasonably necessary and delete it thereafter. You have the right to contact us at any time to ask us not to process your personal data for marketing purposes by writing to us or by sending an email to dataprotection@spooner.co.uk

Disclosure of your personal data

We will only disclose your personal information to another person or organisation where we:
• Need to share the information to provide a product or service you have requested;
• Need to send the information to persons or organisations who engage us to conduct services on their behalf, including where you are that third party’s customer;
• Need to send the information to persons or organisations that work on our behalf to provide a product or service to you but such persons or organisations may only use this information in order to provide such product or service on our behalf and not for any other purpose. Where such a person or organisation does work on our behalf we will ensure that they take appropriate technical and organisational measures to protect your personal information against unauthorised or unlawful processing and against accidental loss or destruction of, or damage to, personal information; or
• Are required to disclose the information in order to comply with the law or the requirements of a regulatory authority.

Where we store your personal data

The personal information that we collect from you will be stored on our servers, which are situated within the UK.

We do not normally process your data internationally; however there are exceptions to this such as:
• to third parties (such as advisers or other Suppliers to our business);
• to overseas clients
• to clients within your country who may, in turn, transfer your data internationally;
• to a cloud-based storage provider; and
• to other third parties, as referred to here.

We want to make sure that your data are stored and transferred in a secure way. We will therefore only transfer data outside of the European Economic Area or EEA where it is compliant with data protection legislation and the means of transfer provides adequate safeguards in relation to your data, for example:
• by way of data transfer agreement, incorporating the current standard contractual clauses adopted by the European Commission for the transfer of personal data by data controllers in the EEA to data controllers and processors in jurisdictions without adequate data protection laws; or
• by signing up to the EU-U.S. Privacy Shield Framework for the transfer of personal data from entities in the EU to entities in the United States of America or any equivalent agreement in respect of other jurisdictions; or
• transferring your data to a country where there has been a finding of adequacy by the European Commission in respect of that country’s levels of data protection via its legislation; or
• where it is necessary for the conclusion or performance of a contract between ourselves and a third party and the transfer is in your interests for the purposes of that contract (for example, if we need to transfer data outside the EEA in order to meet our obligations under that contract if you are a Client of ours); or
• where you have consented to the data transfer.
Retention of your personal data

We will retain your personal information only so long as is reasonably necessary for the purpose for which it was obtained and in accordance with our legal obligations and follow our data destruction policy and processes thereafter.

Links to other websites

This Notice only extends to our website and does not, therefore, extend to your use of, provision of information to and collection of information on any website not connected to which you may link by using the hypertext links within our website.

IP addresses

We may collect information about your computer, including where available your IP address, operating system and browser type, for system administration and to collect aggregate information for us to use. This is statistical data about our users’ browsing actions and patterns, and does not identify any individual.

Your Rights
Under certain circumstances, you have rights under data protection laws in relation to your personal data:
• Request access to your personal data.
• Request correction of your personal data.
• Request erasure of your personal data.
• Object to processing of your personal data.
• Request restriction of processing your personal data.
• Request transfer of your personal data.
• Right to withdraw consent.
If you wish to exercise any of the rights set out above, please contact us.

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.

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.

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

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.

Cookies

What are cookies and why do we use them?

Cookies are small text files that are created and stored on your browser or the hard drive of your computer by websites that you visit to enable the website to operate properly to ‘remember’ who you are and to monitor website traffic. Cookies are generally only visible to the website that serves them and not to other websites.

Cookies are used on our website to ‘remember’ information so that it can be passed from page to page and to collect website statistics. This statistical data collected may be used to help improve our website and the services that we offer to you. Some of our cookies will also recognise you as a previous visitor the next time you visit our website to improve your experience.

How to manage cookies

Most internet browsers accept cookies automatically however, you can accept, delete or disable cookies if you wish; the process for which can usually be found in your internet browser’s ‘Help’ menu.

For more information about cookies and instructions on how to adjust your browsers settings to accept, delete or reject cookies, see the IAB website -http://www.youronlinechoices.com/uk/

The relevant page for adjusting your browser settings is available here – http://www.youronlinechoices.com/uk/five-top-tips

If you disable cookies then, whilst you may be able to browse our entire website, some of the cookies we use may be essential for the website to operate and some features may, therefore, not be available to you. Unless you have adjusted your browser settings so that it will refuse cookies, our system will issue cookies as soon as you visit our website.

Our use of cookies

We use two categories of cookie on our website. None of them stores any information that identifies you personally, such as a name or postal address.

If you register with us or if you continue to use our website, you agree to our use of cookies.

Cookies we use

Statistics
Statistics cookies help us to understand how visitors interact with our website by reporting usage statistics to us anonymously.

Marketing

Marketing cookies are used to track our website visitor’s use across our website. This allows us to display advertisements that are relevant and engaging for the individual user.