The purpose of this privacy notice
This privacy notice gives you information on how we collect and process your personal data including any information you may give us through our website, through any applications or any third party online platform in order to
· place an order or 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 marketing material or information.
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 but 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.
The Company is the controller and is responsible for your personal data.
Under the terms stipulated by the InformationCommissioner’s Office (ICO), which is the UK supervisory authority for data protection issues (www.ico.org.uk), we do not need an appointed data protection officer, but the business has appointed a compliance team to oversee compliance with this privacy notice. If you have any questions about this privacy notice, including any requests to exercise your legal rights, please contact our Compliance Team using the details set out below.
ComplianceTeam, Morrisroe Group, Warwick Road, Borehamwood WD6 1GS
Telephone 020 8731 4000 or email email@example.com
You have the right at any time to make a complaint to the ICO, but to give us an opportunity to deal with your concerns before you approach them, please contact us first.
Your duty to inform us of changes
To ensure the information we hold is correct, please keep us informed if your personal data changes; you can do this directly or through the links on our website.
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 any of 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.
Your personal data, or personal information, means any information about you from which you can be identified.It does not include data where your identity has been removed (known as ‘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 may include first names, last name, any previous names, usernames or similar identifiers, your marital status, title, date of birth, age and gender.
· Contact data includes your billing address, delivery address, email address and telephone numbers.
· Financial data includes bank account and payment details.
· Transaction data includes data relevant to any matter that you instruct us to undertake on your behalf including data provided by you, obtained from other, details about payments to and from you and other details relating to goods and/or services you have asked us to provide to you.
· Technical data includes your internet protocol (IP) address, login data, browser type and version, time zone setting and location, browser plug-in types and versions, applications, operating systems and platforms and other technology on any devices you use to access theCompany or our website.
· Profile data includes information we collect when you contact us through our website, applications, plug-ins or platforms, and may include your username and password, services requested by you, your interests peferences, feedback and survey responses.
· Usage data includes information about how you use the Company, our website and goods and services.
· Marketing and communications data includes your preferences in receiving marketing messages from us, our affiliates and third parties, and your individual communication preferences.
We also collect, use and share aggregated data such as statistical ordemographic data. 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 – although we don’t necessarily collect this data about you, it would include details about your race or ethnicity, religious orphilosophical beliefs, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data and any disability. We do not collect data relating to criminal convictions from you unless this information is specifically provided by you as relevant to a specific matter.
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 don’t provide that data when requested, we might not be able to fulfil 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 contract you have with us, but we will always seek to notify you if this is the case at the time.
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 goods or services directly, via a third party or via our website
> order goods or services or seek a quotation directly, via our website or via any third party platform, app, plug-in or affiliate;
> subscribe to our website, articles, information or other services or publications;
> request information or marketing to be sent to you;
> enter a competition, promotion or survey;
> provide feedback to us
· 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;
> Identity and contact data from providers of technical services, applications, plug-ins, platforms through which you have contacted the Company;
> Service providers acting as processors who provide design services, IT and system administration services;
> Professional advisers acting as processors including lawyers, bankers, auditors and insurers who provide consultancy, banking, legal, insurance and accounting services;
> HM Revenue & Customs, regulators and other authorities acting as processors or joint controllers based in the UK whorequire reporting of processing activities in certain circumstances.
We will only use your personal data how and when the law allows us to, such as 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 and/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 obligations.
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.
And you have the right to withdraw consent to marketing at any time by unsubscribing from communications or contacting our Compliance Team.
In the table below, we have set out all the ways we plan to use your personal data, and the legal bases we rely on to do so. We have also identified what our legitimate interests are, where appropriate.
Note: we may use your personal data for more than one lawful ground depending on the specific purpose for which we are using your data.Please contact our Compliance Team if you need details about the specific legal ground we are relying on to use your personal data where more than one ground has been set out in the table below.
Legitimate interest means the interest of our business in conducting and managing our business to give you the best possible service and the most secure experience.
We always 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 never 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).
For further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities, contacting our Compliance Team at any time.
Performance of contract means using your data where it is necessary for fulfilling a contract which involves you, or to take steps at your request before entering into a contract in connection with the legal services that we provide.
means processing your personal data where it is necessary for compliance with a legal or regulatory obligation.
We always try to provide you with choices regarding certain personal data uses, particularly around any marketing and advertising.
Tailoring promotional offers to your preferences
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.
If you have requested information from us, purchased goods or services from us or registered for a promotion, you will receive marketing communications from us unless you have not opted out of receiving those messages.
Working with trusted third parties
We do not share your personal data with any third party company without your express consent. However, please be aware that If you have contacted us via an app, plug-in, platform, affiliate or other third party, then we may have no control over the marketing activities of any such third party, or their respective privacy policies and notices.
We only disclose your personal data in very specific circumstances
We may have to share your personal data with the parties set out below for the purposes set out in the table above:
a) Third parties detailed in clause 4 in the table above.
b) Third parties to whom we may choose to sell, transfer, or merge parts of our business or our assets. Alternatively, we might acquire or merge with other businesses. 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 insist that all third parties respect the security of your personal data and treat it in accordance with the law. We don’t ever allow our third party service providers to use your personal data for their own purposes and only permit them to process your personal data in accordance with our instructions.
We do not transfer your personal data outside the European Union or European Economic Area except to a limited extent in order to fulfil a contract where you instruct us to actin a matter or require us to deal with another party on your behalf that is located outside of the EEA. In those circumstances we would not transfer any personal data without ensuring the safety and security of your personal data
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.
We also limit access to your personal data to those employees, agents, contractors, distributors and other third parties who have a business need to use it, and they will only process your personal data on our instructions, within 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 can be obtained from our Compliance Team.
Wewill only retain your personal data for as long as necessary to fulfil theprposes we collected it for, including for the purposes of satisfying anylegal, accounting, or reporting requirements. It will then be securely and permanently destroyed. We havestrict policies and procedures in place for this purpose.
To decide 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 our Compliance Team.
Bylaw, we have to keep basic information about our customers in relation to oucntracts and accounts or to comply with tax and accounting rules and anyregulatory obligations. We will not store your personal data for longer than weare required to. In some circumstances you can ask us to delete your data; see section9 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.
Every individual has the following rights under data protection laws; you can:-
Request correction of the personal data that we hold about you. You can ask us to correct any incomplete or inaccurate data we hold about you, once we have checked the accuracy of the new data you provide to us.
Request erasure of your personal data. You can ask us to delete or remove personal data where there is no good reason for us continuing to use 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: we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you at the time of your request.
Object to processing of your personal data. You can object if we are relying on a legitimate interest (or that of a third party) and there is something about your situation which makes you believe 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 give to you, or a nominated third party, your personal data in a structured, commonly used, machine-readable format. Note: this right only applies to automated information which you initially consented to us using 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 legality of any data use 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, but we will advise you if this is the case at the time.
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 a data subject access request:
· we will tryto respond to all legitimate requests within one month although it may take us longer 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 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.
· 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.
If you have any questions, suggestions or complaints about the processing of your personal information or wish to contact us to request/access/amend/update/remove your data, please contact the Morrisroe Data Protection Officer.
Name: Gerry Marapao
Address: Units3 & 4 Oaks Court, Warwick Road, Borehamwood, Herts, WD6 1GS.