We respect your privacy and are 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 as a customer or supplier, or as an employee or representative of either, visit our premises, or visit and use our website (Site).
It also informs you how we will look after your personal data when, and about your privacy rights and how the law protects you. It does not cover any website you have used to access our Site or any website that you access from our Site.
It is important that you read this privacy notice so that you are fully aware of how and why we are using your data.
1. WHO WE ARE
Under the General Data Protection Regulation (GDPR) and other relevant data protection legislation, we act as a data controller (make decisions) in relation to any of your personal data that we collect.
If you have any questions about this privacy notice, including any requests to exercise any of your legal rights, please contact us using the details set out below.
Our full details are:
Full Name of Legal Entity: Calibro Workspace Limited, company number NI633358
Email Address: firstname.lastname@example.org
Postal Address: Calibro Workspace Ltd, Unit 6 Rathenraw Industrial Estate, Antrim, BT41 2SJ
ICO Registration Number: ZA682851
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). However, we would welcome the chance to deal with your concerns before you approach the ICO so would ask that you please contact us in the first instance.
This privacy notice was last updated on 4 December 2020. We reserve the right to vary the terms of this privacy notice from time to time. Any material changes to this privacy notice will be notified to you.
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 Site 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 such third-party websites and are not responsible for their privacy notices. When you leave our Site, we encourage you to read the privacy notice of every website you visit.
2. 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 set out below.
DATA THAT YOU SUPPLY TO US
• General Personal Data – this is personal information about you that you share with us by online forms on our Site, through email, through the post, on the telephone or by any other means. Typically, when you deal with us you may provide information about yourself or your business, including your name, job title, address, business name, personal and/or business email address, telephone and/or mobile phone number and other contact details. You may provide similar information where you contact us or sign up to our newsletter or other marketing emails. You may also communicate your preferences in receiving marketing from us and third-parties and your communication preferences (including details you provide when you opt-in to receive marketing communications from us).
• Financial Data – we do not typically collect or hold your financial details, save where you have provided us with these in order to facilitate payments.
• Contact Data – should you contact us regarding any issue (in writing, by phone or in person), information arising from that contact shall be collected, including relevant notes about the issue and how we responded to the issue.
• Third-Party Personal Data – where you share personal data that do not relate to you, you must ensure you have the consent to do so and have shared this privacy notice with such person(s).
DATA THAT WE COLLECT
• Telephone Recordings – telephone conversations may be recorded to improve training, to ensure a high level of consistent customer service, or otherwise as required in our legitimate interests or to process contracts we have with you or your business.
• CCTV Footage – we may use CCTV cameras on our premises and may record footage of you where you attend our premises in person, and use such footage as required in our legitimate interests, including to ensure the safety and well-being of our staff.
• Technical Data – we may use certain technical services to gather technical data online whenever you use our Site, including information relating to the services we provide.
INFORMATION WE RECEIVE FROM THIRD-PARTIES
• Social Media – where you have responded to us through any social media channel, we may receive profile information about you which can include your name, address, telephone number(s) and/or your business contact details. This information will be used to respond to your interest, to fulfil a request from you and/or to send you future information and offers, where you have given consent to do so.
• Publicly Available Information – we may collect personal information about you from publicly available sources. This can include your name, address and other publicly available information. This may include credit reference agencies such as Experian, public registers such as the Companies House registry or the Electoral Register.
We may 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 feature on our Site. 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 (including details about your race or ethnicity, religious or philosophical beliefs, medical information, sex life, sexual orientation, political opinions, trade union membership, genetic and biometric data or information on your criminal convictions and offences).
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 it is necessary for our legitimate interests (or those of a third-party) and your interests and fundamental rights do not override those interests; and
• where we need to comply with a legal or regulatory obligation.
We do not generally rely on consent as a legal basis for processing your personal data other as set out below in relation to marketing.
We may process your personal data on more than one lawful ground, depending on the specific purpose for which we are using your data.
Our Standard Business Operations:
• to provide the services that we contract with you to provide;
• to provide you with information that you request from us;
• to confirm your identity as a natural living person; and
• as part of our billing, payments and recovery processes.
We may use your 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 only receive marketing communications from us if you have opted to receive them. This includes where you have consented to being contacted by us by email or telephone. You can opt in over the phone, by email, online or in person. You can ask us to stop sending you marketing messages at any time by following the opt-out links on any marketing message sent to you or by contacting us, as appropriate, at any time. Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of a product or service purchase or other transactions.
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 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.
We will process your data pursuant to any legal or regulatory requirements imposed upon us and can use your data to protect our legal position, if legal action is required, including the recovery of any outstanding debts.
By way of further example, we will share your personal data with relevant agencies and without notice, where we are requested to or suspect fraudulent activities, money laundering, terrorist related activities.
4. DISCLOSURES OF YOUR PERSONAL DATA
We may have to share your personal data with the categories of data processors or data controllers set out below for the purposes set out in in section 3 above or otherwise below:
• with 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;
• with third party purchasers, if we buy, sell or merge any business or assets of our business and are required to share data as part of the buying, selling or merger agreement. 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;
• with third party purchasers, if our assets are acquired by a third-party, and data is transferred as part of the purchased assets;
• with selected third parties for performance of our contracts with you;
• with specific selected third parties, determined by us, if you breach any agreement with us, including so as to enforce our rights against you, including credit-reference agencies, debt-collection firms or service providers, solicitors or barristers and law enforcement agencies (if applicable);
• with service providers acting as processors based in the European Economic Area or United Kingdom who provide IT and system administration services, including email marketing services and the providers of data analytics services.
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 the minimal personal data required for the specified purposes and in accordance with our instructions.
In addition to the specific disclosures of personal data set out in this section, we may also disclose your personal data where such disclosure is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person.
We will get your express opt-in consent before we share your personal data with any company outside of our own for marketing purposes.
5. 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.
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.
Unfortunately, the transmission of information via the internet is not completely secure. We cannot guarantee the security of your data transmitted to our Site, and before it reaches us, such data is transmitted at your own risk.
6. 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.
We will keep your data for the term you have consented to, the contracted term between us where there is a legitimate interest for us to remain in contact with you, or for the legally required period, whichever is the longest.
By law we have to keep basic information about any of our customers (including contact, identity, financial and transaction data) for 6 years after you cease being a customer for tax purposes. For the purposes of contract administration, we will also store all data as long as the contract you have placed through us endures and for the 6-year limitation period thereafter in case you raise any claims in relation to any products you have purchased from us.
Generally, however, personal data will be retained for 2 years following your transaction on our Site, at the end of which period it will be deleted from our systems.
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.
7. YOUR LEGAL RIGHTS
Under certain circumstances, you have rights under data protection laws in relation to your personal data. You have the right to:
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.
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.
Please 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.
If you wish to exercise any of the rights set out above, please contact us.
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 such circumstances.
Where you exercise one of your rights, we may need to request specific information from you to help us confirm your identity and ensure your right to exercise such 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.
We try to respond to all legitimate requests within 30 days. 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.
8. LAW & JURISDICTION
This privacy notice shall be governed by and interpreted in accordance with the laws of Northern Ireland and you irrevocably agree that the courts of Northern Ireland shall have exclusive jurisdiction to settle any dispute which may arise out of, under, or in connection with this privacy notice.