Privacy Notice

Fibreactive Ltd: Customer and Supplier Privacy Notice.  22/5/2018
Data Privacy Manager  Mrs Davina Clift
Contact dclift@fibreactive.com or Postal address: Fibreactive Ltd, Unit 25a Ganton Way Techno Trading Estate, Swindon, Wiltshire SN2 8EZ Telephone number: 01793 612222

• Important information and who we are

Controller Fibreactive is a limited company and is the Data Controller and responsible for your personal data (collectively referred to as "we", "us" or "our" in this privacy notice.) We have appointed a Data Privacy Manager (details above) Please contact them with any questions about this privacy notice, and any requests to exercise your legal rights.

Your duty to inform us of changes It is important that the personal data we hold about you is accurate and current. We will periodically (at least every 5 years) review the personal data we hold and may contact you or your organisation to verify its accuracy. Please tell us of any changes. If this notice is updated, the updated version will be posted on our website.

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.

• 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 as follows:

• Identity Data includes first name, last name
  

• Contact Data includes your employer or business billing address, delivery address, email address and telephone numbers.

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 our contract with you and you fail to provide that data when requested, we may not be able to perform the work you require. In this case, we may have to cancel any contract you have with us but we will notify you if this is the case at the time.

• How is your personal data collected?

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

• Direct You may give us your identity and contact details by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you

• Ask us to provide company and/or product information, or send us a request for quotation;

• Provide us with company and/or product information or a quotation for goods or services,

• give us some feedback.
  

• Third parties. We may receive personal data about you from various third parties as part of the execution of contracts or from publicly availably sources such your company website.

• How we use your personal data

The table below shows all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. 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.

We do NOT use your data for automated decision making.

Marketing
We will NEVER sell your personal data to any third party for marketing purposes.

We do NOT use your data for general or bulk marketing messages.

Purpose/Activity

Type of data

Lawful basis for processing including basis of legitimate interest

To register you as a new customer or supplier.

(a) Identity
(b) Contact

Necessary for our legitimate interests to supply/obtain information or quotation for products or services, or to execute a contract with you for the same.

To manage our relationship with you which will include:
(a) Notifying you about changes to our terms or privacy policy
(b) Asking you to leave a review or take a survey

(a) Identity
(b) Contact

(a) Performance of a contract with you
(b) Necessary to comply with a legal obligation
(c) Necessary for our legitimate interests (to keep our records updated and to study how customers/suppliers use/supply the products/services)
(d) Necessary for our legitimate interests in enabling us to respond to repair, maintenance and warranty requirements for products supplied or received.

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 which is compatible with the original purpose. If we do we will tell you and explain the legal basis which allows us to do so.

• Disclosures of your personal data

We may have to share your personal data with the parties set out below for the purposes set out in the table in paragraph 4 above.

• Our Directors, sales, manufacturing and service departments

• Our IT support engineers

• Our accountants and any auditors

• Other people within your organisation, sub-contractors, or other similar organisations required to enable the execution of a contract.

• Any professional body or regulatory to whom we are accountable. For example HMRC, the Police, the Information Commissioners Office.

• Our Insurers

• Third parties to whom we may choose to sell, transfer, or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. 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 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.
  

• International transfers

• We do not transfer your personal data outside the European Economic Area (EEA) without your express consent.
  

• 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 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.

• Data retention. How long will you keep my personal data for?
  

• Your personal data may be held for up to 25 years (due to the design life of many of our products), or until such time that we are informed, or otherwise establish (e.g. through our periodic reviews of the personal data we hold), that you are no longer an employee or otherwise connected to a customer or supplier. The one exception to this is where we reasonably establish retaining your personal data could be of benefit to future maintenance or customer support operations. In addition we will not retain any personal data relating to organisations no longer used by Fibreactive, where we do not need to retain their details for future maintenance or customer support operations. Archive paper contract records may still include your personal data, once all electronic records have been deleted, however these will be stored securely and destroyed after 25 years.
  

• Your legal rights

             Please contact our Data Privacy Manager rights if you want to exercise any of the following rights

Request accessto your personal data (commonly known as a "data subject access request").

Request correction of the personal data that we hold about you.

Request erasure of your personal data. Note, we may not always be able to comply with your request of erasure for specific legal reasons. We will tell you if that is the case.

Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) if 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 processingof your personal data. You can ask us to suspend processing of your personal data  (a) if you want us to check the data's accuracy; (b) where our use of the data is no longer lawful 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.  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 timewhere 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.

No fee usually required
There is no charge to exercise any of the rights. If your request is unfounded, repetitive or excessive we may charge or refuse to comply with your request.

What we may need from you
We may need 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.

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. We will tell you if that applies.

Information Commissioner's Office (ICO)
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.