We are Varley Insulation Products Limited.
We are the ‘data controller’ of the information you provide us with, which means we control the way information is used and processed.
How we collect your personal information?
- ◦ Speaking to, or contacting us in general;
- ◦ creating or registering for an account on our website;
- ◦ subscribing to any of our mailing lists;
- ◦ by giving us some feedback;
- ◦ by sending us emails and text messages;
- ◦ by liking or disliking any element of our business;
- ◦ by interacting with us through social media platforms such as Facebook, or Twitter etc;
Automated technologies or interactions
As you interact with our website(s), we may automatically collect technical data about your equipment, browsing actions and patterns. We collect this personal data by using cookies, server logs and other similar technologies. We may also receive technical data about you if you visit other websites employing our cookies.
Third parties or publicly available sources
We may receive personal data about you from various third parties as set out below:
- ◦ Technical Data from the following parties:
- ◦ analytics providers such as Google based outside the EU;
- ◦ advertising networks; and
- ◦ search information providers.
- ◦ Contact, Financial and Transaction Data from providers of technical, payment and delivery services such as Mastercard, Barclaycard, American Express, Experian based inside and outside of the EEA.
- ◦ Identity and Contact Data from data brokers or aggregators based inside the EEA.
Your Personal Data
We may collect, store, and use the following categories of personal information about you:
Title, first name, last name, username or similar identifier, date of birth, and gender.
Address, email address and telephone numbers.
Bank account and payment card details.
Internet protocol (IP) address;
IMEI number from your phone;
your login data;
browser type and version;
time zone setting and location;
browser plug-in types and versions;
operating system and platform and other technology on the devices you use to access this website;
information where you came to our site from, and where you went when you left it.
We also track how often you visit and use our websites and mobile apps. We do this via email and website cookies and similar tracking technology built into our mobile apps.
your username and password;
your interests, preferences, feedback and survey responses;
Information about how you use our website, products and services;
Information on what you view, click on access by way of our marketing emails and text messages (SMS, MMS), website and mobile.
Marketing and Communications Data
Your preferences in receiving marketing from us, our third parties, and your communication preferences.
Aggregated Data (sometimes referred to a pseudonymised data)
We also collect, use and share Aggregated Data (sometimes referred to a pseudonymised 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 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 Category Data
We may also collect, store and use the following “special categories” of more sensitive personal information such as your racial or ethnic origin, religious beliefs or other beliefs of a similar nature and your physical condition (e.g. if you’re pregnant). We ask for a fair amount of this kind of detail in the forms you fill in, and you can choose whether or not you want to provide it. However, we may also acquire it through social media or as a result of our analysis of your preferences and behaviours.
How we will use information about you?
We will only use your personal information when the law allows us to. We will use your personal information in the following circumstances:
- ◦ When you consent to us doing so;
- ◦ Where we need to perform the contract we have entered into with you;
- ◦ Where we need to comply with a legal obligation;
- ◦ 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.
- ◦ means the interest of our business in conducting and managing our business to enable us to give you the best service/product and the best and most secure experience;
- ◦ We 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 do not 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).
We may also use your personal information in the following situations, which are likely to be rare:
- ◦ Where we need to protect your interests (or someone else’s interests);
- ◦ Where it is needed in the public interest or for official purposes;
We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising.
– Promotional offers from us
If you have expressly opted-in to receive marketing from us 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 (we call this marketing).
You will receive marketing communications from us if you have requested information from us or purchased goods or services from us or if you provided us with your details when you entered a competition or registered for a promotion and, in each case, you have not opted out of receiving that marketing.
– Third-party marketing
We will get your express opt-in consent before we share your personal data with any company outside of Varley Insulation products Limited for marketing purposes.
– Opting out
You can ask us or third parties to stop sending you marketing messages at any time through our website or by contacting us at any time.
– Change of purpose
We will only use your personal information 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 information 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 information without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.
Disclosure of Personal Data
On occasion we may have to share your personal data with the parties set out below for the purposes set out.
External Third Parties
Service providers: acting as processors based within the EEA who provide IT and system administration services.
Professional advisers: acting as processors or joint controllers including lawyers, bankers, auditors and insurers based within the EEA who provide consultancy, banking, legal, insurance and professional service providers.
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.
Other people who help us provide our websites, mobile apps, and related services to you: They include information technology experts who design and host our websites, and payment services companies that make it easy for you to use your credit or payment cards with us. Other examples include market research companies, marketing, advertising, design and PR organisations and general service companies such as printers, mailing houses and form-scanning service providers.
With social media companies such as Facebook and Twitter: and our advertising partners to enable us to run targeted promotions for you on their platforms;
Any new business partners: we may have over time, for example, in the event of a joint venture, reorganisation, business merger or sale that affects us.
The Police, local authorities, Her Majesty’s Revenue and Customs (HMRC), the courts and any other government authority: if they ask us to do so (but only if us doing so is lawful).
Other people who make a ‘subject access request’: where we are required to do so by law.
We may also share the information we collect where we are legally obliged to do so, e.g. to comply with a court order.
Social media, blogs, reviews, etc.
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.
A lot of the information we receive reaches us electronically, originating from your devices, and is then transmitted by your relevant telecoms network provider.
Where it’s within our control, we put measures in place to ensure this ‘in flight’ data is as secure as it possibly can be.
Once it arrives at Varley Insulation Products Limited, you can be sure we take the security of your information very seriously.
We use appropriate procedures and technical security measures (including strict encryption, anonymisation and archiving techniques) to safeguard your information across all our computer systems, networks, websites, mobile apps, and offices.
In particular, we follow the internationally recognised security standard including the Payment Card Industry’s Data Security standards (PCI-DSS).
We use secure means to communicate with you where appropriate, such as ‘https’ and other security and encryption protocols.
If you have any concerns about the security of your own personal computers and mobile devices, we suggest you read the advice of ‘Get Safe Online’, which can be accessed here.
How long do we keep your information for?
To make sure we meet our legal data protection and privacy obligations, we only hold on to your information for as long as we actually need it for the purposes we acquired it for in the first place.
In most cases, this means we will keep your information for as long as you continue to be one of our clients, and for a period of time afterwards if you stop doing so just in case you come back to us again.
After that we will either delete it or anonymise it so that it cannot be linked back to you.
By law we have to keep basic information about our customers (including Contact, Identity, Financial and Transaction Data) for six years after they cease being clients for tax purposes.
In some circumstances you can ask us to delete your data: see Request erasure 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.
Your rights in connection with personal information
Under certain circumstances, by law you have the right to:
Request access: To your personal information (commonly known as a “data subject access request”). This enables you to receive a copy of the personal information we hold about you and to check that we are lawfully processing it.
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 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.
Request access: Of the personal information that we hold about you. This enables you to have any incomplete or inaccurate information we hold about you corrected. We may need to verify the accuracy of any new data you provide to us.
Request erasure: Of your personal information. This enables you to ask us to delete or remove personal information 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 information where you have 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, 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 information 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. You also have the right to object where we are processing your personal information for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which means we can continue to process your personal information.
Request the restriction of processing: Of your personal information. 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 information to another 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.
Right to 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.
Fees for excessive or unreasonable requests
You will not have to pay a fee to access your personal information (or to exercise any of the other rights). However, we may charge a reasonable fee if your request for access is unfounded or excessive. Alternatively, we may refuse to comply with the request in such 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 the information (or to exercise any of your other rights). This is another appropriate security measure to ensure that personal information is not disclosed to any person who has no right to receive it.
Data Protection Officer
The Varley Insulation Products Limited Data Protection Officer (DPO) oversees compliance with this privacy notice. If you have any questions or concerns about this Privacy Notice or how we handle your personal information, please contact the DPO at firstname.lastname@example.org. You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO) https://ico.org.uk/, the UK supervisory authority for data protection issues.