Annet Technologies Europe Limited (ATEL) and its subsidiary companies including RETransform are committed to respecting and protecting our customers’ privacy and treats it with respect. This policy applies where we are acting as a data controller with respect to your personal data, in other words, where we determine the purposes and means of the processing of such personal data. It captures personal data entered across all channels: through our website, app, or via our Customer Account Management team.
We incorporate marketing preferences in your online account, which affect how we will process your personal data. By using the marketing preferences functionality, you can specify whether you would like to receive direct marketing communications and limit the use of your information. You can change your marketing preferences at any time by calling your ATEL account manager or calling our switchboard and asking to speak to our GDPR team.
Please read this policy carefully to understand our views and practices regarding your personal data and how we will treat it.
2. How we use your personal data
In this section we outline how we may process your personal data. All personal data we process falls into one or more of the following categories:
- Order data
- Transaction data
- Financial data
- Internal social data
- Usage data
- Communication data
- Enquiry data
- Digital marketing data
- CCTV where used
We may process your order data (“order data”). The order data may include your name, billing address, delivery address, phone number and email address. The order data will be processed for the purposes of delivering your order to you. The legal basis for this processing is the performance of a contract between you and us.
We may process your transaction data (“transaction data”). The transaction data may include information relating to your previous transactions, including purchases of goods and/or services. The transaction data may include your name, billing address, delivery address, telephone number, email address and purchase history. It may be processed for the purposes of supplying the purchased goods or services and keeping proper records of those transactions. The legal basis for this processing is the performance of a contract between you and us.
We may process financial information (“financial data”) you share with us. The financial data may include data about your company, name and billing address. The financial data may be processed for the purposes of processing your payments and to prevent fraud. The legal basis for this processing is the performance of a contract between you and us.
We may process information that you post for publication on our website or app, such as wall posts or product ratings and reviews (“internal social data”). This internal social data is public and may be processed for the purposes of enabling interaction on the website or app between customers and ATEL staff. In instances where internal social data is stored in an unstructured format (such as free text reviews and wall posts) it is exempt from our data retention rules, however may be deleted upon request. The legal basis for processing internal social data is consent.
We may process data about your use of our website or app, and reaction to our emails and services (“usage data”). The usage data may include your geographical location, browser type and version, operating system, referral source, length of visit, page views and website navigation paths, as well as information about the timing, frequency and pattern of your service use. The sources of the usage data are our analytics packages (including, but not limited to Google Analytics) and email service providers. This usage data may be processed for the purposes of analysing the use of the website, emails and services. The legal basis for this processing is our legitimate interests, namely monitoring and improving our website and services.
We may process information that you provide to us for the purpose of subscribing to our direct marketing communications (“communication data”). The communication data may include your name, email address, postal address, phone number or marketing preferences. This communication data may be processed for the purposes of contacting you with service notifications, such as that your order has been processed, or contacting you with relevant offers and messages. The legal basis for this processing is performance of a contract for service notifications and legitimate interests for direct marketing communications.
We may process information contained in any enquiry you submit to us regarding goods and/or services (“enquiry data”). This enquiry data may be processed for the purposes of providing clarification, resolving issues or marketing relevant goods and/or services to you. The legal basis for this processing is the performance of a contract between you and us and to ensure we are responding to your enquiry.
We may process information that you provide to us for the purpose of improving our digital marketing (“digital marketing data”). We may use digital marketing data in a number of different ways: either to advertise our products and services to you on third party websites such as Facebook, or to advertise our products and services to similar customers (lookalikes) on third party websites such as Facebook. We may also use digital marketing data to exclude you from seeing advertisements from third party websites such as Facebook. The digital marketing data may include your name, email address, billing address, phone number, date of birth, gender, and the user ID of any social platforms you have connected with us on. The legal basis for this processing is our legitimate interests, namely providing better services and enhancing our customer base.
Please be aware that CCTV is in operation in our head office.
We may process any of your personal data identified in this policy where necessary for the establishment, exercise or defence of legal claims, whether in court proceedings or in an administrative or out-of-court procedure. The legal basis for this processing is our legitimate interests, namely the protection and assertion of our legal rights, your legal rights and the legal rights of others.
We may process any of your personal data identified in this policy where necessary for the purposes of obtaining or maintaining insurance coverage, managing risks, or obtaining professional advice. The legal basis for this processing is our legitimate interests, namely the proper protection of our business against risks.
Please do not supply any other person’s personal data to us.
3. Providing your personal data to others
We do not, and will not, sell any of your personal data to any third party – including your name, address, email address or credit card information. We want to earn and maintain your trust, and we believe this is essential in order do that.
However, we may disclose your personal data with the following categories of companies as an essential part of being able to provide our services to you, as set out in this policy:
- To any member of our group of companies (this means our subsidiaries, our ultimate holding company and all its subsidiaries) insofar as reasonably necessary for the purposes, and on the legal bases, set out in this policy
- To our insurers and professional advisers insofar as reasonably necessary for the purposes of obtaining or maintaining insurance coverage, managing risks, obtaining professional advice
- To deliver news, threat warnings and offers to you we will use postal printing and mailing, as well as email service providers
In addition to the specific disclosures of personal data set out in this Section 3, we may disclose your personal data with law enforcement and fraud prevention agencies, so we can help tackle fraud or where such disclosure is necessary for compliance with a legal obligation to which we are subject, in order to protect your vital interests or the vital interests of another natural person, or in connection with the establishment, exercise or defence of legal claims, whether in court proceedings or in an administrative out-of-court procedure.
4. Transfers outside of the European Economic Area (EEA)
Our parent company is based in Mumbai, India and as such members of our team may have access to your data as we all use the same customer relationship management solution. That said your privacy is important to us and we will only access and use your data in compliance with section 2 above. We would also confirm that your data will not be available to any employee or directly employed contractor who has not signed our non-disclosure agreement (NDDA) which clearly states the basis on which client data may be accessed and used. As always if you are not in full agreement with this arrangement we can arrange for consent to be withdrawn and for you to request further restrictions on the use of your data.
5. How long we retain your data
Personal data that we process for any purpose or purposes shall not be kept for longer than is necessary for that purpose or those purposes.
If you have registered on our website, contacted us via telephone or email but have not purchased from us, the length of time we will retain your data is dependent upon whether you have opted into our marketing communications. If you have opted in, we will retain your data for 3 years since your last interaction; if you have not opted in, we will retain your data for 1 year but not use it, giving you the opportunity to re-establish a connection with us should you wish to take advantage or our threat warning, cyber advice or other valuable free services.
Whilst you are an active customer (which, for the avoidance of doubt, means you have purchased goods or services from us or used our paid advisory services) we will retain your data for as long as needed to give you the best possible customer service including the renewal of any subscription services you may have purchased. We will anonymise your personal data 7 years after your last transaction with any ATEL company.
For the purposes of this policy, an interaction is defined as an identifiable website or app session or contacting our Customer Account Management Team. We will inform you before we anonymise your data and give you the option for us to retain your details, so we can continue to serve you.
In all instances outlined above, the process of anonymising your data may take up to one calendar month.
In certain circumstances we may retain your personal data where such retention is necessary for compliance with a legal obligation to which we are subject, to resolve disputes and enforce our agreements.
6. Your rights
You have a number of rights in respect to your personal data. We have summarised the rights that you have under data protection law. You should read the relevant laws and guidance from the regulatory authorities for a full explanation of these rights. You may exercise any of your rights in relation to your personal data by either (a) emailing us at firstname.lastname@example.org or calling our main number +44-(0)20-3287-6426 and asking for our GDPR team.
A. Right of access
You have the right to confirmation as to whether or not we process your personal data and, where we do, access to the personal data, together with certain additional information. That additional information includes details of the purposes of the processing, the categories of personal data concerned and the recipients of the personal data. Providing the rights and freedoms of others are not affected, we will supply to you a copy of your personal data. The first copy will be provided free of charge. In order to fulfil this right, we will ask for government registered ID to confirm your identity and, once this is received, will respond with the relevant information one calendar month from the date of your request.
B. Right to rectification
You have the right to have any inaccurate personal data about you rectified and, considering the purposes of the processing, to have any incomplete personal data about you completed.
C. Right to erasure
In certain circumstances you have the right to the erasure of your personal data without undue delay. However, there are exclusions of the right to erasure, such as where processing is necessary for exercising the right of freedom of expression and information, for compliance with a legal obligation, or for the establishment, exercise or defence of legal claims. If you have entered into a transaction with us, we will keep a record of your personal data for 7 years following the date of your last transaction with us. We will endeavour to respond to your request within one month, but if your request is complex or we receive a number of similar requests at the same time, it might take us longer, in which case we will inform you within one month of the receipt of the request and explain why we think an extension is necessary.
D. Right to restriction on processing
In some circumstances you have the right to restrict the processing of your personal data. Those circumstances are: (a) you contest the accuracy of the personal data, (b) processing is unlawful but you oppose erasure, (c) we no longer need the personal data for the purposes of our processing, but you require personal data for the establishment, exercise or defence of legal claims, and (d) you have objected to processing, pending the verification of that objection. Where processing has been restricted on this basis, we may continue to store your personal data. However, we will only otherwise process it: (a) with your consent, (b) for the establishment, exercise or defence of legal claims, (c) for the protection of the rights of another natural or legal person, or (d) for reasons of important public interest.
E. Right to objection to processing
You have the right to object to our processing of your personal data on grounds relating to your particular situation, but only to the extent that the legal basis for the processing is that the processing is necessary for: (a) the performance of a task carried out in the public interest or in the exercise of any official authority vested in us; or (b) the purposes of the legitimate interests pursued by us or by a third party. If you make such an objection, we will cease to process the personal information unless (a) we can demonstrate compelling legitimate grounds for the processing which override your interests, rights and freedoms, or (b) the processing is for the establishment, exercise or defence of legal claims.
You also have the right to object to our processing of your personal data for scientific or historical research purposes or statistical purposes on grounds relating to your particular situation, unless the processing is necessary for the performance of a task carried out for reasons of public interest.
F. Right to data portability
In certain circumstances, you have the right to receive your personal information in a structured, commonly used and machine-readable format and to transmit that information to another controller to enable it to use the data. The right to data portability applies (a) to personal data you have provided to us as data controller, (b) where the processing is based on your consent or for the performance of a contract and (c) when processing is carried out by automated means. If you request this information, we will transmit the data directly to another controller, if this is technically feasible. We are, however, not required to adopt or maintain processing systems that are technically compatible with other controllers. Also, if the personal data concerns more than one individual, we must consider whether providing the information would prejudice the rights of other individuals.
If you exercise your right to data portability, we will endeavour to respond to your request within one month, but if your request is complex or we receive a number of similar requests at the same time, it might take us longer, in which case we will inform you within one month of the receipt of the request and explain why we think an extension is necessary.
G. Right to stop marketing messages
At any time you can amend your marketing preferences to reduce, remove or increase the amount we contact you with direct marketing communications. You may exercise this right by either (a) emailing us at email@example.com or calling our main number +44-(0)20-3287-6426 and asking for our GDPR team or by contacting your Customer Account Manager.
H. Right to withdraw consent
To the extent that the legal basis for our processing of your personal information is consent, you have the right to withdraw that consent at any time.
I. Right to complain
In the event that you wish to make a complaint about how we process your personal data, please contact us in the first instance and we will endeavour to deal with your request as soon as possible. If you consider that our processing of your personal information infringes data protection laws, you have a legal right to lodge a complaint with a supervisory authority responsible for data protection. You may do so in the EU member state of your habitual residence, your place of work or the place of the alleged infringement. Our supervisory authority is the Information Commissioner’s Office. You can contact them here: https://ico.org.uk
For details of the way we process information relating to external candidates we are happy to provide when requested our recruitment data retention policy.
We may update this policy from time to time by publishing a new version on our website. We will not publish changes and ask you to check our website to confirm you ae happy with any updates.
9. Data Protection Officer
As a company we do not have a data protection officer, but we do have a team trained to help with any data protection query all of whom have passed a GDPR Foundation Examination.