CONTENTS OF PRIVACY NOTICE
What is Glazpart Limited?
Explaining the legal base’s, we rely on
When do we collect your personal data?
What sort of personal data do we collect?
How and why do we use your personal data?
Combining your data for personalised direct marketing
How we protect your personal data
How long will we keep your personal data?
Who do we share your personal data with?
Where your personal data may be processed
What are your rights over your personal data?
How can you stop the use of your personal data for direct marketing?
Contacting the Regulator
If you live outside the UK
1 - Introduction
This Privacy Notice explains in detail the types of personal data we may collect about you when you interact with us. It also explains how we’ll store and handle that data, and how we keep it safe.
We know that there’s a lot of information here, but we want you to be fully informed about your rights, and how the Glazpart Limited uses your data; for example we will explain things such as our credit checking procedure, and how we combine data across the company to build a picture of you.
We hope the following sections will answer any questions you have but if not, please do get in touch with us.
It’s likely that we’ll need to update this Privacy Notice from time to time. And you are welcome to come back and check it whenever you wish.
2. What is Glazpart Limited?
The Glazpart Limited is made up of several related businesses:
Wildmere Industrial Estate
Web site: www.glazpart.com
Telephone: (44) 01295 264533
Fax: (44) 01295 266699
e-mail (General): firstname.lastname@example.org
e-mail (Sales): email@example.com
Registration No.: 1875968
Registered: Feb 1985
S.I.C. Code: 25240
VAT Number: (GB) 408 6578 27
EORI Number: GB408657827000
VAT Deferment No.: 8880183
3. Explaining the legal bases we rely on
The new data protection regulations set out several different reasons for which a company may collect and process your personal data, including:
Consent In specific situations, we can collect and process your data with your consent.
For example, when you tick a box to receive our email newsletters. When collecting your personal data, we’ll always use the minimum data necessary in connection with dealing with Glazpart.
Contractual obligations in certain circumstances, we need your personal data to comply with our contractual obligations.
For example, if you order an item from us, we’ll collect your address details to deliver your purchase, and pass them to our courier.
If the law requires us to, we may need to collect and process your data.
For example, we can pass on details of people involved in fraud or other criminal activity affecting the Partnership to law enforcement.
In specific situations, we require your data to pursue our legitimate interests in a way which might reasonably be expected as part of running our business and which does not materially impact your rights.
For example, we will use your purchase history to send you or make available data on products which you may be of interest to you and for the development of our services or capabilities.
We will also use your contact details to possibly send you direct marketing information by email, telling you about products and services that we think might interest you.
4. When do we collect your personal data?
When you visit any of our websites.
When you make a purchase.
When you open an account with us.
When you purchase a product or service using a credit card but don’t have (or don’t use) an account.
When you engage with us on social media.
When you contact us by any means with queries, complaints or requests for information, prices offer or technical advice etc. This can be following written or verbal contact with a member of staff, during marketing activities such as exhibitions, email shots or your solicited responses our advertising (print or online).
When you ask one of our team to email you information about a product or service.
When you book any kind of sales visit appointment with us or book to attend a sponsored event, for example PIGS (People in Glazing).
When you choose to complete any surveys we send you, such as our regular customer service online survey. When you comment on or review our products and services.
When you fill in any forms. For example, if an accident happens in our factory.
When you’ve given a third-party permission to share with us the information they hold about you. Example if we purchase GDPR compliant direct marketing data.
We collect data from publicly-available sources (such as Industry / market reports) when you have given your consent to share information or where the information is made public as a matter of law.
When you visit our car parks on site which usually have CCTV systems operated for the security of both customers and Partners. These systems may record your image during your visit.
5. What sort of personal data do we collect?
If you have an account with us: your name, invoice and delivery address, orders and receipts, email and telephone number.
Details of your interactions with us through customer service our technical product data.
For example, we collect notes from our conversations with you, details of any complaints or comments you make, details of purchases you made, items or pages viewed online, pages you visit, and you show interest in, web pages you visit and how and when you contact us.
Copies of documents you provide to prove your identity where the law requires this. (including your passport and driver's licence). This will include details of your full name, address, date of birth and facial image. If you provide a passport, the data will also include your place of birth, gender and nationality.
Details of your product group preferences.
For example, which of our website pages you prefer to visit and if you contact us.
Details of your visits to our websites, and which site you came from to ours.
Information gathered using cookies in your web browser.
Personal details which help us to recommend items of interest.
For example, you might tell us you’re in the window industry, which we’ll use to guide our marketing activity directed to you. You might share information on your need for our ventilation products which allows us to recommend appropriate glazing accessories, used for window fabrication or installation.
We’ll only ask for and use your personal data collected for recommending items of interest from Glazpart. Of course, it’s your choice whether you share such details with us.
Payment card information.
Your comments and product reviews.
Your image may be recorded on CCTV when you visit a shop or car park. Your car number plate may be recorded in our car parks to manage parking restrictions.
To deliver the best possible web experience, we collect technical information about your internet connection and browser as well as the country where your computer is located, the web pages viewed during your visit, the advertisements you clicked on, and any search terms you entered.
Your social media username, if you interact with us through those channels, to help us respond to your comments, questions or feedback.
6. How / why do we use your personal data?
We want to give you the best possible customer experience. One way to achieve that is to get a clear picture of who you are by combining the data we may have about you.
We then use this to offer you products and services that are most likely to interest you.
The data privacy law allows this as our legitimate interest in understanding our customers and providing the high levels of service.
Of course, if you wish to change use your data, details in the ‘What are your rights?’ section.
Remember, if you choose not to share your personal data with us, or refuse certain contact permissions, we might not be able to provide some services you’ve asked for.
Here’s how we’ll use your personal data and why:
To process any orders that you place. If we don’t collect your personal data during this process, we won’t be able to process your order and comply with our legal obligations.
For example, your details may need to be passed to a third party to supply or deliver the product or service that you ordered, and we may keep your details for a reasonable period afterwards in-order to fulfil any contractual obligations such as warranties.
To respond to your queries or complaints. Handling the information, you sent enables us to respond. We may also keep a record of these to inform any future communication with us and to demonstrate how we communicated with you throughout. We do this based on our contractual obligations to you, our legal obligations and our legitimate interests in providing you with the best service and understanding how we can improve our service based on your experience.
To protect our business and your account from fraud and other illegal activities. This includes using your personal data to maintain, update and safeguard your account. We’ll also monitor your browsing activity with us to quickly identify and resolve any problems and protect the integrity of our websites. We’ll do all of this as part of our legitimate interest.
For example, we do use automated monitoring of IP addresses to identify site visitors to improve our service and promotional activity.
To protect our customers, premises, assets and Partners from crime, we operate CCTV systems on our site and car parks which record images for security. We do this on the basis of our legitimate business interests.
To process payments and to prevent fraudulent transactions. We do this based on our legitimate business interests. This also helps to protect our customers from fraud.
If we discover any criminal activity or alleged criminal activity through our use of CCTV, fraud monitoring and suspicious transaction monitoring, we will process this data for the purposes of preventing or detecting unlawful acts. We aim is to protect the individuals we interact with from criminal activities.
With your consent, we will use your personal data, preferences and details of your transactions to keep you informed by email, web, text, telephone and through our customer services about relevant products and services.
Of course, you are free to opt out of hearing from us by any of these channels at any time.
To send you relevant, personalised communications by post in relation to updates, services and products. We’ll do this based on our legitimate business interest.
You are free to opt out of hearing from us by post at any time.
To send you communications required by law or which are necessary to inform you about our changes to the services we provide you. For example, Product recall notices, and legally required information relating to your orders. These service messages will not include any promotional content and do not require prior consent when sent by email or text message. If we do not use your personal data for these purposes, we would be unable to comply with our legal obligations.
To display the most interesting content to you on our websites, we’ll use data we hold about your favourite brands or products and so on. We do so on the basis for our website to place cookies or similar technology on your device.
To develop, test and improve the systems, services and products we provide to you. We’ll do this based on our legitimate business interests.
For example, we’ll record your browser’s Session ID to help us understand more when you leave us online feedback about any problems you’re having
To comply with our contractual or legal obligations to share data with law enforcement.
For example, when a court order is submitted to share data with law enforcement agencies or a court of law
To send you survey and feedback requests to help improve our services. These messages will not include any promotional content and do not require prior consent when sent by email or text message. We have a legitimate interest to do so as this helps make our products or services more relevant to you.
Of course, you are free to opt out of receiving these requests from us at any time by updating your preferences in your online account.
To build a picture of who you are and what you may need, and to inform our business decisions, we’ll combine data captured from across Glazpart Limited, third parties and data from publicly-available data as we have described in the section 'What Sort of Personal Data do we collect?' We’ll do this based on our legitimate business interest.
For example, by combining this data, this will help us personalise your experience and decide which inspiration or content to share with you. We also use anonymised data from customer third parties to identify trends in different areas of the country. This may then guide which products we carry out in our marketing.
To process your orders, we’ll need to share your details with a third party who is providing a service (such as delivery couriers or a sales manager visiting your factory). We do so to maintain our appointment with you. Without sharing your personal data, we’d be unable to fulfil your request.
7. Combining your data for personalised direct marketing
We want to bring you product details and marketing offers that are most relevant to your interests at times. To help us form a better, overall understanding of you as a customer, we combine your personal data gathered across Glazpart Limited as described above, for example your purchase history. For this purpose, we also combine the data that we collect directly from you with data that we obtain from third parties to whom you have given your consent to pass that data onto us.
8. How we protect your personal data
We know how much data security matters to all our customers. We will treat your data with the utmost care and take all appropriate steps to protect it.
We secure access to all transactional areas of our computer systems using ‘https’ technology.
Access to your personal data is password-protected.
We regularly monitor our system for possible vulnerabilities and attacks.
All paper waste from the Glazpart site has a contracted out shredding service where all written information is destroyed on site to improve your data security.
9. How long will we keep your personal data?
Whenever we collect or process your personal data, we’ll only keep it for as long as is necessary for the purpose for which it was collected.
At the end of that retention period or end of the customer relationship, your data will either be deleted completely or anonymised, for example by aggregation with other data so that it can be used in a non-identifiable way for statistical analysis and business planning.
Some examples of customer data retention periods:
When you place an order, we’ll keep the personal data you give us for five years, so we can comply with our legal and contractual obligations. In the case of certain products, we may keep the data for 10 years, especially where customer warranties to their customers are for a 10-year period.
If your order included a warranty, the associated personal data will be kept until the end of the warranty period as detailed in our terms and conditions of sale.
We sometimes share your personal data with trusted third parties. We never sell any customer data.
For example, delivery couriers, for fraud management, to handle complaints and so on.
Here’s the policy we apply to those organisations to keep your data safe and protect your privacy:
We provide only the information they need to perform their specific services.
They may only use your data for the exact purposes we specify in our contract with them.
We work closely with them to ensure that your privacy is respected and protected always.
If we stop using their services, any of your data held by them will either be deleted or rendered anonymous.
Examples of the kind of third parties we work with are:
IT companies who support our website and other business systems.
Operational companies such as delivery couriers.
Direct marketing companies who help us manage our electronic communications with you.
Google/Facebook to show you products that might interest you while you’re browsing the internet. This is based on either your marketing consent or your acceptance of cookies on our websites.
Data insight companies to ensure your details are up to date and accurate.
Sharing your data with third parties for their own purposes:
We will only do this in very specific circumstances, for example:
With your consent, given at the time you supply your personal data, we do not sell any personal data
For fraud management, we may share information about fraudulent or potentially fraudulent activity in our premises or systems. This may include sharing data about individuals with law enforcement bodies.
We may also be required to disclose your personal data to the police or other enforcement, regulatory or Government body, in your country of origin or elsewhere, upon a valid request to do so. These requests are assessed on a case-by-case basis and take the privacy of our customers into consideration.
To help improve your journey through the Glazpart website we use the following companies, who may process your personal data as part of their contracts with us:
Get response (Mailchimp)
Contracted exhibition/event organisers/lead capture contractors whose events we pay to attend
Mike Hill Graphics
10. Where your personal data may be processed
Sometimes we will need to share your personal data with third parties and suppliers outside the European Economic Area (EEA), such as the USA.
If you are based outside the UK and place an order with us, we will transfer the personal data that we collect from you to Glazpart Limited in the UK, Glazpart Inc in the USA or trusted resellers within local territories.
Protecting your data outside the EEA
The EEA includes all EU Member countries as well as Iceland, Liechtenstein and Norway. We may transfer personal data that we collect from you to third-party data processors in countries that are outside the EEA.
For example, this might be required to fulfil your order, process your payment details or provide support services.
If we do this, we have procedures in place to ensure your data receives the same protection as if it were being processed inside the EEA. For example, our contracts with third parties stipulate the standards they must follow at all times. If you wish for more information about these contracts, please contact us.
Any transfer of your personal data will follow applicable laws and we will treat the information under the guiding principles of this Privacy Notice.
12. What are your rights over your personal data?
An overview of your different rights
You have the right to request:
Access to the personal data we hold about you, free of charge in most cases.
The correction of your personal data when incorrect, out of date or incomplete.
For example, when you withdraw consent, or object and we have no legitimate overriding interest, or once the purpose for which we hold the data has come to an end (such as the end of a warranty).
That we stop using your personal data for direct marketing (either through specific channels, or all channels).
That we stop any consent-based processing of your personal data after you withdraw that consent.
You have the right to request a copy of any information about you that Glazpart Limited holds at any time, and to have that information corrected if it is inaccurate. To ask for your information, please contact us. To ask for your information to be amended, please update your online account, or contact our Customer Services team.
If we choose not to action your request, we will explain to you the reasons for our refusal.
Your right to withdraw consent
Whenever you have given us your consent to use your personal data, you have the right to change your mind at any time and withdraw that consent.
Where we rely on our legitimate interest
In cases where we are processing your personal data based on our legitimate interest, you can ask us to stop for reasons connected to your individual situation. We must then do so unless we believe we have a legitimate overriding reason to continue processing your personal data.
You have the right to stop the use of your personal data for direct marketing activity through all channels, or selected channels. We must always comply with your request.
Checking your identity
To protect the confidentiality of your information, we will ask you to verify your identity before proceeding with any request you make under this Privacy Notice. If you have authorised a third party to submit a request on your behalf, we will ask them to prove they have your permission to act
13. How can you stop the use of your personal data for direct marketing?
There are several ways you can stop direct marketing communications from us:
Click the ‘unsubscribe’ link in any email communication that we send you. We will then stop any further emails.
Please note that you may continue to receive communications for a short period after changing your preferences while our systems are fully updated.
14. Contacting the Regulator
If you feel that your data has not been handled correctly, or you are unhappy with our response to any requests you have made to us regarding the use of your personal data, you have the right to lodge a complaint with the Information Commissioner’s Office.
If you are based outside the UK, you have the right to lodge your complaint with the relevant data protection regulator in your country of residence. Details can be found in Section 16.
15. If you live outside the UK
For all non-UK customers
By using our services or providing your personal data to us, you expressly consent to the processing of your personal data by us or on our behalf. Of course, you still have the right to ask us not to process your data in certain ways, and if you do so, we will respect your wishes.
Sometimes we’ll need to transfer your personal data between countries to enable us to supply the goods or services you’ve requested. In the ordinary course of business, we may transfer your personal data from your country of residence to ourselves and to third parties located in the UK.
By dealing with us, you are giving your consent to this overseas use, transfer and disclosure of your personal data outside your country of residence for our ordinary business purposes.
This may occur because our information technology storage facilities and servers are located outside your country of residence and could include storage of your personal data on servers in the UK.
We’ll ensure that reasonable steps are taken to prevent third parties outside your country of residence using your personal data in any way that’s not set out in this Privacy Notice. We’ll also make sure we adequately protect the confidentiality and privacy of your personal data.
For the purposes of this Privacy Notice, ‘personal data’ means any information or an opinion about an identified individual, or an individual who is reasonably identifiable, whether the information or opinion is true, and whether the information or opinion is recorded in a material form.
If you are in Australia you may submit any questions, comments or complaints to us and we will try to get back to you within 30 days.
If you are contacting us to complain about an alleged breach of this Privacy Notice or our legal privacy obligations, please provide us with as much detail as possible in relation to your complaint.
We will take every privacy complaint seriously and assess it with the aim of resolving all issues quickly and efficiently. We’d be grateful for your cooperation with us during this process by providing us with any relevant information that we made need.
We are committed to keeping your personal information secure and will take all reasonable precautions to protect it from loss, misuse or unauthorised access or alteration. However, except to the extent liability cannot be excluded due to the operation of statute, we exclude all liability (including in negligence) for the consequences of any unauthorised access to, disclosure of, misuse of or loss or corruption of your personal information.
Nothing in this Privacy Notice restricts, excludes or modifies or purports to restrict, exclude or modify any statutory consumer rights under any applicable law including the Competition and Consumer Act 2010.
To learn more about our cookies and website ‘track’ and ‘do not track’ practices please see our cookies policy.
As your data may be transferred to third parties outside Canada, local police or other enforcement, regulatory or Government bodies may have access to that data, with or without our knowledge.
The personal data we process may be accessed by people within the Partnership, or by our third-party service providers, who require access for the purposes indicated in this Privacy Notice, or as may be permitted or required by applicable law. The personal data we collect is largely held in the UK.
If you have any questions, please contact us.