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Privacy Policy
Thermal Designs UK Privacy Policy
1.0 Introduction
1.1 We are committed to safeguarding the privacy of our website visitors and service users.
1.2 This policy applies where we are acting as a data controller with respect to the personal data of our website visitors and
service users; in other words, where we determine the purposes and means of the processing of that personal data.
1.3 We use cookies on our website. Insofar as those cookies are not strictly necessary for the provision of our website and
services, we may ask you to consent to our use of cookies when you first visit our website.
1.4 Our website does not ask for any personal data. By using the request information form, you can specify whether you would
like to receive direct marketing communications and limit the publication of your information. You can change your privacy
settings at any time by contacting our DPO listed in Section 14.1.
1.5 In this policy, "we", "us" and "our" refer to our DPO Mr. Ray Browne. For more information about us, see Section 13.
2.0 Credits
2.1 This document was created using a template from SEQ Legal (https://seqlegal.com).
3.0 How we use your personal data.
3.1 In this Section 3 we have set out:
(a) the general categories of personal data that we may process
(b) in the case of personal data that we did not obtain directly from you, the source and specific categories of that data
(c) the purposes for which we may process personal data
(d) the legal bases of the processing.
3.2 We may process data about your use of our website and services ("usage data"). The usage data may include your IP
address,
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 source of the
usage data is our analytics tracking system. This usage data may be processed for the purposes of analyzing the use of the
website and services. The legal basis for this processing is our legitimate interests, namely monitoring and improving our
website and services.
3.3 We may process ("account data"). The account data may include your name and email address. The source of the account
data is you or your employer. The account data may be processed for the purposes of operating our website, providing our
services, ensuring the security of our website and services, maintaining back-ups of our databases and communicating
with you. The legal basis for this processing is our legitimate interests, namely the proper administration of our website
and the performance of a contract between you and us and/or taking steps, at your request, to enter into such a contract.
3.4 We may process your personal data that is provided in the course of the use of our services ("service data").The service
data may include name, email address, business address, bank account information, telephone number, fax number,
website, VAT and company registration number. The source of the service data is you or your employer. The service data
may be processed for the purposes of operating our website, providing our services, ensuring the security of our website
and services, maintaining back-ups of our databases and communicating with you. The legal basis for this processing is
our legitimate interests, namely the proper administration of our website and business and the performance of a contract
between you and us and/or taking steps, at your request, to enter into such a contract.
3.5 We may process information that you post for publication on our website or through our services ("publication data"). The
publication data may be processed for the purposes of enabling such publication and administering our website and
services. The legal basis for this processing is consent or our legitimate interests, namely the proper administration of our
website and business or the performance of a contract between you and us and/or taking steps, at your request, to enter
into such a contract.
3.6 We may process information contained in any enquiry you submit to us regarding goods and/or services ("enquiry data").
The enquiry data may be processed for the purposes of offering, marketing and selling relevant goods and/or services to
you. The legal basis for this processing is consent.
3.7 We may process information relating to our customer relationships, including customer contact information ("customer
relationship data"). The customer relationship data may include your name, your employer, your job title or role, your
contact details, and information contained in communications between us and you or your employer. The source of the
customer relationship data is you or your employer. The customer relationship data may be processed for the purposes of
managing our relationships with customers, communicating with customers, keeping records of those communications and
promoting our products and services to customers. The legal basis for this processing is our legitimate interests, namely
the proper management of our customer relationships.
3.8 We may process information relating to transactions, including purchases of goods and services that you enter into with us
and/or through our website ("transaction data"). The transaction data may include your contact details, your card/bank
details and the transaction details. The transaction data may be processed for the purpose of supplying the purchased
goods and services and keeping proper records of those transactions. The legal basis for this processing is the
performance of a contract between you and us and/or taking steps, at your request, to enter into such a contract and our
legitimate interests, namely the proper administration of our business.
3.9 We may process information that you provide to us for the purpose of subscribing to our email notifications and/or
newsletters ("notification data"). The notification data may be processed for the purposes of sending you the relevant
notifications and/or newsletters. The legal basis for this processing is the performance of a contract between you and us
and/or taking steps, at your request, to enter into such a contract.
3.10 We may process information contained in or relating to any communication that you send to us ("correspondence data"). The
correspondence data may include the communication content and metadata associated with the communication. Our
website will generate the metadata associated with communications made using the website contact forms. The
correspondence data may be processed for the purposes of communicating with you and record-keeping. The legal basis
for this processing is our legitimate interests, namely the proper administration of our website and business and
communications with users.
3.11 We may process any of your personal data identified in this policy where necessary for the establishment, exercise or
defense 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.
3.13 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.
3.14 In addition to the specific purposes for which we may process your personal data set out in this Section 3, we may also
process any of your personal data where such processing 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.
3.15 Please do not supply any other person's personal data to us, unless we prompt you to do so.
4.0 Providing your personal data to others
4.1 We may disclose your personal data 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.
4.2 We may disclose your personal data to our insurers and/or professional advisers insofar as reasonably necessary for the
purposes of obtaining or maintaining insurance coverage, managing risks, obtaining professional advice, or the
establishment, exercise or defense of
legal claims, whether in court proceedings or in an administrative or out-of-court procedure.
4.3 Financial transactions relating to our website and services may be handled by our payment services providers. We will
share transaction data with our payment services providers only to the extent necessary for the purposes of processing
your payments, refunding such payments and dealing with complaints and queries relating to such payments and refunds.
You can find information about the payment services providers from our DPO Section 13.
4.4 We may disclose your enquiry data to one or more of those selected third party suppliers of goods and services identified
on our website for the purpose of enabling them to contact you so that they can offer, market and sell to you relevant goods
and/or services. Each such third party will act as a data controller in relation to the enquiry data that we supply to it; and
upon contacting you, each such third party will supply to you a copy of its own privacy policy, which will govern that third
party's use of your personal data.
4.5 In addition to the specific disclosures of personal data set out in this Section 4, we may 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 may also disclose your personal data where such disclosure is
necessary for the establishment, exercise or defense of legal claims, whether in court proceedings or in an administrative or
out-of-court procedure.
5.0 International transfers of your data
5.1 In this Section 5, we provide information about the circumstances in which your personal data may be transferred to
countries outside the European Economic Area (EEA).
5.2 We and our other group companies have offices and facilities in USA & UAE. The European Commission has made an
"adequacy decision" with respect to the data protection laws of each of these countries. Transfers to each of these
countries will be protected by appropriate safeguards, namely the use of standard data protection clauses adopted or
approved by the European Commission, a copy of which can be obtained from the use of binding corporate rules.
5.3 The hosting facilities for our website are situated in the USA. The European Commission has made an "adequacy decision"
with respect to the data protection laws of this country. Transfers of data to this country will be protected by appropriate
safeguards, namely the use of standard data protection clauses adopted or approved by the European Commission.
5.4 You acknowledge that personal data that you submit for publication through our website or services may be available, via
the internet, around the world. We cannot prevent the use (or misuse) of such personal data by others.
6.0 Retaining and deleting personal data
6.1 This Section 6 sets out our data retention policies and procedure, which are designed to help ensure that we comply with
our legal obligations in relation to the retention and deletion of personal data.
6.2 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.
6.3 We will retain your personal data as follows:
(a) Personal data will be retained for a minimum period of 1 year following contact, and for a maximum period of 10 years
following contact.
6.4 In some cases it is not possible for us to specify in advance the periods for which your personal data will be retained. In such
cases, we will determine the period of retention based on the following criteria:
(a) The period of retention of emails & name will be determined based on your requirements or ongoing business
relationship.
(b) The period of retention of personal details or payment information will be determined based on your ongoing business
relationship and will be deleted after a 3-year period of inactivity.
6.5 Notwithstanding the other provisions of this Section 6, we may retain your personal data where such retention 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.
7.0 Amendments
7.1 We may update this policy from time to time by publishing a new version on our website.
7.2 You should check this page occasionally to ensure you are happy with any changes to this policy.
7.3 We may notify you of significant changes to this policy by email or through the private messaging system on our website.
8.0 Your rights
8.1 In this Section 8, we have summarized the rights that you have under data protection law. Some of the rights are complex,
and not all of the details have been included in our summaries. Accordingly, you should read the relevant laws and guidance
from the regulatory authorities for a full explanation of these rights.
8.2 Your principal rights under data protection law are:
(a) the right to access;
(b) the right to rectification;
(c) the right to erasure;
(d) the right to restrict processing;
(e) the right to object to processing;
(f) the right to data portability;
(g) the right to complain to a supervisory authority; and
(h) the right to withdraw consent.
8.3 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, but additional copies may be subject to a reasonable fee.
8.4 You have the right to have any inaccurate personal data about you rectified and, taking into account the purposes of the
processing, to have any incomplete personal data about you completed.
8.5 In some circumstances you have the right to the erasure of your personal data without undue delay. Those circumstances
include: the personal data is no longer necessary in relation to the purposes for which it was collected or otherwise
processed; you withdraw consent to consent-based processing; you object to the processing under certain rules of
applicable data protection law; the processing is for direct marketing purposes; and the personal data has been unlawfully
processed. However, there are exclusions of the right to erasure. The general exclusions include 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 defense of legal claims.
8.6 In some circumstances you have the right to restrict the processing of your personal data. Those circumstances are: you
contest the accuracy of the personal data; processing is unlawful but you oppose erasure; we no longer need the personal
data for the purposes of our processing, but you require personal data for the establishment, exercise or defense of legal
claims; and 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: with your
consent; for the establishment, exercise or defense of legal claims; for the protection of the rights of another natural or
legal person; or for reasons of important public interest.
8.7 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: the performance of a task
carried out in the public interest or in the exercise of any official authority vested in us; or 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 we can demonstrate compelling legitimate grounds for the processing which override your interests, rights and
freedoms, or the processing is for the establishment, exercise or defence of legal claims.
8.8 You have the right to object to our processing of your personal data for direct marketing purposes (including profiling for
direct marketing purposes). If you make such an objection, we will cease to process your personal data for this purpose.
8.9 You 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.
8.10 To the extent that the legal basis for our processing of your personal data is:
(a) consent; or
(b) that the processing is necessary for the performance of a contract to which you are party or in order to take steps at
your request prior to entering into a contract and such processing is carried out by automated means, you have the right to
receive your personal data from us in a structured, commonly used and machine-readable format. However, this right does
not apply where it would adversely affect the rights and freedoms of others.
8.11 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.
8.12 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. Withdrawal will not affect the lawfulness of processing before the withdrawal.
8.13 You may exercise any of your rights in relation to your personal data by written notice to us in addition to the other methods
specified in this Section 8.
9.0 About cookies
9.1 A cookie is a file containing an identifier (a string of letters and numbers) that is sent by a web server to a web browser and is
stored by the browser. The identifier is then sent back to the server each time the browser requests a page from the server.
9.2 Cookies may be either "persistent" cookies or "session" cookies: a persistent cookie will be stored by a web browser and will
remain valid until its set expiry date, unless deleted by the user before the expiry date; a session cookie, on the other hand,
will expire at the end of the user session, when the web browser is closed.
9.3 Cookies do not typically contain any information that personally identifies a user, but personal information that we store
about you may be linked to the information stored in and obtained from cookies.
10.0 Cookies that we use
10.1 We use cookies for the following purposes:
(a) authentication - we use cookies to identify you when you visit our website and as you navigate our website, cookies
used for this purpose are: session cookies.
(b) personalisation - we use cookies to store information about your preferences and to personalise the website for you,
cookies used for this purpose are: session cookies.
(d) security - we use cookies as an element of the security measures used to protect user accounts, including preventing
fraudulent use of login credentials, and to protect our website and services generally, cookies used for this purpose are:
permanent cookies.
(e) advertising - we use cookies to help us to display advertisements that will be relevant to you, cookies used for this
purpose are: session cookies.
(f) analysis - we use cookies to help us to analyse the use and performance of our website and services, cookies used for
this purpose are: session cookies.
(g) cookie consent - we use cookies to store your preferences in relation to the use of cookies more generally, cookies
used for this purpose are: permanent cookies.
11.0 Cookies used by our service providers
11.1 Our service providers use cookies and those cookies may be stored on your computer when you visit our website.
11.2 We use Google Analytics to analyse the use of our website. Google Analytics gathers information about website use by
means of cookies. The information gathered relating to our website is used to create reports about the use of our website.
Google's privacy policy is available at: https://www.google.com/policies/privacy/.
12.0 Managing cookies
12.1 Most browsers allow you to refuse to accept cookies and to delete cookies. The methods for doing so vary from browser to
browser, and from version to version. You can however obtain up-to-date information about blocking and deleting cookies
via these links:
(a) https://support.google.com/chrome/answer/95647?hl=en (Chrome);
(b) https://support.mozilla.org/en-US/kb/enable-and-disable-cookies-website-preferences (Firefox);
(c) http://www.opera.com/help/tutorials/security/cookies/ (Opera);
(d) https://support.microsoft.com/en-gb/help/17442/windows-internet-explorer-delete-manage-cookies
(e) https://support.apple.com/kb/PH21411 (Safari); and
(f) https://privacy.microsoft.com/en-us/windows-10-microsoft-edge-and-privacy (Edge).
12.2 Blocking all cookies will have a negative impact upon the usability of many websites.
12.3 If you block cookies, you will not be able to use all the features on our website.
13.0 Our Details
13.1 This website is owned and operated by Thermal Designs UK LTD
13.2 We are registered in England and Wales under registration number 3240260 and our registered office is at:
Broadway
Market Lavington
Devizes
Wiltshire
SN10 5RQ
13.3 Our principal place of business is at:
Broadway
Market Lavington
Devizes
Wiltshire
SN10 5RQ
13.4 You can contact us:
(a) by post, to the postal address given above;
(b) using our website contact form;
(c) by telephone, on the contact number published on our website from time to time or 01380 816079
(d) by email, using the email address published on our website from time to time or rbrowne@tdiuk.com.
14.0 Data Protection Officer
14.1 Our data protection officer's contact details are:
Mr. Ray Browne
General Manager & DPO
Thermal designs UK ltd.
Broadway
Market Lavington
Devizes
Wiltshire
SN10 5RQ