Last Updated: 26th July 2018
CSL DualCom Limited ("We", “Us”) is committed to protecting and respecting your privacy. This Privacy and Cookies Policy (“Policy”) (together with and any other documents referred to therein) sets out the basis on which the personal data collected from you, or that you provide to Us will be processed by Us. Please read the following carefully to understand our views and practices regarding your personal data and how We will treat it.
For the purpose of the General Data Protection Regulations 2016/679 including any corresponding or equivalent national laws and regulations (collectively the “Data Protection Laws”) the Data Controller is CSL DualCom Limited.
YOUR PERSONAL INFORMATION
Information we collect from you
We collect and process some or all of the following types of information from you in the course of your use of the website or providing our services including any access to our portals or apps (“Apps”):
Information that you provide by filling in forms on the Website or by using our Apps. This includes information provided at e.g. the time of submitting an enquiry using our contact form on the Website, subscribing to our service to use our Apps, or requesting further information or services. We may also ask you for information when you report a problem with the Website.
Specifically, personal details such as name, email address, postal address, postal code, date of birth, telephone or any information you choose to provide to us when using the Website, using our Services, or purchasing products from us.
If you contact Us, We may keep a record of that correspondence.
Details of your visits to the Website and use of our Apps including, but not limited to, traffic data, location data, weblogs and other communication data, and the resources that you access.
Details of your interest in our e-letters including clicks and opens.
The provision of name, address, delivery address, email and contact number is required from you to enable Us to process your order. We will inform you at the point of collecting information from you, whether you are required to provide the information to Us.
Information We Collect From Other Sources
USES MADE OF YOUR INFORMATION
Lawful basis for processing
We rely on legitimate interest as the lawful basis on which We collect and use your personal data. Our legitimate interests are performance of contracts with our customers and suppliers (of which you may be engaged by), marketing and business development and the administration and improvement of our website and Apps. We also rely on legitimate interest where you are an existing or previous customer to provide you with marketing and promotional materials which we feel may be of interest to you.
We rely on your consent (which may be withdrawn at any time by following the procedures below) as the lawful basis on which We collect and use your personal where:
You have signed up on our Website to receive newsletter and promotional materials, we will send you such newsletters and promotional materials which we feel may be of interest to you.
You have provided us with testimonials and reviews, we will use such materials to publish on our Website in order to promote the company.
Purposes of processing
We use information held about you in the following ways:
To provide you with our services.
To ensure that content on the Website and Apps are presented in the most effective manner for you and for the device(s) you use to access and view the Website;
To provide you with information and offers that you request from Us or which We feel may interest you.
To carry out our obligations arising from any contracts entered into between you and Us.
To allow you to participate in interactive features of our service, when you choose to do so.
To notify you about changes to our service.
To contact you, if appropriate, in regards to a rating or review submitted.
To protect the security, legality or integrity of our business.
In addition to the above uses We may use your information, to notify you about goods or services which may be of interest to you. Where We do this, We will contact you by electronic means (e-mail or SMS). If you do not want Us to use your data in this way please either (i) do not tick the relevant box situated on the form on which We collect your data (for example, the registration form); (ii) unsubscribe from our electronic communications using the method indicated in the relevant communication; or (iii) inform Us at any time by contacting Us at the contact details set out below.
Automated decision making/profiling
We utilise a marketing automation tool to create more meaningful and relevant content. It makes decisions based on interest in and response to previous campaigns (such as e-mail “clicks”) to create and deliver more personalised communications for you. You may choose to opt out of such automated decision making by contacting us.
DISCLOSURE OF YOUR INFORMATION
We routinely disclose your personal data to third parties as follows:
We may pass your information to our third party service providers, agents, subcontractors and other associated organisations for the purposes of completing tasks and providing services to you on our behalf (e.g. to host our servers, distribute and fulfilment of our services).
We may disclose your personal data to any member of our corporate group, which means our subsidiaries, our ultimate holding company and its subsidiaries, as defined in section 1159 of the UK Companies Act 2006 (where applicable).
We may also disclose your personal data to third parties:
in the event that We sell or buy any business or assets, in which case We may disclose your personal data to the prospective seller or buyer of such business or assets; or
if We or substantially all of our assets are acquired by a third party, in which case personal data held by Us about our customers will be one of the transferred assets; or
if We are under a duty to disclose or share your personal data in order to comply with any legal obligation, or in order to enforce or apply our Terms and Conditions and other agreements entered into with you; or
to protect Our rights, property, or safety or that of our affiliated entities and our users and any third party We interact with the to provide the Website; or
in relation to selected third parties only, only to the extent that you have consented to such selected third parties notifying you about certain goods or services, which may be if interest to you.
Other than as set out above, and save insofar as is necessary in order for Us to carry out our obligations arising from any contracts entered into between you and Us, We will not share your data with third parties unless We have procured your express consent to do so.
STORING YOUR PERSONAL DATA
We take appropriate measures to ensure that any personal data are kept secure, including security measures to prevent personal data from being accidentally lost, or used or accessed in an unauthorised way. We limit access to your personal data to those who have a genuine business need to know it. Those processing your information will do so only in an authorised manner and are subject to a duty of confidentiality. Where We process payment transactions, these will be encrypted using SSL technology. Where We have given you (or where you have chosen) a password which enables you to access certain parts of the Website, you are responsible for keeping this password confidential.
We also have procedures in place to deal with any suspected data security breach. We will notify you and any applicable regulator of a suspected data security breach where We are legally required to do so.
Unfortunately, the transmission of information via the internet is not completely secure. Although We will do our best to protect your personal data, We cannot guarantee the security of your data transmitted to the Website; any transmission is at your own risk. Once We have received your information, We will use strict procedures and security features to try to prevent unauthorised access.
Keeping your personal data up to date
If your personal details change you may update them by accessing the relevant page of the Website, or by contacting Us using the contact details below. If you have any questions about how We use data collected which relates to you, please contact Us by sending a request by email to the contact details below.
If you contact Us, We will endeavour to update your personal data within seven (7) working days of any new or updated personal data being provided to Us, in order to ensure that the personal data We hold about you is as accurate and up to date as possible.
How long we keep your personal data
Where we hold your personal data in connection with the performance of a contract with one of our customers or suppliers, we will hold your data, and in particular any communications between you and us in relation to the negotiation or performance of the contract by either party for so long as that contract is in force and for a period of at least 7 years after;
We may store other personal information that you have provided us for as long as it is reasonably necessary taking into consideration our need to provide you with the services you have signed up to, to resolve any disputes, enforce our rights and/or respond to queries.
If you have any questions about our data retention policy please contact us.
Where we store your personal data
All information We hold about you is stored on our supplier’s secure servers.
The data that We collect from you may be transferred to, and stored at, a destination outside the European Economic Area ("EEA"). It may also be processed by staff operating outside the EEA who work for Us or for one of our suppliers. Such staff maybe engaged in, among other things, the fulfilment of your orders, the processing of your payment details and the provision of support services.
Such countries do not have the same data protection laws as the United Kingdom and EEA. Whilst the European Commission has not given a formal decision that such countries provide an adequate level of data protection similar to those which apply in the United Kingdom and EEA, any transfer of your personal data will be subject to a written agreement that we will have reviewed and negotiated with the supplier.
If you would like further information please contact Us (see ‘Contact’ below). We will not otherwise transfer your personal data outside of the United Kingdom OR EEA or to any organisation (or subordinate bodies) governed by public international law or which is set up under any agreement between two or more countries.
Under the General Data Protection Regulation you have a number of important rights free of charge. In summary, those include rights to:
access to your personal data and to certain other supplementary information that this Policy is already designed to address
require Us to correct any mistakes in your information which We hold
require the erasure of personal data concerning you in certain situations
receive the personal data concerning you which you have provided to Us, in a structured, commonly used and machine-readable format and have the right to transmit those data to a third party in certain situations
object at any time to processing of personal data concerning you for direct marketing
object to decisions being taken by automated means which produce legal effects concerning you or similarly significantly affect you
object in certain other situations to our continued processing of your personal data
otherwise restrict our processing of your personal data in certain circumstances
claim compensation for damages caused by our breach of any data protection laws.
For further information on each of those rights, including the circumstances in which they apply, see the Guidance from the UK Information Commissioner’s Office (ICO) on individuals rights under the General Data Protection Regulation.
If you would like to exercise any of those rights, please:
email, call or write to Us
let Us have enough information to identify you (name, registration details, company name),
let Us have proof of your identity and address (a copy of your driving licence or passport and a recent utility or credit card bill), and
let Us know the information to which your request relates
HOW TO COMPLAIN
We hope that We can resolve any query or concern you raise about our use of your information.
The General Data Protection Regulation also gives you right to lodge a complaint with a supervisory authority, in particular in the European Union (or European Economic Area) state where you work, normally live or where any alleged infringement of data protection laws occurred. The supervisory authority in the UK is the Information Commissioner who may be contacted at https://ico.org.uk/concerns/ or telephone: 0303 123 1113.
We may collect information about your mobile phone, computer or other device from which you access the Website including where available your IP address, operating system and browser type, for systems administration and to report aggregate information to third parties affiliates. This is statistical data about our users’ browsing actions and patterns, and does not identify any individual. We may, however, use such information in conjunction with the data We have about you in order to track your usage of our services.
A cookie is a small file of letters and numbers that We store on your browser or the hard drive of your computer if you agree. Cookies contain information that is transferred to your computer's hard drive.
The cookies We use include:
“Analytical” They allow Us to recognise and count the number of visitors and to see how visitors move around the Website when they are using it. This helps Us to improve the way our Website works, for example, by ensuring that users are finding what they are looking for easily.
“Strictly necessary” cookies. These are cookies that are required for the operation of our Website. They include, for example, cookies that enable you to log into secure areas of our Website, use a shopping cart or make use of e-billing services.
“Functionality” cookies. These are used to recognise you when you return to our Website. This enables Us to personalise our content for you, greet you by name and remember your preferences (for example, your choice of language or region).
“Targeting” cookies. These cookies record your visit to our Website, the pages you have visited and the links you have followed to our affiliates websites. We will use this information to make our Website, offers e-mailed to you and the advertising displayed on it more relevant to your interests. We may also share this information with third parties for this purpose.
Third Party Websites and affiliates
When you post to a social media website, forum, review website or any other such facility in the public domain any information you choose to post will be available to access on the internet, depending on your own personal account settings. We recommend that you do not make public and sensitive personal information available on these websites.
All questions, comments and requests regarding this Privacy and Cookies Policy should be addressed to firstname.lastname@example.org write to Us at CSL Benelux Office, Looskade 20, Roermond, 6041 LE, Netherlands