Privacy Notice

GDPR Privacy Notice

1. Supalite Tiled Roof Systems Ltd (The “Company”) is committed to protecting to protecting the privacy and security of your personal information. 1.1 The purpose of this policy is to outline how we collect and use personal information about you in accordance with the General Data Protection Policy.

1.2 This policy applies to all individuals who have provided us with their personal details in order to receive further information, obtain a quote or locate an installer.

1.3 Our website is not intended for children and we do not knowingly collect data relating to children.

1.4 The Company is a “data controller”. This means that the Company is responsible for deciding how we hold and use personal information about you. The Company is required under the data protection legislation to notify you of the information contained within this privacy policy.

1.5 You should read this policy, together with any other privacy notice which the Company may provide on specific occasions when we are collecting or processing personal information about you, so that you are aware of how and why the Company are using such information.

1.6 What are the principles of Data Protection?

1.6.1 The Company will at all times comply with data protection law. The law states that any personal information that the Company holds about you must be:

1.6.1.1 Used lawfully, fairly and in a transparent way.

1.6.1.2 Collected only for valid purposes that the Company has clearly explained to you and not used in any way that is incompatible with those purposes;

1.6.1.3 Relevant to the purposes that the Company has told you about and limited to those purposes only;

1.6.1.4 Accurate and kept up to date;

1.6.1.5 Kept only for as long as necessary for the purposes that the Company has told you about, further information on the Company’s policy on the retention documentation can be found in our Retention Policy;

1.6.1.6 Kept securely.

1.7 Third Party Links

1.8 This website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy notice of every website you visit What type of information does the Company hold about me? 1.8.1 The Company will hold personal data, or personal information about you, which means any information which could identify you. This does not include data where your identity has been removed (anonymous data).

1.8.2 The Company will collect, store, and use the following categories of personal data about you, including but not limited to:

1.8.2.1 Identity Data includes first name, maiden name, last name, username or similar identifier, marital status, title, date of birth and gender

1.8.2.2 Contact Data includes billing address, delivery address, email address and telephone numbers

1.8.2.3 Financial Data includes bank account and payment card details

1.8.2.4 Transaction Data includes details about payments to and from you, other details of products and services you have purchased from us, property photographs, CCTV Footage and references

1.8.2.5 Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences

1.8.2.6 Technical Data includes [internet protocol (IP) address, 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

1.8.2.7 Profile Data includes your username and password, purchases or orders made by you, your interests, preferences, feedback and survey responses

1.8.2.8 Usage Data includes information about how you use our website, products and services

We also collect, use and share Aggregated 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.

1.9 How will my personal information be collected?

We use different methods to collect data from and about you including through:

1.9.1 Direct interactions. You may give us your Identity, Contact and Financial Data by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:

1.9.1.1 apply for our products or services;

1.9.1.2 create an account on our website;

1.9.1.3 subscribe to our service or publications;

1.9.1.4 request marketing to be sent to you;

1.9.1.5 give us some feedback.

1.9.2 Automated technologies or interactions. As you interact with our website, 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. Please see our cookie policy for further details

1.9.3 Identity and Contact Data from publicly availably sources such as Companies House and the Electoral Register based inside the EU.

1.10 How will my personal information be stored?

1.10.1 Your personal data will be stored in a secure environment within our accounting software, on our server which is only accessible by a secure password by our staff. It will also be held in a secure paper filing system which access is only permitted to relevant staff.

1.11 How will the Company use information about me?

1.11.1 The Company will only use your personal information when the law allows it to do so.

1.11.2 The Company will mostly commonly use your personal information in the following circumstances:

1.11.2.1 Where the Company needs to perform the contract which it has entered in to with you;

1.11.2.2 Where the Company needs to comply with a legal obligation and

1.11.2.3 Where it is necessary for the Company’s legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.

1.12 In what situations will the company use my personal information?

1.12.1 The Company needs all of the categories of information listed above in 1.6 primarily to allow the Company to perform its contract with you and to enable the Company to comply with legal obligations.

1.12.2 The Company may in some cases use your personal information to pursue legitimate interests of its own or those of third parties, provided that your interests and fundamental rights do not overrise those interests.

1.12.3 The situations in which the Company will process your personal information are when the company is:

1.12.3.1 providing you with information in relation to a product or service you have taken interest in;

1.12.3.2 in order to locate an approved installer in your area;

1.12.3.3 to process a building regulations application;

1.12.3.4 to create an order and/or invoice;

1.12.3.5 during an approved installer application;

1.12.3.6 when processing an application for a credit account (trade only);

1.12.3.7 and to ensure your safety while on our premises.

1.12.4 Some of the above grounds for processing will overlap and here may be several grounds which justifies the use of your personal information.

1.13 What happens if I fail to provide personal information?

1.13.1 If you fail to provide certain information when requested, the Company may not be able to fulfil its obligations to you (such as applying for building regulations or locating an approved installer in your area).

1.14 Can the Company change the purpose for which it is using my personal data?

1.14.1 The Company will only use your personal information for the purposes for which it collected it, unless it reasonably considers it needs to use it for another reason, and that the reason is compatible with the original purpose.

1.14.2 If the Company needs to use your personal information for an unrelated purpose, the Company will notify you and explain the legal basis for this.

1.14.3 The Company may process your personal information with your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

1.15 What is automated decision-making and how will it apply?

1.15.1 Automated decision-making takes place when an electronic system uses personal information to make a decision without human intervention. The Company is allowed to use automated decision- making in the following circumstances:

1.15.1.1 Where it is necessary to perform the contract with you and appropriate measures are in place to safeguard your rights; and

1.15.1.2 In limited circumstances, with your explicit written consent and where appropriate measures are in place to safeguard your rights.

1.15.2 You will not be the subject to decisions that will have a significant impact on you based solely on automated decision-making unless the Company has a lawful basis for doing so and you have been notified.

1.16 What is data sharing and how will this affect me?

1.16.1 The Company may have to share your data with third parties, including third-party service providers and other entities in the Company’s group.

1.16.2 The Company may require third parties to respect the security of your data and to treat it in accordance with the law.

1.17 Why might you share my personal information with third parties?

1.17.1 The Company may share personal information with third parties where required by law, where it is necessary to carry out our obligations to you or where it has another legitimate interest in doing so, for example, providing your name, address and contact number to an approved installer in order for them to contact you in relation to your enquiry.

1.18 Which third-party service providers process & control my personal information?

1.18.1 “Third parties” includes third-party service providers (including contractors and designated agents) and other entities within the Company’s group. Supalite Holdings Limited incorporating Supalite Tiled Roof Systems Ltd, Extralight (UK) Ltd & Supalite Supastore Ltd.

1.18.2 The following third-party service providers process & control personal information about you for the following purposes:

JHAi – Process Building Regulation Applications

Approved Installers – Provide information and offer quotations

(full list of approved installers can be provided on request)

1.19 How secure is my information with third-party service providers and other entities in our group?

1.19.1 All of the Company’s third-party service providers and other entities in the Group are required to take appropriate security measures to protect your personal information in line with Company policies. The Company does not allow its third-party service providers to use your personal data for their own purposes. The Company only permits them to process your personal data for specified purposes and in accordance with our instructions.

1.19.2 To ensure the Company’s third-party service providers are complying with their obligations under data protection regulations and safeguarding your personal data, the Company may conduct audits on third party service providers from time to time as well as seeking contractual commitment for compliance with data protection obligations.

1.20 What is data security and how does it affect me?

1.20.1 The Company has put in place measures to protect the security of your information. Details of these measures are available upon request.

1.20.2 Third parties will only be entitled to process your personal information on the Company’s instructions and where we have agreed to treat information confidential and to keep it secure.

1.20.3 The Company has put in place appropriate security measures to prevent your personal information from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In

addition, we limit access to your personal information to those employees, agents, contractors and other third parties who have a business need to know. We will only process your personal information on our instructions and we are subject to a duty of confidentiality.

1.120.4 The Company has put in place procedures to deal with any suspected data security breach and will notify you and any applicable regulator of a suspected breach where it is legally required to do so.

1.21 How long will you use my information for?

1.21.1 The Company will only retain your personal information for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.

1.21.2 To determine the appropriate retention period for personal data, the Company considers the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.

1.21.3 Details of retention periods for different aspects of your personal data are available in our retention policy which you can request from us by contacting Nina Colquhoun

1.22 What rights do I have in connection to my personal information?

1.22.1 Under certain circumstances, by law you have the right to:

1.22.1.1 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.

1.22.1.2 Request correction of the personal information that we hold about you. This enables you to have any incomplete or inaccurate information we hold about you corrected.

1.22.1.3 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)

1.22.1.4 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.

1.22.1.5 Request the restriction of processing of your personal information. This enables you to ask us to suspend the processing of personal information about you, for example if you want us to establish its accuracy or the reason for processing it.

1.22.6 Request the transfer of your personal information to another party.

1.22.2 If you want to review, verify, correct or request erasure of your personal information, object to the processing of your personal data, or request that the Company transfers a copy of your personal information to another party, please contact Nina Colquhoun in writing.

1.23 Are fees usually required?

1.23.1 Not usually, you will not have to pay a fee to access your personal information (or to exercise any of the other rights). However, the Company may charge a reasonable fee if your request for access is clearly unfounded or excessive. Alternatively, we may refuse to comply with the request in such circumstances.

1.24 Will the Company require anything from me?

1.24.1 The Company may need to request specific information from you to help it 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.

1.25 Am I able to withdraw my consent?

1.25.1 In the limited circumstances where you may have provided your consent to the collection, processing and transfer of your personal information for a specific purpose, you have the right to withdraw your consent for that specific processing at any time. To withdraw your consent, please contact Nina Colquhoun. Once we have received notification that you have withdrawn your consent, we will no longer process your information for the purpose or purposes you originally agreed to, unless we have another legitimate basis for doing so in law.

1.26 Can this policy be amended?

1.26.1 Yes, the Company reserves the right to update this privacy notice at any time, and it will provide you with a new privacy notice when it makes any substantial updates. The Company may also notify you in other ways from time to time about the processing of your personal information.

1.26.2 If you have any questions about this privacy notice, please contact Nina Colquhoun.

1.27 Cookies

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