Telephone: +44 (0)1829 740 992

enquiries@icpmscones.co.uk

Privacy

Last updated on: April 2022

ICPMS Cones LTD’S

WEBSITE PRIVACY NOTICE

  1. 1. INTRODUCTION
    • 1.1. This is ICPMS Cones Ltd’s website privacy notice.
    • 1.2. We respect your privacy and are determined to protect your personal data. The purpose of this privacy notice is to inform you as to how we look after your personal data when you visit this website (regardless of where you visit it from), post on our website’s forum, contact us, sign up to our newsletter, or purchase a product or service.
    • 1.3. We would like to assure you that we do not sell any of the personal data that we collect from you to any third parties.
    • 1.4. This privacy notice is provided in a layered format so you can click through to the specific areas set out below. Alternatively, you can download a pdf version of the policy here.
    • 1.5. If you are unsure of what any terms mean, please see our Glossary in paragraph 14.
  1. 2. WHO WE ARE AND IMPORTANT INFORMATION
  2. 3. THE PERSONAL DATA WE COLLECT ABOUT YOU
  3. 4. HOW WE COLLECT YOUR PERSONAL DATA
  4. 5. HOW WE USE YOUR PERSONAL DATA
  5. 6. PURPOSES FOR WHICH WE WILL USE YOUR PERSONAL DATA
  6. 7. AUTOMATED DECISION MAKING
  7. 8. WHO WE SHARE YOUR PERSONAL DATA WITH
  8. 9. INTERNATIONAL TRANSFERS
  9. 10. DATA SECURITY
  10. 11. DATA RETENTION
  11. 12. YOUR LEGAL RIGHTS
  12. 13. CHANGES TO THIS NOTICE AND YOUR DUTY TO INFORM US OF CHANGES
  13. 14. GLOSSARY
  1. 2. WHO WE ARE AND IMPORTANT INFORMATION 

What is the purpose of this privacy notice?

Controller

Contact details

Queries, requests, concerns or complaints

Third-party links outside of our control

  1. 3. THE PERSONAL DATA WE COLLECT ABOUT YOU
    • 3.1. “Personal data”, or “personal information”, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).  For a more detailed definition, please see our Glossary in paragraph 14.
    • 3.2. We may collect, use, store and transfer different kinds of personal data about you which we have grouped together follows:
      • 3.2.1. Identity Dataincludes title, first name, last name and username.
      • 3.2.2. Contact Dataincludes billing address, delivery address, email address(es) and telephone numbers.
      • 3.2.3. Job Role Data includes current and previous job title, current and previous employers’ name(s) and address(es).
      • 3.2.4. Financial Dataincludes bank account details and payment card details.
      • 3.2.5. Transaction Data includes details about payments to and from you, and other details of products and services that you have purchased from us.
      • 3.2.6. Technical Dataincludes 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.
      • 3.2.7. Profile Dataincludes your username and password, purchases or orders made by you, your interests, preferences and feedback, as well as your public social media handles or profiles.
      • 3.2.8. Usage Datainformation about how you use our website, products and services.
      • 3.2.9. Marketing and Communications Dataincludes your preferences in receiving marketing and your communication preferences.
    • 3.3. We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data could be derived from your personal data but is not considered personal data in law as this data will 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.
    • 3.4. We do not collect any Special Categories of Personal Dataabout you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data). Nor do we collect any information about criminal convictions and offences.

If you fail to provide personal data

  1. 4. HOW WE COLLECT YOUR PERSONAL DATA
    • 4.1. We use different methods to collect personal data from and about you including through:
      • 4.1.1. Direct interactions.You may give us your Identity, Contact, Financial, Job Role and Profile Data, and Marketing and Communications Data, by filling in forms, using the website forum or by corresponding with us by post, phone, email or otherwise.  This includes personal data you provide when you:
        • 4.1.1.1. Complete any form on our website;
        • 4.1.1.2. Apply for our products or services;
        • 4.1.1.3. Use our website;
        • 4.1.1.4. Purchase any of our products or services;
        • 4.1.1.5. Subscribe to our publications including our newsletter, bulletins, webinars or white papers;
        • 4.1.1.6. Visit us at a trade show and provide us with your details;
        • 4.1.1.7. Give us your business card;
        • 4.1.1.8. Request marketing to be sent to you;
        • 4.1.1.9. Share content from our website on social media; or
        • 4.1.1.10. Post about ICPMS on social media.
      • 4.1.2. Automated technologies or interactions.As you interact with our website, we may automatically collect Usage Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies and other similar technologies. Please see our cookie policy for further details, which is accessible via: https://www.icpmscones.co.uk/cookies.
      • 4.1.3. Third parties or publicly available sources. We may receive personal data about you from various third parties as set out below:
        • 4.1.3.1. Identity, Contact and Job Role Data from your employer or main contractor based inside and outside the UK and EEA;
        • 4.1.3.2. Technical Data from analytics providers such as Google Analytics; or
        • 4.1.3.3. Identity and Contact Data from publicly available sources such as Companies House and the Electoral Register based inside the UK.

 

  1. 5. HOW WE USE YOUR PERSONAL DATA
    • 5.1. We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:
      • 5.1.1 Performance of Contract this means processing your data where it is necessary for the performance of a contract which you are a party to, or to take steps at your request before entering into that contract.
      • 5.1.2 Legitimate Interest this means the interest of our business in conducting and managing our business to enable us to give you the best service/product and the most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us (please see paragraph 6).
      • 5.1.3 Comply with a legal or regulatory obligationthis means processing your personal data where it is necessary for compliance with a legal or regulatory obligation that we are subject to.
    • 5.2. Generally we do not rely on consent as a legal basis for processing your personal data, except as set out in paragraph 6. You have the right to withdraw consent to marketing at any time by contacting us (see paragraph 2.6 for further information about how to contact us and see paragraphs 6.3 – 6.8 for further information about marketing).
  1. 6. PURPOSES FOR WHICH WE WILL USE YOUR PERSONAL DATA
    • 6.1. We have set out below, in a table format, a description of all the ways we plan to use your personal data, with the legal bases we rely on to do so.We have also identified what our legitimate interests are where appropriate.
    • 6.2. Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below.
Purpose/Activity Type of data Lawful basis for processing including basis of legitimate interest

To register you as a new customer.

(a) Identity
(b) Contact
(c) Job Role Data

Performance of a contract with you

To process and deliver your order including delivery and managing payments, fees and charges.

(a) Identity
(b) Contact
(c) Financial
(d) Transaction

Performance of a contract with you

To manage our relationship with you which will include:
(a)           contacting you about your purchase(s);
(b)           contacting you about the contract between us;
(c)            corresponding with you;
(d)           responding to your queries;
(e)           responding to any complaint raised by you;
(f)             notifying you about changes to any of our applicable terms or our privacy policy; and
(g)           asking you to leave a review or take a survey.

(a) Identity
(b) Contact
(c) Job Role
(d) Financial
(e) Transaction
(f) Technical
(g) Profile
(h) Usage
(i) Marketing and Communications

(a) Performance of a contract with you
(b) Necessary to comply with a legal obligation
(c) Necessary for our legitimate interests (to provide customer service, to keep our records updated and to study how customers use our products/services)

The running and managing of our business including:
(a)   internal record keeping; and
(b)   to satisfy any legal, regulatory, tax, accounting or reporting requirements.

(a) Identity
(b) Contact
(c) Job Role
(d) Financial
(e) Transaction
(f) Technical
(g) Profile
(h) Usage
(i) Marketing and Communications

Necessary for our legitimate interests (to run our business, to keep our records up to date, to receive the benefit from the agreements we have with our service providers and to receive professional services to benefit our business (also see paragraph 8.1below), and to retain your records for the period of time that you may make a claim against us);
Necessary to comply with a legal obligation (for example, to comply with data protection law or for tax purposes).

Enforce our rights under the contract we have with you, including:
(a)           collecting and recovering money owed to us; and
(b)           commencing or responding to any claim brought against you or by you.

(a) Identity
(b) Contact
(c) Job Role
(d) Financial
(e) Transaction
(f) Technical
(g) Profile
(h) Usage
(i) Marketing and Communications

Necessary for our legitimate interests (to act in our businesses best interest and recover debts due to us, to protect our business and reputation);
Necessary to comply with a legal obligation (for example, to comply with a court order).

To enable you to complete a survey.

(a) Identity
(b) Contact

Performance of a contract with you
Necessary for our legitimate interests (to study how customers use our website, products and services, to develop our website, products and services and grow our business)

To enable you to take part in any interactive features on our website.

(a) Profile
(b) Usage

Necessary for our legitimate interests (to offer features that are used by and are appealing to our customers to help maintain our customer base and grow our business, and to improve our website).

To administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data).

(a) Identity
(b) Contact
(c) Technical
(d) Usage

(a) Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise)
(b) Necessary to comply with a legal obligation

To deliver relevant website content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you.

(a) Identity
(b) Contact
(c) Technical
(d) Profile
(e) Usage
(f) Marketing and Communications

Necessary for our legitimate interests (to study how and why customers use our products/services, to develop them, to grow our business and to inform our marketing strategy)

To use data analytics to improve our website, products/services, marketing, customer relationships and experiences.

(a) Technical
(b) Usage

Necessary for our legitimate interests (to define types of customers for our products and services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy)

To make suggestions and recommendations to you about products/services that may be of interest to you.

(a) Identity
(b) Contact
(c) Technical
(d) Profile
(e) Usage

Consent; or
Necessary for our legitimate interests (to develop our products/services and grow our business and to inform our marketing strategy)

To make our website work more efficiently, as well as to provide information to us about you and your use of our website. For further information about cookies see paragraphs 6.9 – 6.11(inclusive).

(a) Identity
(b) Usage

Your consent to non-essential cookies

Marketing

Promotional offers from us

Third-party marketing

Opting out

Cookies

Change of purpose

  1. 7. AUTOMATED DECISION MAKING
    • 7.1. We will not use your personal data in order to undertake any form of automated decision making or profiling.
  1. 8. WHO WE SHARE YOUR PERSONAL DATA WITH
    • 8.1. We may share your personal data with the parties set out below for the purposes set out in the table under paragraph 2 and below:
      • 8.1.1. Service providers based [in the UK and USA] who host our website, provide website development services and who keep our website up and running.
      • 8.1.2. Service providers based in [the UK] who deliver our products.
      • 8.1.3. Professional advisers including lawyers, bankers, auditors and insurers based in the UK, EAA and USA who provide consultancy, banking, legal, insurance and accounting services.
      • 8.1.4. HM Revenue & Customs, regulators and other authorities based in the UK, EAA and USA who require reporting of processing activities in certain circumstances.
      • 8.1.5. Third parties to whom we may choose to sell, transfer, or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy notice.
    • 8.2. We require all third parties to respect the security of your personal data and to treat it in accordance with the law. Where our service providers are acting as Processors, we do not allow them to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.
  1. 9. INTERNATIONAL TRANSFERS
    • 9.1. We share your personal data within our company group. This will involve transferring your data outside of the UK and EEA.The companies in our company group are based in the UK and USA.
    • 9.2. Whenever we transfer your personal data out of the UK or EEA, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:
      • 9.2.1. we will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data; or
      • 9.2.2. we may use specific contracts approved for use in the UK or EEA, which give personal data the same protection it has in the UK or EEA, or we may use another safeguard or mechanism permitted by law.
    • 9.3. Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the UK or EEA.
  1. 10. DATA SECURITY
    • 10.1. We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.
    • 10.2. We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.
  1. 11. DATA RETENTION
    • 11.1. We will only retain your personal data for as long as reasonably necessary to fulfill the purposes we collected it for. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.
    • 11.2. To determine the appropriate retention period for personal data, we consider 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, regulatory, tax, accounting or other requirements.
    • 11.3. By law we have to keep basic information about our customers (including Contact, Identity, Financial and Transaction Data) for six years after they cease being customers for tax purposes.
    • 11.4. In some circumstances you can ask us to delete your data: see your legal rights in paragraph 12below for further information.
    • 11.5. In some circumstances we may anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes in which case we may use this information indefinitely without further notice to you.
  1. 12. YOUR LEGAL RIGHTS
    • 12.1. Under certain circumstances, you have rights under data protection laws in relation to your personal data. You have the right to:
      • 12.1.1. Request access to your personal data (commonly known as a “data subject access request”). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
      • 12.1.2. Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
      • 12.1.3. Request erasure of your personal data. This enables you to ask us to delete or remove personal data 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 data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, when we respond to your request.
      • 12.1.4. Object to processing of your personal data 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 as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
      • 12.1.5. Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios:
        • 12.1.5.1. If you want us to establish the data’s accuracy.
        • 12.1.5.2. Where our use of the data is unlawful but you do not want us to erase it.
        • 12.1.5.3. Where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims.
        • 12.1.5.4. You have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
      • 12.1.6. Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
      • 12.1.7. Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.
      • 12.1.8. If you wish to exercise any of the rights set out above, see paragraph 6 for how to contact us.

No fee required – with some exceptions

What we may need from you

Time limit to respond

  1. 13. CHANGES TO THIS NOTICE AND YOUR DUTY TO INFORM US OF CHANGES
    • 13.1. This version of our privacy notice was last updated on the date stated at the beginning of it.
    • 13.2. Please keep us informed if your personal data changes during your relationship with us. It is important that the personal data we hold about you is accurate and current.
  1. 14. GLOSSARY
    • 14.1. “Controller” means the natural or legal person, public authority, agency or other body which alone or jointly with others, determines the purposes and means of the processing of personal data.
    • 14.2. “HMRC” means HM Revenue and Customs (https://www.gov.uk/government/organisations/hm-revenue-customs).
    • 14.3. “ICO” means the Information Commissioners Office (ico.org.uk).
    • 14.4. “personal data” means any information relating to an identified or identifiable natural person (data subject); an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.
    • 14.5. “process” or “processing” means any operation or set of operations which is performed on personal data or on sets of personal data, whether or not by automated means, such as collection, recording, organisation, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction.
    • 14.6. Processor” means a natural or legal person, public authority, agency or other body which processes personal data on behalf of the Controller.
    • 14.7. “website” means https://www.icpmscones.co.uk.