Privacy Statement and The Purpose Of This Privacy Policy
At Steve Vick International, your privacy is important to us. As a manufacturer and service provider within the utilities industry, we need to collect and use information on our suppliers, customers, and potential customers. We use this information to manage our business, meet the needs and contractual obligations of our customers, and meet our legislative obligations.
This privacy policy aims to give you information on how we collect your personal information, sets out how we handle it through the use of this website, including any data you may provide through this website when you purchase a product or service, and describes how we protect your personal information whilst ensuring we are compliant with legislation. This policy applies to all personal data that is processed, regardless of how the information is stored or whether it relates to past, present, or potential customers/suppliers/users of our website.
This website is not intended for children, and we do not knowingly collect data relating to children.
It is important that you read this privacy policy together with any other privacy policy or fair processing policy we may provide on specific occasions when we are collecting or processing personal information about you so that you are fully aware of how and why we are using your data. This privacy policy supplements other notices and privacy policies and is not intended to override them.
Definitions
Comply with a legal obligation means processing your personal information where it is necessary for compliance with a legal obligation that we are subject to.
External Third Parties
- Service providers acting as processors who provide IT and system administration services;
- Professional advisers acting as processors or joint controllers including lawyers, bankers, auditors and insurers based in the United Kingdom who provide consultancy, banking, legal, insurance and accounting services; and
- HM Revenue & Customs, regulators and other authorities acting as processors or joint controllers based in the United Kingdom who require reporting of processing activities in certain circumstances.
Internal Third Parties means other companies in the Steve Vick International Limited Group acting as joint controllers or processors and who are based in the United Kingdom.
Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give you the best service/product and the best and 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 information for our legitimate interests. We do not use your personal information 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.
Performance of a Contract means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.
Legislation
Unless otherwise specified, legislation refers to the retained EU law version of the General Data Protection Regulation ((EU) 2016/679) – and the Data Protection Act 2018.
Controller
Steve Vick International Limited is the controller and responsible for your personal information (collectively referred to as “we”, “us” or “our” in this privacy policy).
We have appointed Steve Edwards, Financial Director, as our data protection officer (DPO) who is responsible for overseeing questions in relation to this privacy policy. If you have any questions about this privacy policy, including any requests to exercise your legal rights, please contact the DPO as per the details set out below.
Contact Details
If you have any questions about this privacy policy or our privacy practices, please contact our DPO in the following ways:
Full name of legal entity: Steve Vick International Limited
Email address: info@stevevick.com
Postal address: FAO: Tim Smith, Steve Vick International Ltd, Treenwood Industrial Estate, Bradford on Avon BA15 2AU
Telephone number: 01225 864864
You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK regulator for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.
Changes To The Privacy Policy And Your Duty To Inform Us Of Changes
We keep our privacy policy under regular review. This version was last updated on [DATE]. Historic versions can be obtained by contacting us.
It is important that the personal information we hold about you is accurate and current. Please keep us informed if your personal information changes during your relationship with us.
Third Party Links
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 policy of every website you visit.
What Information Does Steve Vick International Collect?
We will collect the minimum amount of personal information we need to complete a given task. For example, if you make an enquiry through our website we will only collect initial contact details. The personal information we collect will be relevant only for the intended purpose and legitimate interest of Steve Vick International Ltd.
When you sign up to our mailing list, contact us via our website, or use any of our other services we may collect personally identifiable information such as your name, address, contact phone number, email address in various types of record.
We may collect, use, store and transfer different kinds of personal information about you which we have grouped together as follows:
- Identity Data includes first name, maiden name, last name, username or similar identifier title, date of birth and gender.
- Contact Data includes billing address, delivery address, email address and telephone numbers.
- Financial Data includes bank account and payment card details.
- Transaction Data includes details about payments to and from you and other details of products and services you have purchased from us.
- 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.
- Profile Data includes your username and password, purchases or orders made by you, your interests, preferences, feedback and survey responses.
- Usage Data includes information about how you use our website, products and services.
- Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences
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 information but is not considered personal information 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 information so that it can directly or indirectly identify you, we treat the combined data as personal information which will be used in accordance with this privacy policy.
We do not collect any Special Categories of Personal Data about 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 information
Where we need to collect personal information by law, or under the terms of a contract we have with you, and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with goods or services). In this case, we may have to cancel a product or service you have with us but we will notify you if this is the case at the time.
Data retention
We will only retain your personal information for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal information 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.
To determine the appropriate retention period for personal information, we consider the amount, nature and sensitivity of the personal information, the potential risk of harm from unauthorised use or disclosure of your personal information, the purposes for which we process your personal information and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements. Depending on the type of record, we hold this information for the following periods:
Customer Related
- Financial transaction records: 6 years after account is closed
- Contracts: 6 years after account is closed
- Letters: 6 years after account is closed
- Complaints: 6 years after account is closed
- Enquiries: 3 years after account is closed
- Investigations: 10 years after account is closed
- Telephone calls: 3 years from date of creation
- Job application and interview records: 6 months following unsuccessful application
Health & Safety
- Accident/Incident Book: 15 years
- Legal/Accident/Incident Forms: 4 years from date of accident
- Risk Assessments: 7 years
- Health & Safety Reports: 15 years
- Fire Procedure: Until superseded but retain copies of earlier versions
- Health & Safety Policy: Until superseded but retain earlier versions up to 15 years and review as necessary
- Records of monitoring areas where employees are likely to come into contact with asbestos: Retain for 40 years (refer to The Control of Substances Hazardous to Health Regulations 2002)
- Records of monitoring areas where employees/ are likely to come into contact with radiation: Retain for 50 years (refer to The Ionising Radiations Regulations 1999)
- Fire log books: Retain for 7 years
Legal
- Third party contracts: 6 years after date of termination (unless signed as a deed, in which case 12 years after date of termination)
Other
- Job application and interview records: 6 months following unsuccessful application
- CCTV footage: 30 days
How Is Your Personal Information Collected?
We use different methods to collect data from and about you including through:
- 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 information you provide when you:
- apply for our products or services;
- create an account on our website;
- subscribe to our service or publications;
- request marketing to be sent to you; or
- give us feedback or contact us.
- Automated technologies or interactions. As you interact with our website, we will automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal information 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.
- Third parties or publicly available sources. We will receive personal information data about you from various third parties as set out below :
Technical Data from the following parties:
- analytics providers such as Google based outside the UK; and
- search information providers based inside the UK.
Contact, Financial and Transaction Data from providers of technical, payment and delivery services inside the UK.
How Does Steve Vick International Use Your Personal Information?
We will only process information for legitimate business reasons. We will ensure that it is processed lawfully, and fairly. We will not send marketing material to your personal email address or home address without prior consent. However, if you are an existing customer we may end you marketing materials if your details were obtained during the course of a sale and you were given an opportunity to opt-out.
We will only use your personal information when the law allows us to. Most commonly, we will use your personal information in the following circumstances:
- Where we need to perform the contract we are about to enter into or have entered into with you.
- Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
- Where we need to comply with a legal obligation.
Generally, we rely on consent as a legal basis for processing your personal information and we will get your consent before sending third party direct marketing communications to you via email or text message. You have the right to withdraw consent to marketing at any time by contacting us.
Purposes for which we will use your personal information
We have set out below, in a table format, a description of all the ways we plan to use your personal information, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.
Note that we may process your personal information 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 information 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 |
Performance of a contract with you |
| To process and deliver your order including:
(a) Manage payments, fees and charges (b) Collect and recover money owed to us |
(a) Identity
(b) Contact (c) Financial (d) Transaction (e) Marketing and Communications |
(a) Performance of a contract with you
(b) Necessary for our legitimate interests (to recover debts due to us) |
| To manage our relationship with you which will include:
(a) Notifying you about changes to our terms or privacy policy (b) Asking you to leave a review or take a survey |
(a) Identity
(b) Contact (c) Profile (d) 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 keep our records updated and to study how customers use our products/services) |
| 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 |
(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) Profile (d) Usage (e) Marketing and Communications (f) Technical |
Necessary for our legitimate interests (to study how 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 goods or services that may be of interest to you | (a) Identity
(b) Contact (c) Technical (d) Usage (e) Profile (f) Marketing and Communications |
Necessary for our legitimate interests (to develop our products/services and grow our business) |
If you decide to open an account with Steve Vick International, we may use your information to run a credit check in order to confirm your identity and assist in the prevention of unlawful activities.
Marketing
We strive to provide you with choices regarding certain personal information uses, particularly around marketing and advertising.
Promotional offers from us
We may use your Identity, Contact, Technical, Usage and Profile Data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which products, services and offers may be relevant for you (we call this marketing).
You will receive marketing communications from us if you have requested information from us or purchased goods or services from us and you have not opted out of receiving that marketing.
Opting out
You can ask us to stop sending you marketing messages at any time by contacting us at any time.
Where you opt out of receiving these marketing messages, this will not apply to personal information provided to us as a result of a product/service purchase, warranty registration, product/service experience or other transactions.
Storage
Your personal information is held in CRM, ERP, and email marketing software. This data is stored on premises in our database which resides on our internal servers.
If you are a SMARTester™ customer, personal information is held on our hosted platform, the data of which is stored on secure, UK based servers.
Security
We will endeavour to ensure your personal information is protected whether in electronic or paper form. We have 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. They will only process your personal information on our instructions and they are subject to a duty of confidentiality.
We have put in place procedures to deal with any suspected personal information breach and will notify you and any applicable regulator of a breach where we are legally required to do so.
Documents containing personal information should be stored securely when not required. Documents containing personal information will only be removed from the business premises when necessary. Documents will be protected whilst offsite and will not be left unattended.
Change of purpose
We will only use your personal information for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.
If we need to use your personal information for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.
Please note that we may process your personal information without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.
Disclosure Of Your Personal Information
In general we are prohibited from sharing personal information with third parties unless contractual arrangements along with safeguards have been put in place. Where such information is required to be disclosed to a third party such as a supplier or another customer, we will seek to obtain your consent prior to sharing the data.
We have a duty of confidentiality to our customers when processing personal information. All Steve Vick International Ltd employees must sign a confidentiality agreement before starting work at Steve Vick International Ltd.
We may share your personal information with the parties set out below for the purposes set out in the table Purposes for which we will use your personal information above.
- Internal Third Parties;
- External Third Parties; and
- 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 information in the same way as set out in this privacy policy.
We require all third parties to respect the security of your personal information and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal information for their own purposes and only permit them to process your personal information for specified purposes and in accordance with our instructions.
International Transfers
We do not transfer your personal information outside the UK.
Your Legal Rights
Under certain circumstances, you have rights under data protection laws in relation to your personal information. You have the right to:
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.
Request correction of the personal information 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.
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 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 information 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, at the time of your request.
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 as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal information 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.
Request restriction of processing of your personal information. This enables you to ask us to suspend the processing of your personal information in the following scenarios:
- If you want us to establish the data’s accuracy.
- Where our use of the data is unlawful but you do not want us to erase it.
- 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.
- You have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
Request the transfer of your personal information to you or to a third party. We will provide to you, or a third party you have chosen, your personal information 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.
Withdraw consent at any time where we are relying on consent to process your personal information. 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.
If you wish to exercise any of the rights set out above, please contact us.
No fee usually required
You will not have to pay a fee to access your personal information (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we could refuse to comply with your request in these circumstances.
What we may need from you
We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal information (or to exercise any of your other rights). This is a security measure to ensure that personal information is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.
Time limit to respond
We try to respond to all legitimate requests within one month. Occasionally it could take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.
Other Terms
Our website provides links to other websites including social media sites. If you click on any of these links you will no longer be protected by this privacy policy.
Steve Vick International reserves the right to amend this policy as it deems necessary.
