WEC Alarms Limited
Privacy Policy
Data Protection & Privacy Policy
Introduction: Welcome to WEC Alarm Ltd’s data protection and privacy policy (referred to as “WEC”, “we”, “us” or “our” in this data protection and privacy policy).
This policy has been written in for compliance with the General Data Protection Regulations (GDPR) and to explain when and why we collect personal information about people who are employees or our clients or potential clients, how the Company uses it, the conditions under which we may disclose it to others and how we keep it secure. We are registered for the Information Commissioner’s Office (ICO) Registration No. Z5680100.
WEC respects your privacy and is committed to protecting your personal data. This data protection and privacy policy will inform you as to how we look after your personal data when: (a) you visit our website (regardless of where you visit it from) or otherwise contact us; or (b) you enter into a contract with us for the purchase of products or services by signing our contract; (c) your employer, or other business you are engaged by, enters into a contract with us for the purchase of products or services by signing our contract and provides us with your contact details; and tell you about your privacy rights and how the law protects you.
Please also use the Glossary to understand the meaning of some of the terms used in this data protection and privacy policy.
1. IMPORTANT INFORMATION AND WHO WE ARE
2. THE DATA WE COLLECT ABOUT YOU
3. HOW IS YOUR PERSONAL DATA COLLECTED
4. HOW WE USE YOUR PERSONAL DATA
5. DISCLOSURES OF YOUR PERSONAL DATA
6. INTERNATIONAL TRANSFERS
7. DATA SECURITY
8. DATA RETENTION
9. YOUR LEGAL RIGHTS
10. GLOSSARY
1. Important information and who we are:
Purpose of this data protection and privacy policy
This data protection and privacy policy aims to give you information on how WEC collects and processes your personal data through: (a) your use of this website or when you otherwise contact us; (b) you entering into a contract with us for the purchase of products and services; and (c) your employer, or other business you are engaged by, enters into a contract with us for the purchase of products or services by signing our contract and provides us with your contact details.
This website is not intended for children and we do not knowingly collect data relating to children.
It is important that you read this data protection and privacy policy together with any other data protection and privacy policy or fair processing notice we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data.
This data protection and privacy policy supplements the other notices and is not intended to override them.
Controller
WEC is the controller and responsible for your personal data.
We have appointed a ‘data privacy manager’ who is responsible for overseeing questions in relation to this data protection and privacy policy. If you have any questions about this data protection and privacy policy, including any requests to exercise your legal rights, please contact the data privacy manager using the details set out below.
Contact details
Our full details are:
Full name of legal entity: WEC Alarms Limited
Name of current data privacy manager: Steve Beal
Email address of current data privacy manager: stevebeal@wecalarms.com
Postal address: 2 Willow Wong, Burton Joyce, Nottingham NG14 5FD
You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK supervisory authority 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 data protection and privacy policy and your duty to inform us of changes
This version was last updated on 21st May 2018.
The data protection law in the UK will change on 25th May 2018. Although this data protection and privacy policy sets out most of your rights under the new laws, we may not yet be able to respond to some of your requests (for example, a request for the transfer of your personal data) until 25th May 2018 as we are still working towards getting our systems ready for some of these changes.
It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.
Third-party links
Our 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 data protection and privacy policy of every website you visit.
2. The data we collect about you
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).
We may collect, use, store and transfer different kinds of personal data about you which we have grouped together follows:
· Identity Data includes [first name, maiden name, last name, username or similar identifier, marital status, title, date of birth and gender].
· Contact Data includes [home address, billing address, trading address, email address and telephone numbers].
· Financial Data includes [bank account and payment card details].
· Transaction Data includes [details about payments from you and other details of products and services you have purchased from us].
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 data
Where we need to collect personal data 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 products 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.
3. How is your personal data collected?
We use different methods to collect data from and about you including through:
· Direct interactions. You may give us your [Identity and Contact Data] by filling in forms on our website or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:
o apply for our products or services;
o complete and sign our contract;
o give us some feedback.
· Third parties or publicly available sources. We may receive personal data about you from various third parties [and public sources] as set out below:
o Identity and Contact Data from your employer, or the business you are engaged by, to whom we are providing products or services.
o Identity and Contact Data from publicly availably sources [such as Companies House and the Electoral Register based inside the EU].
4. How we use your personal data
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:
· 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 (for example, to send suggestions and recommendations to you about products or services that may be of interest to you, your employer or the business you are engaged by).
· Where we need to comply with a legal or regulatory obligation.
Generally, we do not rely on consent as a legal basis for processing your personal data. You have the right to withdraw consent at any time by contacting our data privacy manager using their contact details above.
Purposes for which we will use your personal data
We have set out below, in a table format, a description of all the ways we plan to use your personal data, 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 data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us using the contact details above 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 potentially pitch legitimate products and services to you | (a) Identity(b) Contact | Procuring new business |
| To register you as a new customer | (a) Identity(b) Contact | Performance of a contract with you |
| To register your employer, or the business you are engaged by, as a new customer | (a) Identity(b) Contact | Necessary for our legitimate interests (to perform a contract with your employer or the business you are engaged by) |
| 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 | (a) Performance of a contract with you[(b) Necessary for our legitimate interests (to limit your credit available to an amount for which you are creditworthy; and to recover debts due to us)] |
| To process and deliver an order placed by your employer, or the business you are engaged by, including:(a) Manage payments, fees and charges(b) Collect and recover money owed to us | (a) Identity(b) Contact(c) Financial(d) Transaction | Necessary for our legitimate interests (to:(a) perform a contract with your employer, or the business you are engaged by; and(b) recover debts due to us) |
| To manage our relationship with you which will include:(a) Notifying you about changes to our terms or data protection and privacy policy(b) Asking you to leave a review or take a survey(c) Arrange appointments in person | (a) Identity(b) Contact(c) Profile(d)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 customer records updated) |
| To manage our relationship with your employer, or the business you are engaged by, which will include:(a) Notifying them via you about changes to our terms or data protection and privacy policy(b) Asking them via you to leave a review or take a survey(c) Arrange appointments in person | (a) Identity(b) Contact(c) Profile(d)Communications | (a) Necessary to comply with a legal obligation(b) Necessary for our legitimate interests (to keep our contact records updated and to study how customers and contacts use our products / services) |
| To enable you to complete a survey | (a) Identity(b) Contact(c) Profile(d) Usage(e)Communications | (a) Performance of a contract with you(b) Necessary for our legitimate interests (to study how customers and contacts use our products / services, to develop them and grow our business) |
Cookies
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Change of purpose
We will only use your personal data 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 data 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 data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.
5. Disclosures of your personal data
We may have to share your personal data with the parties set out below for the purposes set out in the table in paragraph 4 above.
· External Third Parties as set out in the Glossary.
· Specific third parties when alarm system are monitored include: the Police & EMCS.
We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers 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.
6. International transfers
We do not transfer your personal data outside the European Economic Area (EEA).
7. Data security
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 use encryption and 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.
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.
8. Data retention
How long will you use my personal data for?
We will only retain your personal data 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.
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 requirements.
Details of retention periods for different aspects of your personal data are available in our ‘WEC GDPR info flow document’ which you can request by contacting us at stevebeal@wecalarms.com.
In some circumstances you can ask us to delete your data: see Request erasure below for further information.
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.
9. Your legal rights
Under certain circumstances, you have rights under data protection laws in relation to your personal data.
· Request access to your personal data.
· Request correction of your personal data.
· Request erasure of your personal data.
· Object to processing of your personal data.
· Request restriction of processing your personal data.
· Request transfer of your personal data.
· Right to withdraw consent.
If you wish to exercise any of the rights set out above, please contact us by telephone, post or email using the contact information set out above.
No fee usually required
You will not have to pay a fee to access your personal data (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 may 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 data (or to exercise any of your other rights). This is a security measure to ensure that personal data 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 may 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.
10. Glossary
LAWFUL BASIS
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 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 by telephone, post or email using the contact information set out above.
Performance of 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.
Comply with a legal or regulatory obligation means processing your personal data where it is necessary for compliance with a legal or regulatory obligation that we are subject to.
Consent means processing your personal data where you have given your unambiguous consent to our processing of your personal data.
THIRD PARTIES
External Third Parties
· Lawyers, bankers, auditors and insurers based in the United Kingdom who provide banking, legal, insurance and accounting services.
· HM Revenue & Customs, regulators and other authorities based in the United Kingdom who require reporting certain circumstances.
YOUR LEGAL RIGHTS
You have the right to:
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.
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.
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. Unless the Company has reasonable grounds to refuse to erase personal data, all requests for erasure shall be complied with, and you will be informed of the erasure, within one month of receipt of your request. The period can be extended by up to two months in the case of complex requests. If such additional time is required, the you shall be informed. 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 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.
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: (a) if you want us to establish the data’s accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) 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; or (d) 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 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.
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.
