CSI Limited understands that your privacy is important to you and that you care about how your personal data is used. We respect and value the privacy of everyone who visits this website, https://www.csiltd.co.uk/ (“Our Site”) and will only collect and use personal data in ways that are described here, and in a way that is consistent with our obligations and your rights under the law.
This website is not intended for children and we do not knowingly collect data relating to children.
1. DEFINITIONS AND INTERPRETATION
In this Policy the following terms shall have the following meanings:
2. INFORMATION ABOUT US
Registered address: Lynton House, 7-12 Tavistock Square, London WC1H 9BQ United Kingdom
DPO: Simon Paterson
Email address: [email protected]
Postal Address: CSI House, 2940 Trident Court, Birmingham Business Park, Solihull Parkway, Birmingham, B37 7YN
3. WHAT DOES THIS POLICY COVER?
4. WHAT IS PERSONAL DATA?
Personal data 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).
Personal data covers obvious information such as your name and contact details, but it also covers less obvious information such as identification numbers, electronic location data, and other online identifiers.
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.
5. WHAT ARE MY RIGHTS?
Under the data protection laws, you have the following rights, which we will always work to uphold:
B. The right to access the personal data we hold about you. Part 14 will tell you how to do this.
C. The right to have your personal data corrected if any of your personal data held by us is inaccurate or incomplete. Please contact us using the details in Part 16 to find out more.
D. The right to request erasure, i.e. the right to ask us to delete or otherwise dispose of any of your personal data where there is no good reason for us continuing to process it.. Please contact us using the details in Part 16 to find out more.
E. The right to restrict (i.e. prevent) the 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.
F. The right to object to us using your personal data for a particular purpose or purposes i.e. 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.
G. The right to 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.
H. The right to 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.
For more information about our use of your personal data or exercising your rights as outlined above, please contact us using the details provided in Part 16.
Further information about your rights can also be obtained from the Information Commissioner’s Office or your local Citizens Advice Bureau.
If you have any cause for complaint about our use of your personal data, you have the right to lodge a complaint with 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.
6. WHAT DATA DO WE COLLECT?
- First and Last Name;
- Email address;
- Telephone number;
- Business name;
- Job title;
- IP address;
- Web browser type and version;
- Operating system;
- Your preferences in receiving marketing from us and our third parties and your communication preferences;
- Details of transactions you carry out through our site and of the fulfilment of your orders.
7. 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, 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:
- 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;
- enter a competition, promotion or survey; or
- give us feedback or contact us.
Third parties or publicly available sources. We will receive personal data about you from various third parties and public sources as set out below:
Technical data from the following parties:
- analytics providers such as Google;
- advertising networks; and
- search information providers.
Contact, financial and transaction data from providers of technical, payment and delivery services.
Identity and contact data from data brokers or aggregators.
Identity and contact data from publicly available sources.
8. HOW DO YOU USE MY PERSONAL DATA?
Under the data protection laws, we must always have a lawful basis for using personal data. This may be because the data is necessary for our performance of a contract with you, necessary to comply with a legal obligation, because you have consented to our use of your personal data, or because it is necessary for our legitimate interests to use it.
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.
Your personal data may be used for the following purposes:
- Providing and managing your access to Our Site;
- Personalising and tailoring your experience on Our Site;
- Supplying our products AND/OR services to you. Your personal details are required in order for us to enter into a contract with you.
- Personalising and tailoring our products AND/OR services for you.
- Communicating with you. This may include responding to emails or calls from you.
- Supplying you with information by email AND/OR post that you have opted-in to (you may unsubscribe or opt-out at any time).
- Analysing your use of Our Site and gathering feedback to enable us to continually improve Our Site and your user experience.
- With your permission AND/OR where permitted by law, we may also use your personal data for marketing purposes, which may include contacting you by email AND/OR telephone AND/OR text message AND/OR post with information, news, and offers on our products AND/OR services. You will not be sent any unlawful marketing or spam. We will always work to fully protect your rights and comply with our obligations under the data protection laws and the Privacy and Electronic Communications (EC Directive) Regulations 2003, and you will always have the opportunity to opt-out.
9. HOW LONG WILL YOU KEEP MY PERSONAL DATA?
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.
We will not keep your personal data for any longer than is necessary in light of the reason(s) for which it was first collected. If you have not transacted business with us, your personal data will be deleted from our systems within 2 years.
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.
10. HOW AND WHERE DO YOU STORE OR TRANSFER MY PERSONAL DATA?
We may store or transfer some or all of your personal data in countries that are outside the UK and are not part of the European Economic Area (the “EEA” consists of all EU member states, plus Norway, Iceland, and Liechtenstein). These are known as “third countries” and may not have data protection laws that are as strong as those in the UK and/or the EEA. This means that we will take additional steps in order to ensure that your personal data is treated just as safely and securely as it would be within the UK and under the data protection.
Whenever we transfer your personal data out of the UK, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:
- we will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data;
- where we use certain service providers, we may use specific contracts approved for use in the UK which give personal data the same protection it has in the UK.
Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the UK.
11. DO YOU SHARE MY PERSONAL DATA?
We may sometimes contract with third parties to supply certain products AND/OR services. These may include payment processing, delivery, and marketing. In some cases, those third parties may require access to some or all of your personal data that we hold.
If any of your personal data is required by a third party, as described above, we will take steps to ensure that your personal data is handled safely, securely, and in accordance with your rights, our obligations, and the third party’s obligations under the law, as described above in Part 10.
We may share your personal data with the parties set out below for the purposes set out in this policy:
Internal Third Parties i.e. other companies in our group.
External Third Parties:
- Service providers acting as processors for example who provide IT and system administration services;
- Business partners, suppliers and sub-contractors where they are associated with the provision of services to you or otherwise as part of our performance of a contract with you;
- Professional advisers acting as processors or joint controllers including lawyers, bankers, auditors and insurers based in who provide consultancy, banking, legal, insurance and accounting services;
- HM Revenue & Customs, regulators and other authorities acting as processors or joint controllers who require reporting of processing activities in certain circumstances.
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.
If any personal data is transferred outside of the EEA, we will take suitable steps in order to ensure that your personal data is treated just as safely and securely as it would be within the UK and under the data protection laws, as explained above in Part 10.
In some limited circumstances, we may be legally required to share certain personal data, which might include yours, if we are involved in legal proceedings or complying with legal obligations, a court order, or the instructions of a government authority.
12. HOW CAN I CONTROL MY PERSONAL DATA?
In addition to your rights under the data protection laws, set out in Part 5, when you submit personal data via Our Site, you may be given options to restrict our use of your personal data. In particular, we aim to give you strong controls on our use of your data for direct marketing purposes (including the ability to opt-out of receiving emails from us which you may do by unsubscribing using the links provided in our emails).
You may also wish to sign up to one or more of the preference services operating in the UK: The Telephone Preference Service (“the TPS”), the Corporate Telephone Preference Service (“the CTPS”), and the Mailing Preference Service (“the MPS”). These may help to prevent you receiving unsolicited marketing. Please note, however, that these services will not prevent you from receiving marketing communications that you have consented to receiving.
13. CAN I WITHHOLD INFORMATION?
You may access certain areas of Our Site without providing any personal data at all. However, to use all features and functions available on Our Site you may be required to submit or allow for the collection of certain 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 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.
14. HOW CAN I ACCESS MY PERSONAL DATA?
If you want to know what personal data we have about you, you can ask us for details of that personal data and for a copy of it (where any such personal data is held). This is known as a “subject access request”.
All subject access requests should be made in writing and sent to the email or postal addresses shown in Part 16. To make this as easy as possible for you, a Subject Access Request Form is available for you to use. You do not have to use this form, but it is the easiest way to tell us everything we need to know to respond to your request as quickly as possible.
There is not normally any charge for a subject access request. If your request is ‘manifestly unfounded or excessive’ (for example, if you make repetitive requests) a fee may be charged to cover our administrative costs in responding. Alternatively, we could refuse to comply with your request in these circumstances.
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.
We will respond to your subject access request within one month of receiving it. Normally, we aim to provide a complete response, including a copy of your personal data within that time. In some cases, however, particularly if your request is more complex, or you have made a number of requests, more time may be required to respond. You will be kept fully informed of our progress.
16. HOW DO I CONTACT YOU?
To contact us about anything to do with your personal data and data protection, including to make a subject access request, please use the following details (for the attention of The Data Protection Officer):
Email address: [email protected]
Postal Address: CSI House, 2940 Trident Court, Birmingham Business Park, Solihull Parkway, Birmingham, B37 7YN.
- means an account required to access and/or use certain areas and features of Our Site;
- means a small text file placed on your computer or device by Our Site when you visit certain parts of Our Site and/or when you use certain features of Our Site. Details of the Cookies used by Our Site are set out in Part 15, above and in our Cookies Policy https://www.csiltd.co.uk/cookie-policy; and
17. 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 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.
We may change this Privacy Notice from time to time. This may be necessary, for example, if the law changes, or if we change our business in a way that affects personal data protection.
Any changes will be posted on Our Site. We recommend that you check this page regularly to keep up-to-date.
Data Processing Compliance
The content on this page should be read in conjunction with our Statement of Work and Framework Agreement.