Privacy Policy

Privacy Policy Notice

1. Introduction
We appreciate the trust you place in us when sharing your personal data. The security of that data is very important to us.
This privacy notice/policy explains how we collect and use your personal data, during and after your relationship with us, in accordance with our obligations under data protection legislation. It also covers who we share it with and what rights you have with regards to your personal data and how you can exercise those rights.

2. Who we are - companies and websites within scope

For the purposes of the General Data Protection Regulation (“GDPR”) Cu-Plas Callow (IOM) Limited is the Data Controller. The scope also includes personal data that is collected through our websites, by telephone, through Live Chat and through any related social media applications. This means that we determine what data is collected, how this data is going to be used and how this data is protected.

It is important that you read this notice, together with any other privacy notice we may provide on specific occasions when we are collecting or processing personal data about you, so that you are aware of how and why we are using such information.

If you have questions about how we process personal data, or would like to exercise your data subject rights, please use the information supplied in the Contact Us section below.

3. The kind of data we hold about you

We may collect, store, and use the following categories of personal data about you (please note this list is not exhaustive):

• Personal contact details such as name, title, addresses, telephone numbers, and personal email addresses
• Business contact details such as position, company name, company address, business contact information such as telephone number and email addresses
• Age/Date of birth
• Bank account details and tax/vat status information
• For credit arrangements, other data relating to trading information
• Where you visit our site or have deliveries from us, CCTV footage and other information obtained through electronic means such as geolocation data for deliveries
• Cookie information and information about your use of our information and communications systems

4. Collection of personal data

We collect personal data from you for one or more of the following purposes:

• To fulfil a contract that we have entered into with you or with the entity (or organisation) that you represent. In these circumstances it may be your entity (or organisation), rather than yourself, that has provided us with your personal data
• To initiate and complete commercial transactions with you, or the entity (or organisation) that you represent, for the purchase of products and/or services
• To deliver product you have purchased directly or indirectly from us
• To communicate with suppliers of goods and services
• Keeping accounts and other business records
• To carry out marketing, electronic or otherwise including sharing within the Cu-Plas group
• Complying with legal or regulatory requirements including health and safety obligations
• Dealing with complaints or queries from our customers and our suppliers
• Generating data analytics to monitor and improve the performance of our website
• To ensure the security and safe operation of our websites and underlying business infrastructure
• We may also collect additional information from third parties including credit reference agencies

Technical and Cookie information

In addition, to ensure that each visitor to any of our websites can use and navigate the site effectively, we collect the following:

• Technical information, including the IP (Internet Protocol) address used to connect your device to the Internet
• Your login information, browser type and version, cookies, time zone setting, browser plug-in types and versions
• Operating system and platform
• Information about your visit, including the URL (Uniform Resource Locators) clickstream to, through and from our site

In section 9 below, we identify your rights in respect of the personal data that we collect and describe how you can exercise those rights.

5. Lawful basis for the processing of personal data

We believe that it is in our legitimate interests, or is necessary for the performance of a contract, or we obtain consent to collect and use personal data to operate our business and to provide a service that you have requested. In some cases, we may be under a legal duty to use or disclose personal data, for example to comply with a request from an official body.

When we process on the lawful basis of legitimate interest, we ensure our interests and fundamental rights do not override your interests.

6. Sharing your personal data
We may share your personal data, but this will be done on a ‘need to know’ basis and only where it is necessary to do so or where we are required to share information. Such as our professional advisors and service providers including:

• Accountants
• Legal counsel
• Consultants
• Insurers
• Information technology and communications service providers.
• Suppliers
• Logistics and transport services.

We may also share personal data:

• With any competent law enforcement or regulator as require by law
• When we buy or sell any businesses or assets.

We aim to put the necessary safeguards in place to ensure that personal data that the company is legally responsible for remains properly protected and is used appropriately when in the hands of a third party.

We may share personal data when we buy or sell any business or assets. We aim to put the necessary safeguards in place to ensure that personal data that we are legally responsible for remains properly protected and is used appropriately when shared with third parties.

7. How long do we keep your personal data?
We will take steps to keep your data for only as long as is necessary for our business needs and in compliance with any legal or regulatory duties to retain personal data for a particular period. However long we retain personal data for, we will ensure it is subject to appropriate security.

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.

8. Security measures
We will implement measures to protect your data, including 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 individuals, agents, contractors and other third parties who have a business need to know. We do not, however, have any control over what happens between your device and the boundary of our information infrastructure. You should be aware of the many information security risks that exist and take appropriate steps to safeguard your own information. We accept no liability in respect of breaches that occur beyond our sphere of control.

9. Your rights as a data subject
As a data subject whose personal data we hold, you have certain rights. If you wish to exercise any of these rights, please use the information supplied in the Contact Us section below. To process your request, we will ask you to provide a valid form of identification for verification purposes. Your rights are as follows:

• The right to be informed
  As a Data Controller, we are obliged to provide clear and transparent information about our data processing activities. This is provided by this privacy notice/policy and any related communications we may send you.
• The right of access (also known as a ‘data subject access request’)
  You have the right to request a copy of the personal data we hold about you (or having it transferred to another organisation) free of charge.

Once we have verified your identity and, if relevant, the authority of any third-party requestor, we will provide access to the personal data we hold about you, how we are using it, who we are sharing it with and how we obtained your data.

• The right to rectification (the ‘right to erasure’)
  You have the right to ask us to rectify or correct any of your personal data you think is inaccurate. You also have the right to ask us to complete data you think is incomplete. This may be used with the right to restrict processing to make sure that incorrect/incomplete data is not processed until it is corrected/complete.
• The right to erasure (the ‘right to be forgotten’)
  You have the right to request that we erase/delete your personal data in certain circumstances, for example where no overriding legal basis or legitimate reason continues to exist for processing personal data. This includes personal data that may have been unlawfully processed. We will take all reasonable steps to ensure erasure.
• The right to restrict processing
  You have the right to ask us to stop processing your personal data. We will still hold the data but will not process it any further. This right is an alternative to the right to erasure.
• The right to data portability
  You have the right to request your set of personal data be transferred to another Data Controller or Processor, provided in a commonly used and machine-readable format. This right only applies to data you have given us, the original processing was on the basis of consent/explicit consent/fulfilment of a contractual obligation and the processing is by automated means (is held electronically).
• The right to object
  You have the right to object to our processing of your personal data where
  a) Processing is based on legitimate interest (including profiling);
  b) Processing is for the purpose of direct marketing; or
  c) Processing is for the purpose of a task carried out in the public interest.
• The right to withdraw consent
  In the circumstances where you may have provided your consent to the collection, processing and transfer of your personal data for a specific purpose, you have the right to withdraw your consent for that specific processing at any time. Once we have received notification that you have withdrawn your consent, we will no longer process your personal data for the purpose or purposes you originally agreed to, unless we have another legitimate basis for doing so in law.
• Right to human intervention If the personal data is being used to make automated decisions about you as the data subject (e.g. profiling), to be told what logic the system uses to make those decisions and to be able to request human intervention to override any such automated decisions

You are not required to pay any charge for exercising any of your rights. We have one month to respond to you.

10. Do you have to provide your personal data to us?
You are never required to provide personal data to us, but you may need to do so when you enter into a contract for the provision of our services or products. We will not be able to provide our services or products unless you provide us with the personal data, we need to do so.
In addition, you will be required to provide certain personal data if you contact us to exercise your rights under GDPR as set out in section 10.

11. Automated decision-making and Cookies
We may carry out automated decision-making when you use our website. The automated decision making involves providing content to you based on your online behaviour obtained using Cookies. If consent is given for Cookies which are more than those required for essential use of the website, we will be able to display content that is relevant to you. Please refer to paragraph 14 below.

You can adjust cookies through the cookie preference settings.

12. Do we use your personal data for marketing?
Yes, we may use your personal data to carry out marketing. We will only contact people who want to receive marketing as well as for our own legitimate interests. If you object to marketing, whether electronic or otherwise, please let us know and we will stop contacting you for marketing. We may still need to contact you for the purposes of providing services and products.

13. Cookies consent management
We use cookies, which are small text files placed on your computer by websites that you visit, to make our website work properly, to monitor its usage and to display content that we believe will be relevant to you. If you register with us or if you continue to use our site, we may ask if we can collect additional data from you automatically through cookies or similar technology. You will be asked to agree to our use of them through our cookie consent tool.

You can also block cookies by adjusting your browser settings. However, if you choose to block all cookies you may not be able to access all, or parts, of our site and some features will not work properly.

14. Contact us
Any comments, questions or suggestions about this privacy policy or our handling of your personal data should be emailed to info@cuplas.co.im
Alternatively, you can contact us at the following postal address for our registered office:Cu-Plas Callow (IOM) Limited, Unit 18 Snugborough Trading Estate, Braddan, Isle of Man, IM4 4LG

15. Complaints
We have appointed a Data Protection Privacy Champion to oversee compliance with this privacy notice. If you have any questions about this privacy notice or how we handle your personal data, please contact us. If you have any concerns about our use of your personal data, we would like the opportunity to respond to your concerns. You can make a complaint to us using the contact details above.

You have the right to contact the Information Commissioner’s Office (ICO) if you are unhappy with our response to your concerns. The ICO is the independent regulatory office dealing with the Data Protection Act 2018 and the General Data Protection Regulation across the UK

The ICO’s address:

Information Commissioner’s Office, Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF

Helpline number: 0303 123 1113 ICO website: https://ico.org.uk/global/contact-us/

16. Changes to this privacy notice
We reserve the right to update this privacy notice at any time; this policy was last updated January 2022.