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When we process your personal data we are required to comply with the General Data Protection Regulation 2016 (“GDPR”) and the Data Protection Act 2018, which supplements GDPR in the UK (the “DPA). The DPA and GDPR are together referred to in this notice as the “Data Protection Laws”.

Your personal data includes all the information we hold that identifies you or is about you, including but not limited to your name, email address, postal address, and in some cases opinions that we document about you. It does not include data where the identity has been removed and is therefore anonymous. More information about the types of personal data we process about you is set out below.

Everything we do with your personal data counts as processing it, including collecting, storing, amending, transferring and deleting it. We are therefore required to comply with the Data Protection Laws to make sure that your information is properly protected and used appropriately.

This fair processing notice provides information about the personal data we process about you, why we process it and how we process it. It applies to customers and suppliers as well as candidates contacting us in relation to job vacancies or to send a speculative CV.

Our responsibilities

Siddall & Hilton Products Limited (a company registered in England with registered company number 03460387 and registered address at Birds Royd Lane, Brighouse, West Yorkshire HD6 1LT) is the data controller of the personal data you provide.

We have nominated our Technology Director to have day to day responsibility for ensuring we comply with the Data Protection Legislation and dealing with any requests we receive from individuals exercising their rights under the Data Protection Legislation.

What data do we process about you?

· Customer and Suppliers

Personal data that we may process about you (depending on the extent of the information you have provided to us) includes:

o identity data such as your first name, middle names, last name, marital status, title, date of birth and gender;

o contact data such as your billing address and delivery address (whether residential or your company address), email address and telephone numbers;

o financial data including your bank account and payment card details;

o transaction data including details about payments to and from you and other details of products and services you have purchased from us; and

o technical data which is referred to in more detail in our website privacy policy available [here].

We do not collect any special categories of data about you.

· Candidates

Personal data that we are likely to process about you includes:

o Identity data such as your first name, middle names and last name;

o Contact data such as your postal address, email address and telephone numbers;

o Background data such as your education, career background and work experience;

o Personal information such as your skills and qualities;

o Any other information that you include on any CV, application or covering letter you send to us. If this information includes special categories of data we will process that information on the grounds of consent, because you have chosen to provide it to us.

Why do we process your personal data?

· Customers and Suppliers

We may need personal data from you to be able to enter into a contract with you and provide you with all the information you need. If we do not receive that personal data from you, we may be unable to fulfil our obligations to you. We may also process your information for business relationship purposes and to respond to any queries or comments you submit to us.

We process most of your information on the grounds of our legitimate interests, to fulfil our contract with you and/or to comply with a legal obligation.

If none of the grounds set out above applies, we will ensure we are able to rely on another ground to process your data and, if necessary, we will obtain consent from you to the processing of your personal data. You can withdraw your consent at any time. This won’t affect the lawfulness of any processing we carried out prior to you withdrawing your consent.

· Candidates

We will process your information on the grounds of our legitimate interests to determine whether or not we have a suitable vacancy for you.

Our collection of your personal data

· Customers and Suppliers

We use different methods to collect data from and about you including through:

o Direct interactions

You may give us your personal data by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you: place an order for our products or services; submit a query about our products or service whether on our website or by email or phone; request for marketing to be sent to you; or give us feedback or contact us.

o Automated technologies or interactions

As you interact with our website, we will automatically collect personal data about you. You can find out more information in our privacy policy available [here] and cookie policy available [here].

Who will receive your personal data?

Your personal data is only transferred to the extent that this is necessary. Recipients of your personal data include:

· logistics companies to the extent they are required to process your personal data in order to provide services to you on our behalf;

· legal advisers to the extent they need to see your personal data to provide us with legal advice;

· 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 policy.

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.

We may transfer your personal data outside of the EEA if we are working with you in respect of a project based outside of the EEA, in which case we will provide you with further information about

the transfer if and when it becomes relevant. We will ensure that there are appropriate safeguards in place in respect of the transfer of data.

How long will we keep your personal data?

Customers and Suppliers

Your personal data is retained for no more than 8 years from the date of the last order or purchase order placed by you or by us, as applicable. It is retained for this period in case any issues arise or in case you have any queries and to allow us a rolling annual period for deletion and destruction of your data. Your information will be kept securely at all times. Following the end of the 8 period, your files and personal data we hold about you will be permanently deleted or destroyed. If we are required to obtain your consent to send you marketing communications, any information we use for this purpose will be kept until you withdraw your consent, unless we have other legitimate reasons to retain the data.

Candidates

We will retain your application, CV and/or covering letter and any other personal data you provided to us for 6 months from the date we reach our decision in case any other suitable roles arise in which we think you may be interested, or in case you have any questions about our decision. After that date, your personal data will be permanently deleted or destroyed or, if you accept a permanent position with us, it will be processed in line with our employee privacy policy, a copy of which will be made available to you.

What are your rights?

You benefit from a number of rights in respect of the personal data we hold about you. We have summarised your rights below, and more information is available from the Information Commissioner’s Office website (https://ico.org.uk/for-organisations/guide-to-the-general-data-protection-regulation-gdpr/individual-rights/). These rights apply for the period in which we process your data.

1. Access to your data

You have the right to ask us to confirm that we process your personal data, as well as access to and copies of your personal data. You can also ask us to provide a range of information, although most of that information corresponds to the information set out in this fair processing notice.

We will provide the information free of charge unless your request is manifestly unfounded or excessive or repetitive, in which case we are entitled to charge a reasonable fee. We may also charge you if you request more than one copy of the same information.

We will provide the information you request as soon as possible and in any event within one month of receiving your request. If we need more information to comply with your request, we’ll let you know.

2. Rectification of your data

If you believe personal data we hold about you is inaccurate or incomplete, you can ask us to rectify that information. We will comply with your request within one month of receiving it, unless we don’t feel it’s appropriate in which case we’ll let you know why. We will also let you know if we need more time to comply with your request.

3. Right to be forgotten

In some circumstances, you have the right to ask us to delete personal data we hold about you. This right is available to you:

· where we no longer need your personal data for the purpose for which we collected it;

· where we have collected your personal data on the grounds of consent and you withdraw that consent;

· where you object to the processing and we don’t have any overriding legitimate interests to continuing processing the data;

· where we have unlawfully processed your personal data (i.e. we have failed to comply with GDPR); and

· where the personal data has to be deleted to comply with a legal obligation.

There are certain scenarios in which we are entitled to refuse to comply with a request. If any of those apply, we’ll let you know.

4. Right to restrict processing

In some circumstances you are entitled to ask us to suppress processing of your personal data. This means we will stop actively processing your personal data but we don’t have to delete it. This right is available to you:

· if you believe the personal data we hold isn’t accurate – we’ll cease processing it until we can verify its accuracy;

· if you have objected to us processing the data – we’ll cease processing it until we have determined whether our legitimate interests override your objection;

· if the processing is unlawful; or

· if we no longer need the data but you would like us to keep it because you need it to establish, exercise or defend a legal claim.

5. Data portability

You have the right to ask us to provide your personal data in a structured, commonly used and machine-readable format so that you are able to transmit the personal data to another data controller. This right only applies to personal data you provide to us:

· where processing is based on your consent or for performance of a contract (i.e. the right does not apply if we process your personal data on the grounds of legitimate interests); and

· where we carry out the processing by automated means.

We’ll respond to your request as soon as possible and in any event within one month from the date we receive it. If we need more time, we’ll let you know.

6. Right to object

You are entitled to object to us processing your personal data:

· if the processing is based on legitimate interests or performance of a task in the public interest or exercise of official authority;

· for direct marketing purposes (including profiling); and/or

· for the purposes of scientific or historical research and statistics.

We do not intend to use your personal data to send you direct marketing nor for scientific or historical research and statistics.

In order to object, you must have grounds for doing so based on your particular situation. We will stop processing your data unless we can demonstrate that there are compelling legitimate grounds which override your interests, rights and freedoms or the processing is for the establishment, exercise or defence of legal claims.

Automated decision making

Automated decision making means making a decision solely by automated means without any human involvement.

We don’t carry out any automated decision making using your personal data.

Your right to complain about our processing

If you think we have processed your personal data unlawfully or that we have not complied with GDPR, you can report your concerns to the supervisory authority in your jurisdiction. The supervisory authority in the UK is the Information Commissioner’s Office (“ICO”). You can call the ICO on 0303 123 1113 or get in touch via other means, as set out on the ICO website – https://ico.org.uk/concerns/.

Any questions?

If you have any questions or would like more information about the ways in which we process your data, please contact info@sandhp.com.