1.1 We are committed to safeguarding the privacy of our website visitors and service users.
1.2 This policy applies where we are acting as a data controller with respect to the personal data of our website visitors; in other words, where we determine the purposes and means of the processing of that personal data.
1.4 In this policy, “we”, “us” and “our” refer to Stiltz Ltd. For more information about us, see Section 12.
1.5 “Personal data” is defined in Article 4(1) of the GDPR:
(1) ‘personal data’ means any information relating to an identified or identifiable natural person (‘data subject’); an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person”.
2. How we use your personal data
2.1 In Section 2 we have set out:
(a) the general categories of personal data that we may process;
(b) the purposes for which we may process personal data; and
(c) the legal bases of the processing.
2.2 We may process data about your use of our website and services (“usage data“). The usage data may include your IP address, geographical location, browser type and version, operating system, referral source, length of visit, page views and website navigation paths, as well as information about the timing, frequency and pattern of your service use. The source of the usage data is our analytics tracking system. This usage data may be processed for the purposes of analysing the use of the website and services. The legal basis for this processing is our legitimate interests, namely monitoring and improving our website and services.
2.3 We may process your contact data (“contact data“). The contact data may include your name, postal address, landline and/or mobile number and email address. The source of the contact data is the information you enter into the form/s on our website and submit to us or which you may give to us via a phone call. The contact data may be processed for the purposes of providing information on our services and communicating with you about our products or services via phone, email and post.
2.4 We may process information contained in any enquiry you submit to us regarding goods and/or services (“enquiry data“). The enquiry data may be processed for the purposes of offering, marketing and selling relevant goods and/or services to you. The legal basis for this processing is consent.
2.5 We may process information relating to transactions, including purchases of goods and services, that you enter into with us (“transaction data“). The transaction data may include your contact details, your card details and the transaction details. The transaction data may be processed for the purpose of supplying the purchased goods and services and keeping proper records of those transactions. The legal basis for this processing is the performance of a contract between you and us and/or taking steps, at your request, to enter into such a contract and our legitimate interests, namely our interest in the proper administration of our business. The transaction information will be held for the minimum statutory period as defined by HMRC.
2.7 We may process information that you provide to us for the purpose of subscribing to our email notifications and/or newsletters (“notification data“). The notification data may be processed for the purposes of sending you the relevant notifications and/or newsletters. The legal basis for this processing is consent.
2.8 We may process information contained in or relating to any communication that you send to us (“correspondence data“). The correspondence data may include the communication content and metadata associated with the communication. Our website will generate the metadata associated with communications made using the website contact forms. The correspondence data may be processed for the purposes of communicating with you and record-keeping. The legal basis for this processing is our legitimate interests, namely the proper administration of our website and business and communications with users.
2.9 We may process any of your personal data identified in this policy where necessary for the establishment, exercise or defence of legal claims, whether in court proceedings or in an administrative or out-of-court procedure. The legal basis for this processing is our legitimate interests, namely the protection and assertion of our legal rights, your legal rights and the legal rights of others.
2.10 We may record calls to enable us to double-check information, to ensure our quality of customer communication is of an acceptable standard and for ongoing training purposes.
2.11 In addition to the specific purposes for which we may process your personal data set out in this Section 2, we may also process any of your personal data where such processing is necessary, for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person.
2.12 By supplying your telephone number, you agree to Stiltz making reasonable telephone contact to service your enquiry and provider suitable and reasonable product advice via the telephone. You can at any time review and reverse this by requesting that we no longer contact you.
2.13 Please do not supply any other person’s personal data to us, unless we prompt you to do so or unless it is required in order for us to discharge our contractual obligations to you.
3. Providing your personal data to others
3.1 We may disclose your personal data to any member of our group of companies (this means our subsidiaries, our ultimate holding company and all its subsidiaries) insofar as reasonably necessary for the purposes, and on the legal bases, set out in this policy.
3.2 We may disclose your personal data to our insurers and/or professional advisers insofar as reasonably necessary for the purposes of managing risks, obtaining professional advice, or the establishment, exercise or defence of legal claims, whether in court proceedings or in an administrative or out-of-court procedure].
3.3 We may disclose names, phone numbers email addresses and postal addresses to our trusted/approved suppliers, agents or subcontractors insofar as reasonably necessary for sales advice, building works or installation or any other related activity, to take place. These may include but not be limited to electrical contractors, builders, third party installers (where used), surveyors and building control administration partners.
4. International transfers of your personal data
4.1 In this Section 4, we provide information about the circumstances in which your personal data may be transferred to countries outside the European Economic Area (EEA).
4.2 We have offices and distributors in a number of non-EEA locations. The European Commission has made an “adequacy decision” with respect to the data protection laws of each of these countries. Transfers to each of these countries will be protected by appropriate safeguards, namely the use of standard data protection clauses adopted or approved by the European Commission.
4.3 Where an enquiry is received via the Stiltz website from an overseas prospect, we will electronically transmit the information from that enquiry to the relevant overseas market to enable the local office to respond.
4.4 You acknowledge that personal data that you submit for publication through our website or services may be made available via electronic transmission to offices in the country where you reside or to offices of the country responsible for the territory in which you reside. Once transmitted, we in the UK cannot prevent the use (or misuse) of such personal data by others as the data is subject to local jurisdiction.
4.5 Please note that Epsilon Abacus may transfer data outside the EEA. The transfer will take place in the presence of appropriate safeguards, including standard data protection clauses adopted by the EU Commission. If you would like more information, please call us on 0330 222 0334, write to us at our address below or email us at email@example.com
5. Retaining and deleting personal data
5.1 This Section 5 sets out our data retention policies and procedure, which are designed to help ensure that we comply with our legal obligations in relation to the retention and deletion of personal data.
5.2 Personal data that we process for any purpose or purposes shall not be kept for longer than is necessary for that purpose or those purposes.
5.3 We will retain your personal data as follows:
(a) Personal data will be retained for a minimum period of 3 years following date of receipt and for a maximum period of until you advise us you wish your personal data to be deleted.
5.4 In some instances it is not possible for us to specify in advance the periods for which your personal data will be retained. In such cases, we will determine the period of retention based on the following criteria:
(a) the period of retention of customer data (those who have purchased a product) will be determined based on business need and the need to potentially advise of any product recalls or similar.
(b) the period of retention of prospect data will be determined by historical evidence of the sales cycle for our products being longer than many other sales cycles and as such will be a minimum of three (3) years
5.5 Notwithstanding the other provisions of this Section 5, we may retain your personal data where such retention is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person.
6.1 We may update this policy from time to time by publishing a new version on our website.
6.2 You should check this page occasionally to ensure you are happy with any changes to this policy.
6.3 We may notify you of changes to this policy by email via our email distribution software system.
7. Your rights
7.1 You may instruct us to provide you with any personal information we hold about you; provision of such information will be subject to the supply of appropriate evidence of your identity presented in person to an authorised employee of Stiltz Ltd. For this purpose, we will usually accept an original or a photocopy of your passport or driving license certified by a solicitor or bank, plus an original copy of a utility bill showing your current address and being no older than three (3) months.
7.2 We may withhold personal information that you request to the extent permitted by law.
7.3 You may instruct us at any time not to process your personal information for marketing purposes.
7.4 You have the right to have any inaccurate personal data about you rectified and, taking into account the purposes of the processing, to have any incomplete personal data about you completed.
7.5 In practice, you will usually either expressly agree in advance to our use of your personal information for marketing purposes, or we will provide you with an opportunity to opt out of the use of your personal information for marketing purposes.
7.6 You have the right to object to our processing of your personal data for direct marketing purposes (including profiling for direct marketing purposes). If you make such an objection, we will cease to process your personal data for this purpose.
7.7 You have the right to object to our processing of your personal data for scientific or historical research purposes or statistical purposes on grounds relating to your particular situation, unless the processing is necessary for the performance of a task carried out for reasons of public interest.
7.8 If you consider that our processing of your personal information infringes data protection laws, you have a legal right to lodge a complaint with a supervisory authority responsible for data protection. You may do so in the EU member state of your habitual residence, your place of work or the place of the alleged infringement.
7.9 To the extent that the legal basis for our processing of your personal information is consent, you have the right to withdraw that consent at any time. Withdrawal will not affect the lawfulness of processing before the withdrawal.
8. About cookies
8.1 A cookie is a file containing an identifier (a string of letters and numbers) that is sent by a web server to a web browser and is stored by the browser. The identifier is then sent back to the server each time the browser requests a page from the server.
8.2 Cookies may be either “persistent” cookies or “session” cookies: a persistent cookie will be stored by a web browser and will remain valid until its set expiry date, unless deleted by the user before the expiry date; a session cookie, on the other hand, will expire at the end of the user session, when the web browser is closed.
8.3 Cookies do not typically contain any information that personally identifies a user, but personal information that we store about you may be linked to the information stored in and obtained from cookies.
9. Cookies that we use
10. Cookies used by our service providers
11. Managing cookies
11.1 Most browsers allow you to refuse to accept cookies and to delete cookies. The methods for doing so vary from browser to browser, and from version to version. You can however obtain up-to-date information about blocking and deleting cookies via these links:
(d) https://support.microsoft.com/en-gb/help/17442/windows-internet-explorer-delete-manage-cookies (Internet Explorer);
(e) https://support.apple.com/kb/PH21411 (Safari); and
11.2 Blocking all cookies will have a negative impact upon the usability of many websites.
11.3 If you block cookies, you will not be able to use all the features on our website.
12. Our details
12.1 This website is owned and operated by Stiltz Ltd
12.2 We are registered in [England and Wales] under registration number 07375515 and our registered office is at Building 5, Bay 1, First Avenue, Pensnett Estate, Kingswinford. DY6 7TE
12.3 Our principal place of business is at Building 5, Bay 1, First Avenue, Pensnett Estate, Kingswinford. DY6 7TE
12.4 You can contact us:
(a) by post, to the postal address given above;
(b) using our website contact form;
(c) by telephone, on the contact number published on our website
(d) by email, using the email address published on our website