Privacy Policy

Privacy Notice

Effective Date: from 25 May 2018

This Privacy Notice explains how The Harboro Rubber Co Limited collect, use and disclose your personal data, and your rights in relation to the personal data we hold.

In this Privacy Notice, “us”, “we” and “our” is the data controller of your personal data and is subject to the EU General Data Protection Regulation 2016/679 (the “GDPR”) and any locally applicable data protection laws.

Your rights

 Under the GDPR you have the following rights:

• To obtain access to, and copies of, the personal data that we hold about you;
• To require that we cease processing your personal data if the processing is causing you damage or distress;
• To require us not to send you marketing communications;
• To require us to erase your personal data;
• To require us to restrict our data processing activities;
• To receive from us the personal data we hold about you which you have provided to us, in a reasonable format specified by you, including for the purpose of you transmitting that personal data to another data controller; and
• To require us to correct the personal data we hold about you if it is incorrect.

Please note that the above rights are not absolute, and we may be entitled to refuse requests where exceptions apply.

You can find out more about your rights at www.ico.org.uk.

How we collect your data

We collect your personal data in a number of ways, for example:

• From the information you provide to us when you meet us;
• From information about you provided to us by your company or an intermediary;
• When you communicate with us in writing, by telephone, fax, website, email or other forms of electronic communication. In this respect, we may monitor, record and store any such communication;
• When you complete (or we complete on your behalf) account application or other introductory forms;
• From publicly available sources or from third parties.

The categories of personal data we collect

 We collect the following categories of personal data about you:

Your name and contact information such as your business address, job title, email address and telephone number;

The basis for processing your personal data (other than with your consent), how we use that personal data and whom we share it with

(i) Performance of a contract

We process your personal data because it is necessary for the performance of a contract to which you or the company you are employed by are a party to or in order to take steps at your request prior to entering into a contract.

In this respect, we use your personal data for the following:

• To prepare a quotation for you regarding the goods or services we offer;
• To provide you with the goods or services as set out in our quotation or as otherwise agreed with you from time to time;
• To make enquiries concerning goods or services we may require;
• To provide us with goods and services which we may order or as otherwise agreed with you from time to time.
• To deal with any associated correspondence, complaints or feedback;
• For any other purpose for which you provide us with your personal data.

In this respect, we may share your personal data with or transfer it to the following:

• Third parties whom we engage to assist in delivering goods or services to you.
• Our professional advisers where it is necessary for us to obtain their advice or assistance, including lawyers, accountants, IT, insurers or public relations advisers;
• Debt collection agencies where it is necessary to recover money owed to us;
• Other third parties such as intermediaries who we introduce to you. We will wherever possible tell you who they are before we introduce you;
• Our data storage providers.

(ii) Legitimate interests

We also process your personal data because it is necessary for our legitimate interests.

• For marketing to you. In this respect, see the separate section on Marketing below;
• Training our staff or monitoring their performance;
• For the administration and management of our business and archiving or statistical analysis;

In this respect we will share your personal data with the following:

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• Our advisers or agents where it is necessary for us to obtain their advice or assistance;

(iii) Legal obligations

We also process your personal data for our compliance with a legal obligation which we are under.

In this respect, we will use your personal data for the following:

• To meet our compliance and regulatory obligations, such as compliance with tax authorities, any competent court or legal authority or anti-money laundering laws;

In this respect, we will share your personal data with the following:

• Our advisers where it is necessary for us to obtain their advice or assistance;
• Our auditors where it is necessary as part of their auditing functions;
• With third parties who assist us in conducting background checks;
• With relevant regulators or law enforcement agencies where we are required to do so.

Marketing

We will send you marketing about goods and services we provide which may be of interest to you, as well as other information in the form of alerts, newsletters and invitations to events or functions which we believe might be of interest to you or in order to update you with information (such as exhibition or innovative technical news) which we believe may be relevant to you.

We will communicate this to you in a number of ways including by post, telephone, email or other digital channels.

If you object to receiving marketing from us at any time, please contact us:

By post: The Data Officer, The Harboro Rubber Co Ltd, Riverside, Market Harborough, LE16 7PZ

By email: dataofficer@harboro.co.uk

By telephone: +44 (0)1858 410 610

To withdraw your consent at any time, please use the same contact.

Transfer and processing of your personal data outside the European Union

When sharing your personal data with third parties as set out in this Privacy Notice, it may be transferred outside the European Union. In these circumstances, your personal data will only be transferred on one of the following bases:

• The country that we send the personal data to is approved by the European Commission as providing an adequate level of protection for personal data;
• The transfer is to a recipient in the United States of America who has registered under the EU/US Privacy Shield;
• The recipient has entered into European Commission standard contractual clauses with us; or
• You have explicitly consented to the same.

Retention of your data

We will only retain your personal data for a period of seven years after the termination of our contractual or other relationship with you in case any claims arise out of the provision of our goods or services to you.

Concerns

If you have any questions about how we use your personal data, or you wish to exercise any of the rights set out above, please contact:

By post: The Data Officer, The Harboro Rubber Co Limited, Riverside, Market Harborough, Leicestershire LE16 7PZ

By email: dataofficer@harboro.co.uk

By telephone: +44 (0)1858 410 610

This Privacy Notice supersedes any previous Privacy Notice or equivalent which you may have been provided with or seen prior to the Effective Date stated above.

If you are not satisfied with how we are processing your personal data, you can make a complaint to www.ico.org.uk.

Third Party Processors

Our carefully selected partners and service providers may process personal information about you on our behalf as described below:

Digital Marketing Service Providers
We periodically appoint digital marketing agents to conduct marketing activity on our behalf, such activity may result in the compliant processing of personal information. Our appointed data processors include:
(i) Prospect Global Ltd (trading as Sopro) Reg. UK Co. 09648733. You can contact Sopro and view their privacy policy here:http://sopro.io. Sopro is registered with the ICO Reg: ZA346877 their Data Protection Officer can be emailed at: dpo@sopro.io.