Privacy statement

Interflon (UK) Limited – Privacy Policy

Interflon (UK) Limited manufacturers high performance lubricants, cleaners and hardware. Our products reduce maintenance costs, power consumption and CO2 emissions whilst promising component reliability and factory output. In our work we are eligible with personal data, which we treat with great care.

Interflon (UK) Limited respects your privacy and is committed to protecting your personal data. This privacy policy will inform you as to how we look after your personal data when you visit our online easy ordering system and/or our website (regardless of where you visit it from) and tell you about your privacy rights and how the law protects you.

Important information and who we are

Purpose of this privacy policy

This privacy policy gives you information about how Interflon (UK) Limited collects and processes your personal data through your provision of that data to us and your use of our online easy ordering system and/or our website, including any data you may provide when you register with us, purchase a product or service, take part in a survey, or contact us.

To process our work quickly and efficiently and to optimise our services to you, we process personal data.

This online easy ordering system nor the website is intended for children, and we do not knowingly collect data relating to children.

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

Contacts

Who is the Controller and Data Protection Officer

Interflon (UK) Limited is the controller and responsible for your personal data (collectively referred to as Interflon (UK) Limited, Interflon (UK), Interflon, "we", "us" or "our" in this privacy policy). We are the ‘data controller’ for your personal data under the applicable legislation and it is primarily responsible for processing and ensuring proper protection of your data. We may collect and process data from EEA and UK residents online.

This means that we are responsible for deciding how we hold and use personal information about you. We are required under data protection legislation to notify you of the information contained in this privacy policy.

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

We have appointed a data protection administrator (DPA) who is responsible for overseeing questions in relation to this privacy policy. If you have any questions about this privacy policy, including any requests to exercise your legal rights, please contact the DPA using the information set out in the contact details section below.

Contact details

If you have any questions about this privacy policy or our privacy practices, please contact our DPA in the following ways:

Position: Data Protection Administrator

Email address: [email protected]

Postal address: Interflon (UK) Limited, Crofton House, Crofton Road, Stockton on Tees TS18 2QZ

Telephone number: 01642 615002

You have the right to make a complaint at any time to 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.

Changes to the privacy policy and your duty to inform us of changes

We keep our privacy policy under regular review. We request that you read the privacy policy regularly, so that you are kept informed of the current content.

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.

Third-party links

Our ordering system and our website may include links to third-party websites, systems, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites, systems or applications and are not responsible for their privacy statements. When you leave our ordering system and/or our website, we encourage you to read the privacy policy of every website/system/application you visit.

1. The types of personal data we collect about you

Personal data or personal information 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).

We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:

• Identity Data includes name (or similar identifier), marital status, title, date of birth and gender.
• Contact Data includes billing address, delivery address, email address and telephone numbers.
• Financial Data includes bank account and payment card details.
• Transaction Data includes details about payments to and from you and other details of products and services you have purchased from us.
• Technical Data includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, device ID and other technology on the devices you use to access our ordering system and/or our website.
• Profile Data includes your username and password, purchases or orders made by you, your interests, preferences, feedback and survey responses.
• Usage Data includes information about how you interact with and use our ordering system, website, products and services.
• Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.
• Location Data may include your location, the location of your device or where the facility that serves you is located.

We also collect, use and share aggregated data such as statistical or demographic data which is not personal data as it does not directly (or indirectly) reveal your identity. For example, we may aggregate individuals' Usage Data to calculate the percentage of users accessing a specific website feature in order to analyse general trends in how users are interacting with our ordering system or our website to help improve the ordering system and/or website and our service offering. Aggregated Data could be derived from your personal data but is not considered personal data in law as this data will not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific ordering system feature or a specific website feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy policy.

We do not collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health, and genetic and biometric data). Nor do we collect any information about criminal convictions and offences.

If you fail to provide personal 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.

2. How is your personal data collected?

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

• Your interactions with us. You may give us your personal data by filling in online forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you complete orders on our online easy ordering system or our website:
• apply for our products or services;
• create an account on our website and/or our ordering system;
• 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.
• Automated technologies or interactions. As you interact with our online ordering system or with our website, we will automatically collect Technical Data about you, your equipment, browsing actions and patterns. We collect this personal data by using cookies and other similar technologies. We also collect data from our general inline payment portal.
• 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 is collected from the following parties:
• analytics providers;
• advertising networks; and
• search information providers.
• Contact, Financial and Transaction Data is collected from providers of technical, payment and delivery services including Sage and Opayo.
• Identity and Contact Data is collected from data brokers or aggregators.
• Identity and Contact Data is collected from publicly available sources.

3. How we use your personal data

Legal basis

The law requires us to have a legal basis for collecting and using your personal data. We rely on one or more of the following legal bases:

• Performance of a contract with you: Where we need to perform the contract we are about to enter into or have entered into with you.
• Legitimate interests: We may use your personal data where it is necessary to conduct our business and pursue our legitimate interests, for example to prevent fraud and enable us to give you the best and most secure customer experience. We make sure we consider and balance any potential impact on you and your rights (both positive and negative) before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law).
• Legal obligation: We may use your personal data where it is necessary for compliance with a legal obligation that we are subject to. We will identify the relevant legal obligation when we rely on this legal basis.
• Consent: We rely on consent only where we have obtained your active agreement to use your personal data for a specified purpose, for example if you subscribe to an email newsletter.

Purposes for which we will use your personal data

We have set out below, in a table format, a description of all the ways we plan to use the various categories of your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.

Marketing

We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising.

Promotional offers from us

We may use your Identity, Contact, Technical, Usage and Profile Data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which products, services and offers may be relevant for you (we call this marketing).

You will receive marketing communications from us if you have requested information from us or purchased goods from us and you have not opted out of receiving that marketing.

Third-party marketing

We will get your express consent before we share your personal data with any third party for their own direct marketing purposes.

Opting out of marketing

You can ask that we stop sending you marketing communications at any time.

Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of a product/service purchase, warranty registration, product/service experience or other transactions.

Cookies

We use cookies on our website as well as our ordering system. A cookie is a simple small file with information about your visit that is sent along with the pages of our website and our ordering system. These cookies are stored on your hard drive. We use these cookies to ensure that our website and our ordering system functions correctly.

Cookies from Google are also placed on our website and our ordering system as part of the "Analytics" service. We use this service to keep track of and get reports on how visitors use the website and ordering system. Google may provide this information to third parties if Google is legally required to do so, or insofar as third parties process the information on Google's behalf. We have no influence on this. The information that Google collects is made anonymous as much as possible. Your IP address is explicitly not given. The information is transferred to Google.

You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of this website and ordering system may become inaccessible or not function properly.

Change of purpose

We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.

If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.

Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

4. Disclosures of your personal data

We may share your personal data where necessary with the parties set out below:

• Internal and external third parties including suppliers for the purpose of delivering any goods to you and professional advisors of Interflon (UK) Limited.
• External third parties including suppliers for the purpose of obtaining payment and delivering any goods to you, including any professional advisors of Interflon (UK) Limited;
• Our group and associated companies including Interflon B.V.
• 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.

5. International transfers

We share your personal data within the Interflon Group. This may involve transferring your data outside the UK and the European Economic Area (EEA).

Some of our third-party service provided are based outside of the UK and/or the EEA so their processing of your personal information will involve a transfer of data outside the UK and/or the EEA.

Whenever we, or our partners transfer your personal data out of the UK to countries which have laws that do not provide the same level of data protection as the UK law, we always ensure that a similar degree of protection is afforded to it by ensuring that safeguards are implemented.

We may transfer your personal data to service providers that carry out certain functions on our behalf. This may involve transferring personal data outside the UK to countries which have laws that do not provide the same level of data protection as the UK law.

Whenever we transfer your personal data out of the UK to service providers, we ensure a similar degree of protection is afforded to it by ensuring that the following safeguards are in place:

• We will only transfer your personal data to countries that have been deemed by the UK to provide an adequate level of protection for personal data;
• We may use specific standard contractual terms approved for use in the UK which give the transferred personal data the same protection as it has in the UK.

Please contact us (on [email protected]) if you would like further information on the specific mechanism used by us when transferring your personal information out of the UK and/or the EEA.

6. Data security

We treat personal data with care and treat it confidentially. 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.

7. Closure

If you think you have found a weak spot in one of our (digital) services, or you can view or access confidential information such as personal data (data breach), then we would like to work with you to resolve this situation.

8. Data retention

How long will you use my personal data for?

We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. 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.

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.

At the end of a client contract to provide goods or services, we may share your personal data as part of the staff transfer process. This may be with our client or any new service provider. We do this to minimise the impact of any change of service provider of the goods or services that our client uses. Any data sharing will be carried out in line with Data Sharing Code of Practice. We will document the data sharing and the controls we put in place to protect and respect your personal data.

9. Your Legal rights

You have a number of rights under data protection laws in relation to your personal data.

Under certain circumstances your rights are as follows:

Request access to your personal data (commonly known as a "data subject access request"). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.

Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.

Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.

Object to processing of your personal data 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.

Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios:

• If you want us to establish the data's accuracy.
• Where our use of the data is unlawful but you do not want us to erase it.
• 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.
• You have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.

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.

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.

If you wish to exercise any of the rights set out above, please contact us see Contact details above.

No fee usually required

You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we could refuse to comply with your request in these circumstances.

What we may need from you

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.

Time limit to respond

We try to respond to all legitimate requests within one month. Occasionally it could take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.

10. Glossary

Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give you the best service/product and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us.

Performance of Contract means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.

Comply with a legal obligation means processing your personal data where it is necessary for compliance with a legal obligation that we are subject to.