Last updated: 31st July 2018
This privacy notice tells you what to expect when GWP Group collects your personal information.
GWP Group Ltd is committed to protecting and respecting your privacy. This policy sets out the basis on which any personal information we collect from you, or that you provide to us, will be processed by us.
Please read the following carefully to understand our views and practices regarding your personal information and how we will treat it.
Please use the table of contents below to jump to a particular area of interest.
Alternatively, please contact us on 01793 754 444 or email@example.com should you have any questions or concerns regarding GWP Groups’ processing of your data.
1: Quick Guide / Summary
It avoids using legal terms where possible, and covers the key points of how and why we process your data, how it is used for marketing communications, and how you can object to this.
However, if you have any questions after reading this section and the extended policy below, please contact us on 01793 754 444 or email firstname.lastname@example.org.
1.2: GWP Group may collect the following information from you when you use our website
(a) search terms you have used to either find our website or used on our website
(b) a record of all browsing behaviour including links clicked, pages viewed, downloads, forms completed etc. This is done via a cookie which is set on your first interaction with our website and the contents of any form you submit to us.
(c) information disclosed by you that will help us contact you in the future like: name, company name, address, phone and email.
(d) information disclosed by you that will help us tailor the content and communications we provide to you, such as: industry sector, job role, product interest and geographical location.
(e) information on engagement with the emails and marketing communication you receive from us.
1.3: GWP will not collect:
(a) Information about your website browsing outside of our own domains (namely www.gwp.co.uk)
(b) Personal information relating to you and your private life, such as gender, age, date of birth, race etc.
(c) Any payment details, passwords or other sensitive data of this nature
(d) Any information identifying or relating to any persons under the age of 18
1.4: GWP Group may append information freely available from third party sources to the data you submit to us. This may include company data such as turnover, number of employees, office locations etc. It will not include any personal information relating to your private life.
1.5: The data that GWP Group collects will be used to:
(a) Improve the content and relevance of the marketing communications we send to you
(b) Help improve the content we display on our website, including personalisation of the content you see
(c) Respond to and answer any questions you may have submitted, such as requests for pricing or product information
(d) Provide you with any downloadable guides or resources you may have requested
(e) Publish advertising on third party websites related to the products / services you have expressed an interest in
(f) Ensure we remain compliant under the terms of the GDPR.
1.6: The legal basis for the processing of the data as detailed in sections 1.1, 1.3 and 1.4 is our legitimate interests, namely the proper administration of our website and business, and direct marketing.
GWP Group have carried out a Legitimate Interest Assessment (LIA) and Privacy Impact Assessment (PIA) to ensure this does not affect your rights or privacy.
1.7: We only store data on our own UK based, managed secure environment, and on SendinBlue (a secure, third party service provider). SendinBlue’s servers are based within the EU, and are fully compliant with GDPR and other applicable legislation. More info can be found on the SendinBlue website at: www.sendinblue.com/legal/privacypolicy/
1.8: As mentioned in 1.5, we will use any business details you submit to send you follow up marketing communications. This may be emails, text messages, phone calls or other forms of communication.
By submitting your information into one of GWP Group data capture forms you are confirming the following:
(a) you are doing so in your capacity as a representative of a company.
(b) you are over 18 years of age.
(c) you are accepting the relevance of the GWP Group products and services to the business interests of your company.
(d) you are providing contact information that will facilitate the communication between GWP Group and your company only.
1.9: If we identify that contact details appear to be non business related (for example, use of hotmail and gmail email addresses) then we will use the supplied details to fulfil your specific request only. This could include providing a quote or sending a free resource such as a PDF.
Upon fulfilment of the request, your personal details will be removed from our system, and you will not receive any follow up marketing communications unless you actively consent to further contact.
1.10: You can also contact GWP Group at any time to ask that we do not process and / or contact you using the information you have supplied.
(a) by using the unsubscribe links present on all emails and electronic communication that we send
(b) by post, by writing to Data Controller, GWP Group, Unit 20 Chelworth Park, Cricklade, Wiltshire SN6 6HE
(c) using our website contact form;
(d) by telephone, on 01793 754 444; or
(e) by email, using email@example.com.
Your request will be actioned within 28 days of its receipt (unless using the unsubscribe link in which case the request will be actioned immediately). You must include your name and email address for us to ensure its removal.
1.11: GWP will retain your information for differing lengths of time depending on your interaction with our business.
(a) For existing customers of GWP Group, we will retain your data indefinitely. Your details will be used for financial reporting, accounts and marketing purposes.
(b) For individuals associated with a business (identified by using a business email address) making an enquiry or requesting to download information and resources from the GWP website, we will retain your data, and use it for marketing purposes for a maximum of 24 months from the last time you engage with our communications and / or website.
(c) For individuals not associated with a business (identified primarily by not using a business email address) making an enquiry or requesting to download information and resources from the GWP website, we will use your data to fulfil the request only. We will not retain your data beyond the time it takes to satisfy your specific request, unless you actively consent to further communications.
1.12 GWP Group will only pass on the personal information collected if we have a legal obligation to do so. We will not sell your information or share it with any Third Parties.
2: General Information
2.1: We are committed to safeguarding the privacy of our website visitors and service users.
2.2: This policy applies where we are acting as a data controller with respect to the personal data of our website visitors and service users; in other words, where we determine the purposes and means of the processing of that personal data.
2.4: Our website incorporates privacy controls which affect how we will process your personal data. By using the privacy controls, you can specify whether you would like to receive direct marketing communications and limit the publication of your information. You can access the privacy controls via the links present on every email GWP Group will send to you.
2.5: In this policy, “we”, “us” and “our” refer to GWP Group Limited. For more information about us, see Section 18.
3: How we use your personal data
3.1: In this Section 3 we have set out:
(a) the general categories of personal data that we may process;
(b) in the case of personal data that we did not obtain directly from you, the source and specific categories of that data;
(c) the purposes for which we may process personal data; and
(d) the legal bases of the processing.
3.2: 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 use of the GWP Group website. The source of the usage data is our analytics tracking systems, Google Analytics and Hubspot. 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.
3.3: We may process your personal data (“personal data“). The personal data may include your name, telephone number, email address, company name, postal address and job title. The source of the personal data is you or your employer. The personal data may be processed for the purposes of operating our website, providing our services, ensuring the security of our website and services, maintaining back-ups of our databases and communicating with you. The legal basis for this processing is our legitimate interests, namely the proper administration of our website and business and direct marketing.
3.4: We may process your service data that are provided in the course of the use of our online ordering services (“service data“). The service data may include your name, (business) address, telephone number and email address. The source of the service data is you or your employer. The service data may be processed for the purposes of operating our website, providing our services, ensuring the security of our website and services, maintaining back-ups of our databases and communicating with you. 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.
3.5: 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 our legitimate interests, namely the proper administration of our website and business and direct marketing.
3.6: 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 our legitimate interests, namely the proper administration of our website and business and direct marketing.
3.7: 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.
3.8: 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.
3.9: We may process any of your personal data identified in this policy where necessary for the purposes of obtaining or maintaining insurance coverage, managing risks, or obtaining professional advice. The legal basis for this processing is our legitimate interests, namely the proper protection of our business against risks.
3.10: In addition to the specific purposes for which we may process your personal data set out in this Section 3, 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.
3.11: Please do not supply any other person’s personal data to us, unless we prompt you to do so.
4: Automated decision making
4.1: We will use your personal data for the purposes of automated decision-making in relation to the content we display to you on the GWP Group website, and the types of marketing communications we send to you.
4.2: This automated decision-making will involve analysis of information you provide to us, including product interests (which may be signified by browsing behaviour, downloads etc.), geographical location, job role / title, industry sector and so on.
4.3: The significance and possible consequences of this automated decision-making are that the content made available to you should be more closely aligned with your interests and requirements.
Please note that no information or resources on the GWP Group website will be made unavailable to you as a result of this profiling.
5: Providing your personal data to others
5.1: 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.
5.2: We may disclose your business details to our suppliers or subcontractors insofar as reasonably necessary for the performance of a contract between you and us and/or taking steps, at your request, to enter into such a contract.
5.3: In addition to the specific disclosures of personal data set out in this Section 4, we may disclose your personal data where such disclosure 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. We may also disclose your personal data where such disclosure is necessary for the establishment, exercise or defence of legal claims, whether in court proceedings or in an administrative or out-of-court procedure.
5.4: GWP Group will never share or sell your data with any third parties not specified within this Section 5.
6: International transfers of your personal data
6.1: GWP Group Ltd will not transfer any of your data to countries outside the European Economic Area (EEA).
6.2: The hosting facilities for our website are situated in the United Kingdom.
6.3: We use a third party service, SendinBlue, for processing of data for marketing purposes (see section 3). SendinBlues servers are based within the EU (Paris, France), and so are governed by the provisions set out in the GDPR.
6.4: GWP Group Ltd’s servers and network infrastructure is based within the United Kingdom.
7: Retaining and deleting personal data
7.1: This Section 7 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.
7.2: 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.
7.3: We will retain your personal data as follows:
(a) personal and contact details, submitted by yourself in order to download a resource will be retained for a minimum period of 3 months following their submission on the GWP Group website, and for a maximum period of 24 months following any period of inactivity; and
(b) details relating to any GWP Group customer will be retained indefinitely, unless you request for us to delete them.
7.4: The exception to section 7.3 is when personal data submitted is identified as not being associated with a business. In this instance, the data will be retained for a period long enough to fulfil the request, and will then be deleted (usually within 28 days).
7.5: Notwithstanding the other provisions of this Section 7, 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.
8: Security of personal data
8.1: We will take appropriate technical and organisational precautions to secure your personal data and to prevent the loss, misuse or alteration of your personal data.
8.2: We will store all your personal data on secure servers, personal computers and mobile devices, and in secure manual record-keeping systems.
8.3: The following personal data will be stored by us in encrypted form: your name, contact information and (if an existing customer) financial information relating to historical purchases made with GWP Group Ltd.
8.4: Data that is sent from your web browser to our web server, or from our web server to your web browser, will be protected using encryption technology.
8.5: You acknowledge that the transmission of unencrypted (or inadequately encrypted) data over the internet is inherently insecure, and we cannot guarantee the security of data sent over the internet.
8.6: For specific information on SendinBlue data storage and encryption, please view their guidelines at www.sendinblue.com/legal/privacypolicy/
9.1: We may update this policy from time to time by publishing a new version on our website.
9.2: You should check this page occasionally to ensure you are happy with any changes to this policy.
10: Your Rights
10.1: In this Section 10, we have summarised the rights that you have under data protection law. Some of the rights are complex, and not all of the details have been included in our summaries. Accordingly, you should read the relevant laws and guidance from the regulatory authorities for a full explanation of these rights.
10.2: Your principal rights under data protection law are:
(a) the right to access;
(b) the right to rectification;
(c) the right to erasure;
(d) the right to restrict processing;
(e) the right to object to processing;
(f) the right to data portability;
(g) the right to complain to a supervisory authority; and
(h) the right to withdraw consent.
10.3: You have the right to confirmation as to whether or not we process your personal data and, where we do, access to the personal data, together with certain additional information. That additional information includes details of the purposes of the processing, the categories of personal data concerned and the recipients of the personal data. Providing the rights and freedoms of others are not affected, we will supply to you a copy of your personal data. The first copy will be provided free of charge, but additional copies may be subject to a reasonable fee.
10.4: 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.
10.5: In some circumstances you have the right to the erasure of your personal data without undue delay. Those circumstances include: the personal data are no longer necessary in relation to the purposes for which they were collected or otherwise processed; you withdraw consent to consent-based processing; you object to the processing under certain rules of applicable data protection law; the processing is for direct marketing purposes; and the personal data have been unlawfully processed. However, there are exclusions of the right to erasure. The general exclusions include where processing is necessary: for exercising the right of freedom of expression and information; for compliance with a legal obligation; or for the establishment, exercise or defence of legal claims.
10.6: In some circumstances you have the right to restrict the processing of your personal data. Those circumstances are: you contest the accuracy of the personal data; processing is unlawful but you oppose erasure; we no longer need the personal data for the purposes of our processing, but you require personal data for the establishment, exercise or defence of legal claims; and you have objected to processing, pending the verification of that objection. Where processing has been restricted on this basis, we may continue to store your personal data. However, we will only otherwise process it: with your consent; for the establishment, exercise or defence of legal claims; for the protection of the rights of another natural or legal person; or for reasons of important public interest.
10.7: You have the right to object to our processing of your personal data on grounds relating to your particular situation, but only to the extent that the legal basis for the processing is that the processing is necessary for: the performance of a task carried out in the public interest or in the exercise of any official authority vested in us; or the purposes of the legitimate interests pursued by us or by a third party. If you make such an objection, we will cease to process the personal information unless we can demonstrate compelling legitimate grounds for the processing which override your interests, rights and freedoms, or the processing is for the establishment, exercise or defence of legal claims.
10.8: 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.
10.9: To the extent that the legal basis for our processing of your personal data is:
(a) consent; or
(b) that the processing is necessary for the performance of a contract to which you are party or in order to take steps at your request prior to entering into a contract, or
(c) our Legitimate Interests as set out in Section 3
and such processing is carried out by automated means, you have the right to receive your personal data from us in a structured, commonly used and machine-readable format. However, this right does not apply where it would adversely affect the rights and freedoms of others.
10.10: 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.
10.11: 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.
10.12: You may exercise any of your rights in relation to your personal data by written notice to us, in addition to the other methods specified in this Section 9.
11: Third party websites
11.1: Our website includes hyperlinks to, and details of, third party websites.
11.2: We have no control over, and are not responsible for, the privacy policies and practices of third parties.
12: Personal data of children
12.1: Our website and services are targeted at persons over the age of 18.
12.2: If we have reason to believe that we hold personal data of a person under that age in our databases, we will delete that personal data.
13: Updating information
13.1: Please let us know if the personal information that we hold about you needs to be corrected or updated.
14: Acting as a data processor
14.1: In respect of data appended to your contact details by Hubspot (for example Company name, geographical location etc.), we do not act as a data controller; instead, we act as a data processor.
14.2: Insofar as we act as a data processor rather than a data controller, this policy shall not apply. Our legal obligations as a data processor are instead set out in the contract between us and the relevant data controller.
15: Our details
15.1: This website is owned and operated by GWP Group Limited.
15.2: We are registered in England and Wales under registration number 05459368, and our registered office is at Unit 20 Chelworth Park Industrial Estate, Chelworth Road, Cricklade, Wiltshire, SN6 6HE.
15.3: Our principal place of business is at Unit 20 Chelworth Park Industrial Estate, Chelworth Road, Cricklade, Wiltshire, SN6 6HE.
15.4: You can contact us:
(a) by post, to the postal address given above;
(b) using our website contact form;
(c) by telephone, on 01793 754 444; or
(d) by email, using firstname.lastname@example.org.
16: Data protection registration
16.1: We are registered as a data controller with the UK Information Commissioner’s Office.
16.2: Our data protection registration number is Z2729638.
17: Data protection officer
17.1: GWP Group Limited are not required by law to have a Data Protection Officer. However, to discuss any privacy or data processing concerns you may have, you can contact GWP Group using the details in Section 15.4
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