RSM Lining Supplies Global Ltd

Website and Mobile Application Privacy Policy (GDPR and DPA 2018) (UK)

September 2023

Introduction

RSM Lining Supplies Global Limited (RSM), a company incorporated (Company House Registration No 06412005), whose registered office is Unit 2 Connection Business Park Woodfield Way, Balby, Doncaster, South Yorkshire, England, DN4 8GE, provides a range of services and products which includes training, technical support, equipment hire, lining supplies, point repair, lining equipment, installation and curing methods.  Our website rsm-web.com provides more information on the services, products and systems available together with information regarding the company and its workforce.

RSM respects our users privacy and is committed to looking after your data.  This includes data it holds on employees; service users (and their representatives) and partner organisations. This policy has been developed taking into account the requirements of the General Data Protection Regulations which were issued in May 2018 and will be kept up to date as legislation changes.

This privacy notice for RSM Lining Supplies Global Limited (we, us or our) describes how and why we might collect, store, use and/or share (process) your information when you use our website or applications (services) such as when you:

• Visit our website https://www.rsm-web.com or any website of ours that links to this privacy notice;
• Download and use our mobile application (RSM) or any other application of ours that links to this privacy notice;
• Engage with us in other related ways, including any sales, marketing or events.

Reading this privacy notice will help you understand your privacy rights and choices  If you do not agree with our policies and practices, please do not use our services.  If you still have any questions or concerns, please contact us at Jayne Rowntree, Office Manager, jayne@rsm-web.com or 0330 043 9604.

Controller

RSM Lining Supplies Global Limited is the controller and responsible for your personal data (collectively referred to as “we”, “us” or “our” in this privacy policy).

We have appointed a data protection officer (DPO) 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 rights, please contact the DPO using the details set out below.

Contact details

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

Full name of legal entity: RSM Lining Supplies Global Ltd

Email address: jayne@rsm-web.com

Postal address: Unit 2 Connection Business Park, Woodfield Way, Balby, Doncaster, South Yorkshire, DN4 8GE

You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK supervisory authority 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. This version was last updated in September 2023.

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

This website may include links to third-party websites, 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 and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy policy of every website you visit.

1. The data we collect about you

We collect personal data, or personal information, that you voluntarily provide to us when you register, or express an interest in obtaining information about us, our products or our services, via our website or via our mobile application.

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

• Identity Data includes first name, last name, username or similar identifier, marital status, title, date of birth and gender.
• Contact Data includes home address; billing address, work address, delivery address, email address, mailing address, contact preferences 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 and contact or authentication data;.
• 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, and other technology on the devices you use to access this website.
• Social media login data includes any option you may choose to register with us using your existing social media account detail, like your Facebook, X (Twitter), Instagram, Threads or other social media account. If you choose to register in this way we will collect the information described in the section called “how do we handle your social media logins”
• 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 use our website, products and services.
• Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.

We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. 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 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.

Information Automatically collected

In short – some information such as your internet protocol (IP) address and/or browser and device characteristics, are collected automatically when you visit our website or app.

We automatically collect certain information when you visit, use or navigate the website or app.  This information does not reveal your specific identity (like your name or contact information) but may include device and usage information, such as your IP address, browser and device characteristics, operating system, language preferences, referring URLs, device name, country, location, information about how and when you use our website or services and other technical information.  This information is primarily needed to maintain the security and operation of our website/app and for our internal analytics and reporting purposes.

Information collected from other sources

In short – We may collect limited data from public databases, marketing partners, social media platforms and other outside sources.

In order to enhance our ability to provide relevant marketing, offers and services to you and update our records, we may obtain information about you from other sources, such as public databases, joint marketing partners, affiliate programmes, data providers, social media platforms, and from other third parties.  This information includes mailing addresses, job titles, email addresses, phone numbers, intent data (or user behaviour data) internet protocol, addresses, social media profiles, social medial URLs and custom profiles, for purposes of targeted advertising and event promotion.  If you interact with us on a social media platform using your social media account (eg Facebook, X (Twitter) or Instagram) we receive personal information about you such as your name, email address, and gender. Any personal information that we collect from your social media accounts depends on your social media account’s privacy settings.

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 process your personal information for a variety of reasons, depending on how you interact with our website/app including:

• To facilitate account creation and authentication and otherwise manage user accounts, we may process your information so you can create and log in to your account as well as keep your account in working order;
• To deliver and facilitate delivery of services to the users, we may process your information to provide you with the requested services
• To respond to user enquiries/offer support to users, we may process your information to respond to your enquires and solve any potential issues you might have with the requested service(s)
• To send administrative information to you, we may process your information to send you details about our products and services, changes to our terms and conditions or policies and other similar information,
• We fulfil and manage your orders, we may process your information to fulfil and manage your orders, payments, returns and exchanges made through the website or app
• To enable user to user communications we may process your information if you choose to use any of our offerings that allow for communication with another user
• To request feedback, we may process your information when necessary to request feedback and to contact you about your use of the services
• To send you marketing and promotional communications we may process the personal information you send to us for our marketing purposes, if this is in accordance with your marketing preferences
• You can opt out of our marketing emails at any time. For more information see What are our Privacy Rights.
• To deliver targeted advertising to you we may process your information to develop and display personalised content and advertising tailored to your interests, local and more
• To save or protect an individual’s vital interests we may process your information when necessary to save or protect an individual’s vital interests such as to prevent harm.

3. What legal basis do we rely on to process your information?

In you are located in the EU or UK, this section applies to you:

The General Data Protection Regulation (GDPR) and UK GDPR require us to explain the valid legal bases we rely on in order to process your personal information.  As such, we may rely on the following legal bases to process your personal information:

• Consent – we may process your information if you have given us permission (ie consent) to use your personal information for a specific purpose. You can withdraw your consent at any time
• Performance of a contract – we may process your personal information when we believe it is necessary to fulfil our contractual obligations to you, including providing our services or products to you via the website or app or at your request prior to entering into a contract with you.
• Legitimate interests -we may process your information when we believe it is reasonably necessary to achieve our legitimate interests and those interests do not outweigh your interests and fundamental rights and freedoms. For example we may process your personal information for some of the following purposes:
  • Send users information about special offers and discounts on our products and services
  • Develop and display personalised and relevant advertising content for our users
  • Understand how our users use our products and services so we can improve user experience.
• Legal obligations – we may process your information where we believe it is necessary for compliance with our legal obligations such as to cooperate with a law enforcement body or regulatory agency, exercise or defend our legal rights or disclose your information as evidence in litigation in which we are involved.
• Vital interests – we may process your information where we believe it is necessary to protect your vital interests or the vital interests of a third party, such as situations involving potential threats to the safety of a person.

If you are located in Canada this section applies to you:

We may process your information if you have given us specific permission (expressed consent) to use your personal information for a specified purpose or in situations where your permission can be inferred (implied consent). You can withdraw your consent at any time. In some exceptional cases we may be legally permitted under applicable law to process your information without your consent including for example:

• If collection is clearly in the interests of an individual and consent cannot be obtained in a timely way
• For investigations and fraud detection and prevention
• For business transactions provided certain conditions are met
• If it is contained in a witness statement and the collection is necessary to assess, process or settle an insurance claim
• For identifying injured, ill or deceased persons and communicating with their next of kin
• If we have reasonable grounds to believe an individual has been is or may be victim of financial abuse
• If it is reasonable to expect collection and use with consent would compromise the availability or the accuracy of the information and the collection is reasonable for purposes related to investigating a breach of an agreement or a contravention of the laws of Canada or a province
• If disclosure is required to comply with a subpoena, warrant, court order, or rules of the court relating to the production of records
• If it was produced by an individual in the course of their employment, business, or profession and the collection is consistent with the purposes for which the information was produced
• If the collection is solely for journalistic, artistic or literary purposes
• If the information is publicly available and is specified by the regulations

Third-party marketing

We may link our website and app to third-party marketing, websites, online services or mobile applications and/or contain advertisements from third parties that are not affiliated with us and which may link to other websites, services or applications.  Accordingly, we do not make any guarantee regarding any such third parties, and we will not be liable for any loss or damage caused by the use of such third-party websites, services or applications.  The inclusion of a link towards a third-party website, service or application does not imply an endorsement by us.  We cannot guarantee the safety and privacy of data you provide to any third party.  Any data collection by third parties is not covered by this privacy notice.  We are not responsible for the content or privacy and security practices and policies of any third parties, including other websites, services or applications that may be linked to or from the services.  You should review the policies of such third parties and contact them directly to respond to your questions.

4. Use of Cookies and Other tracking technologies

We may use cookies and similar tracking technologies, like web beacons and pixels, to access or store information.

5. Social Media Logins

Our website and app may offer you the ability to register and log in using your third-party social media account details, like your Facebook or Twitter account. Where you choose to do this, we will receive certain profile information about you from your social media provider.  The profile information we receive may vary depending on the social media provider concerned but will often include your name, email address, friends list, and profile information or picture, as well as other information you choose to make public on such a social media platform.

We will use the information we receive only for the purposes that are described in this privacy notice or that are otherwise made clear to you on the relevant website/application.  Please  note that we do not control and are not responsible for other uses of your personal information by your third-party social media provider.  We recommend that you review their privacy notice to understand how they collect, use and share your personal information and how you can set your privacy preferences on the sites and apps.

6. Opting out

You can ask us or third parties to stop sending you marketing messages at any time by logging into the website and checking or unchecking relevant boxes to adjust your marketing preferences or by following the opt-out links on any marketing message sent to you.

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.

7. 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.

8. Disclosures of your personal data

We may share your personal data with the parties set out below for the purposes.

• Internal Third Parties
• External Third Parties
• 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.

Whenever we transfer your personal data out of the EEA, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:

• We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data by the European Commission. For further details, see European Commission: Adequacy of the protection of personal data in non-EU countries.
• Where we use certain service providers, we may use specific contracts approved by the European Commission which give personal data the same protection it has in Europe. For further details, see European Commission: Model contracts for the transfer of personal data to third countries.
• Where we use providers based in the US, we may transfer data to them if they are part of the Privacy Shield which requires them to provide similar protection to personal data shared between Europe and the US. For further details, see European Commission: EU-US Privacy Shield.
• Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the EEA.

9. How long will we keep your information

We will only keep your personal information for as long as it is necessary of the purposes set out in this privacy notice, unless a longer retention period is required or permitted by law (such as tax, accounting or other legal requirements). No purpose in this notice will require us keeping your personal information for longer than six months past the start date of the idle period of the user’s account.

When we have no ongoing legitimate business need to process your personal information, we will either delete or anonymise such information or if this is not possible, for example because your personal information has been stored in backup archives, then we will securely store your personal information and isolate it from any further processing until deletion is possible.

10. Data security

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.

We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

11. Controls for Do Not Track Features

Most web browsers and some mobile operating systems and mobile applications include a Do Not Track (DNT) feature or setting you can activate to signal your privacy preference not to have data about your online browsing activities monitored and collected.  At this stage no uniform technology standard for recognising and implementing DNT signals has been finalised.  As such, we do not currently respond to DNT browser signals or any other mechanism that automatically communicates your choice not to be tracked online  If a standard for online tracking is adopted that we must follow in the future, we will inform you about that practice in a revised version of this privacy notice.

12. Your legal rights

Under certain circumstances if you live in the UK, EEA or Canada, you have rights under data protection laws in relation to your personal data.

If you wish to exercise any of the rights set out above, please contact us using the information on page 1 of this document.

If you are located in Switzerland, you may contact the Federal Data Protection and Information Commissioner.

If you are located in California USA, you are also granted specific rights regarding access to your personal information – California Civil Code Section 1798.83 also known as the Shine the Light law, permits our users who are California residents to request and obtain from us, once a year and free of charge, information about categories of personal information (if any) we disclosed to third parties for direct marketing purposes and the names and address of all third parties with which we shared personal information in the immediately preceding calendar year.  If you require any further information please contact us.

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.

13. Glossary

Lawful Basis

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.

THIRD PARTIES

Internal Third Parties

Other companies who we work with and who are based in the UK and provide for example HR, IT and system administration services and undertake leadership reporting.

External Third Parties

• HM Revenue & Customs, regulators and other authorities acting as processors or joint controllers based in the United Kingdom who require reporting of processing activities in certain circumstances.

YOUR LEGAL RIGHTS

You have the right to:

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.

Account information

If you would at any time like to review or change your information in your account or terminate your account you can either log in to your account settings and update your user account or contact us directly to request your account be terminated.  We will deactivate your account or delete your account and information from our active databases. However, we may retain some information in our files to prevent fraud, troubleshoot problems, assist with any investigations, enforce our legal terms and/or comply with applicable legal requirements.