PRIVACY NOTICE – ICEROBOTICS LTD
UPDATED: 23 MAY 2018
As a Company, IceRobotics Ltd is committed to safeguarding the personal information you provide to us. This Privacy Notice provides details on what personal information we may collect from you, how we use it and how we protect it. It also provides details of any circumstances where we may disclose your information. We will only collect and process your personal data in ways that are described here, and in a way that is consistent with our obligations and your rights under the law.
If you have any questions about how we collect and use your personal data, please contact us using the details below.
- About us
IceRobotics Ltd is registered in Scotland under registration number SC331391 and our registered office is at 5th floor, 125 Princes Street, Edinburgh, EH2 4AD, United Kingdom.
Our principal place of business is at IceRobotics Ltd, Bankhead Steading, Bankhead Road, South Queensferry, Edinburgh EH30 9TF, Scotland, UK.
We are registered with the Information Commissioners Office with reference number ZA117935.
- Contacting us
You can contact us by:
- writing to us at IceRobotics Ltd, Bankhead Steading, Bankhead Road, South Queensferry, Edinburgh EH30 9TF, Scotland, UK.
- email to firstname.lastname@example.org
- telephone on +44 (0) 131 541 2010
- What does this Privacy Notice cover?
This Privacy Notice explains how we use your personal data: how it is collected, how it is held, and how it is processed. It also explains your rights under the law relating to your personal data.
- What is Personal Data?
Personal data is defined by the General Data Protection Regulation (EU Regulation 2016/679) (the “GDPR”) as ‘any information relating to an identifiable person who can be directly or indirectly identified in particular by reference to an identifier’.
Personal data is, in simpler terms, any information about you that enables you to be identified. Personal data covers obvious information such as your name and contact details, but it also covers less obvious information such as identification numbers, electronic location data, and other online identifiers.
The personal data that we use is set out in Part 7, below.
- What are your Rights?
Under the GDPR, you have the following rights, which we will always work to uphold:
- The right to be informed about our collection and use of your personal data. This Privacy Notice should tell you everything you need to know, but you can always contact us to find out more or to ask any questions using the details in Part 3.
- The right to access the personal data we hold about you. Part 13 will tell you how to do this.
- The right to have your personal data rectified if any of your personal data held by us is inaccurate or incomplete. Please contact us using the details in Part 3 to find out more.
- The right to be forgotten, i.e. the right to ask us to delete or otherwise dispose of any of your personal data that we have. Please contact us using the details in Part 3 to find out more.
- The right to restrict (i.e. prevent) the processing of your personal data.
- The right to object to us using your personal data for a particular purpose or purposes.
- The right to data portability. This means that, if you have provided personal data to us directly, we are using it with your consent or for the performance of a contract, and that data is processed using automated means, you can ask us for a copy of that personal data to re-use with another service or business in many cases.
- Rights relating to automated decision-making and profiling. We do not use your personal data in this way.
For more information about our use of your personal data or exercising your rights as outlined above, please contact us using the details provided in Part 3.
Further information about your rights can also be obtained from the Information Commissioner’s Office or your local Citizens Advice Bureau.
If you have any cause for complaint about our use of your personal data, you have the right to lodge a complaint with the Information Commissioner’s Office.
The contact details for the Information Commissioner’s Office can be found at www.ico.org.uk
- What Personal Data do we collect and why?
We may collect some or all of the following personal data (this may vary according to your relationship with us). We need information from you to provide you with details of appropriate products and services, and to be able to conduct our business, including working with our suppliers and partners.
- Preferred Title (eg Mr, Ms, Dr)
- Business Address
- Email address
- Telephone number
- Business name
- Job title
- Payment information
- Information about your preferences and interests that you have shared
- Information about your contact with us
- Your IP address (for delivering our products and services)
- Location identifier (for delivering our products and services) Web browser type and version (for delivering and improving our products and services)
- Operating system (for delivering and improving our products and services)
- Your activity on Our Sites (for delivering and improving our products and services)
- Date and time of your visit to the site (for delivering and improving our products and services)
Your personal data may be obtained, with your consent, from the following third parties:
- Sales & business partners, including agents and distributors
- Other organisations who may refer you to us
- How do we use your Personal Data?
Under the GDPR, we must always have a lawful basis for using personal data. This may be because the data is necessary for our performance of a contract with you, because you have consented to our use of your personal data, or because it is in our legitimate business interests to use it. Your personal data may be used for the following purposes:
- Supplying our products and/or services to you. Your personal details are required in order for us to enter into a contract with you.
- Providing and managing your account
- Personalising and tailoring our products and/or services for you
- Providing you with product support and training
- Communicating with you. This may include responding to emails or calls from you.
- Supplying you with information by email and telephone and post to which you have opted-in. You may unsubscribe or opt-out at any time by selecting opt out in an email or by going to the Privacy section of icerobotics.comor cowalert.comor by contacting us using the contact detail in section 3 above.
- Paying you if you are a Supplier
With your permission and/or where permitted by law, we may also use your personal data for marketing purposes, which may include contacting you by email and/or telephone and/or text message and/or post with information, news, and offers on our products and services. You will not be sent any unlawful marketing or spam. We will always work to fully protect your rights and comply with our obligations under the GDPR and the Privacy and Electronic Communications (EC Directive) Regulations 2003, and you will always have the opportunity to opt-out.
We use the following automated system for carrying out certain kinds of decision-making. If at any point you wish to query any action that we take on the basis of this or wish to request ‘human intervention’ (i.e. have someone review the action themselves, rather than relying only on the automated method), the GDPR gives you the right to do so. Please contact us to find out more using the details in Part 3.
The following automated decision-making method(s) may be used:
- Customer database query to enable us to provide you with appropriate, tailored information, for example identifying customers in a certain geographical area to advise them on a local training event
We do not undertake automatic profiling using your personal data.
- How long will we keep your Personal Data?
We will not keep your personal data for any longer than is necessary in light of the reason(s) for which it was first collected. Your personal data will therefore be kept for the following periods (or, where there is no fixed period, the following factors will be used to determine how long it is kept):
- During the period in which we are in a business relationship with you
- As required by law where we have had a contractual relationship with you
- For one year after the end of a Contract, if there is no legal obligation to keep your personal information for longer, unless you then opt in to keeping in touch via our newsletter and other marketing related tools.
- How and where do we store or transfer your Personal Data?
We use industry standard business tools to help us manage our business. We may therefore store or transfer some or all of your personal data in countries that are not part of the European Economic Area (the “EEA” consists of all EU member states, plus Norway, Iceland, and Liechtenstein). These are known as “third countries” and may not have data protection laws that are as strong as those in the UK and/or the EEA. This means that we will take additional steps in order to ensure that your personal data is treated just as safely and securely as it would be within the UK and under the GDPR as follows.
Where we transfer your data to a third party based in the USA, this may be protected if they are part of the EU-US Privacy Shield. This requires that third party to provide data protection to standards similar levels of data protection to those in Europe. More information is available from the European Commission or from www.privacyshield.gov
Please contact us using the details in Part 3 for further information about the particular data protection mechanism used by us when transferring your personal data to a third country.
- How do we protect your Personal Data?
The security of your personal data is essential to us. To protect your data we take a number of important measures. These include organisational methods such as processes and procedures, and technical methods such as passwords, firewalls and encryption, to keep your data safe. We will always ensure, as far as is reasonably possible, that your personal information is kept confidential. Please contact us using the details in Part 3 if you have any questions about the security of your data.
- Sharing your Personal Data
We may sometimes contract with third parties to supply products and/or services to you. In order to do this, we may need to provide them with some of your personal details so that may contact you directly. The reasons that we might do this are:
- Product delivery
- Product installation
- Product training
- To enable us to integrate with another 3rdparty product, where you have requested this
- Payment processing
- To enable our asset finance partner to process the purchase of product, where you have selected this option
- Product update information
- Marketing Information, where you have opted in to receive this
Where any of your personal data is required by a third party, as described above, we will take steps to ensure that your personal data is handled safely, securely, and in accordance with your rights, our obligations, and the third party’s obligations under the law, as described above.
If any personal data is transferred outside of the EEA, we will take suitable steps in order to ensure that your personal data is treated just as safely and securely as it would be within the UK and under the GDPR.
In some limited circumstances, we may be legally required to share certain personal data, which might include yours, if we are involved in legal proceedings or complying with legal obligations, a court order, or the instructions of a government authority.
- Access to your Personal Data and correction
If you want to know what personal data we have about you, you can ask us for details of that personal data and for a copy of it (where any such personal data is held). This is known as a “subject access request”.
All subject access requests should be made in writing and sent to the email or postal addresses shown in Part 3. A form is available to help us answer your query as soon possible; please email email@example.com and use “subject access request” in the email subject line to request the form.
If you decide not to use the form, please provide specific details (along with any relevant dates) of the information being requested and any additional information that may help us to locate your personal data and to confirm your identity.
There is not normally any charge for a subject access request. If your request is ‘manifestly unfounded or excessive’ (for example, if you make repetitive requests) a fee may be charged to cover our administrative costs in responding.
We will respond to your subject access request within one month of confirming your identity. Normally, we aim to provide a complete response, including a copy of your personal data within that time. In some cases, however, particularly if your request is more complex, more time may be required up to a maximum of three months from the date we receive your request. You will be kept fully informed of our progress.
You also have a right to contact us if you believe that the personal information that we hold may not be correct, or if you believe we are no longer entitled to hold your personal data. Please contact us using the details in Part 3 if you believe this to be the case, or would like to discuss how we use your personal information.
- Changes to this Privacy Notice
We may change this Privacy Notice from time to time. This may be necessary, for example, if the law changes, or if we change our business in a way that affects personal data protection.