Privacy Notice  
 
Dated: 24 May 2018 
 
 
Introduction 
 
Welcome to the PSV Glass & Glazing Ltd and group companies (PSV Group) privacy notice – the group companies include, PSV Glass & Glazing Ltd, IGP Solutions Ltd, ILE Solutions Ltd and Coach Glazing Services Ltd 
 
PSV Group respects your privacy and is committed to protecting your personal data. This privacy notice will inform you as to how we look after your personal data when you interact with us and tell you about your privacy rights and how the law protects you. 
 
This privacy notice is provided in a layered format so you can click through to the specific areas set out below. You can also download a pdf version of the policy here [LINK]]. Please also use the Glossary to understand the meaning of some of the terms used in this privacy notice. 
 
 
10. Glossary 
 
1. Important information and who we are 
 
Purpose of this privacy notice 
 
This privacy notice aims to give you information on how PSV Group collects and processes your personal data when you interact with us, including any data you may provide to us. 
Our website is not intended for children and we do not knowingly collect data relating to children. 
 
It is important that you read this privacy notice together with any other privacy notice or fair processing notice 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. This privacy notice supplements the other notices and is not intended to override them. 
 
Controller 
 
As above, PSV Group is made up of different legal entities. This privacy notice is issued on behalf of the PSV Group so when we mention PSV Group, "we", "us" or "our" in this privacy notice, we are referring to the relevant company in the PSV Group responsible for processing your data. We will let you know which entity will be the controller for your data when you purchase a product or service with us. 
 
We have appointed a data protection officer (DPO) who is responsible for overseeing questions in relation to this privacy notice. If you have any questions about this privacy notice, including any requests to exercise your legal rights, please contact the DPO using the details set out below. 
Contact details 
 
Name or title of DPO: Jonathan Ballard 
Email address: jonathan.ballard@psvglass.co.uk 
Postal address: 16 Hillbottom Road, High Wycombe, Bucks HP12 4HJ 
Telephone number: 01494 533131 
 
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 notice and your duty to inform us of changes 
 
This version was last updated on 24 May 2018. 
 
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 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 notice of every website you visit. 
 
2. The data we \ 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 follows: 
 
Identity Data includes first name, maiden name, last name, username 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. 
Health Data includes details of health, allergies and disabilities. 
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 and other technology on the devices you use to access 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 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 may be derived from your personal data but is not considered personal data in law as this data does 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 notice. 
 
We do collect Special Categories of Personal Data about some data subjects mainly employees and workers. This includes details about race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership and information about health. We do we collect 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. 
 
3. How is your personal data collected? 
 
We use different methods to collect data from and about you including through: 
 
Direct interactions. You may give us your Identity, Contact and Financial Data by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you: 
 
enquire about our products or services; 
create an account directly or via our website; 
purchase good or services from us; 
subscribe to our service or publications; 
request marketing to be sent to you; 
enter a competition, promotion or survey; or 
give us some feedback or lodge a complaint. 
 
We also collect Identity, Contact, Health, Financial Data and Special Categories of Personal Data when recruiting and employing persons. We have a separate HR Privacy Policy to cover candidates, employees and workers, a copy of which shall be made available if you apply for positions or are employed by us. A copy is also available from our DPO. 
 
Automated technologies or interactions. As you interact with our website, we may automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies, server logs and other similar technologies. We may also receive Technical Data about you if you visit other websites employing our cookies. 
 
Cookies 
First-party cookies are set when you interact with our site. Your browser will only send these cookies in requests to our site. 
 
Essential cookies 
These cookies are necessary for our site to work correctly. You can block these cookies through your browser settings, but if you choose to do so some features will no longer work. 
 
w_c 
This cookie is used to remember your cookie preferences. It is created when you change your cookie preferences and expires after thirty days. 
 
Google Analytics cookies 
These cookies are used by Google Analytics to track visitor interaction with our site in order to produce statistical reports for us. These cookies are created when you first view our site. For more information, see the Google Analytics below. 
 
_ga 
This cookie is used to distinguish each visitor. It expires after two years. 
 
_gid 
This cookie is used to distinguish each visitor. It expires after one day. 
 
_gat_gtag_UA_109295176_46 
This cookie is used to limit the number of requests sent to Google. It expires after one minute. 
 
Third parties or publicly available sources. We may receive personal data about you from various third parties and public sources as set out below: 
 
Technical Data from the following parties: 
analytics providers such as Google based outside the EU; 
Contact, Financial and Transaction Data from providers of technical, payment and delivery services based inside the EU. 
Identity and Contact Data from publicly availably sources such as Companies House, DVLA, enforcement bodies and the Electoral Register based inside the EU; 
Identity, Contact Data & Profile Data from suppliers & customers of PSV Group; 
Identity, Contact Data & Profile Data from recruiters, former employers, landlords, agents and referees. 
 
4. How we use your personal data 
 
We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances: 
 
Where we need to perform the contract we are about to enter into or have entered into with you or your organisation. 
Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests. 
Where we need to comply with a legal or regulatory obligation; 
Where it is in your “Vital Interests”. 
 
Generally we do not rely on consent as a legal basis for processing your personal data other than in relation to certain categories of direct marketing, You have the right to withdraw consent to marketing at any time by contacting us
 
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 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. 
 
Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below. 
Purpose / Activity 
Type of data  
Lawful basis for processing including basis of legitimate interest 
To register you as a new customer 
(a) Identity 
(b) Contract  
Performance of a contract with you 
To register you as a new supplier 
(a) Identity 
(b) Contact 
Performance of a contract with you 
To process and deliver your order including: 
(a) Manage payments, fees and charges 
(b) Collect and recover money owed to us 
(a) Identity 
(b) Contact 
(c) Financial 
(d) Transaction 
(e) Marketing and Communications 
(a) Performance of a contract with you 
(b) Necessary for our legitimate interests 
To manage our relationship with you which will include: 
(a) Notifying you about changes to our terms or privacy policy 
(b) Asking you to leave a review or take a survey 
(a) Identity 
(b) Contact 
(c) Profile 
(d) Marketing and Communications 
(a) Performance of a contract with you 
(b) Necessary to comply with a legal obligation 
(c) Necessary for our legitimate interests (to keep our records updated and to study how customers use our products/services) 
To enable you to partake in a prize draw, competition or complete a survey 
(a) Identity 
(b) Contact 
(c) Profile 
(d) Usage 
(e) Marketing and Communications 
a) Performance of a contract with you 
(b) Necessary for our legitimate interests (to study how customers use our products/services, to develop them and grow our business) 
To administer and protect our business and our website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data) 
(a) Identity 
(b) Contact 
(c) Technical 
a) Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, health & safety, fire risk management, legal protection, to meet customer requirements, to prevent fraud and in the context of a business reorganisation or group restructuring exercise) 
(b) Necessary to comply with a legal obligation 
To use data analytics to improve our website, products/services, marketing, customer relationships and experiences 
(a) Technical 
(b) Usage 
Necessary for our legitimate interests (to define types of customers for our products and services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy) 
To send you marketing information and to make suggestions and recommendations to you about goods or services that may be of interest to you 
(a) Identity 
(b) Contact 
(c) Technical 
(d) Usage 
(e) Profile 
Necessary for our legitimate interests (to develop our products/services and grow our business) 
When recruiting or employing staff 
 
(We have a separate HR Privacy notice) 
(a) Identity 
(b) Contact 
(c) Financial 
(d) Health 
(e) Special Category data 
(a) Performance of a contract with you 
(b) Necessary for our legitimate interests 
(c) Vital Interests 
Marketing 
 
We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising. Any direct marketing carries an unsubscribe function. You have the right to opt out of direct marketing. 
 
Promotional offers from us 
 
We may use your Identity, Contact, 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 or services from us or if you provided us with your details when you entered a competition or registered for a promotion and, in each case, you have not opted out of receiving that marketing. 
 
Third-party marketing 
We will get your express opt-in consent before we share your personal data with any company outside the PSV Group of companies for marketing purposes. 
 
Opting out 
 
You can ask us or third parties to stop sending you marketing messages at any time by contacting us 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 
 
As referred to above, 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 our website 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. 
 
5. Disclosures of your personal data 
 
We may have to share your personal data with the parties set out below for the purposes set out in the table in paragraph 4 above. 
 
Internal Third Parties as set out in the Glossary. 
External Third Parties as set out in the Glossary. 
 
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 notice. 
 
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. 
 
6. International transfers 
 
We do not transfer your personal data outside the European Economic Area (EEA). 
 
Whenever we do 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 the 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. 
 
7. 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. 
 
8. Data retention 
 
How long will you use my personal data for? 
 
We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements. 
 
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 requirements. 
 
Details of retention periods for different aspects of your personal data are available in our retention policy which you can request from us by contacting us 
 
In some circumstances you can ask us to delete your data: see Request erasure below for further information. 
 
In some circumstances we may anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes in which case we may use this information indefinitely without further notice to you. 
 
9. Your legal rights 
 
Under certain circumstances, you have rights under data protection laws in relation to your personal data. Please click on the links below to find out more about these rights: 
 
Request access to your personal data. 
Request correction of your personal data. 
Request erasure of your personal data. 
Object to processing of your personal data. 
Request restriction of processing your personal data. 
Request transfer of your personal data. 
Right to withdraw consent. 
 
If you wish to exercise any of the rights set out above, 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 may 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 may 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 
 
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 or regulatory obligation means processing your personal data where it is necessary for compliance with a legal or regulatory obligation that we are subject to. 
 
THIRD PARTIES 
 
Internal Third Parties 
 
Other companies in the PSV Group acting as joint controllers or processors and who are based the UK and Ireland to which PSV Glass and Glazing Limited provide IT and system administration services and undertake leadership reporting. 
 
External Third Parties 
 
Service providers acting as processors based in the EEA who provide IT, system administration and banking/payment services (e.g Fidget Computerware Limited). 
Professional advisers acting as processors or joint controllers including lawyers, bankers, auditors and insurers based in the UK and Ireland who provide consultancy, banking, legal, insurance and accounting services. 
HM Revenue & Customs, DVLA, HSE, the Police, regulators and other authorities acting as processors or joint controllers based in the United Kingdom and Ireland who require reporting of processing activities in certain circumstances; 
Customers and suppliers (contact information only). 
 
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: (a) if you want us to establish the data's accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) 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; or (d) 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. 
Issue No 
Description of change  
Approval  
Date of Issue  
Date to review  
Version 1.0 
Original Document  
Toni Beasley 
24 May 2018 
24 May 2019 
 
 
 
 
 
 
 
 
 
 
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