Welcome to Malton Plastics (UK) Ltd.’s privacy notice.
We welcome any comments on content or questions which need clarification.
Malton Plastics (UK) Ltd. is committed to ensuring that your privacy is protected. Should we ask you to provide certain information by which you can be identified when using this website, then you can be assured that it will only be used in accordance with this privacy statement.
1. IMPORTANT INFORMATION AND WHO WE ARE
2. THE DATA WE COLLECT ABOUT YOU
3. HOW IS YOUR PERSONAL DATA COLLECTED
4. HOW WE USE YOUR PERSONAL DATA
5. DISCLOSURES OF YOUR PERSONAL DATA
6. INTERNATIONAL TRANSFERS
7. DATA SECURITY
8. DATA RETENTION
9. YOUR LEGAL RIGHTS
11. LEGITIMATE INTEREST
12. LEGITIMATE INTEREST ASSESSMENT
1. Important information and who we are
Purpose of this privacy notice
This privacy notice aims to give you information on how Malton Plastics (UK) Ltd. collects and processes your personal data as a customer, consumer and through your use of this website, including any data you may provide through this website when you sign up to our newsletter, directly contact us, purchase a product or service or take part in a competition.
This website is not intended for children and we do not knowingly collect data relating to children.
Malton Plastics (UK) Ltd. is the controller and is responsible for your personal data (collectively referred to as Malton Plastics (UK) Ltd. “, “we”, “us” or “our” in this privacy notice). We are 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 Malton Plastics (UK) Ltd. using the details set out below.
Company name: Malton Plastics (UK) Ltd.
Managing Director: Graeme Smith
Email address: firstname.lastname@example.org
Postal address: 29 Enterprise Way, Thornton Road Industrial Estate, Pickering, United Kingdom, YO18 7NA
Telephone number: 01751 477720
Fax number: 01751 477760
Company Number: 04019121
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
Malton Plastics (UK) Ltd may change this policy from time to time by updating this page. You should check this page from time to time to ensure that you are happy with any changes. This policy is effective from May 2018.
The data protection law in the UK will change as of the 25th May 2018. This privacy notice sets out most of your rights under the new General Data Protection Regulation (GDPR) law. Our previous policy was in line with the previous Data Protection Act 1998 whereas it is now updated to comply with the new policies outlined within GDPR.
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.
This website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling connections may allow third parties to collect or share data about you. We do not control third-party websites and are not responsible for their privacy statements. When you leave our website, we advise you to read the privacy notice of every website you visit.
2. The data we collect about you
Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data)
Malton Plastics (UK) Ltd. may collect, use, store and transfer different kinds of personal data about you which can be grouped together under the following headings:
• 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.
• 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, 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.
• Profile Data includes purchases or orders made by you, your preferences or feedback.
• Usage Data includes information about how you use our website, products and services.
To summarise our business activities we primarily hold names, job titles, phone numbers, email addresses, billing addresses, and delivery addresses. Furthermore we also have data concerning payments and past transactions.
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). Neither do we collect any information about criminal convictions and offences.
Failure 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 collect your data using various methods, which includes:
• 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:
– apply for our products or services;
– create an account on our website(s) – though not currently possible this is something we may explore in the future of which the policy will/would be updated to reflect this;
– subscribe to our service or publications;
– request marketing to be sent to you;
– enter a competition, promotion or survey; or
– give us some feedback.
• 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:
– Technical Data from the following parties:
analytics providers such as Google based outside the EU;
– Identity and Contact Data from publicly availably sources such as Companies House and the Electoral Register based inside the EU.
4. How we use your personal data
We will only use your personal data when the law allows us to. 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.
• 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.
Generally we do not rely on consent as a legal basis for processing your personal data other than in relation to sending direct marketing communications to you via email or text message. 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, 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 below.
To register you as a new customer
Performance of a contract with you
To process and deliver your order including or collect and recover money owed to us
Identity, Contact, Financial, Transaction
- Performance of a contract with you
- Necessary for our legitimate interests (to recover debts due to us)
Identity, Contact, Profile, Marketing and Communications
- Performance of a contract with you
- Necessary to comply with a legal obligation
- Necessary for our legitimate interests (to keep our records updated)
- Study and review how customers use and perceive our products/services
To administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)
Identity, Contact, Technical
- Necessary for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise)
- Necessary to comply with a legal obligation
To deliver relevant website content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you
Identity, Contact, Profile, Usage, Marketing and Communications, Technical
- Necessary for our legitimate interests (to study how customers use our products/services, to develop them, to grow our business and to inform our marketing strategy)
To use data analytics to improve our website, products/services, marketing, customer relationships and experiences
- 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 make suggestions and recommendations to you about goods or services that may be of interest to you
Identity, Contact, Technical, Usage, Profile
- Necessary for our legitimate interests (to develop our products/services and grow our business)
We aim to provide you with choices regarding certain personal data uses, particularly around marketing and advertising. We know you don’t like spam and neither do we. If you have opted-in, we hope you find our direct marketing of value to yourself and/or your business. If you do not want to receive marketing from us, please contact us via phone, email, post or via the opt-out option on the marketing format.
Promotional offers from us
We may use your Identity, and Contact Data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which products, services and offers may be relevant for you (we call this marketing).
You will receive marketing communications from us if you have requested information from us or purchased goods from us (or if you provided us with your details when you entered a competition or registered for a promotion) and, in each case, you have opted-in by providing explicit consent.
If you no longer want to receive a certain or all types of promotional offers from us, please request us to do so. If you wish to know what promotional lists we have you on, also feel free to request what information we have on you and how we are using it.
We share your Personal Information with third parties to help us use your Personal Information, as described above. For example, we use Shopify to power our online store–you can read more about how Shopify uses your Personal Information here: https://www.shopify.com/legal/privacy. We also use Google Analytics to help us understand how our customers use the Site–you can read more about how Google uses your Personal Information here: https://www.google.com/intl/en/policies/privacy/. You can also opt-out of Google Analytics here: https://tools.google.com/dlpage/gaoptout.
Finally, we may also share your Personal Information to comply with applicable laws and regulations, to respond to a subpoena, search warrant or other lawful request for information we receive, or to otherwise protect our rights.
As described above, we use your Personal Information to provide you with targeted advertisements or marketing communications we believe may be of interest to you. For more information about how targeted advertising works, you can visit the Network Advertising Initiative’s (“NAI”) educational page at http://www.networkadvertising.org/understanding-online-advertising/how-does-it-work.
You can opt out of targeted advertising by:
FACEBOOK – https://www.facebook.com/settings/?tab=ads
GOOGLE – https://www.google.com/settings/ads/anonymous
BING – https://advertise.bingads.microsoft.com/en-us/resources/policies/personalized-ads
Additionally, you can opt out of some of these services by visiting the Digital Advertising Alliance’s opt-out portal at: http://optout.aboutads.info/.
You can ask us to stop sending you marketing messages at any time by following the opt-out links on any marketing message sent to you, or 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 purchase, warranty registration, product experience or other transactions.
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 section 4.
- We may have to share your details with the following external third parties for legal reasons: Professional advisers acting as processors or joint controllers including lawyers, bankers, auditors and insurers based who provide consultancy, banking, legal, insurance and accounting services, 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.
- 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 personal consumer data outside the European Economic Area (EEA) without the explicit consent from the consumer to do so.
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.
By law we have to keep basic information about our customers (including Contact, Identity, Financial and Transaction Data) for six years after they cease being customers for tax purposes.] Also, you can ask us to delete your data.
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
You have rights under data protection laws in relation to your personal data.
• The right to access to your personal data.
• The right to correction of your personal data.
• The right to erasure of your personal data.
• The right to Object to processing of your personal data.
• The right to the restriction of processing your personal data.
• The right to transfer your personal data.
• The right to withdraw consent.
If you wish to exercise any of the rights mentioned, 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.
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.
Your Legal Rights
You have the right to:
- Access 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.
- The 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.
- 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.
- The 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.
- Transfer 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.
11. Legitimate Interest
What is Legitimate Interests?
Legitimate Interests is one of the six lawful bases for processing personal data under the GDPR (General Data Protection Regulation). You must have a lawful basis in order to process personal data in line with the ‘lawfulness, fairness and transparency’ principle.
Legitimate interests might be your own interests, or the interests of the third party receiving the data, or a combination of the two.
Latest guidance from the Information Commissioner says that legitimate interests may be the most appropriate basis when:
“the processing is not required by law but is of a clear benefit to you or others; there’s a limited privacy impact on the individual; the individual should reasonably expect you to use their data in that way; and you cannot, or do not want to, give the individual full upfront control (i.e. consent) or bother them with disruptive consent requests when they are unlikely to object to the processing.”
You can read the Information Commissioner’s guidance on legitimate interests in full on the ICO website
12. Legitimate Interest Assessment
To comply with GDPR, Malton Plastics (UK) Ltd. has carried out a Legitimate Interests Assessment which is documented below.
Purpose of Processing
Malton Plastics (UK) Ltd. has a legitimate interest to process personal data relating to decision makers, budget holders in medium-to-large organisations in the UK and public consumers with interest in our products. The data is gathered from publicly available sources and directly from the companies concerned.
Lawful Business Objective
The processing is necessary in order to supply Malton Plastics (UK) Ltd.’s clients information on injection moulding services and products of specific interest; a lawful business objective specifically identified by the Privacy and Electronic Communications Regulations 2003 (PECR). Recital 47 of the GDPR identifies direct marketing as a legitimate use of personal information.
The data subjects are senior businesspeople with decision making and budgetary responsibilities and can reasonably expect to be contacted with marketing material relating to their professional roles.
The data subjects are general consumers with specified interest in certain categories of product who would be interested in our products.
Adequate, Relevant & Limited
The data collected is limited to names of senior managers and directors, their job titles, company addresses, company landline telephone numbers and corporate email addresses. If a person leaves their role, their name and contact details are deleted from the database.
If a data subject requests that their data is removed from the database, it is suppressed so that it cannot be accessed or added again later.
In supplying accurate, regularly updated and targeted data, Malton Plastics (UK) Ltd. provides a valuable service to B2B and B2C customers. In the absence of Malton Plastics (UK) Ltd. and similar high quality service providers, UK businesses would have to source plastic components outside of the UK, detrimental to UK manufacturing and with ethical implications due to the source of the supply China.[03/04/2020]