Electrosonic EMEA Privacy Statement

INTRODUCTION

Electrosonic, Ltd (“Electrosonic” or “We”), is a limited company registered in England and Wales under company number 00794221. Our registered Address is Hawley Mill, Hawley Road, Dartford, Kent, DA2 7SY, UK.

Electrosonic respects and values your privacy and is committed to protecting the privacy and security of your personal information. This privacy notice describes how we collect, use and store your personal information during and after your business relationship with us, in accordance with the General Data Protection Regulation (EU 2016/679) (GDPR) and the Data Protection Act 2018 (“Data Protection Laws”).

Electrosonic is a registered "data controller" (ICO registration number Z5678904). This means that we are responsible for deciding how we hold and use and store personal information about you. We are required to notify you of the information contained in this privacy notice.

DATA PROTECTION PRINCIPLES

We will handle your personal information in accordance with the data protection principles set out below:

1. Used lawfully, fairly and in a transparent way.
2. Collected only for valid purposes that we have clearly explained to you and not used in any way that is incompatible with those purposes.
3. Relevant to the purposes we have told you about and limited only to those purposes.
4. Accurate and kept up to date.
5. Kept only as long as necessary for the purposes we have told you about.
6. Kept securely.

THE TYPE OF INFORMATION THAT WE HOLD ABOUT YOU

Personal data, or personal information, can be any information that identities (directly or indirectly) and relates to a living person. It does not include data where the identity has been removed (anonymous data).

There are also "special categories" of sensitive personal data which require a higher level of protection.

We will collect, store, and use the following categories of personal information about you:

• Personal contact details such as name, title, address, telephone numbers, personal/business email addresses and IP address.
• Information about your use of our information and communications systems.
• Applicant’s details such as their personal contact details, details of qualifications, skills, experience and employment history, whether or not they have a disability that we need to make reasonable adjustments for during recruiting process, whether or not they are entitled to work in the UK and equal opportunities monitoring information.
• Transactional data detailing payments to and from the account you hold with us
• Contractual data detailing the services we provide to you
• Location data where you have made contract with us via our website, we collect your IP address together with your website usage information using Cookies. For more information on how we and why we use Cookies, please see our Cookie Policy.
• Communications such as what we learn about you from letters, emails and conversations between us.
• Open data such as details about you that are in the public records for example the Electoral Register or Companies House.

HOW YOUR PERSONAL INFORMATION IS COLLECTED

We typically collect personal information about you directly as follows

• Data Entry forms: When you enter data on any of our data entry forms, we will use this information to keep you updated on our latest products, services, company news, events, announcements, webinars as well as direct marketing to you in accordance to your marketing preferences

• Enquiries: When you complete our online “General Queries” or “Technical Support’ enquiry form, we will ask you for some basic information relating to your name, contact details and contact information, as well as the nature of your enquiry. This data is collected to help us provide you with the best possible service.

• Job application: When you apply for a vacancy, we will collect your personal data on our job application form, passports or other identity documents, interviews and assessment process and online tests or personality questionnaires.

• Communications made via telephone and email are recorded to reflect the history of the event.

We will sometimes collect additional information from third parties (including data providers). If appropriate, you will be provided with this Privacy Notice within one month we obtained the information about you. The source will also be specified and if applicable, whether the source is publicly accessible.

HOW WE USE YOUR PERSONAL INFORMATION ABOUT YOU

We will only use your personal information when the law allows us to. Most commonly, we will use your personal information in the following circumstances:

1. Administering your account with us.
2. Administering and performing in accordance with the contract, we have entered into with you to provide our products and services to you
3. Business management and planning, including accounting and auditing.
4. Complying with legal or regulatory obligations
5. Conducting data analytics studies to review and better understand customer engagement, retention and attrition rates
6. Dealing with legal disputes involving you, or any disputes that will arise under the contract that we have with you or the way in which we provide our products and services to you.
7. Ensuring network and information security, including preventing unauthorised access to our computer and electronic communications systems and preventing malicious software distribution.
8. Fraud prevention
9. In the protection of where we need to protect your interests (or someone else's interests).
10. Information about other products or services that is sent to you upon your request.
11. Job or general applications or responses to an enquiry about a possible job or request you submitted.
12. Notifications of changes to our products and services.
13. When product and service reviews are sought
14. Where it is needed in the public interest (Administration, Finance, Marketing) or for official purposes.

THE REASONS WE WILL USE YOUR PERSONAL INFORMATION

Data Protection law allows Electrosonic to use your personal information only if we have a proper reason to do so. This includes sharing your information with other organisations. We must have one of more of the following grounds for using your personal information. Your personal information can be used when:

1. You have given clear consent or, where applicable, explicit consent to use your personal information for a specific purpose.
2. It’s necessary for performing in terms of a contract or because you have asked us to take specific steps before entering into a contract.
3. It’s necessary to comply with the law or a legal obligation (not including contractual obligations).
4. It’s necessary to protect someone’s life.
5. It’s necessary to perform a task in the public interest or for our official functions, and the task or function has a clear basis in law.
6. It’s necessary for our legitimate interests or the legitimate interests of a third party.

We will only use your personal information for our legitimate interest where it is reasonable and fair.

We will tell you when we require your consent to use your personal data. You have the right to withdraw your consent at any time however this may affect our ability to provide certain services to you. If this applies, we will tell you. You can withdraw your consent at any time by phoning, emailing or writing to us on any of the details in 'Contact us' below. You will need to tell us which service you are using so that we can deal with your request.

Some of the above grounds for processing will overlap and there may be several grounds which justify our use of your personal information.

THE FAILURE TO PROVIDE US PERSONAL INFORMATION

If you fail to provide us certain personal information when requested, we may not be able to perform the contract we have entered into with you (such as providing you with our services or guarantees), or we may be prevented from complying with our legal obligations (such as financial and tax reporting and insurance maintenance), furthermore we may be prevented from processing requests / applications submitted by you.

CHOICES YOU HAVE WITH YOUR PERSONAL INFORMATION

You have a choice about whether or not you wish to receive information from us. If you do not want to receive direct marketing communications from us about the work we do and our products and services, then you can change your marketing preferences at any time by contacting us, or unsubscribing from the last email you have received.

We only market to other Limited or Corporate entities by email, post or telephone, for which legitimate interest has been identified as the legal basis of processing. We will not contact you for marketing purposes if you have indicated that you do not wish to be contacted. You can change your marketing preferences at any time by contacting us, or unsubscribing from the last email you have received.

YOUR RIGHTS

You will not have to pay a fee in the exercise of your rights. However, we might charge you an administration fee if the request is unfounded or excessive. We may in certain circumstances refuse to comply with your request; you will be notified regarding the reason if permitted by law. We may request some supplementary information as to narrow the scope and direct our search to meet your request.

Right to be informed

We have a duty to inform you about our uses of your personal data, this includes being informed should we use it for another reason other than when 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 we need to use your personal information for an unrelated purpose, we will notify you in writing and we will explain the legal basis which allows us to do so.

Please note that we will process your personal information without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

Right to access your information

You have the right to request a copy of the information we hold about you. This request is known as an Access Request. The obligatory one month to respond to a request may be extended to two months where the request is complex or numerous requests have been made. We will inform you within one month of receiving your request of this extension and the reasons for the delay.

Right to rectify your information

You have the right to correct any incomplete or inaccurate information we hold about you.

Right to erasure (Right to be forgotten)

You have the right to ask us to delete or remove personal information where

1. There is no good reason for us continuing to process it.
2. We rely on consent to use your personal information, and you have withdrawn it
3. We use your personal data for direct marketing purposes and you object to the use.
4. We have used your information unlawfully
5. The information has to be erased to comply with legal obligation

Right to restrict processing

You have the right to request the restriction or suppression of your personal information in the following circumstances:
1. Accuracy of your personal data is contested, and we are verifying it.
2. We have unlawfully used your information and you request restriction instead of erasure.
3. We no longer need the personal data, but you would like us to keep it in order to establish, exercise or defend a legal claim, or
4. We will restrict it where you have objected to us using your personal information and we are considering if your interest outweighs our legitimate ground.

Right to portability

You have the right to receive personal information, which you have provided to us, in a structured, commonly used and machine-readable format. You also have the right to require us to transfer this personal data to another organisation.

Right to object

You have the right to request that we stop using your information in relation to any service, and particularly if it affects your interests, rights and freedoms. However, please note that if this is approved, this may cause delays or prevent us from delivering a service to you. If this is the case, you will be informed of the consequences

Right to complain

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.

AUTOMATED DECISION MAKING AND PROFILING

Automated individual decision-making is where decisions are made solely by a computer (or other software/technology) without any human involvement. Profiling means that information about an individual is used by a computer in order to determine and evaluate certain things about that individual.
You have the following rights over automated decision-making:
• To request that we do not make our decision based on the automated score alone
• To object to an automated decision and ask that a person review it.

SHARING YOUR PERSONAL DATA WITH THIRD PARTIES

We may have to share your personal data with the parties set out below for the purposes outlined above:

• If you decide to make on-line payments, some information will be disclosed to our service provider for validation purposes

• External third-party service providers: there may be times when external organisations use your personal information as part of providing a service to us or as part of checking the quality of our service, such as our auditors;

• Law enforcement or other government and regulatory agencies: we may be required by law to disclose certain information to the police or another relevant authority in circumstances e.g. where we think you or someone else is at serious risk of harm.

We may also receive requests from third parties with authority to obtain disclosure of personal data. We will only fulfil such requests where we are permitted to do so in accordance with applicable law or regulation.

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 – we only permit them to process your personal data for specified purposes and in accordance with our instructions. We may use third party providers to deliver our services, such as externally hosted software or cloud providers, and those providers may involve transfers of personal data outside of the EU. Whenever we do this, to ensure that your personal data is treated by those third parties securely and in a way that is consistent with UK data protection law, we require such third parties to agree to put in place safeguards, such as the EU model clauses or equivalent measures.

DATA TRANSFER OUT OF THE EU

Personal information will be transferred to members of our group companies where necessary. These companies exist around the globe and in some cases are outside the European Economic Area (EEA). We do ensure a similar degree of protection is used should the data be sent outside of the EEA, making sure it has at least one of the following safeguards:

• Transfers of data outside the EEA are governed by an agreement that incorporates specific contractual clauses approved by the European Commission which give personal data the same protection it has in Europe.

• The country to which the data is transferred has been deemed to provide an adequate level of protection for personal data by the European Commission.

• Where we use certain service providers, we may use specific contractual clauses approved by the European Commission which give personal data the same protection it has in Europe.

• 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.

We require all our group companies to follow the same rules when processing your personal data. These rules are called "binding corporate rules".

Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the EEA.

DATA SECURITY

We have put in place appropriate technical and security measures:

• To protect the security of your personal information. Details of these measures are available upon request. Third parties will only process your personal information on our written instructions and where they have agreed to treat the information confidentially and to keep it secure as part of their contractual arrangement with us.

• To prevent your personal information from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal information to those employees, workers, agents, contractors and other third parties who have a business need to know. They will only process your personal information on our instructions and they are subject to a duty of confidentiality. Details of these measures are available upon request.

• To deal with any suspected data security breach and will notify you and any applicable regulator of a suspected breach where we are legally required to do so.

HOW LONG DO WE KEEP YOUR PERSONAL INFORMATION

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, and in accordance with the Electrosonic Data Retention Schedule.

COOKIES

Electrosonic’s website uses cookies. 'Cookies' are small pieces of information sent by an organisation to your computer and stored on your hard drive to allow that website to recognise you when you visit. They collect statistical data about your browsing actions and patterns and do not identify you as an individual. For example, we use cookies to store your country preference. This helps us to improve our website and deliver a better more personalised service.

It is possible to switch off cookies by setting your browser preferences. For more information on how to switch off cookies on your computer, visit your website browser settings. Turning cookies off may result in a loss of functionality when using our website.
For more information on how we use cookies, please see our Cookie Policy

CHANGES TO THIS PRIVACY NOTICE

We reserve the right to update this privacy notice at any time, and we will provide you with a new privacy notice when we make any substantial updates. We will also notify you in other ways from time to time about the processing of your personal information.

This notice was last updated the 29 August 2018.

CONTACT US

We have appointed a Data Privacy Team to oversee compliance with this privacy notice. If you have any questions about this privacy notice or how we handle your personal information, please contact the Data Privacy Team.

If you have any questions about this privacy notice, please contact the Data Privacy Team:

By email: UKDPO@electrosonic.com

By telephone: (+44) 1322 222211

In writing:

Data Protection Team
Hawley Mill
Hawley Road
Dartford
Kent DA2 7SY

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