1. OUR DETAILS
THIS POLICY WAS LAST MODIFIED ON 23rd May 2018.
Sentinel Performance Solutions Ltd ("us", "we", or "our") operates www.sentinelprotects.com (the "Site").
If you have any questions regarding how we use your information or you wish to exercise any of your rights set out below, please contact us at Sentinel Performance Solutions Ltd, 7650 Daresbury Park, Daresbury, Warrington, Cheshire WA4 4BS or on 01928 704330 or by email at firstname.lastname@example.org
2. WHAT INFORMATION DO WE COLLECT AND WHEN?
We only collect information that we will use for the purposes set out in this notice.
Specifically, we collect:
• Information you submit to us
• Through completing forms on our Site e.g. when you register with us or place an order for products or services on our Site or request information from us;
• By applying for or registering accounts with us. This includes your contact details, account details, your marketing preferences and any passwords;
• By communicating with us via emails, text messages, in person or over the telephone;
• Contacting us via social media or in response to our requests for feedback;
• Providing your details to our marketing agencies.
Please note: If you submit details to us of any other person (e.g. a colleague), please make sure you have their permission before doing so.
• Information we collect about you
o Full details of the purchases you make on the Site including the time and date of purchase, the products you purchase from us, any relevant delivery address and details of any relevant payment cards or bank account details.
o Technical information about the devices you use to access the Site. We collect each device’s unique identifying code (MAC address), relevant IP address, operating system and version, web browser and version, and geographic location.
o Information from banking and credit cards about your financial status and the status of any payment card presented to us (for example, if it has been reported stolen) to check we are likely to be paid for any transaction and to reduce the risk of fraud.
o [Information collected independently by online advertising networks (for example Facebook, Twitter) through which we place advertisements. The information we obtain varies from network to network. It often summarises the actions of lots of people, in which case it does not enable us to identify you individually. It relates to what you view, click on, and access through Sites in their network, including the subject matter of the Site you started at and where you subsequently go. It may also include their analysis of your behaviour across the wider internet and a profile of you.
If you are unhappy about this happening you should look out for "settings" and "Do Not Track" options in online advertisements and in the privacy and cookies functionality on your devices and consider changing your settings to block third party cookies in particular. We do not control the information about you that such networks obtain, or the technology they use to do so.]
3. HOW DO WE USE YOUR INFORMATION?
We use the information we collect for the following purposes:
• To provide you with the Site which requires a certain amount of technical information to be collected in order to work properly.
• To enable you to order products and services from us which again requires a certain amount of information to be collected, for example payment card or bank account details so we can take payment and the products you buy so we can provide you with a receipt.
• To gather feedback from you about the Site, our products, other services and activities from time to time. We may invite you to provide this feedback on occasion, for example by emailing you to ask if you would like to review a product you have bought. We may use independent research and feedback providers to do so on our behalf.
• To contact you from time to time about things we think you may be interested in or, where you have told us what you want to hear about, in accordance with your preferences, for example our products and services, news, offers, competitions and any sponsored events.
• To respond to any questions, suggestions, issues or complaints you have raised with us.
• To respond to any social media posts or other public comments you make where these are made to or about us, the Site, our products, services or other activities.
• To communicate with you about operational changes to the Site and our products and services for example if we were to change this privacy notice.
• To perform any contract we have entered into with you but also to enforce a contract against you if you do not honour it, including seeking to collect any debts that you may owe us.
• To check that you have or are likely to have the means to pay us for any products or services you have ordered from us.
• To monitor use of the Site to see if it is being abused or threatened, for example by people posting inappropriate comments in review areas or by potential hackers attempting to undermine security.
• To protect you and our business against any other criminal behaviour, including identity theft and fraud.
• To understand you better and, in particular, your use of our Site. By having really good information about how you use our Site, we can focus on the products and services we think are most likely to be of real interest to you, and especially when we send you offers, news, information on our products and details of new competitions and sponsored events.
• To maintain administrative and legal records about our business to enable us to understand what we have sold, how, when, where and at what price and account to HM Revenue & Customs for the related taxes that we have to pay.
• To enable us and our third party service providers to plan and manage our day-to-day business and related services as effectively as possible, for example in predicting likely sales volumes for each of our products and services, so we can try and make sure we have enough stock and resource to meet likely demand.
• To enable us to understand our customer and user base. We do this by combining your information with information about our other customers and users of the Site so we can spot trends and common factors. We can then further tailor our business approach and in particular our marketing communications, products and services to the things we think you and other people or businesses like you and/or your business would be most interested in.
• In the process of anonymising your information so that you are no longer identifiable to us.
• To test new systems and processes as we roll them out to make sure they work and will meet the high expectations we set for ourselves.
• To assist us in the development of new products and services over time, for example to gauge whether a new product is likely to appeal to a large proportion of our customer base.
4. LEGAL BASIS FOR USING YOUR INFORMATION
In accordance with data protection law, we are obliged to inform you that we are using your information as described in this policy on one or more of the following legal bases:
• you have given your consent to us using your information as described in this notice;
• the use is necessary to perform a contract between us or to take steps which you requested us to take before entering into a contract;
• the use is necessary to comply with a legal obligation to which we are subject;
• the use is necessary to save your life or that of another individual;
• the use is necessary for the performance of a task carried out in the public interest or in the exercise of our official authority;
• the use is necessary for the purposes of legitimate interests (including direct marketing to you).
5. USE OF YOUR SENSITIVE PERSONAL INFORMATION
We may collect sensitive personal information about you where this is provided as part of other information that we require from you. By way of example, this information may be included within the identification information you provide to us as part of our account opening process and/or we may check and record this information during our verification process on collection of our hire equipment.
We will use this sensitive personal information for the purposes of identifying individuals to combat fraud and other criminal activity. We will share this sensitive personal information with the police and our insurers and other organisations that provide similar products and services to ours for the purpose of fraud and crime prevention.
6. WHO DO WE SHARE YOUR INFORMATION WITH?
We cannot run our business or provide many of our services and benefits without involving other people and businesses and sometimes we pass your information to these other people and businesses as set out below. We only share your information where we can do so in accordance with our legal data protection and privacy obligations. We share the information we collect with:
• Our insurers and insurance brokers where required in order for us to be able to obtain insurance against risks we face in running our business. They may retain this information for the purpose of ongoing risk assessment and insurance broking and underwriting services.
• Business partners, suppliers and sub-contractors for the performance of any contract we enter into with them or you.
• The prospective buyer of any part of our business or assets that we may sell.
• Our professional advisers for example our lawyers, accountants and technology consultants when they need it to provide advice to us.
• The police, local authorities, HM Revenue & Customs (HMRC), the courts and any other central or local government bodies where they request it and/or where we may lawfully disclose it, for example for the prevention and detection of crime.
• Other people who make a subject access request to us, where we are allowed to do so by law (see Managing Your Information below for what we mean by a subject access request).
We may also share the information we collect where we are legally able to do so, for example, to comply with a court order.
7. HOW LONG DO WE KEEP YOUR INFORMATION FOR?
In accordance with our legal data protection and privacy obligations, we will only retain your information for so long as is necessary for the purpose for which we process that data.
We will then either securely delete it or anonymise it so that it cannot be linked back to you.
See How do we use your information? above for full details of those purposes.
8. MANAGING YOUR INFORMATION
You can contact us to discuss your information at any time using the details provided below.
It is very important to us that all the information we hold about you remains accurate and up to date to reduce the risk of a misunderstanding.
We need your help in doing so. If you have an online account with us, please ensure that the information (for example, contact information) you provide to us through that account remains accurate and up to date. Please review and update it regularly.
You have a number of rights which we respect and aim to uphold in everything we do. These rights are set out below.
We reserve the right not to comply with any requests we receive where we may lawfully do so, for example if we reasonably believe a request to be malicious, technically very onerous, to involve disproportionate effort or harmful to the rights of others.
Asking us about your information You have the right to ask us whether we hold information about you and, if so, for us to give you certain details about that information and/or the information itself. In the case of information which you have provided to us, you have the right to access that information. This right is commonly known as a subject access request. If you would like to make a subject access request, please do so in writing to the address above.
Correcting inaccurate information If you have reason to believe any of the information we collect on you may be inaccurate or incomplete, and you cannot correct such inaccuracy or omission yourself through your registered account with us, please contact us (our contact details are set out below).
Erasing information You have the right to require us to erase your information without undue delay in the following circumstances:
a) the information is no longer necessary for the purposes for which we collected it;
b) we need your consent to use the information and you withdraw your consent;
c) you object to us using your information: (1) for the performance of a task carried out in the public interest or in the exercise of our official authority; or (2) for the purposes of our legitimate interests (e.g. in relation to sending direct marketing to you
d) you unsubscribe from our marketing communications;
e) we have used your information unlawfully;
f) the information must be erased for compliance with a legal obligation to which we are subject.
Restricting processing You have the right to require us to restrict our use of your information where one of the following applies:
a) while we verify the accuracy of the information that we hold about you where you contest the accuracy of that information;
b) we have used your information unlawfully, but you request us to restrict its use instead of erasing it;
c) we no longer need the information for the purpose for which we collected it, but you need it to deal with a legal claim; or
d) while we check whether our legitimate grounds for processing your information override your right to object where you have objected to us using your information.
Right to object Where we are using your information on the basis of public interest or our legitimate interests (see paragraph 4), you have the right to object to this at any time by contacting us using the contact details set out below.
Withdrawal of consent Where you have given your consent to us using your information for marketing purposes you have the right to alter your preferences or withdraw this consent at any time by contacting us using the contact details set out below. This will not affect the lawfulness of any use of your information that we make before you amend your preferences or withdraw your consent.
If you have any questions or complaints about our use of your information, please contact us at Sentinel Performance Solutions Ltd, 7650 Daresbury Park, Daresbury, Warrington, Cheshire WA4 4BS or on 01928 704330 or by email at email@example.com
We will do our very best to answer any question and resolve any complaint to your satisfaction. We hope that we can resolve any query or concern you raise about our use of your information but you can also contact the Information Commissioner at ico.org.uk/concerns/ or telephone: 0303 123 1113 for further information about your rights and how to make a formal complaint.