Special EFX Ltd understands that your privacy is important to you and that you care about how your personal data is used and shared online. We respect and value the privacy of everyone who visits this website, www.efx.co.uk (“Our Site”) and will only collect and use personal data in ways that are described here, and in a manner that is consistent with Our obligations and your rights under the law.
1. Definitions and Interpretation
In this Policy, the following terms shall have the following meanings:
|“personal data”||means any and all data that relates to an identifiable person who can be directly or indirectly identified from that data. In this case, it means personal data that you give to Us via Our Site. This definition shall, where applicable, incorporate the definitions provided in the EU Regulation 2016/679 – the General Data Protection Regulation (“GDPR”); and|
|“We/Us/Our”||means Special EFX Ltd , a limited company registered in England under company number 05027569, whose registered address is Ettington Park Business Centre, Stratford upon Avon, Warwickshire, CV37 8BT.|
2. Information About Us
2.1 Our Site is hosted by SGN of 17 Mann Island, Liverpool, L3 1BP
2.2 Our VAT number is GB 834 3566 20
2.3 Our Data Protection Officer is Melanie Osborne, and can be contacted by email at email@example.com, by telephone on 01789 450005, or by post at Special EFX Ltd, Ettington Park Business Centre, Stratford upon Avon, Warwickshire, CV37 8BT.
2.4 We are a member of the following associations:
The British Promotional Merchandise Association (BPMA)
Membership number: 3461
Unit 5, Avenue Business Park, Brockley Road, Elsworth, Cambridge, CB23 4EY. Tel: 0203 875 7942. Email: firstname.lastname@example.org
PSI – Promotional Product Service Institute
Membership number: 18233
Völklinger Straße 4, 40219 Düsseldorf. Tel: +49 211 90191-600. Email: email@example.com
3. What Does This Policy Cover?
4. Your Rights
4.1 As a data subject, you have the following rights under the GDPR, which this Policy and Our use of personal data have been designed to uphold:
4.1.1 The right to be informed about Our collection and use of personal data;
4.1.2 The right of access to the personal data We hold about you (see section 12);
4.1.3 The right to rectification if any personal data We hold about you is inaccurate or incomplete (please contact Us using the details in section 13);
4.1.4 The right to be forgotten – i.e. the right to ask Us to delete any personal data We hold about you, please contact Us using the details in section 13;
4.1.5 The right to restrict (i.e. prevent) the processing of your personal data;
4.1.6 The right to data portability (obtaining a copy of your personal data to re-use with another service or organisation);
4.1.7 The right to object to Us using your personal data for particular purposes; and
4.1.8 Rights with respect to automated decision making and profiling.
4.2 If you have any cause for complaint about Our use of your personal data, please contact Us using the details provided in section 13 and We will do Our best to solve the problem for you. If We are unable to help, you also have the right to lodge a complaint with the UK’s supervisory authority, the Information Commissioner’s Office.
4.3 For further information about your rights, please contact the Information Commissioner’s Office or your local Citizens Advice Bureau.
5. What Data Do We Collect?
Depending upon your use of Our Site, We may collect some or all of the following personal and non-personal data:
5.2 business/company name
5.3 job title;
5.5 contact information such as email addresses and telephone numbers;
5.6 demographic information such as post code, preferences, and interests;
5.7 financial information such as credit / debit card numbers and bank account details;
5.8 IP address;
5.9 web browser type and version;
5.10 operating system;
5.11 a list of URLs starting with a referring site, your activity on Our Site, and the site you exit to;
6. How Do We Use Your Data?
6.1 All personal data is processed and stored securely. We will comply with Our obligations and safeguard your rights under the GDPR at all times. For more details on security see section 7, below.
6.2 Our use of your personal data will always have a lawful basis, either because it is necessary for Our performance of a contract with you, because you have consented to Our use of your personal data (e.g. by subscribing to emails), or because it is in Our legitimate interests. Specifically, We may use your data for the following purposes:
6.2.1 Supplying Our products to you (please note that We require your personal data in order to enter into a contract with you);
6.2.2 Personalising and tailoring Our products for you ahead of your event presentation;
6.2.3 Replying to emails from you;
6.2.4 Supplying you with emails that you have opted into (you may unsubscribe or opt-out at any time by clicking on the link at the bottom of our emails;
6.2.5 Market research;
6.3 With your permission and/or where permitted by law, We may also use your data for marketing purposes which may include contacting you by email AND/OR telephone AND/OR post with information, news, and offers on Our products. We will not, however, send you any unsolicited marketing or spam and will take all reasonable steps to ensure that We fully protect your rights and comply with Our obligations under the Privacy and Electronic Communications (PECR Directive) Regulations 2003.
6.4 You have the right to withdraw your consent to Us using your personal data at any time, and to request that We delete it.
7. How and Where Do We Store Your Data?
7.1 The majority of your data will be stored in the UK but some of your data may be stored outside of the European Economic Area (“the EEA”) (The EEA consists of all EU member states, plus Norway, Iceland, and Liechtenstein) in the form of secure cloud server backups. You are deemed to accept and agree to this by using Our Site and submitting information to Us. If We do store data outside the EEA, We will take all reasonable steps to ensure that your data is treated as safely and securely as it would be within the UK and under the GDPR.
7.1.1 Your data is held in the following places: Outlook (Giacom datacentres utilising Microsoft’s exchange 2013 platforms), Apple Mac mini RAID Server, Apple Mac mini aACE server, GFI Backup cloud servers, Microsoft Windows and Apple Mac desktop computers. Please refer to manufacture’s websites for their full privacy policies by following the links above.
7.2 Data security is very important to Us, and to protect your data We have taken suitable measures to safeguard and secure data collected through Our Site.
7.3 Steps We take to secure and protect your data include:
7.3.1 Using appropriate technical and organisational steps, and will store it on our database within a secure network.
7.3.2 To protect against any data breaches, antivirus and malware protection is installed onto all machines and the drives are encrypted.
8. Do We Share Your Data?
8.1 Subject to section 8.2, We will not share any of your data with any third parties for any purposes.
8.2 In certain circumstances, We may be legally required to share certain data held by Us, which may include your personal data, for example, where We are involved in legal proceedings, where We are complying with legal obligations, a court order, or a governmental authority.
9. What Happens If Our Business Changes Hands?
9.2 In the event that any of your data is to be transferred in such a manner, you will be contacted in advance and informed of the changes. When contacted you will be given the choice to have your data deleted or withheld from the new owner or controller.
10. How Can You Control Your Data?
10.1 In addition to your rights under the GDPR, set out in section 4, when you submit personal data via Our Site, you may be given options to restrict Our use of your data. In particular, We aim to give you strong controls on Our use of your data for direct marketing purposes (including the ability to opt-out of receiving emails from Us which you may do by unsubscribing using the links provided in Our emails and at the point of providing your details).
10.2 You may also wish to sign up to one or more of the preference services operating in the UK: The Telephone Preference Service (“the TPS”), the Corporate Telephone Preference Service (“the CTPS”), and the Mailing Preference Service (“the MPS”). These may help to prevent you receiving unsolicited marketing. Please note, however, that these services will not prevent you from receiving marketing communications that you have consented to receiving.
11. Your Right to Withhold Information
You may access Our Site without providing any data at all. However, to submit an enquiry on Our Site you may be required to submit or allow for the collection of certain data.
12. How Can You Access Your Data?
You have the right to ask for a copy of any of your personal data held by Us (where such data is held). Under the GDPR, no fee is payable and We will provide any and all information in response to your request free of charge. Please contact Us for more details at firstname.lastname@example.org, or using the contact details below in section 13.
13. Contacting Us