Sabre Plastics Tooling Ltd 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 either engage us to provide services to you or visit our website (regardless of where you visit it from) and tell you about your privacy rights and how the law protects you.
This privacy notice is provided in a layered format so that you can click through to the specific areas set out below. Please also use the Glossary to understand the meaning of some of the terms used in this privacy notice.
1. IMPORTANT INFORMATION AND WHO WE ARE
PURPOSE OF THIS PRIVACY NOTICE
This privacy notice aims to give you information on how Sabre Plastics Tooling Ltd collects and processes your personal data when you engage us to provide services to you or when you use our website, including any data you may provide through our website when you sign up to access certain features or receive particular materials. Sabre Plastics Tooling Ltd operates the website and will be responsible for the control and processing of any personal data collected through your use of the website. The Sabre Plastics Tooling Ltd entity that provides services to you will be responsible for your personal data provided in relation to those services.
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.
Sabre Plastics Tooling Ltd (or, where applicable, the associated entity that provides services to you) is the controller and responsible for your personal data (collectively referred to as “we”, “us” or “our” in this privacy notice).
We have appointed a data privacy officer 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 data privacy officer using the details set out below.
Details of Sabre Plastics Tooling Ltd and our data privacy officer are set out in this section.
- Full name of legal entity: Sabre Plastics Tooling Ltd
- Name or title of data privacy officer: Robin Stimson
- Email address: email@example.com
- Postal address: Sabre Plastics Tooling Ltd, Unit 5 Jubilee Trading Estate, Jubilee Road, Letchworth, Herts. SG6 1SP
- Telephone number: +44 (0)1462 484 648
If you have concerns about the way in which we have dealt with your personal data, you may make a complaint to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk) or, where applicable, to the corresponding supervisory authority in Denmark or Sweden, as the case may be. 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 1st June 2020 and historic versions can be obtained by contacting us.
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. You may do this by contacting us at firstname.lastname@example.org.
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 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).
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, last name and title.
- Contact Data includes email address and telephone numbers.
- Financial Data includes bank account and payment card details.
- Transaction Data includes details about payments to and from you and other details of services we have provided to you.
- Technical Data includes internet protocol (IP) addresses, 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 this website.
- Profile Data includes your username and password (where applicable), your interests, preferences, feedback and survey responses.
- Usage Data includes information about how you use our website and services.
- Marketing and Communications Data includes your preferences as regards the marketing communications that you would like to receive from us and the ways in which you would like to receive them.
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 clients using a particular service or 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 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). Nor do we collect any information about criminal convictions and offences.
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 and Contact Data by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:
- instruct us in relation to a matter;
- subscribe to any service that we provide or to any of our publications;
- request marketing to be sent to you;
- complete a survey;
- give us some feedback; or
- attend an event that we run or that we host for someone else.
- 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 analytics providers such as Lead Forensics and Google based outside the EU;
- Contact, Financial and Transaction Data from providers of technical services based inside or outside the EU.
- Identity and Contact Data from publicly availably sources such as Companies House and the Electoral Register based inside the EU.
- Identity Data and Contact Data from organisers of events hosted by us.
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 that we are about to enter into, or have entered into, with you for the provision of our services.
- 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 marketing communications to you including via email. You have the right to withdraw consent to marketing at any time by contacting us at email@example.com.
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.
|Purpose/Activity||Type of data||Lawful basis for processing including basis of legitimate interest|
|Where applicable, to set you up as a client and to provide our services to you including:(a) Managing payments, fees and charges; and(b) Collecting and recovering 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 recover debts due to us)|
|To enable you to complete a survey||(a) Identity(b) Contact(c) Profile(d) Usage(e) Marketing and communications||(a) Necessary for our legitimate interests (to study how clients or website visitors use our services or website, to develop those services and website andto 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, to prevent fraud and in the context of a business reorganisation or group restructuring exercise)(b) 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||(a) Identity(b) Contact(c) Profile(d) Usage(e) Marketing and communications(f) Technical||Necessary for our legitimate interests (to study how clients and other visitors use the website, to develop our website, to grow our business and to inform our marketing strategy)|
|To use data analytics to improve our website, products/services, marketing, client relationships and experiences||(a) Technical(b) Usage||Necessary for our legitimate interests (to define types of clients for our 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 our 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 services and grow our business)|
We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising.
We may use your Identity, Contact, Technical, Usage and Profile 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 services may be relevant for you.
You will only receive marketing communications from us if you have opted to receive such communications.
You can ask us to stop sending you marketing messages by contacting us at any time at firstname.lastname@example.org or by using the unsubscribe link in our marketing emails.
CHANGING 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 receive an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us at email@example.com.
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.
- 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 will not transfer your personal data outside the European Economic Area (EEA) except where we need to transfer such data to professional advisers based outside the EEA in order that we can perform our contract to provide certain services to you or obtain the provision of services for you.
If we do transfer your personal data outside the EEA, then:
- 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;
- 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.
- 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.
Please contact us if you would like further information on the specific mechanism used by us when transferring your personal data out of the EEA.
7. DATA SECRUITY
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.
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 including:
- 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 at firstname.lastname@example.org.
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.
A cookie is a small file of letter and numbers that we store on your browser or the hard drive of your computer if you agree. Cookies contain information that is transferred to your computer’s hard drive.
- Enable functionality on the site
- Allow you to share pages with social networks
- Track website usage, so we can continue to improve our website for you
- Provide information from third-party services
By continuing to use this website after seeing our notice and/or reading this page you are indicating that you are happy for us to set cookies in your browser in line with this document. If you wish to use this site but would like us not to set cookies in your browser, you can learn how to disable or remove cookies below. Please note however that doing so may prevent you from using certain functionality of this site.
OUR OWN COOKIES
We set our own (first-party) cookies to achieve the following:
- Determining if you are logged in or not
- Remembering if you’ve set any preferences on the site
To stop us setting these cookies, you will need to set up your browser to reject all cookies.
Our site may from time to time include functionality provided by other websites, such as YouTube videos, or images located on third-party servers. These third parties may set cookies that we have no control over.
We use services on our website that may set third-party cookies, examples of which are:
- Social media action buttons
- Embedded videos
- Embedded Google maps
- Google Analytics
ANONYMOUS VISITOR STATISTICS COOKIES
We use the services provided by Google Analytics and Lead Forensics to track visitors and build up a picture of how visitors use our website, where they have come from, the pages they visit etc. In order to do this, Google analytics will set up to three cookies on your browser. No personally identifiable information is stored, and all the data we receive is anonymous.
TURNING COOKIES OFF
In all modern browsers, you may elect to reject cookies. Please note, however, that by doing so, parts of our website may no longer function as expected. If your concerns are based around third party cookies, then we recommend you reject only those cookies, rather than all cookies, so that we can still provide you with the functionality you expect.
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 at email@example.com.
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.
External Third Parties:
- Service providers acting as processors located in the UK and elsewhere who provide IT and system administration services, CRM systems, printing, marketing and PR services, credit references.
- Professional advisers acting as processors or joint controllers including overseas patent and trade mark attorneys, lawyers, bankers, auditors and insurers whom we instruct to provide services to you either on their own account or as our sub-contractors.
- 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.
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 services to you. We will advise you if this is the case at the time you withdraw your consent.