GDPR: Data Privacy Notice For Customers and Clients - Introduction
RUGGED MOBILE Systems Ltd ("We") respect your privacy and your rights to control your personal data. We are committed to providing clear information about the types of data we collect and our reasons for collecting it and are committed to protecting and respecting your privacy as an individual.
RUGGED MOBILE Systems Ltd primary purpose for collecting personal data is to provide ongoing support and assistance to our clients, and to communicate with prospective clients in accordance with our legitimate business interests.
This policy (together with any other documents referred within it) sets out the basis on which any personal data we collect from you, or that you provide to us, will be processed by us. Please read the following carefully to understand our views and practices regarding your personal data and how we will treat it.
We do not sell personal data to third parties.
The rules on processing of personal data are set out in the General Data Protection Regulations 2018 (the “GDPR”).
1. Definitions for the purpose of GDPR
Data controller - A controller determines the purposes and means of processing personal data.
Data processor - A processor is responsible for processing personal data on behalf of a controller.
Data subject – Natural person
Categories of data: Personal data and special categories of personal data
Personal data - The GDPR applies to ‘personal data’ meaning any information relating to an identifiable person who can be directly or indirectly identified in particular by reference to an identifier (as explained in Article 6 of GDPR). For example name, passport number, home address or private email address. Online identifiers include IP addresses and cookies.
Special categories personal data - The GDPR refers to sensitive personal data as ‘special categories of personal data’ (as explained in Article 9 of GDPR). The special categories specifically include genetic data, and biometric data where processed to uniquely identify an individual. Other examples include racial and ethnic origin, sexual orientation, health data, trade union membership, political opinions, religious or philosophical beliefs.
Processing - means any operation or set of operations which is performed on personal data or on sets of personal data, whether or not by automated means, such as collection, recording, organisation, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction.
Third party - means a natural or legal person, public authority, agency or body other than the data subject, controller, processor and persons who, under the direct authority of the controller or processor, are authorised to process personal data.
2. Who are we?
RUGGED MOBILE Systems Ltd is the data controller. This means we decide how your personal data is processed and for what purposes. Our contact details are: RUGGED MOBILE Systems Ltd, Park View Business Centre, Combermere, Whitchurch, SY13 4AL . For all data matters contact us on email@example.com .
3. The purpose(s) of processing your personal data
We use your personal data for the following purposes:
- To enable us to enter into contracts with your company or organisation, and meet our obligations within those contracts
- To enable us to deliver the products and services associated with contacts we have with your company or organisation
- To follow up on contacts made by your company or organisation through various channels including formal tender notices, informal tender requests, events and exhibitions and conferences, visiting our website, telephone contact etc.
- To enable us to contact you to identify and/or tender for appropriate business opportunities within your company or organisation
- To contact you about products and services that we reasonably believe to be of interest to your company or organisation
4. The categories of personal data concerned
With reference to the categories of personal data described in the GDPR definitions section above, we process the following categories of your data:
- Personal data [for example your name, work address, telephone and work email address]
- Special categories of data [for example data regarding your ethnic origin or race; political or philosophical beliefs; your health and details of any disability or long term ill-health].
Personal Data we hold may include some of, if not all of, the following:
- Your name
- Your company address, company email address and company telephone number and mobile telephone number
- Your job title
- Your company payment and delivery history, including billing and delivery addresses
- Site name and address
- Any other information you provide
Specialised categories of data will not be collected or processed by us, except for details of health and disability information that may be specifically needed to facilitate safe and appropriate events, such as meetings and visits etc. Such information will only be obtained when needed and will not be retained beyond the time of such events.
We have obtained your personal data from you either directly or through our partners who are, or potentially will be, providing a service to you.
5. What is our legal basis for processing your personal data?
There are different legal bases that we rely on to use your personal information, namely:
Performance of a contract
The use of your personal information is necessary to perform any contract you have with us. For example, to complete your purchase, or lease, of a product or service, to help with delivery, to handle returns and to ensure your product performs its basic functions in a secure way.
We may use your personal information for our legitimate business interests.
For example, we rely on our legitimate interest to analyse and improve products and/or services, to improve performance, content and functionality on our websites, to send you notifications about hardware, software or firmware updates, or to use your personal information for administrative, fraud detection or legal purposes.
We may process data to produce marketing communications on the grounds that the recipient has a legitimate interest in, or requirement for, our products and services. In all instances where we use our legitimate interests in this regard, we complete a Legitimate Interest Assessment (LIA) and balance our business interests against individual’s rights as described by the ICO.
Where we process your personal information based on our legitimate interest we will provide an opt-out mechanism. Please contact us to request a copy of our Legitimate Interest GDPR LIA Compliance document at firstname.lastname@example.org.
Should you be unable to locate the opt-out mechanism in any communication you receive from us, you may exercise your right to object by sending an email to email@example.com .
6. How we use personal information
We use your personal data listed above for the following purposes:
- Providing you with products or services
- Customer Support
- Product Improvement
- Security, Safety, and Dispute Resolution
- Business Operations
- Communication and Marketing
Providing you with products or services
We use your personal data to establish and fulfil a contract with you, for example, if you make a purchase from us or enter into an agreement to receive our products or services on a lease or rental basis.
This data allows us to verify your identity, take payments, communicate with you, provide technical support, and arrange the delivery or other provision of products or services.
This processing is necessary for us to perform a contract.
We use personal data to respond to incoming support requests, diagnose product or service problems, assist in the repair of products and provide other customer care and support services.
This processing is necessary for us to provide pre-contract/pre-sales support, to perform a contract, or to provide continued support outside of a contract term.
Product and Service Improvement
We use data to help develop and improve the range of products and services that we offer, including assessing performance requirements, the need for adding new products or features or capabilities. This processing is necessary to serve our legitimate interest.
Security, Safety and Dispute Resolution
We use data to protect the security and safety of our products and our customers, to detect and prevent fraud, to resolve disputes and enforce our agreements. This processing is necessary to serve our legitimate interest.
We use data to develop aggregate analysis and business intelligence that enable us to operate, protect, make informed decisions, and report on the performance of our business. This processing is necessary to serve our legitimate interest.
Communication and Marketing
We use the data we collect to deliver and personalise our communications with you. For example, we may contact you by email or other means of direct or electronic communication to inform you about new products or services, upcoming events, security or software updates, update you on a support issue, invite you to take part in a survey, or inform you of special offers. This processing is necessary to serve our legitimate interest.
- Your Rights
- Your Communication and Marketing Preferences
7. How We May Share Personal Information
Your personal data will be treated as strictly confidential and will be shared (minimum levels required only) with our Third Party suppliers and partners to enable us to provide the service(s) requested.
We will only share your data for performance of a contract, or associated support services, or in pre-sales or pre-contract situations where there is a business or legal need for other of our business partner companies such as: equipment manufacturers; distributors/suppliers; software providers; installation subcontractors; leasing brokers etc., to be involved. In such cases we will only share your personal data where we have obtained your authorisation to do so.
We will ensure that all such partners also have a GDPR policy in place.
For questions about third-party vendors, please send an email to firstname.lastname@example.org
8. Security, Storage and Retention of Personal Information
RUGGED MOBILE Systems Ltd has a commitment to the security of data. We have processes and procedures in place that are regularly reviewed to ensure the protection of your data.
We have in place precautionary measures to help prevent information about you from loss, theft, misuse and unauthorised access, disclosure, alteration and destruction.
For example, we store the personal data you provide on computer systems that have limited access and that are in secure facilities. Additionally, your data is protected with encryption.
Personal data collected by RUGGED MOBILE Systems Ltd will be stored and processed in the United Kingdom.
We will retain your personal information for as long as we deem it necessary, to enable us to provide continued support to your organisation, and, to comply with applicable laws.
9. How long do we keep your personal data?
We keep your personal data for no longer than reasonably necessary.
10. Your rights and your personal data
Unless subject to an exemption under the GDPR, you have the following rights with respect to your personal data:
- The right to request a copy of the personal data which we hold about you;
- The right to request that we correct any personal data if it is found to be inaccurate or out of date;
- The right to request your personal data is erased where it is no longer necessary to retain such data;
- The right to withdraw your consent to the processing at any time, where consent was your lawful basis for processing the data;
- The right to request that we provide you with your personal data and where possible, to transmit that data directly to another data controller, (known as the right to data portability), (where applicable i.e. where the processing is based on consent or is necessary for the performance of a contract with the data subject and where the data controller processes the data by automated means);
- The right, where there is a dispute in relation to the accuracy or processing of your personal data, to request a restriction is placed on further processing;
- The right to object to the processing of personal data, (where applicable i.e. where processing is based on legitimate interests or the performance of a task in the public interest/exercise of official authority; direct marketing and processing for the purposes of scientific/historical research and statistics).
Where we process your personal information based on legitimate interest you have the right to object at any time to that use of your personal information.
We rely on you to ensure that your personal information is complete, accurate and up to date. Please do inform us promptly of any changes to or inaccuracies in your personal information by contacting email@example.com. We will respond to your request within 30 days.
We are committed to working with you to obtain a fair resolution of any complaint or concern you may have about our use of your personal information. To exercise all relevant rights, queries or complaints please in the first instance contact our Managing Director on email address firstname.lastname@example.org or in writing at RUGGED MOBILE Systems Ltd, Park View Business Centre, Combermere, Whitchurch, Shropshire SY13 4AL.
If this does not resolve your complaint to your satisfaction, you have the right to lodge a complaint with the Information Commissioners Office on 0303 1231113 or via email https://ico.org.uk/global/contact-us/email/ or at the Information Commissioner's Office, Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF, England.
11. Your Communication and Marketing Preferences
Every marketing communication sent to you from RUGGED MOBILE Systems Ltd will contain a link for you to ‘opt-out’ of receiving further correspondence. You can also opt out of receiving email marketing messages by contacting email@example.com and ask to be removed from any and all subscription lists. We respect your choice, and we will no longer send you promotional emails once you unsubscribe.
Please note, regardless of any amends you make to your marketing and communication setting, we will continue to communicate with you regarding any changes to RUGGED MOBILE Systems Ltd terms and conditions, policy updates, software or firmware updates, routine customer service messages such as information about current or past purchase, delivery of products, data breaches or other significant information about a product you own such as airtime and warranty expiration, safety issues and product recalls.
A cookie is a small data file containing a string of characters that is sent to your computer when you visit a website. When you visit the website again, the cookie allows that site to recognise your browser. The length of time a cookie will stay on your computer or mobile device depends on whether it is a "persistent" or "session" cookie. We can potentially use both types of cookies.
Session cookies will only stay on your device until you stop browsing. Persistent cookies stay on your computer or mobile device until they expire or are deleted. We use the following types of cookies on our website.
• Strictly necessary cookies. These cookies are essential for you to browse our website and use its features.
• Performance cookies. These cookies collect information about how you use our websites. This data may be used to help optimise our website and make it easier for you to navigate.
• Functional cookies. These cookies allow our websites to remember choices you make while browsing and personalise your experience. We may store your geographic location in a cookie for instance, to ensure that we show you the website relevant to your area.
• Analytics cookies. We use analytics cookies, like those offered by Google Analytics and Lead Forensics, to help us understand things like how long a visitor stays on our website, what pages they find most useful, and how they arrived at our website www.ruggedmobilesystems.co.uk or www.rm-systems.co.uk . To learn more about Google Analytics and your data, visit this Google webpage - https://support.google.com/analytics/answer/6004245
• IP address tracking. RUGGED MOBILE Systems Ltd uses a number of IP tracking tools on its website to measure performance and inform strategic business decisions. These tools include Lead Forensics. To find out more about these tools, and how they comply with GDPR regulations, visit the following links: Lead Forensics: https://blog.leadforensics.com/how-lead-forensics-complies-with-gdpr .
How to control Cookie Settings
Most web browsers allow you to control cookies through their settings preferences. However, if you limit the ability of websites to set cookies, you may impair your overall user experience, as it will no longer be personalised to you. Some browsers offer a “Do Not Track” (“DNT”) signal where you can indicate your preference regarding tracking and cross-site tracking. Although we do not currently employ technology that recognises DNT signals, we will only process your personal data in accordance with this State
11. Transfer of Data Abroad
We do not transfer personal data outside the UK.
13. Automated Decision Making
We do not use any form of automated decision making in our business.
14. Further processing
If we wish to use your personal data for a new purpose, not covered by this Data Privacy Notice, then we will provide you with a new notice explaining this new use prior to commencing the processing and setting out the relevant purposes and processing conditions.
This policy was updated in May 2018 by RUGGED MOBILE Systems Ltd.