- IMPORTANT INFORMATION AND WHO WE ARE
- THE DATA WE COLLECT ABOUT YOU
- HOW IS YOUR PERSONAL DATA COLLECTED?
- HOW WE USE YOUR PERSONAL DATA
- DISCOLSURE OF YOUR PERSONAL DATA
- INTERNATIONAL TRANSFERS
- DATA SECURITY
- DATA RETENTION
- YOUR LEGAL RIGHTS
- Vohkus Limited 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 visit our website (regardless of where you visit it from) and tell you about your privacy rights and how the law protects you.
- You can download a pdf version of the policy here. Please also use the Glossary at the end to understand the meaning of some of the terms used in this privacy notice.
- This privacy notice aims to give you information on how Vohkus Limited collects and processes your personal data through your use of this website. This website is not intended for use by persons under the age of 18. We do not knowingly collect data relating to anyone under the age of 18 through the use of this website.
- 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.
- You have the right to make a complaint at any time to the Information Commissioner's Office ("ICO"), the UK supervisory authority for data protections issues (ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.
WHO WE ARE
- Vohkus Limited is responsible as the ‘controller' for your personal data (referred to as "Vohkus", "we", "us" or "our" in this privacy notice) which is collected and processes through your use of this website. Vohkus is a value added reseller company incorporated under company number 04142508 and registered with the Information Commissioner's office under registratoin number 74270537. Our data protection officer ("DPO") 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 rights, please contact us using the details set out below:
The Data Protection Officer
Centurion House, Barnes Wallis Road, Segensworth, Hampshire PO15 5TT
Tel: 0845 647 3020
- This 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.
THE DATA WE COLLECT ABOUT YOU
- Personal data, or personal information, means any information about a living individual from which that person can be identified. It does not include data where the identity has been removed, which is anonymous data. We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:
- Identity Data includes: first name, maiden name, last name, username or similar identifier, marital status, title, date of birth, gender
- Contact Data includes: billing address, delivery address, 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 products and services you have purchased from us
- Technical Data includes: internet protocol ("IP") address, 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, purchases or orders made by you, your interests, preferences, feedback and survey responses
- Usage Data includes: information about how you use our website, products and services
- Marketing and Communications Dataincludes: your preferences in receiving marketing from us and our third parties and your communication preferences.
- 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 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 will not collect Special Categories of Personal Data about you ("sensitive personal data"). Sensitive personal data 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. Neither will we collect information about criminal convictions and offences.
If you fail to provide personal data
- Where we need to collect personal data by law, or under the terms of a contract we have with your company and you fail to provide the data when requested, we may not be able to perform the contract we have or are trying to enter into. In this case, we may have to terminate our services but we will notify you if this is the case at the time.
HOW IS YOUR PERSONAL DATA COLLECTED?
- We use different methods to collect data from and about you including:
- Direct interactions: You or your company may give us details of your identity, address, by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when:
- we are engaged to provide you with goods and/or services
- we are contacted through our website or social media
- a subscription to our services or publications is taken out
- marketing is requested to be sent to you
- a competition, promotion or survey is entered or completed
- Third parties or publicly available sources: We may receive personal data about you from various third parties and public sources as set out below:
- business information providers, such as MintUK,
- analytics providers, such as Google Analytics
- other publicly available sources, such as Companies House, LinkedIn.
HOW WE USE YOUR PERSONAL DATA
- Where we need to perform the contract we are about to enter into or have entered into with your company.
- 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.
- See the section below on the types of lawful basis that we will rely on to process your personal data.
- Generally we do not rely on consent as a legal basis for processing your personal data other than in relation to sending third party direct marketing communication to you via email or text message. You have the right to withdraw consent to marketing at any time by unsubscribing from the communication you receive or contacting us at firstname.lastname@example.org.
- 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. Please contact us at email@example.com if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out.
Type of data
Lawful basis for processing including basis of legitimate interest
To register your company as a new client
(c) Usage Data
(a) Performance of a contract with you
In providing goods and services, including:
(a) delivering goods to your company
(b) providing services to you in relation to those goods
(c) retaining information after the matter has come to an end
(d) Marketing and Communications
(a) Performance of a contract with you
(b) Necessary for our legitimate interests (to provide services to your company) except where such interests are overridden by your interests or fundamental rights and freedoms
To manage our relationship with you which will include:
(b) asking you to leave a review or take a survey
(d) Marketing and Communications
(a) Performance of a contract with you
(b) Necessary to comply with a legal obligation
(c) Necessary for our legitimate interests (to keep our records updated and to study how customers use our products/services)
To enable you to partake in a prize draw, competition or complete a survey
(e) Marketing and Communications
(a) Performance of a contract with you
(b) Necessary for our legitimate interests (to study how customers use our products/services, to develop them and grow our business)
To administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)
(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
(e) Marketing and Communications
(a) Necessary for our legitimate interests (to study how customers use our products/services, to develop them, to grow our business and to inform our marketing strategy)
To use data analytics to improve our website, products/services, marketing, customer relationships and experiences
(a) Necessary for our legitimate interests (to define types of customers for our products 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 goods or services that may be of interest to you
(a) Necessary for our legitimate interests (to develop our products/services and grow our business)
- We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising. You have the right to withdraw consent to marketing at any time by contacting us at firstname.lastname@example.org.
Promotional offers from us
- We may use your Identity, Contact, Technical, Usage and Profile Data to form a view on what we think your business may want or need, or what may be of interest. This is how we decide which services and offers may be relevant for your business (we call this marketing).
- You will receive marketing communications from us if you have requested information from us or purchased services from us and, in each case, you have opted in to receive that marketing. If you do not wish to receive marketing communications from us please contact us at email@example.com or follow the unsubscribe option in the communication you receive from us.
- We will not share your personal data with any other company for marketing purposes without first asking you for your express opt-in consent.
- You can ask us or Internal Third Parties to stop sending you marketing messages at any time by contacting us at any time on firstname.lastname@example.org or following the unsubscribe option in the communication you receive from us.
- Where you opt out of receiving these marketing messages, this will not affect the lawful reasons we have for processing your personal data you have provided to us as a result of the services we are providing to you.
- When interacting with us on social media, your username and public-facing information are available for us to view. You have the right to ask us to delete this personal data, however, as the data is transferred from the social networks it may not be feasible for us to fully delete the information.
- Facebook: Our website may use Facebook's advertising service known as "Facebook lookalike audiences" if you have informed Facebook that you use our platforms. Facebook lookalike may allow us to identify new potential customers and users of our platforms and products on the basis that those new potential users share similar characteristics with you on Facebook, for example, on the basis that both users have "liked" the same Facebook pages. We may therefore share your name and email address with Facebook if you have logged into the platforms via your Facebook account, or have downloaded our platforms onto your device through a Facebook advertisement. More information about Facebook lookalike audiences can be found at https://www.facebook.com/full_data_use_policy
- Twitter: Functions of the Twitter service are integrated on our website. These features are available through Twitter Inc., 1355 Market Street, Suite 900, San Francisco, CA 94103, USA. When interacting with us on Twitter, your username and public-facing information are available for us to view and conversations or ‘Re-Tweets' can be stored. More information about the Twitter Privacy Notice can be found at https://twitter.com/privacy
Change of purpose
- We will only use your personal data for the purpose 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 get 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 or we will ask for your consent.
- 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.
DISCLOSURE 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 above.
- Internal Third Parties as defined in the Glossary below
- External Third Parties as defined in the Glossary below.
- Specific third parties in connection with the purposes set out in the table above.
- 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 given them permission to process your personal data for specified purposes and in accordance with our instructions.
- We do not transfer your personal data outside the European Economic Area("EEA"). In the event your personal data is to be transferred to one of our suppliers based outside the EEA, we will ensure that a similar degree of protection is afforded by ensuring at least one of the following safeguards is implemented:
- 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 Europe and the US.
- 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.
- 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 the section below for further information on your legal rights.
- 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.
YOUR LEGAL RIGHTS
Under certain circumstances, you have rights under data protection laws in relation to your personal data as follows:
- 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 your personal data – thus enabling 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 – thereby enabling 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, 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 – thereby enabling 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 transfer of your personal data – whether to you or to a third party. We will provide 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.
- Right to 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 consent. If you withdraw consent, we may not be able to provide certain products or services to you, or to complete the contract for which we were retained. We will advise you if this is the case at the time you withdraw your consent.
- If you wish to exercise any of these rights set out above, please contact our DPO, David Boniface, on firstname.lastname@example.org. If we have reasonable doubts concerning your identity we may request the provision of additional information to confirm your identity.
No fee usually required
- You do 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 for the administrative costs of complying with your request if it is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in those 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 within one month and keep you updated.
- 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 interest. 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.
- Performance of Contract means processing your data where it is necessary for the performance of a contract to which you are a party or take steps at your request before entering into such a contract.
- 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.
- Internal third parties means other companies owned or controlled by Vohkus Limited (acting as joint controllers or processors) and who are based in England and provide system and administering services to Vohkus Limited.
- External third parties means:
- Service providers (acting as processors) based in the EEA and who provide delivery and courier services, or IT and system administration services.
- Professional advisers (acting as processors), including lawyers, auditors, insurers, and other professional experts based in the EEA who provide consultancy, banking legal, expert, insurance and accounting services.
- HM Revenue & Customs, Information Commissioner's Office, regulators and authorities (acting as processors or joint controllers) based in the United Kingdom, and who require reporting of processing activities in certain circumstances.
- Other third parties who in our opinion need to be involved in the best interests of our provision of goods and services.
This website is operated by Vohkus Limited.
This policy describes what information the cookies on this website gather, how we use that information and why we sometimes need to store these cookies.
This policy also lets you know how you can prevent these cookies from being stored, however, please be aware that doing this may downgrade or ‘break' certain elements of the website's functionality and may affect your use and experience of our website.
- improve the user experience of our website;
- tell us which parts of the website the users have visited;
- provide enhanced services; and
- remember the location and language settings for individual users.
THE COOKIES WE SET
The cookies we place on your device fall into the following categories:
- Strictly necessary cookies
These cookies are essential for you to be able to navigate our website and use its features. This category of cookies cannot be disabled.
- Performance cookies
These cookies collect information about how you use our website, e.g. which pages you go to most often. These cookies do not collect personal information about you. All information collected by these cookies is aggregated and anonymous and is only used to improve how our website works.
- Session cookies:
These allow our website to link your actions during a particular browser session. These expire each time you close your browser and do not remain on your device afterwards
- Persistent cookies
These are stored on your device in between browser sessions. These allow your preferences or actions across our website to be remembered. These will remain on your device until they expire, or you delete them from your cache.
IN PARTICULAR OUR WEBSITE USES:
Users can set preferences for how Google advertises to you using Google Ad Settings page. Alternatively you can opt-out by visiting the Network Advertising Initiative Opt Out page (https://www.networkadvertising.org/understanding-online-advertising/what-are-my-options/) or by using the Google Analytics Opt Out Browser add-on (https://tools.google.com/dlpage/gaoptout).
|_ga||This cookie name is asssociated with Google Universal Analytics - which is a significant update to Google's more commonly used analytics service. This cookie is used to distinguish unique users by assigning a randomly generated number as a client identifier. It is included in each page request in a site and used to calculate visitor, session and campaign data for the sites analytics reports.|
|_gat_UA-141502869-1||This is a pattern type cookie set by Google Analytics, where the pattern element on the name contains the unique identity number of the account or website it relates to. Used to limit the amount of data recorded by Google on high traffic volume websites.|
|_gid||This cookie name is asssociated with Google Universal Analytics. This appears to be a new cookie and as of Spring 2017 no information is available from Google. It appears to store and update a unique value for each page visited.|
Further reference: Google Analytics Cookie Usage on Websites
HubSpot uses log files. Log files may collect demographic information from you, for example age, gender or interests. They may also collect information about your computer hardware and software. This can include your IP addresses, device and software identifiers, referring and exit URLs, on-site behavior, feature use metrics and statistics. This information is used for the Subscription Service. For these purposes, we do link this automatically-collected data to Personal Information such as name, email address and phone number.
We may collect navigational information when you visit HubSpot hosted pages. The navigational information is used to improve your experience of using the website and ease navigation around the site.
The HubSpot Acceptable Use Policy applies to our website and prohibits the use of our website to send unsolicited commercial email in violation of applicable laws, and requires the inclusion in every email sent using the Subscription Service to have an "opt-out" mechanism.
Hubspot Cookies used on the Vohkus Shop
|_hssc||This cookie keeps track of sessions. This is used to determine if HubSpot should increment the session number and timestamps in the __hstc cookie. It contains the domain, viewCount (increments each pageView in a session), and session start timestamp.|
|_hssrc||Whenever HubSpot changes the session cookie, this cookie is also set to determine if the visitor has restarted their browser. If this cookie does not exist when HubSpot manages cookies, it is considered a new session.|
|_htsc||The main cookie for tracking visitors. It contains the domain, utk, initial timestamp (first visit), last timestamp (last visit), current timestamp (this visit), and session number (increments for each subsequent session).|
|hubspotutk||Keeps track of a visitor's
identity. This cookie is passed to the marketing platform HubSpot on form
submission and used when de-duplicating contacts.
Further reference: Cookies set in a visitor's browser by HubSpot
Pages of our website are hosted in England and by HubSpot whose registered address is: 25 First Street, 2nd Floor, Cambridge, MA 02141, USA. Data captured and obtained within the UK may be processed outside of the UK. HubSpot is a certified participant of the EU-US Privacy Shield Framework. A copy of their certificate can be found at https://www.privacyshield.gov/participant?id=a2zt0000000TN8pAAG&status=Active.
For complete information about every cookie we use, please email firstname.lastname@example.org.
The table below lists the e-commerce cookies we collect and what information they store.
|Cookie Name||Cookie Description|
|FORM_KEY||Stores randomly generated key used to prevent forged requests.|
|PHPSESSID||Your session ID on the server.|
|GUEST-VIEW||Allows guests to view and edit their orders.|
|PERSISTENT_SHOPPING_CART||A link to information about your cart and viewing history, if you have asked for this.|
|STF||Information on products you have emailed to friends.|
|STORE||The store view or language you have selected.|
|MAGE-CACHE-SESSID||Facilitates caching of content on the browser to make pages load faster.|
|MAGE-CACHE-STORAGE||Facilitates caching of content on the browser to make pages load faster.|
|MAGE-CACHE-STORAGE-SECTION-INVALIDATION||Facilitates caching of content on the browser to make pages load faster.|
|MAGE-CACHE-TIMEOUT||Facilitates caching of content on the browser to make pages load faster.|
|SECTION-DATA-IDS||Facilitates caching of content on the browser to make pages load faster.|
|PRIVATE_CONTENT_VERSION||Facilitates caching of content on the browser to make pages load faster.|
|X-MAGENTO-VARY||Facilitates caching of content on the server to make pages load faster.|
|MAGE-TRANSLATION-FILE-VERSION||Facilitates translation of content to other languages.|
|MAGE-TRANSLATION-STORAGE||Facilitates translation of content to other languages.|
Most devices automatically accept cookies but you can change your browser settings to restrict, block or delete cookies if you want. Each browser is different, so check the 'Help' menu of your particular browser (or your mobile phone's handset manual) to learn how to change your cookie preferences. Many browsers have universal privacy settings for you to choose from.
Most web browsers allow some control of most cookies through the browser settings. You may refuse to accept cookies by activating the settings on your browser. However, if you select this setting you may be unable to access certain parts of our website.
If there is something that you are not sure whether you need or not it is usually safer to leave cookies enabled in case it does interact with one of the features you use on our site. However, if you are still looking for more information then please contact us today for more information at email@example.com.
Alternatively, a number of websites provide detailed information on cookies, including Aboutcookies.org and Allaboutcookies.org
CHANGES TO THIS POLICY
This policy was last updated on 15 October 2018.
GDPR ARTICLE 28 POLICY
- Vohkus Limited takes the protection of ‘personal data' (as defined in the EU's General Data Protection Regulations 2016/679 ("Regulations")) and the rights of individuals very seriously.
- As part of its policy of openness and transparency, Vohkus Limited has decided to publish this policy about its ‘processing' activities in connection with ‘personal data' it might receive from a data ‘controller'. This Policy incorporates in full the wording of Article 28 of the Regulations. It will form part of the terms and conditions upon which Vohkus Limited (the data ‘processor') will contract with a data ‘controller'. This Policy complies with the requirement of Article 28 of the Regulations for there to be a contract in writing between the ‘controller' and ‘processor'.
- All terms in this Policy will have the same definitions which are in the Regulations.
WHAT TYPES OF PERSONAL DATA MIGHT BE PROCESSED
- Because of the nature of the goods and services provided by Vohkus Limited, the types of ‘personal data' it receives from a ‘controller' will be the ‘personal data' of the staff of the ‘controller', and typically this is limited to: name, business email address, business telephone number.
- Vohkus Limited will retain such ‘personal data' for as long as the agreement with the ‘controller' continues, whereupon it will be deleted or, if retained, it will be anonymised such that it cannot be used on its own or in conjunction with any other information to identify a data subject.
- If you wish to access your ‘personal data' or exercise any of your rights under the Regulations you should submit your request to the ‘controller' in accordance with Chapter III of the Regulations.
HOW WILL VOHKUS LIMITED PROCESS PERSONAL DATA RECEIVED FROM A CONTROLLER
- In compliance with Article 28 of the Regulations, Vohkus Limited will process ‘personal data' it receives from a ‘controller' in the following ways:
- Vohkus Limited guarantees to implement appropriate technical and organisational measures such that the ‘processing' of the ‘personal data' will be in accordance with the requirements of the Regulations, the Data Protection Act 2018 ("the Act"), and all applicable law and legislation relating to the protection of ‘personal data', and such that the measures will also protect the rights of data subjects.
- Vohkus Limited will not engage another ‘processor' without prior specific or general written authorisation of the ‘controller'.
- A further contract may be entered with the ‘controller' if necessary to set out: (i) a wider category of subject-matter of the ‘processing', (ii) a wider nature and purpose of the ‘processing', (iii) a wider type of ‘personal data' and categories of ‘data subjects', and/or (iv) any additional obligations and rights of the ‘controller'.
- Vohkus Limited will only process ‘personal data' on documented instructions from the ‘controller', unless required to do so by applicable law in which case Vohkus Limited will notify the ‘controller' unless prohibited from doing so by law on the grounds of public interest.
- Vohkus Limited will ensure that anyone who is authorised to process ‘personal data' on behalf of the ‘controller' owes a duty of confidentiality or are under a statutory obligation of confidentiality in relation to the ‘personal data'.
- Vohkus Limited will implement appropriate technical and organisational measures to ensure a level of security appropriate to the risk (in accordance with Article 32 of the Regulations).
- Where Vohkus Limited engages another ‘processor' to carry out specific processing activities on behalf of the ‘controller' the same data protection obligations as set out in this Policy and any other contract with the ‘controller' shall be imposed on the other ‘processor'.
- If the other processor fails to fulfil its data protection obligations Vohkus Limited shall remain fully liable to the ‘controller' for the performance of the obligations of the other ‘processor'.
- Given the nature of the ‘processing' Vohkus Limited will assist the ‘controller' by appropriate technical and organisational measures, insofar as is possible, in complying with a response to a request from a ‘data subject' exercising his/her rights in accordance with Chapter III of the Regulations.
- Taking into account the nature of ‘processing' and the information disclosed, Vohkus Limited will assist the ‘controller' in complying with the obligations in Articles 32-36 of the Regulations to: (i) keep the ‘processing' secure; (ii) notify a breach to the relevant supervisory authority; (iii) notify a breach to the relevant ‘data subjects'; (iv) conduct a data protection impact assessment when appropriate to do so; and (v) notify the relevant supervisory authority where an impact assessment suggests the ‘processing' will result in a high risk to ‘data subjects' without measures being put in place.
- If requested to do so by the ‘controller' Vohkus Limited will delete or return all ‘personal data' once the services being provided have come to an end, unless some other applicable law requires the ‘personal data' to be stored. This does not affect the right of Vohkus Limited to keep any such ‘personal data' after such date in anonymised form.
- Vohkus Limited will make all information available to the ‘controller' necessary to demonstrate compliance with the obligations in Article 28 of the Regulations, and will allow for and contribute to audits and inspections. In the event such an instruction infringes the Regulations Vohkus Limited will notify the ‘controller' accordingly.
- Vohkus Limited will comply fully with its requirements, duties and obligations under Article 28 of the Regulations, the Act and all applicable law and legislation relating to the protection of ‘personal data'.
This Policy became effective on 25 May 2018. Any queries relating to this Policy or the processing of personal data should be sent to our DPO, Mr David Boniface, at firstname.lastname@example.org.