Thewallcladdingstore.co.uk Privacy and Data Protection Policy and Notice
Last Updated: Aug 16, 2020
The Wallcladding store and its affiliates (including wholly and partially owned subsidiaries) ("The Thewallcladding", "we", "our" or the "Company", and their cognates) respects the privacy of its customers, employees and candidates, and is committed to protecting the personal information you may share with us.
We also protect the privacy of our website visitors, site visitors, followers, vendors, service providers, partners and others who come in contact with The Thewallcladding (these and any others with respect to whom we collect personal data, shall collectively be referred to as "Customers" or "you" or “Data Subjects”).
Please read the following carefully to understand our practices regarding your personal data and how we will treat it.
For the purposes of European Union data protection law, including Regulation (EU) 2016/679 – the General Data Protection Regulation (the "GDPR") and the UK Data Protection Act 2018, (together the "Data Protection Law"), The Thewallcladding will usually be a data controller (the "Controller").
1. WHICH INFORMATION DO WE COLLECT, AND HOW?
Summary: we collect Personal Data about you from your transactions with us, like using our websites, visiting our facilities, calling our call center, making a purchase or entering an agreement with us.
One type of Data is non-identifiable and anonymous information ("non-personal data"). We also collect several categories of personal data ("Personal Data"). Personal Data we collect consists of any personal data provided by you, or by an organization you represent or are associated with or through your use of the Websites, or in preparing and executing a contract with Thewallcladding, or when you visit The Thewallcladding facilities or otherwise engage with The Thewallcladding.
For purchases, this generally includes your first and last names, email address, phone numbers, delivery address, billing and payment details, and purchase history.
For marketing emails, this generally includes your first and last names, email address, and your organization, as well as engagement history.
For website visitors, this generally includes online identifiers such as internet protocol (IP) addresses, uniform resource locators (URL), and technical and browsing information such as operating system, type of browser, browser plug-in types and versions, screen resolution, Flash version, time zone setting, the User’s ‘clickstream’ on the website, the period of time the User visited the website, methods used to browse away from a page, and any phone number used to call our customer service number. We likewise may place cookies on your browsing devices (see section 'Cookies' below).
For registered users, this will also include the above details, and browsing and purchasing history, your The Wallcladding store account username and password and usage details, and other information you may choose to provide to The Wallcladding store.
Additionally, we may obtain location data related to the geographic location of your laptop, mobile device or other digital device on which the Websites are used.
The Wallcladding Store may also collect the email addresses of people who communicate with The Wallcladding store via email or via messenger services or other social media platforms or create accounts and login credentials. The Wallcladding store may also collect information of people who call us by phone, including information that enables us to identify the caller and follow-up on the call, as well as any information that is provided in the course of the call, including a voice recording of the call.
By registering on the Websites, or submitting requests for support or information via the Websites, Thewallcladding will collect details as above, including also your first and last name, your organization, phone number and email, shipping and billing address and other related information.
You do not have any legal obligation to provide any information to us, however, we require certain information in order to perform contracts for sales of our products, or purchase of our materials, or employment agreements. If you choose not to provide us with certain information, we may not be able to provide you with some or all of the services or fulfil your order for products.
You may create a The Wallcladding store account on certain The Wallcladding store websites. In some cases you may be able to access The Wallcladding store services through login credentials of a designated third party website or service (each a “Third Party Account”), including but not limited to Google, LinkedIn, Facebook or Twitter. Doing so will enable you to link your The Wallcladding store account and your Third Party Account. If you choose this option, then you will be required to approve the connection as well as the provision of information (which may include Personal Information, such as your profile picture, gender, birthdate, headline, summary, friends’ lists, previous positions and organizations), that we may obtain from your Third Party Account. Any data submitted to any Third Party Account, even on and through The Wallcladding Store services, is managed directly by such third party and is not the responsibility of The Wallcladding Store.
Additional third party services may be accessed through our Websites. The Wallcladding Store is not responsible for any personal data or other data submitted to, or otherwise processed through, such third party services. For example, where a credit card purchase is made on our Websites, customers will be redirected to a third party service provider to submit payment, and all aspects of that service and payment, including also any personal data submitted in connection with that service, are within the responsibility of the third party service provider, and not of The Wallcladding store.
We collect contact and related data about potential customers via our Websites, at events, through social media (such as Facebook and LinkedIn), when it is given for that purpose to our professionals, and through other such sources. This data is used to market our products and keep our followers up to date on The Wallcladding Store. We store this data with third party providers of marketing data processing (for example, Hubspot), including in the USA and elsewhere.
2. WHAT ARE THE PURPOSES OF PERSONAL DATA WE COLLECT?
Summary: we use Personal Data for a range of lawful purposes, such as: staying in touch, improving our services, meeting our obligations, providing support.
We will use Personal Data to provide and improve our services and products and meet our contractual, ethical and legal obligations, including for example:
Processing which is necessary for the performance of a contract to which you are a party or in order to take steps at your request prior to entering into a contract (GDPR Article 6(1)(b))
- carrying out our obligations arising from any contracts entered into between you or your employer or organization and The Thewallcladding and/or any contracts entered into with The Wallcladding Store and to provide you with the information, products and services that you request from The Wallcladding Store;
- administering your account with The Wallcladding Store including to identify and authenticate you;
- verifying and carry out financial transactions in relation to payments you make in connection with the products;
Processing is necessary for the purposes of the legitimate interests pursued by Thewallcladding or by a third party (GDPR Article 6(1)(f)) of providing an efficient and wide-ranging service to customers
- notifying you about changes to our service and products;
- contacting you for the purpose of providing you with technical assistance and other related information about the products;
- replying to your queries, troubleshooting problems, detecting and protecting against error, fraud or other criminal activity;
- contacting you to give you commercial and marketing information about events or promotions or additional services and products offered by Thewallcladding, including in other locations;
- soliciting feedback in connection with your use of the services and the products purchased;
- tracking use of The Wallcladding Store facilities and services to enable us to optimize them;
- contacting you to inform you of additional services and products which may be of interest to you;
Processing which is necessary for compliance with a legal obligation to which Thewallcladding is subject (GDPR Article 6(1)(c))
- compliance and audit purposes, such as meeting our reporting obligations in our various jurisdictions, and for crime prevention and prosecution in so far as it relates to our staff, customers, facilities etc;
- if necessary, we will use Personal Data to enforce our terms, policies and legal agreements, to comply with court orders and warrants and assist law enforcement agencies as required by law, to collect debts, to prevent fraud, infringements, identity thefts and any other service misuse, and to take any action in any legal dispute and proceeding;
- for security purposes and to identify and authenticate your access to the parts of the facilities.
3. SHARING DATA WITH THIRD PARTIES
Summary: we share data with other companies in our group, and with our vendors and service providers.
We may transfer Personal Data to:
Members of our Group: This includes any member of our group, which means companies held by the group that owns Thewallcladding, in the EU, in the US and elsewhere. See section 5 below regarding international transfers.
Third Parties. We transfer Personal Data to third parties in a variety of circumstances. We take industry standard steps to ensure that these third parties use your information only to the extent necessary to perform their functions, and we have a contract in place with them to govern their processing on our behalf. These third parties include business partners, suppliers, affiliates, agents and/or sub-contractors for the performance of any contract we enter into with you. They may assist us in providing the products we offer, processing transactions, fulfilling requests for information, receiving and sending communications, analysing data, providing IT and other support services or in other tasks, from time to time. These third parties may also include analytics and search engine providers that assist us in the improvement and optimisation of our website, our application, and our marketing.
We periodically add and remove third party providers. At present our third party providers to whom we may transfer Personal Data include also the following: Websites analytics (Google); computing providers (Microsoft); customer ticketing and support (Zendesk); on-site and cloud based database services (Amazon Web Services); website and ecommerce hosting (Magento); vendor and customer interface; payroll and pension management systems and providers; HR management software; time and attendance software (Synel); CRM software (Salesforce); ERP software (SAP); visitors registration system; project management software; web VC and meeting room platforms; call center and telephony systems; recruiting and applicant management software and partners; data backup providers; CCTV, physical and cyber security system providers; IT service and support providers; our lawyers, accountants; and other standard business services.
In addition, we will disclose your Personal Data to third parties: if some or all of our companies or assets are acquired by a third party including by way of a merger, share acquisition, asset purchase or any similar transaction, in which case Personal Data may be one of the transferred assets. Likewise, we will transfer Personal Data to third parties if we are under a duty to disclose or share your Personal Data in order to comply with any legal or audit or compliance obligation, in the course of any legal or regulatory proceeding or investigation, or in order to enforce or apply our terms and other agreements with you or with a third party; or to assert or protect the rights, property, or safety of The Wallcladding Store, our customers, or others. This includes exchanging information with other companies and organisations for the purposes of fraud protection and credit risk reduction and to prevent cybercrime.
For avoidance of doubt, Thewallcladding may transfer and disclose non-personal data to third parties at its own discretion.
4. WHERE DO WE STORE YOUR DATA?
Summary: we store your data securely at The Wallcladding Store locations or through service providers.
We may keep Personal Data in servers and systems owned or controlled by theThe Wallcladding Store and its group companies in its various sites, or processed by third parties on behalf of The Wallcladding Store, by reputable cloud-service providers and other such service providers. Including in any and all The Wallcladding Store group locations, such as USA, Israel, UK, EU, and others. Data is also stored in our onsite and offsite backups.
INTERNATIONAL DATA TRANSFERS
Summary: Personal Data may be transferred between Thewallcladding locations and others, and where applicable the necessary safeguards will be implemented.
- To Israel. The Wallcladding Stores group is headquartered in Israel. Israel is considered by the European Commission to offer an adequate level of protection for the personal information of EU Member State residents; we may transfer data to other countries with an adequacy ruling too; and
- To the United States of America and additional non-EU locations. Transfer to the US and elsewhere is done subject to Standard Contractual Clauses, or some other mechanism valid under GDPR; and
- Within the EU.
We may transfer your Personal Data outside of the EEA, in order to:
- Store or backup the information;
- Enable us to provide you with the services and products and fulfil our contract with you;
- Fulfill any legal, audit, ethical or compliance obligations which require us to make that transfer;
- Facilitate the operation of our group businesses, where it is in our legitimate interests and we have concluded these are not overridden by your rights;
- To serve our customers across multiple jurisdictions; and
- To operate our parent company, subsidiaries and affiliates in an efficient and optimal manner.
6. DATA RETENTION
Summary: we do not retain Personal Data once it no longer serves the purposes for which we collected it.
The Wallcladding Store will retain Personal Data it processes only for as long as required in our view, to provide the services and as necessary to comply with our legal and other obligations, to resolve disputes and to enforce agreements, and generally to meet the purposes for which it was collected. We will also retain Personal Data to meet any audit, compliance and business best-practices. The retention period will vary based on the form and purpose of the data, and the jurisdictions involved. We operate in accordance with our group data retention policy.
7. WEBSITE AND APPLICATION DATA COLLECTION AND COOKIES
Summary: our website places and tracks cookies, and collects some data, such as IP addresses. Our website has a cookie management tool that enables you to block non-essential cookies. You can also control and stop cookies through your web browser.
When you access or use our website, Thewallcladding uses industry standard technologies such as cookies, pixels and similar technologies, which store certain information on your computer or browsing device and which will allow us to identify the computer or device and in some cases to identify them with the user, and to enable automatic activation of certain features, and make your website experience more convenient and effortless. It also enables us to track users browsing from social media sites and advertisements, to our site. We use different types of cookies: some cookies are strictly necessary, they are required for the operation of our sites and under our terms with you; this includes for example, cookies that enable you to log into secure areas of our services. We also use analytical and performance monitoring cookies, which allow us to recognize and count the number of visitors and to see how visitors move around our website when they are using it. Finally, we use functionality cookies which are used to recognize you when you return to our Site. This enables us to personalize content to your preferences, including for example, your choice of language or region.
Different cookies are kept for different periods. Session cookies keep track of your activities online in a given browsing session, and usually expire when the browser is closed, though they may be retained for a period on your device. Permanent cookies remain in operation even when you have closed the browser, and are used to remember your login details and password. Third-party cookies, such as for Google Analytics, are installed by third parties with the aim of collecting certain information to research behaviour, demographics. Likewise, pixels from third-parties enable integration of third-party service providers (eg Facebook, Twitter, Youtube, Pintrest, Instagram) which may be embedded on our site. Third party cookies will be retained according to the terms of those third parties, and you can control those cookies in your browser settings.
Most browsers will allow you to erase cookies from your computer’s hard drive, block acceptance of cookies, or receive a warning before a cookie is stored. However, if you block or erase cookies your online experience on our website will be limited.
How to disable cookies: the effect of disabling cookies depends on which cookies you disable but, in general, the website and some services delivered through it may not operate properly, may not recognize your device, may not remember your preferences and so on, if cookies are disabled or removed. However, allowing or disabling cookies is your choice and in your control. If you want to disable cookies on our site, you need to change your browser settings to reject cookies. How you can do this will depend on the browser you use. Further details on how to disable cookies can be found here:
- Internet Explorer: http://windows.microsoft.com/en-GB/internet-explorer/delete-manage-cookies
- Google Chrome: https://support.google.com/chrome/answer/95647?hl=en
- Firefox: https://support.mozilla.org/en-US/kb/enable-and-disable-cookies-website-preferences
- Safari: http://help.apple.com/safari/mac/8.0/#/sfri11471
Our websites may, from time to time, contain links to external sites. We are not responsible for the operation, privacy policies and practices or the content of such sites.
8. SECURITY AND STORAGE OF INFORMATION
Summary: we store personal data securely, but there is no such thing as perfect data security.
We take great care in implementing, enforcing and maintaining the security of the Personal Data we process. The Wallcladding Store implements, enforces and maintains security measures, technologies and policies to prevent the unauthorized or accidental access to or destruction, loss, modification, use or disclosure of Personal Data. We likewise take steps to monitor compliance of such policies on an ongoing basis. Where we deem it necessary in light of the nature of the data in question and the risks to data subjects, we may encrypt data. As noted above, we also delete Personal Data which no longer serves its purpose. Likewise, we take industry standard steps to ensure our websites and application are safe.
Note however, that no data security measures are perfect or impenetrable, and we cannot guarantee that unauthorized access, leaks, viruses and other data security breaches will never occur.
Thewallcladding will act in accordance with its policies and with applicable law to promptly notify, where so required, the relevant authorities and data subjects in the event that any Personal Data processed by Thewallcladding is lost, stolen, or where there has been any unauthorized access to it, all in accordance with applicable law and on the instructions of qualified authority.
9. DATA SUBJECT RIGHTS
Summary: you have various rights regarding your Personal Data.
Data subjects have rights under GDPR and local Data Protection Laws, including, in different circumstances, rights to data portability, rights to access data, rectify data, object to processing, and erase data. It is clarified for the removal of doubt, that where Personal Data is provided by a customer being the data subject's employer, such data subject rights may have to be effected through that customer. In addition, data subject rights cannot be exercised in a manner inconsistent with the rights of Thewallcladding employees and staff, with The Wallcladding Store proprietary rights, and third-party rights. As such, job references, reviews, internal notes and assessments, documents and notes including proprietary information or other forms of intellectual property or business confidential information, cannot be accessed or erased or rectified. In addition, these rights may not be exercisable where they relate to data that is not in a structured form, for example emails, or where other exemptions apply.
Where a request for erasure is made, some Personal Data may remain in our backups and various systems until they are cycled out or until it is feasible to remove that data. Where processing occurs based on consent, data subjects may have a right to withdraw their consent, which will not affect the lawfulness of processing that occurred prior to the removal of the consent. If such a request is made in connection with cookies, the data subject will need to give effect to that request through browser settings or our cookie management tool.
If, for any reason, a data subject wishes to exercise their rights to access, modify, delete, move or object to processing of their Personal Data, they may be able to do so by contacting Thewallcladding and its data protection officer at sales@Thewallcladdingstore.co.uk. Note that The Wallcladding Store may have to undertake a process to identify a data subject exercising their rights. The Wallcladding Store may keep details of such rights exercised for its own compliance and audit requirements.
A complaint may be lodged with a data protection supervisory authority. If the supervisory authority fails to deal with a complaint you may have the right to an effective judicial remedy.
Minors. We do not knowingly collect or solicit information or data from children age 16 years or under, or knowingly allow children age 16 years or under to register for The Wallcladding Store services. If you are 16 years or under, do not register or attempt to register for any of The Wallcladding Store service or send any information about yourself to us. If we learn that we have collected or have been sent Personal Data or from a child age 16 years or under, we will delete that Personal Data as soon as reasonably practicable without any liability to The Wallcladding Store. If you believe that we might have collected or been sent information from a minor age 16 or under, please contact us at: firstname.lastname@example.org, as soon as possible.
Enquiries regarding our data protection practices, and any data subject requests, may be lodged with us and our Data Protection Officer at email@example.com.