This is a notice to inform you of our company policy about all information that we record about you. It sets out the conditions under which we may process any information that we collect from you, or that you provide to us. It covers information that could identify you (“personal information”) and information that could not. In the context of the law and this notice, “process” means collect, store, transfer, use or otherwise act on information.
PelGar International Ltd is a British company operating from the UK. We are committed to protecting your privacy in relation to the information we hold about you in line with the legal requirements of the European Union’s General Data Protection Regulation (“GDPR”). Your data may also be processed in countries outside the European Union (EU) but, unless other international data protection rules apply that surpass GDPR, PelGar will apply this EU regulation to all data it controls regardless of where you reside or where in the world your data may be processed by its employees.
Who we are
For the purposes of GDPR we are the Data Controller and can be contacted by post at Unit 13 Newman Lane, Alton, Hampshire GU34 2QR or by email at email@example.com.
References to “our websites” are to www.pelgar.com and its subsidiary sites www.pelgar.co.uk, www.pelgar.asia www.pelgar-usa.com and www.getthatrat.co.uk
What information we may collect from you
Much of the information we collect from you will be business details, but some may be personal information that can identify you as an individual.
When we enter in to sales communication with you leading up to and throughout an order we will collect information that may include your name, company name, address, postcode, email address, telephone number and relevant correspondence.
Where you have agreed to receive marketing updates on products and offers we may record additional information you have given us on your preferences, so that we can tailor this information for you.
When you visit our websites general information is collected automatically. This may include your IP address, your location, the name of your internet service provider, the website from which you visited us and any website you visit while you are with us.
The regulations recognise that certain categories of personal information are more sensitive, including health information, race, religious beliefs and political opinions. We do not usually collect this type of information unless there is a clear reason for doing so.
Why we collect and process data about you
Under the regulations there are six defined basis by which we may legitimately collect, process and hold your personal data. We principally use four of these:
- Processing is necessary for the performance of a contract, or the steps prior to entering in to a contract with us.
- Processing is necessary for the purpose of the legitimate interests pursued by PelGar International.
- Processing is necessary for compliance with a legal obligation to which we are subject.
- You have given us active consent to the processing of your personal data for one or more specific purposes.
If the basis on which we collect your personal data is no longer valid, or changes, then we will cease using your data immediately.
Information we process because we have, or are entering in to, a contract with you
When you request information and quotations from us, create an account with us, buy a product or service from us, or otherwise agree to our terms and conditions, we are leading up to or forming a contract between you and us.
To carry out our obligations under that contract we use the information you give us to process your order and any matters arising from it, inform you of stock availability or any changes to our products and services and deal with accounting matters.
We will continue to process this information until the contract between us ends or is terminated by either party under the terms of the contract, or until the fulfilment of all legal obligations.
Information we process because we have a legitimate business interest
When you have requested information from us as a potential customer, you are an existing customer, or you are a previous customer, we may use your data to keep you up to date with our products and services including any offers and promotions we may have.
We may use this information to provide you with quotations, suggestions and advice about our products and services and how to get the most from using our websites. Additionally we may use the information to monitor our performance in providing our products and services to you, including asking you directly for your views and comments.
We only use this data to tell you about our own products and services; we do not promote any third parties or pass your data to third parties for them to do so. We keep your data for as long as you are trading with us, or until it is no longer relevant. At any time you can request to be removed from this data by writing to us at the contact details above or unsubscribing from our e-newsletter.
Information we process because we have a legal obligation
We are subject to the law like everyone else. Sometimes we must process your information to comply with a statutory obligation, for example financial data. We may also be required to give information to legal authorities if they so request or if they have the proper authorisation such as a warrant or court order. This may include your personal information. We will hold this information on our systems for as long as is necessary for the relevant activity, or the duration set out in any contract you have with us.
Information we process with your consent
Through certain actions when otherwise there is no contractual relationship between us, such as when you browse our website or ask us to give you more information about our business, including our products and services, you provide your consent to us to process information that may be personal information.
Except where you have consented to our use of your information for a specific purpose, we do not use your information in any way that would identify you personally. We may aggregate it in a general way and use it to provide class information, for example to monitor the performance of our website.
We continue to process your information on this basis until you withdraw your consent, or it can be reasonably assumed that your consent no longer exists.
You may withdraw your consent at any time by instructing us at the contact details above, under ‘who we are’.
How we collect your data and what we do with it
We collect information from you from various sources and for various reasons as outlined below:
A) Sales enquires
When you contact us, whether by telephone, through our website or by e-mail, we collect the data you have given to us so that we can reply with the information you need. We record your request and our reply to increase the efficiency of our business. We keep personally identifiable information associated with your message, such as your name and email address, to be able to track our communications with you to provide a high quality service.
When you order products and services from us we record a large amount of data to process that order, on the legal basis that you have entered in to a contract with us. This will include company details, contact details, financial information, shipping information and whatever additional commercial information we may need to fulfil that contract. We will hold this data until the end of the contract with you or until the end of any legal obligations we have for financial, tax and other purposes.
When you visit our websites, requests by your web browser to our servers for web pages and other content on our website are recorded. We automatically record information such as your geographical location, your Internet service provider and your IP address. We also record information about the software you are using to browse our website, including the type of computer or device and the screen resolution.
We use all this combined information in an anonymous form to track and analyse how people are using our websites. From this information we can improve the attractiveness, content and functionality of our websites to improve their performance for you. We also use this information to track how effective our other marketing campaigns are, for example by analysing how busy the website is after a promotion or where the web traffic is coming from.
If combined with other information we know about you from previous visits, the data possibly could be used to identify you personally, even though you are not signed in to our website(s).
What is an IP address?
This is a string of numbers unique to your computer. When you request any page or component of our website it is recorded by our web server. This statistical information about your browsing patterns is used to monitor the use and effectiveness of our website and does not identify you.
What are cookies?
Our websites may contain links to and from partners, affiliates and social network sites. If you follow a link to any of these websites, please note that these sites have their own privacy policies and that we do not accept responsibility or liability for those policies. Please check those privacy policies before you submit any personal data to those websites as they may not be on the same terms as ours.
We aim to communicate with you about our products and services in ways that you find relevant, timely and respectful. To do this we use contact data that we have stored about you as well as any preferences you may have told us about.
In the case of postal mailings, we use our legitimate business interest as the legal basis for communications with you. You may object to receiving these at any time using the contact details at the top of this policy to be removed from our data.
In the case of digital mailings we use a double opt-in procedure for you to sign up to receive our e-newsletters. After you have subscribed to our newsletter on our website you will receive an email message asking you to confirm your subscription. If you do not confirm your subscription the second time your details will be automatically deleted, and you will not receive any e-newsletters. We also provide you with an option to unsubscribe in every email that we subsequently send you, or you can alternatively use the contact details at the top of this policy.
When we receive a complaint, we record all the information you have given to us so that we can resolve your complaint. If your complaint reasonably requires us to contact another company, we may decide to give to that other company some of the information contained in your complaint. We do this as infrequently as possible, but it is a matter for our sole discretion as to whether we do give information, and if we do, what that information is. We may also compile statistics from these records to assess the level of service we provide, but not in a way that could identify you or any other person.
How we store your data securely
We use technical and organisational security measures to protect all the information we hold, on whatever basis and for whatever purpose. These measures protect your information from being manipulated, lost, destroyed or accessed by unauthorised persons. Our security measures are continuously reviewed and revised in line with the latest technology.
On our European websites we use Secure Sockets Layer (SSL) certificates to verify our identity to your browser and to encrypt any data you give us. Look for the closed padlock symbol or other trust mark in your browser’s URL bar or toolbar.
How long we store your data for?
We keep your information only for as long as it is required by us, according to the basis we are processing it and to provide you with the services you have requested. In the course of our business this may include longer periods to comply with legal obligations, including finance, tax and the registration of our products around the world.
We review our retention periods for personal information on a regular basis. We will hold your personal information on our systems for as long as is necessary for the relevant activity, or as long as is set out in any relevant contract you hold with us.
If the basis on which we collect your personal data is no longer valid, or changes, then we will cease using your data immediately.
We may have occasion to pass your information to third parties for legal reasons or to resolve complaints. We do not share, sell or rent your information to third parties for marketing purposes.
In the course of our marketing activity we do use external service providers to monitor our websites and send out our email newsletters. Where data is passed on to external service providers, we have taken technical and organisational measures to ensure that the data protection regulations are observed.
Where we hold your information under a legal basis in the pursuit of our business we do not need your consent to do so. Even so, you may contact us at any time to request that we:
- update any personal information which is out of date or incorrect;
- delete any personal information which we are holding about you;
- restrict the way that we process your personal information;
- provide your personal information to a third-party provider of services; or
- provide you with a copy of any personal information which we hold about you.
Where we hold your information for marketing purposes and you have given us consent to do so, you may also withdraw that consent at any time. Please note that opting-out may prevent us from providing you with information requested by you.
When we receive any request to access, edit or delete personal identifiable information we will take reasonable steps to verify your identity before taking any action. This is important to safeguard your information. We will consider all such requests and provide our response within the time period stated by applicable law.