Privacy Notice

Introduction

Welcome to the Applied Relational Technology Limited (‘ART’) privacy notice.

ART 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.

  1. Important information and who we are

    Purpose of this privacy notice

    This privacy notice aims to give you information on how ART collects and processes your personal data through your use of this website, including any data you may provide through this website when you sign up to our newsletter, purchase or use a product or service.

    We have appointed a data privacy manager who is responsible for overseeing questions in relation to this privacy notice. If you have any questions about this privacy notice, including any requests to exercise your legal rights, please contact the data privacy manager using the details set out below.

    Contact details

    Our full details are: Applied Relational Technology Limited incorporated and registered in England and Wales with company number 1589528 whose registered office is at The Old rectory, Ashford Road, Char`tham, Canterbury, Kent CT4 7HS

    Name or title of DPO: Lin Wallace

    Email address: dpo@artsoftwaregroup.com

    You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues (www.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.

    Changes to the privacy notice and your duty to inform us of changes

    This version was last updated on 11th May 2018 and historic versions can be obtained by contacting us.

    It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.

    Third-party links

    This website contains links to other websites plug-ins and applications. Please note that we are not responsible for the privacy practices of other websites. This privacy statement applies solely to information collected by this website.

  2. The data we collect about you

    Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).

    We may collect, use, store and transfer different kinds of personal data about you which we have grouped together follows:

    • Identity Data includes first name, maiden name, last name, username or similar identifier, marital status, title, date of birth and gender.
    • Contact Data includes[billing address, delivery address, email address and telephone numbers.
    • 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 Data includes 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 do not collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data). Nor do we collect any information about criminal convictions and offences.

  3. How is your personal data collected?

    We use different methods to collect data from and about you including through:

    • We collect personal information that you voluntarily provide via the Site. For example, when registering with the Site we may ask you to provide your name, address, telephone numbers, email address and date of birth. This is not an exhaustive list and we may ask for additional information as relevant from time to time.
    • During your use of the Site, certain information may be gathered through automated technologies without your actively providing it information) using various technologies and means, such as Internet Protocol (IP) addresses and web logs; and “cookies”.
    • We may receive personal data about you from various third parties and public sources.
  4. How we use your personal data

    We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:

    • Where we need to perform the contract we are about to enter into or have entered into with you.
    • Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
    • Where we need to comply with a legal or regulatory obligation.

    Generally we do not rely on consent as a legal basis for processing your personal data other than in relation to sending third party direct marketing communications to you via email or text message. You have the right to withdraw consent to marketing at any time by contacting us

    Purposes for which we will use your personal data

    We may use your personal information: (a) to respond to your questions or requests for additional information; (b) to provide you with information that you have specifically requested or that we have asked if you would like to receive; and (c) for internal analysis so that we can better understand how we can improve our Site, products and services.

    In addition we may use your information to inform you from time to time of other products and/or services we offer which we consider may be of interest to you. If you do not want to receive information in this way then you should leave the relevant box in the Site blank when we ask for your consent to do this. You may otherwise email us at any time at marketing@mcarthurglen.com to indicate that you do not want to receive information in this way from us.

    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 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 in the table below.

    You will receive marketing communications from us if you have requested information from us or purchased services from us [or if you provided us with your details when you entered a competition or registered for a promotion] and, in each case, you have not opted out of receiving that marketing.

    We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.

    If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.

    Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

    Third-party marketing

    We do not provide your personal data to any company for marketing purposes.

    Opting out

    You can ask us or third parties to stop sending you marketing messages at any time by contacting us at any time.

    Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of a product/service purchase, or other transactions.

    Cookies

    A cookie is a piece of data stored on a user’s hard drive containing information about the user. The information below explains the cookies we use on our website and why we use them:

    [Google Analytics cookies: we use these cookies to collect information about how visitors use our website, including details of the site where the visitor has come from and the total number of times a visitor has been to our website. We use the information to improve our website and enhance the experience of its visitors.

    [ASP.Net cookie: we use this cookie to allow visitors to view the website without logging in as a registered user. Once you close your browser, the cookie is deactivated.

    [Local Shared Objects (Flash cookies): we use Adobe Flash Player to deliver certain content. Local Shared Objects, otherwise known as Flash cookies, are used for this in order to check if your browser supports Flash.

    You can enable or disable cookies by modifying the settings in your browser. You can find out how to do this, and find more information on cookies, at: www.allaboutcookies.org.

    You can also find out how to disable Flash cookies at Adobe.com – see www.adobe.com/products/flashplayer/security for details. [You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of this website may become inaccessible or not function properly.

  5. Disclosures of your personal data

    We may have to share your personal data with third parties as follows:-.

    • We may use third parties to perform functions on our behalf in relation to the Site and the purposes set out in this Policy (for example, website hosting). Such third parties may be provided with access to your personal information if needed to perform their specific functions, but may not use such information for any other purpose.
    • We may also share information about visitors to this Site in an anonymous or aggregate form with third parties including advertisers, business partners, and sponsors, to understand customer trends and patterns and manage and improve our business relationships..
    • 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.
    No fee usually required

    You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.

    What we may need from you

    We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

    Time limit to respond

    We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.

    We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.

  6. International transfers

    We do not transfer your personal data outside the European Economic Area (EEA) unless you have provided that data to us acting as a data processor where you are an employee of a company which is a data controller and your employer allows transfer outside the EEA.

    Whenever we transfer your personal data out of the EEA, we ensure a similar degree of protection is afforded to it 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. For further details, see European Commission: Adequacy of the protection of personal data in non-EU countries.
    • 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. For further details, see European Commission: Model contracts for the transfer of personal data to third countries.
    • Where we use providers based in the US, we may transfer data to them if they are part of the Privacy Shield which requires them to provide similar protection to personal data shared between the Europe and the US. For further details, see European Commission: EU-US Privacy Shield.
  7. Data security

    We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.

    We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

  8. Data retention
    How long will you use my personal data for?

    We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements. By law we have to keep basic information about our customers (including Contact, Identity, Financial and Transaction Data) for six years after they cease being customers for tax purposes.

    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 below for further information.

    In some circumstances we may anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes in which case we may use this information indefinitely without further notice to you.

  9. Your legal rights

    You have the right to:

    Request access to your personal data (commonly known as a “data subject access request”). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.

    Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.

    Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.

    Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.

    Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios: (a) if you want us to establish the data’s accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.

    Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.

    Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.