Privacy Policy (General)

In this privacy policy, we explain how we collect and use your personal information. ‘We’ means Startwell Engineering (U.K.) Limited of business address No 58 Wilbury Way, Hitchin. Hertfordshire SG4 0TP. We are the data controller for the purposes of the Data Protection Act 1998 & 2018 and the EU General Data Protection Regulation.

You can use our Contact Form, or the contact details on our website, to contact us with any questions you may have about privacy or data protection.

Please note that links from our website may take you to external websites not covered by this policy. We recommend that you check their privacy policies yourself before submitting any personal information to such external website. We will not be responsible for the content, function or information collection policies of these external websites.

What information do we collect about you and how do we collect it?

You are not required (by law or by any contract with us) to provide personal information to us via this website. We will only require you to provide personal information to us where it is necessary for us to provide you with a service.

Information you provide to us

We may receive personal information about you whenever you contact us. For example, by doing the following:

• completing our Contact Form
• using and browsing our website
• telephoning, texting, writing by post or emailing us

This information may include the following:

• normal identification information, such as your full name, date of birth, age, gender, marital status;
• contact information, such as your postal address, email address and telephone number;
• additional information relevant to your use of our site and services, such as your marketing preferences, survey responses and feedback.

Information we collect about you on our website

We collect information using cookies and other similar technologies to help distinguish you from other users of our website. These can streamline your online experience by saving you from re-inputting some information and also allow us to make improvements to our website. For more information about how and why we use cookies, please take a look through our Cookie Policy.

When you visit our website, we may collect the following information:

• which pages you view and which links you follow
• your IP address and general location
• details of the hardware and software that you are using to access the site
• any passwords that you use on our website

Our website is not intended for children and we do not knowingly collect data relating to children.

Information we collect about you from other sources

We may collect information about you from other sources. This may include the following:

• Publicly available information, from sources such as Companies House, the Electoral Roll, County Court Judgements and repossessions this may include details about your home, household, vehicles, financial situation and debts
• Information you have shared publicly, including on social media

This list is not exhaustive and, in specific instances, we may need to collect additional data for the purposes set out in this policy.

Information we receive about you from other sources

Sometimes you will have given your consent for other websites, services or third parties to provide information to us.

It could also include information from third parties that we work with to provide our products and services, such as payment processors, our accountants, delivery companies, technical support companies and advertising companies. Whenever we receive information about you from these third parties, we will let you know what information we have received and how and why we intend to use it.

How do we use your personal information?

We take data protection law seriously, so below we have set out exactly how and why we use your information, and what our legal basis is to be able to use your information in each way. We need all the categories of information listed above to allow us to enter into and perform our contract with you*, to enable us to comply with legal obligations**, and in order to pursue legitimate interests of our own or those of third parties*** (provided your interests and fundamental rights do not override those interests). The situations in which we will process your personal data are listed below. We have indicated by asterisks the purpose or purposes for which we are processing or will process your personal information.

• Verifying your identity (*, **, ***)
• Making a decision about order. (*)
• Administering the contract we have entered into with you. (*)
• Contacting you about any similar products or services we may offer (***)
• Dealing with any complaints you may have (*, ***)
• Business management and planning, including accounting and auditing. (**, ***)
• Conducting performance reviews, managing performance and determining performance requirements. (*, ***)
• Gathering evidence for possible grievance or disciplinary hearings. (*, **, ***)
• Dealing with legal disputes involving you. (**, ***)
• To detect and prevent fraud, money-laundering and other crimes. (**)
• To monitor your use of our information and communication systems to ensure compliance with our IT policies. (*, ***)
• To ensure network and information security, including preventing unauthorised access to our computer and electronic communications systems and preventing malicious software distribution. (***)
• To conduct data analytics studies to review and better understand employee retention and attrition rates. (***)
• To interact and respond to any communications you send us, including social media posts that you tag us in. (***)
• To let you know about any important changes to our business or policies. (***)
• To protect your interests, or the interests of others (such as in the event of criminality such as identity theft, piracy or fraud). (**, ***)

Providing our services

It is necessary for us to use personal information about you to enter into and perform the contracts that we make with you, such as when you purchase our goods. Using your information in this context is necessary so that we can:

• provide you with information about your products;
• verify your identity;
• deal with any complaints you may have;
• contact you about any changes that we make to our products or services; and
• administer our website, including troubleshooting problems, analysing statistics, conducting research and tests and keeping the site secure.

Where you obtain from us any other service that we offer free of charge, it is necessary for us to use your personal information and we have a legitimate interest in providing these services to you. Using your information is necessary so that we can:

• provide you with information about our products and services, including the availability of our products according to criteria that you select;
• provide you with other news and information.

Telling you about other products or services that we think may be of interest to you

We may use your information to identify and tell you about our products or services that we think may be of interest to you. We will only do this where you have informed us that you would like to receive marketing communications.

We may also use your information to invite you to participate in market research. If we do contact you about market-research, you do not have to participate. If you tell us that you do not want to receive market-research communications, we will respect this.

Whether you choose to receive marketing communications, or market research communications is entirely up to you. You can choose to receive both, none, or just one or the other. Your choice will not affect any products or services that you have purchased from us, nor will it affect any quotes for products or services you buy in future.

You can update your preferences by using the links in any of our emails to you, or by getting in touch using our Contact Form.

Telling you about products or services that are similar to ones that you have already bought

If you have already bought a product from us, or you have already obtained a quote from us, we may contact you with some information about products that are similar.

We will only contact you by email and you can choose not to receive these messages at any time. Simply follow the instructions in the message, or get in touch using our Contact Form.

Making our business better

We always want to offer the best products, services and experience that we can. Sometimes this means we may use your information to find ways that we can improve what we do, or how we do it.

In this context, we will only use your information where it is necessary so that we can:

• review and improve our existing products and services and develop new ones;
• review and improve the performance of our systems, processes and staff (including training);
• improve our site to ensure that content is presented in the most effective manner for you and for your computer; and
• measure and understand the effectiveness of advertising we serve to you and others, and to deliver relevant advertising to you.

Contacting you

We want to stay in touch with you. Sometimes we may need to use the information that we have about you in order to respond to your questions or let you know about important changes.

We will only use your information in this respect where it is necessary so that we can:

• interact and respond to any communications you send us, including where you use our Contact Form, and any social media posts that you tag us in; and
• let you know about any important changes to our business or policies.

Verifying your identity

We may use your information where it is necessary for us to do so in order to meet our legal obligations or to detect and prevent fraud, money laundering and other crimes.

Protecting you and others from harm

We may use your information where it is necessary to protect your interests, or the interests of others. This may include in the event of criminality such as identity theft, piracy or fraud.

Who do we share your personal information with?

Sharing your information within our company

We share the information that you provide to us with our staff so that we can provide our products and services to you.

Sharing your information with third parties

We will not generally share your personal information with any third parties.

There are certain exceptional circumstances in which we may disclose your information to third parties. This would be where we believe that the disclosure is:

• required by the law, or in order to comply with judicial proceedings, court orders or legal or regulatory proceedings;
• necessary to protect the safety of our employees, our property or the public;
• necessary for the prevention or detection of crime, including exchanging information with other companies or organisations for the purposes of fraud protection and credit risk reduction;
• proportionate as part of a merger, business or asset sale, in the event that this happens we will share your information with the prospective seller or buyer involved;

How long do we keep your personal information?

We will only store your personal information for as long as we need it for the purposes for which it was collected. Where we provide you with any service (including you purchase one of our products, or ask to receive further information from us), we will retain any information you provide to us at least for as long as we continue to provide that service to you.

How do we protect your personal information?

We will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this policy.

We try to ensure that all information you provide to us is transferred securely via the website (always check for the padlock symbol and “https” at the beginning of the URL). Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted to our site; any transmission is at your own risk. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorised access.

All information you provide to us is stored on our/third party secure servers. Where we have given you (or where you have chosen) a password which enables you to access certain parts of our site, you are responsible for keeping this password confidential. We ask you not to share a password with anyone.

What rights do you have in respect of your personal information?

You have the right to be informed

We have a legal obligation to provide you with concise, transparent, intelligible and easily accessible information about your personal information and our use of it. We have written this policy to do just that, but if you have any questions or require more specific information, you can get in touch using our Contact Form.

You have the right to access your personal data

You have the right to ask us to confirm whether or not we hold any of your personal information. If we do, you have the right to have a copy of your information and to be informed of the following:

• why we have been using your information;
• what categories of information we were using;
• who we have shared the information with; and
• how long we envisage holding your information.

In order to maintain the security of your information, we will have to verify your identity before we provide you with a copy of the information we hold.

The first copy of your information that you request from us will be provided free of charge, if you require further copies we may charge an administrative fee to cover our costs.

You have the right to correct any inaccurate or incomplete personal data

Where you have requested a copy of the information we hold about you, you may notice that there are inaccuracies in the records, or that certain parts are incomplete. If this is the case you can contact us so that we can correct our records.

You have the right to be forgotten

There may be times where it is no longer necessary for us to hold personal information about you. This could be if:

• The information is no longer needed for the original purpose that we collected it for
• You withdraw your consent for us to use the information (and we have no other legal reason to keep using it)
• You object to us using your information and we have no overriding reason to keep using it
• We have used your information unlawfully
• We are subject to a legal requirement to delete your information

In those situations you have the right to have your personal data deleted. If you believe one of these situations applies to you, please get in touch using our Contact Form.

You have the right to have a copy of your data transferred to you or a third party in a compatible format

Also known as data portability, you have the right to obtain a copy of your personal data for your own purposes. This right allows you to move, copy or transfer your personal data more easily from one IT system to another, in a safe and secure way.

If you would like us to transfer a copy of your data to you or another organisation in a structured, commonly use and machine-readable format, please contact us. There is no charge for you exercising this right.

You have the right to object to direct marketing

You can tell us at any time that you would prefer that we do not use your information for direct marketing purposes. If you would not like to receive any direct marketing from us, please contact us or use the links provided in any of our marketing communications, and we will stop sending direct marketing immediately.

You have the right to object to us using your information for our own legitimate interests

Sometimes, we use your personal information to achieve goals that will help us as well as you. This includes:

• When we tell you about products or services that are similar to ones that you have already bought
• When we use you information to help us make our business better
• When we contact you to interact, communicate or let you know about changes we are making

We aim to always ensure that your rights and information are properly protected. If you believe that the way we are using your data is not justified due to its impact on you or your rights, you have the right to object. Unless we have a compelling reason to continue, we must stop using your personal data for these purposes.

In order to exercise your right to object to our use of your data for the purposes above, please contact us.

You have the right to restrict how we use your personal data

You have the right to ask us to stop using your personal data in any way other than simply keeping a copy of it. This right is available where:

• You have informed us that the information we hold about you is inaccurate, and we have not yet been able to verify this
• You have objected to us using your information for our own legitimate interests and we are in the process of considering your objection
• We have used your information in an unlawful way, but you do not want us to delete your data
• We no longer need to use the information, but you need it for a legal claim

If you believe any of these situations apply, please contact us.

Changes to our Privacy Policy

Any changes we make to our privacy policy in the future will be posted on this page and, where appropriate, notified to you by email. Please check back frequently to see any updates or changes to our privacy policy.

Complaints

If you wish to make a complaint about our collection or use of your personal data, please contact us in the first instance so that we may seek to resolve your complaint.

You have the right to lodge a complaint with the Information Commissioner’s Office (ICO), the statutory body which oversees data protection law in the UK. Please visit the ICO website if you wish to lodge a complaint with the ICO.