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Privacy Notice

PRIVACY NOTICE – SERVICE SUPPLY NETWORK LTD TRADING AS “Service Supply Network”

Introduction

Welcome to Service Supply Network Ltd’s privacy notice.

Service Supply Network Ltd operates under the trading name of “Service Supply Network”.

Service Supply Network 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.

This privacy notice is provided in a layered format so you can click through to the specific areas set out below. Alternatively, you can download a pdf version of the policy here [ download ] . Please also use the Glossary to understand the meaning of some of the terms used in this privacy notice.

1. IMPORTANT INFORMATION AND WHO WE ARE

Purpose of this privacy notice

This privacy notice aims to give you information on how Service Supply Network collects and
processes your personal data through your use of www.servicesupplynetwork.co.uk, including
any data you may provide through this website when you request a quotation from us,
purchase services, submit enquiries or give us feedback.

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

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.

Controller

Service Supply Network Ltd trading as “Service Supply Network” is the controller and responsible for your
personal data (collectively referred to as “Service Supply Network”, “we”, “us” or “our” in this
privacy notice).

We have appointed a data protection officer 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:

Full name of legal entity: Service Supply Network Ltd, a private limited company with registered number 10761390

Name or title of data protection officer: Samir Dungersi

Email address: samir.dungersi@servicesupplynetwork.co.uk

Postal address: 47-49 Burrowfield, Industrial Estate, Welwyn Garden City, Hertfordshire, AL7 4SS

We hope that we can resolve any query or concern you raise about our use of your information. We
would appreciate the chance to deal with your concerns in the first instance. However, you
also 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 ).

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

This version was last updated in October 2019 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 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.

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, or similar identifier.
  • 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 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.

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 you
and you fail to provide that data when requested, we may not be able to perform the contract
we have or are trying to enter into with you (for example, to provide you with goods or services). In this case, we may have to cancel a product or service you have with us but we
will notify you if this is the case at the time.

3. HOW IS YOUR PERSONAL DATA COLLECTED?

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

  • Direct Interactions. You may give us your Identity, Contact and Financial Data by
    filling in forms or by corresponding with us by post, phone, email or otherwise. This
    includes personal data you provide when you:
  • speak to us on the telephone (including the personal data we may collect by
    recording our telephone conversations with you);
  • request a quotation through our website;
  • purchase goods or services through us;
  • submit enquiries;
  • request marketing to be sent to you;
  • enter a competition, promotion or survey; or
  • give us feedback.
  • Automated technologies or interactions. As you interact with our website, we may
    automatically collect Technical Data about your equipment, browsing actions and
    patterns. We collect this personal data by using cookies, server logs and other similar
    technologies. We may also receive Technical Data about you if you visit other websites
    employing our cookies. Please see our cookie policy here for further details.

Where you speak to us on the telephone, if we tell you that we may be recording your call, we
will automatically collect any personal data provided to us over the telephone by you as
part of our recording.

  • Third parties or publicly available sources. We may receive personal data about
    you from various third parties and public sources as set out below:
  • Technical Data from analytics providers such as Google and Facebook based
    outside the EU;
  • Contact, Financial and Transaction Data from providers of technical, payment
    and delivery services such as Sage Pay Limited based inside the EU.
  • Identity and Contact Data from publicly availably sources such as Companies
    House and the Electoral Register based inside the EU.

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.

Click here to find out more about 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 placing cookies and 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.

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 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.

Purpose/Activity
Type of data
Lawful basis for processing including basis of legitimate interest
To register you as a new customer

(a) Identity

(b) Contact

Performance of a contract with you

To process and deliver your order including:

(a) Manage payments, fees and charges

(b) Collect and recover money owed to us

(a) Identity

(b) Contact

(c) Financial

(d) Transaction

(e) Marketing and Communications

(a) Performance of a contract with you

(b) Necessary for our legitimate interests (to recover debts due to
us)

To manage our relationship with you which will include:

(a) Notifying you about changes to our terms or privacy policy

(b) Asking you to leave a review or take a survey

(a) Identity

(b) Contact

(c) Profile

(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

(a) Identity

(b) Contact

(c) Profile

(d) Usage

(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) Identity

(b) Contact

(c) Technical

(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

(a) Identity

(b) Contact

(c) Profile

(d) Usage

(e) Marketing and Communications

(f) Technical

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) Technical

(b) Usage

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) Identity

(b) Contact

(c) Technical

(d) Usage

(e) Profile

Necessary for our legitimate interests (to develop our products/services and grow our business)
To deliver and improve our customer services, relationships and experience and to undertake staff training to
improve the delivery of our customer services

(a) Identity

(b) Contact

(c) Technical

(d) Usage

(e) Profile

(f) Financial

(g) Transaction

(a) Performance of a contract with you

(b) Necessary for our legitimate interests (to study how our customers use our products/services, to develop our customer services and inform our staff training to improve our service experience)

Marketing

We strive to provide you with choices regarding certain personal data uses, particularly around
marketing and advertising. You can ask us to stop sending marketing messages at any time
by contacting us.

Promotional offers from us

We may use your Identity, Contact, Technical, Usage and Profile Data to form a view on what we
think you may want or need, or what may be of interest to you. This is how we decide which
products, services and offers may be relevant for you (we call this marketing).

You will receive marketing communications from us if you have requested information from us or
purchased goods or services from us and, in each case, you have not opted out of receiving
that marketing.

Third-party marketing

We will get your express opt-in consent before we share your personal data with any company
outside Service Supply Network Ltd’s group of companies 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, warranty registration,
product/service experience or other transactions.

Cookies

We will get your consent before placing cookies on your computer when you visit our website except
in relation to certain cookies which are essential for the functioning of our website. You can
also 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. For more information about the
cookies we use, please see our cookie policy here.

Change of purpose

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.

5. DISCLOSURES 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 in paragraph 4 above.

  • Internal Third Parties as set out in the Glossary.
  • External Third Parties as set out in the Glossary.
  • 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 permit them to process your personal data for specified
purposes and in accordance with our instructions.

6. INTERNATIONAL TRANSFERS

Some of our External Third Parties are based outside the European Economic Area (EEA) so their
processing of your personal data will involve a transfer of data 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.
  • 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 the Europe and the US.

Please contact us if you want further information on the specific mechanism used by us when
transferring your personal data out of the EEA.

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.

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.

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.

In some circumstances you can ask us to delete your data: see Request erasure 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

Under certain circumstances, you have rights under data protection laws in relation to your personal
data. Please click on the links below to find out more about these rights:

If you wish to exercise any of the rights set out above, please contact us.

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.

10. GLOSSARY

LAWFUL BASIS

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 interests. 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.

Performance of Contract means processing your data where it is necessary for the performance of
a contract to which you are a party or to 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.

THIRD PARTIES

Internal Third Parties

Other companies in Concrete Network Ltd’s group acting as joint controllers or processors and who
are based inside the EEA and provide administration and back-office services.

External Third Parties

We employ other companies to perform functions on our behalf such as:

  • Service providers acting as processors based inside and outside the EEA. These
    services may include fulfilling orders for products or services, providing customer
    relationship management, marketing assistance and supporting our website and IT
    functionality. These service providers may be supplied with or have access to your
    personal data solely for the purpose of providing these services to us on our behalf.
    Concrete Network Ltd trading as “Service Supply Network“ is the data controller and will
    remain accountable for your personal data.
  • Professional advisers acting as processors or joint controllers including lawyers,
    bankers, auditors and insurers based inside the EEA who provide consultancy,
    banking, legal, insurance and accounting services.
  • HM Revenue & Customs, regulators and other authorities acting as processors or joint
    controllers based in the United Kingdom who require reporting of processing activities
    in certain circumstances.

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.

Service Supply Network Ltd trading as “Service Supply Network”

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