CE Global Ltd (“We”) are committed to protecting and respecting your privacy.
This policy (together with our Online Compliance Policy and any other documents referred to on it) sets out the basis on which any personal data we collect from you, or that you provide to us, will be processed by us. Please read the following carefully to understand our views and practices regarding your personal data and how we will treat it.
The rules on processing of personal data are set out in the General Data Protection Regulation (the “GDPR”).
Data controller – a controller determines the purposes and means of processing personal data.
Data processor – a processor is responsible for processing personal data on behalf of a controller.
Data subject – natural person.
Categories of data – personal data and special categories of personal data.
Personal data – the GDPR applies to ‘personal data’ meaning any information relating to an identifiable person who can be directly or indirectly identified by reference to an identifier (as explained in Article 6 of GDPR). For example, name, passport number, home address or private email address. Online identifiers include IP addresses and cookies.
Special categories personal data – the GDPR refers to sensitive personal data as ‘special categories of personal data’ (as explained in Article 9 of GDPR). The special categories specifically include genetic data, and biometric data, where processed to uniquely identify an individual. Other examples include racial and ethnic origin, sexual orientation, health data, trade union membership, political opinions, religious or philosophical beliefs.
Processing – means any operation or set of operations which is performed on personal data or on sets of personal data, whether or not by automated means, such as collection, recording, organisation, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction.
Third party – means a natural or legal person, public authority, agency, or body other than the data subject, controller, processor, and persons who, under the direct authority of the controller or processor, are authorised to process personal data.
WHO WE ARE?
CE Global Ltd is the data controller. This means we decide how your personal data is processed and for what purposes. For all data matters contact our data representative on +44 (0)161 477 2201.
THE PURPOSE OF PROCESSING YOUR PERSONAL DATA
We use your personal data for the following purposes:
- To perform a contract with/involving you
- To open a customer/supplier account
- To maintain our own accounts and records
- To inform you of news, offers, events or activities
- You may give us information about yourself by filling in forms on our site www.ceglobal.com (our site) or by corresponding with us by phone, e-mail or otherwise. This includes information you provide when you register to use our site, subscribe to our service, search for a product, place an order on our site, participate in discussion boards or other social media functions on our site, enter a competition/promotion or survey and when you report a problem with our site.
THE CATEGORIES OF PERSONAL DATA CONCERNED
With reference to the categories of personal data described in the definitions section, we process the following categories of your data: Personal data (name, address, email address, phone number, financial and credit card information).
We may obtain personal data from publicly available sources such as Companies House.
We may purchase your data from third-party providers. These contacts will only be purchased from credible sources that can provide sufficient assurances that they are meeting their data protection obligations.
WHAT IS OUR LEGAL BASIS FOR PROCESSING YOUR PERSONAL DATA?
Our lawful basis for processing your general personal data:
Consent of the data subject; we may rely on your consent to use your personal data for marketing purposes, for example, by subscribing online to our marketing emails or if your business is run as a sole trader or partnership.
Processing necessary for the performance of a contract with the data subject or to take steps to enter into a contract.
We will obtained your personal data (including your client’s/end user’s personal information where necessary) when you have obtained a quote from us, applied for an account with us or purchased from/supplied us.
Processing necessary for the purposes of the legitimate interests of the data controller or a third party, except where such interests are overridden by the interests or fundamental rights or freedoms of the data subject.
Our primary market is business to business. We will only engage in marketing activity by email, telephone, social media (such as LinkedIn) or direct mail to existing customers/suppliers or prospects if there is a legitimate interest to do so, for example, to develop our products/services. We will assess that legitimate interest is valid and that this interest does not outweigh the interests, fundamental rights, or freedoms of the data subject.
SHARING YOUR PERSONAL DATA
Your personal data will be treated as strictly confidential, and will be shared only with:
- Third party suppliers and service providers (such as freight companies, payment processing companies) as part of contractual obligations
- Third party service providers who provide IT and System administration services (such as accounting/CRM software services, website development/support services)
- Any legal, government or regulatory bodies where disclosure is a legal requirement or where we are involved in legal proceedings
- Professional advisers including lawyers, bankers, auditors and insurers who provide consultancy, banking, legal, insurance, and accounting services
HOW LONG DO WE KEEP YOUR PERSONAL DATA?
We keep your personal data for no longer than reasonably necessary and we only retain your data for the following purposes and use the following criteria to determine how long to retain your personal data:
- Personal data we collect from you (or a client relating to you) will be retained where we have an ongoing legitimate business reason to do so, for example, fulfilling our obligations to you, complying with regulatory and legislative requirements.
PROVIDING US WITH YOUR PERSONAL DATA
We require your personal data as it is a requirement necessary to enter into a contract.
If you fail to adhere, the consequences will be that we will not be able to engage in business with you
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.
YOUR RIGHTS AND YOUR PERSONAL DATA
Unless subject to an exemption under the GDPR, you have the following rights with respect to your personal data:
- The right to request a copy of the personal data which we hold about you
- The right to request that we correct any personal data if it is found to be inaccurate or out of date
- The right to request your personal data is erased where it is no longer necessary to retain such data
- The right to withdraw your consent to the processing at any time, where consent was your lawful basis for processing the data
- The right to request that we provide you with your personal data and where possible, to transmit that data directly to another data controller (known as the right to data portability), where applicable, i.e., where the processing is based on consent or is necessary for the performance of a contract with the data subject, and where the data controller processes the data by automated means
- The right, where there is a dispute in relation to the accuracy or processing of your personal data, to request a restriction is placed on further processing
- The right to object to the processing of personal data, where applicable, i.e., where processing is based on legitimate interests or the performance of a task in the public interest/exercise of official authority, direct marketing and processing for the purposes of scientific/historical research and statistics.
TRANSFER OF DATA ABROAD
To fulfil certain contracts, the information you give us may be transferred to countries outside the European Economic Area (EEA). These countries may not have similar data protection laws to the UK. When we do transfer your personal data outside of the EEA, we ensure that any party with access to your information has implemented the necessary security and privacy measures, to ensure that your personal data is kept secure and confidential as outlined in this policy.
If we wish to use your personal data for a new purpose, not covered by this Data Privacy Notice, then we will provide you with a new notice explaining this new use prior to commencing the processing and setting out the relevant purposes and processing conditions.
HOW TO MAKE A COMPLAINT
To exercise all relevant rights, queries, or complaints please in the first instance contact Data Representative on +44 (0)161 477 2201.
If this does not resolve your complaint to your satisfaction, you have the right to lodge a complaint with the Information Commissioners Office on 03031231113 or via email https://ico.org.uk/global/contact-us/email/ or at the Information Commissioner’s Office, Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF, England.