1. Introduction
At Saywell International we take the protection of your personal data very seriously and undertake to respect your privacy at all times.
This privacy notice (“notice”) will explain how we look after your personal data and how the law can help to protect your rights to privacy. The notice applies to the processing of personal data by Saywell International in connection with any:
Any references in this notice to “you” or “your” are references to individuals whose personal data Saywell International processes in connection with customer and supplier services. When we refer to our “customers” or our “suppliers” this includes their employees or other staff whose personal details we process.
This Privacy notice is issued on behalf of Saywell International Limited and its wholly owned subsidiary Saywell International Inc. Together, they are referred to as “Saywell International”. References in this notice to “Saywell International”, “we”, “us” or “our” are references to the relevant company in the group responsible for processing your data. Saywell International Limited is the controller responsible for this website and whose registered office is Aviation Centre, Downlands Business Park, Worthing, West Sussex BN14 9LA, England.
2. Importance of personal data protection
We recognise that the use and disclosure of personal data has important implications for us and for the individuals whose personal data we process.
3.Purpose of this notice
This notice aims to give you information about how we collect and process your personal data. It is important that you read this notice together with any other notices we may provide on specific occasions when we are collecting or processing your personal data, so that you are fully aware of how and why we are using your personal data. This notice supplements the other notices and is not intended to override them.
4. Who is the controller for the personal data processed?
A “controller” is a person or organisation who alone or jointly determines the purposes for which, and the manner in which, any personal data is, or is likely to be, processed. Saywell International Limited is the controller for your personal data.
We have appointed a data protection officer (DPO) who you can contact If you have any questions about this notice, including any requests to exercise your rights.
Contact details are as follows:
Aviation Centre, Downlands Business Park
Worthing
West Sussex
BN14 9LA
UK
Data Protection Officer: DPO@saywell.co.uk
5. How to make a complaint about the use of your personal data by us
If you have any concerns or would like to make a complaint about our processing of your personal data, please contact our Data Protection Officer in the first instance. You have the right to complain at any time to the Information Commissioner’s Office (ICO) the UK supervisory authority for data protection issues (www.ico.org.uk). However, we would encourage you to contact us in the first instance as we aim to promptly, efficiently and satisfactorily resolve any concerns or complaints you may have in relation to Saywell International’s processing of your personal data.
6. Changes to the notice or to your personal data
The first version of this notice was issued in May 2018 and this notice was last updated on the “as amended on” date (if any) on the cover page of this notice. Any prior versions of this notice can be obtained by contacting us at DPO@saywell.co.uk.
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. If you wish to update your personal data, please contact your usual Saywell International contact.
7. The personal data we collect about you
Personal data includes any information about an individual from which that person can be identified. It does not include personal data where the identity has been removed (anonymous data).
We collect, use, store and transfer different kinds of personal data about you. We have grouped together the following categories of personal data to explain how this type of information is used by us. These terms are used throughout this notice:
Neither our website or the services we offer are intended for children and we do not knowingly collect data relating to children.
8. If you fail to provide personal data to us
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 the personal 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 a product or services). In this case, we may have to decline to provide or receive the relevant services, but we will notify you if this is the case at the time the personal data is collected.
9. How your personal data is collected
We use different methods to collect personal data from and about you, including through the channels set out below.
Direct interactions: You give us your personal data in your direct interactions with us. Such personal data includes Identity Data, Contact Data, Financial Data, Services Data, Profile Data, Usage Data, Marketing and Communications Data, Professional Information, and/or Professional History which you give us from time to time (i) by filling in forms on our website or (ii) corresponding with us by email, post, in person, telephone or otherwise. Such direct interactions include, for example, instances when you:
Website, cookies and marketing: You give us your personal data, which includes Profile Data, Usage Data, Professional Information and/or Marketing and Communications Data, when you use our website or review the publications or marketing we send you.
Third-party sources: We receive Identity Data, Contact Data, Financial Data and Professional Information about you from third parties, when we:
Publicly available sources: We collect Identity Data, Contact Data, Financial Data, Professional Information, Professional History from publicly availably sources, including from:
10. How we use your personal data
We will only process (i.e. use) your personal data when the law allows us to, that is, when we have a legal basis for processing. Section 11 (Purposes and legal basis for which we will use your personal data) below sets out further information about the legal bases that we rely on to process your personal data.
We use your personal data in the following circumstances:
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).
With limited exceptions (for instance, in relation to some of our electronic marketing), generally we do not rely on consent as the legal basis for processing your personal data. You have the right to withdraw consent to electronic marketing at any time by following the unsubscribe instructions in such marketing materials or by contacting us at DPO@saywell.co.uk. Please refer to Section 13 (Marketing and exercising your right to opt-out of marketing) for more information about how we use your personal data for marketing purposes and your rights.
11. Purposes and legal basis for which we will use your personal data
We set out below, in a table format, a description of the ways in which we use your personal data and the legal bases we rely on to do so. Where appropriate, we have also identified our legitimate interests in processing your personal data.
We may process your personal data for more than one legal basis depending on the specific purpose for which we are using your personal data. Please contact us at DPO@saywell.co.uk if you need details about the specific legal basis we are relying on to process your personal data where more than one ground has been set out in the table below.
Purpose and/or activity | Type of data | Legal basis for processing |
To register you on as a new customer |
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To deliver our product or services to you including (among others) to manage payments, fees and charges and to collect and recover money owed to us |
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To manage our relationship with you which will include notifying you about changes to our terms of business or this notice |
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To manage and protect our business, including improving data security, troubleshooting data and systems, system maintenance and testing, data hosting, managing our offices and other facilities |
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To invite you to take part in marketing or other promotional events and to manage your participation in them |
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To send you marketing (including paper and electronic marketing communications) or to contact you by other means to offer you our products or services |
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To ask you for feedback (for instance, in a survey) about our services and to manage, review and act on the feedback we are getting |
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12. Change of purpose
We will only use your personal data for the purposes for which we collected it as detailed in Section 10 (How we use your personal data) andSection 11 (Purposes and legal basis for which we will use your personal data), 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 receive an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us at DPO@saywell.co.uk.
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.
13. Marketing and exercising your right to opt-out of marketing
We will not use your personal data to send you marketing materials if you have requested not to receive them. If you request that we stop processing your personal data for marketing purposes, we shall stop processing your personal data for those purposes.
We would encourage you to make such requests via email to your usual Saywell International contact or to DPO@saywell.co.uk. In any event, such request can be made at any time free of charge.
14. Third-party marketing
We do not share your personal data with any organisations outside of Saywell International for marketing purposes.
15. Disclosures of your personal data
We may have to share your personal data with the entities and persons set out below for the purposes for which we collected the personal data, as detailed in Section 10 (How we use your personal data) and Section 11 (Purposes and legal basis for which we will use your personal data).
We require any person or entity to whom we disclose personal data to respect the confidentiality and security of your personal data and to treat it in accordance with applicable laws and regulations. We do not allow such recipients of your personal data to use it for their own purposes, and we only permit them to process your personal data for specified purposes and in accordance with our instructions.
16. International transfers
We may share your personal data within the Saywell International group. This may involve transferring your personal data outside the European Economic Area (“EEA”).
In some cases, our external third parties are based outside the EEA. Therefore their processing of your personal data will involve a transfer of such 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:
Please contact us at DPO@saywell.co.uk if you would like further information about the specific mechanism used by us when transferring your personal data out of the EEA.
17. Data security
Taking into account the state of the art, the costs of implementation and the nature, scope, context and purposes of processing as well as the risk of varying likelihood and severity for the rights and freedoms of natural persons, we implement appropriate technical and organisational measures to ensure a level of security appropriate to the risk of processing, including:
We ensure that those who have permanent or regular access to personal data, or that are involved in the processing of personal data, or in the development of tools used to process personal data, are trained and informed of their rights and responsibilities in when processing personal data.
18. Data retention
We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for. This includes for example the purposes of satisfying any legal, regulatory, reporting or accounting 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.
It is a legal requirement in the United Kingdom to keep basic information about customers (including Contact, Identity, Financial and Transaction Date) for six years even after they cease being customers.
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.
19. Your legal rights
Under certain circumstances, you have rights under data protection laws in relation to your personal data.
Details of your rights are set out below:
You may exercise any of your rights at any using the contact details set out in Section 4. 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.
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.
We try to respond to all legitimate requests within one calendar month. Occasionally it may take us longer than one calendar 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.
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