Effective from 25th May 2018.
We are committed to protecting and respecting your privacy.
Everyone has rights with regard to the way in which their personal data is handled. During the course of our activities we will collect, store and process personal data about our customers, suppliers and other third parties, and we recognise that the correct and lawful treatment of this data will maintain confidence in the organisation and will provide for successful business operations.
This policy 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.
For the purpose of UK data protection laws, the data controller is Completion Limited of Adelaide Cottage, 281 Old Bath Road, Cheltenham, England, GL53 9AJ.
Data Protection Principles
When processing your information, we must comply with the six enforceable principles of good practice. These provide that your personal data must be:
processed lawfully, fairly and in a transparent manner,
processed for specified, explicit and legitimate purposes,
adequate, relevant and limited to what is necessary,
accurate and kept up-to-date,
kept for no longer than is necessary, and
processed in a manner than ensures appropriate security.
Information you give to us
You may give us information (such as your name, company details, address, email address, phone number, bank account details, social media account details, by filling in forms on our website, or requesting further information about our products and services, participating in discussions on social media outlets, or corresponding with us by phone, email, letter or otherwise.
We may use the information you give to us for a number of different purposes. For each purpose, we are required to confirm the ‘legal basis’ that allows us to use your information, as follows:
As stated in the table above, it is a legal obligation for you to provide us with certain information. If you do not provide us with that information, we may not be able to provide our services to you.
It is also a contractual requirement for you to provide us with certain information. If you do not provide us with that information, we may not be able to perform the contract.
All other information you give us is given entirely as your discretion. If you do not provide that information, then we will be unable to provide a comprehensive service.
Information we collect about you from other sources
When you visit our website, we may collect information about you (such as [the Internet protocol (IP) address used to connect your computer to the Internet, your browser type and version, time zone setting, browser plug-in types and versions, operating system and platform).
When you visit our website, using a mobile device, we may collect information about you (such as country code, language, device name, operating system name and version, GPS location data).
We may also collect information about you by conducting searches of public records (e.g. Companies House, and credit reporting agencies).
We may use the information we collect about you for a number of different purposes. For each purpose, we are required to confirm the ‘legal basis’ that allows us to use your information, as follows:
Purposes for which we will use the information you give to us
1a. To carry out our obligations under any contracts entered into between you and us and to provide you with the information, products and services that you request from us.
1b. To provide you with information about products or services that you request from us, where you have consented to be contacted for such purposes.
1c. To notify you about changes to our products and services.
1d. To assist us in responding to whatever query or interest you have expressed in our products and services.
1e. Any other purpose that we notify to you, but are not expressly listed in this table.
1a. It will be necessary for the performance of the contract between you and us.
1b. We will only do this if you give us your consent by some specific, informed and unambiguous method.
1c. It will be necessary for our legitimate business interests to ensure you are aware of the latest updates to the products and services we provide, or may provide, to you.
1d. It will be necessary for our legitimate business interests to satisfy your queries and concerns and ensuring that we provide a complete service.
1e. We will only do this if you give us your consent by some specific, informed and unambiguous method.
Purposes for which we will process the information
2a. To administer our website and for internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes, to allow you to participate in interactive features of our service, when you choose to do so, to measure or understand the effectiveness of the goods and services we provide you and others, and to make suggestions and recommendations to you and other users of our site about goods or services that may interest you or them.
2b. To obtain further information about you, or any organisation you represent, with a view to sending you marketing information by email.
2c. To obtain further information about you, or any organisation you represent, with a view to us entering into a contract with you or the organisation you represent.
Legal basis for the processing
2a. It will be necessary for our legitimate business interests to ensure you receive the best experience possible when accessing and using our website, and when purchasing our goods and/or services.
2b. It will be necessary for our legitimate business interests to send you correct or relevant information.
2c. It will be necessary for our legitimate business interests to ensure we are fully aware of all issues relating to your organisation that is the subject of the goods and/or services you have expressed an interest in from us.
Disclosure of your information
You agree that we have the right to share your personal information with:
third parties with whom we are collaborating,
our auditors and quality assurance assessors;
business partners, customers, suppliers and sub-contractors to the extent we reasonably consider that it is in your best interests for us to do so, or it is necessary for our legitimate business interests;
analytics and search engine providers that assist us in the improvement and optimisation of our site;
We will disclose your personal information to third parties:
in the event that we enter into negotiations to sell or buy any business or assets, in which case we will disclose your personal data to the prospective seller or buyer of such business or assets;
if Completion Limited or substantially all of its assets are acquired by a third party, in which case personal data held by it about you will be one of the assets transferred to the third party; or
Identifying you as a customer
We may identify you as a customer in our marketing material, although we will never publicly disclose any confidential information without having obtained your prior consent. If you do not agree to us identifying you as a customer, please notify us by writing to the address at the top of this policy, or by emailing us at firstname.lastname@example.org.
Where we store your personal data
All information you provide to us is stored on our secure servers in the United Kingdom, US and Canada.
We will take all steps reasonably necessary to ensure that your data is treated securely, including taking the following safeguards:
Credit cards. We do not store any credit card details.
Entry controls to our building and office.
Secure lockable desks and cupboards. Desks and cupboards are kept locked when not in use if they hold confidential information of any kind.
Methods of disposal. Paper documents are disposed of by shredding in a manner that ensures confidentiality.
Equipment. Our internal policies require that individual monitors do not show confidential information to passers-by and that users lock or log-off from their computer when it is unattended.
Some of the data that we collect from you may be transferred to, and stored at, a destination outside the United Kingdom. It may also be processed by personnel operating outside the United Kingdom who work for us, our group companies or for one of our suppliers. This includes staff engaged in, among other things, the fulfilment of your orders, the processing of your payment details and the provision of support services. By submitting your personal data, you agree to this transfer, storing or processing. If you are concerned about the levels of data security in any of those countries, please let us know and we will endeavour to advise what steps will be taken to protect your data when stored overseas.
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.
How long we will store your personal data
The length of time that we will store your data will depend on the ‘legal basis’ for why we are using that data, as follows:
3a. Where we use/store your data because it is necessary for the performance of the contract between you and us.
3b. Where we use/store your data because it is necessary for us to comply with a legal obligation to which we are subject.
3c. Where we use/store your data because it is necessary for our legitimate business interests.
3d. Where we use/store your data because you have given us your specific, informed and unambiguous consent.
Length of time
3a. We will use/store your data for as long as it is necessary for the performance of the contract between you and us.
3b. We will use/store your data for as long as it is necessary for the performance of the contract between you and us.
3c. We will use/store your data until you ask us to stop. However, if we can demonstrate the reason why we are using/storing your data overrides your interests, rights and freedoms, then we will continue to use and store your data for as long as it is necessary for the performance of the contract between you and us (or, if earlier, we no longer have a legitimate interest in using/storing your data).
3d. We will use/store your data until you ask us to stop.
You have various legal rights in relation to the information you give us, or which we collect about you, as follows:
You have a right to access the information we hold about you free of charge, together with various information about why and how we are using your information, to whom we may have disclosed that information, from where we originally obtained the information and for how long we will use your information.
You have the right to ask us to rectify any information we hold about you that is inaccurate or incomplete.
You have the right to ask us to erase the information we hold about you (the ‘right to be forgotten’). Please note that this right can only be exercised in certain circumstances and, if you ask us to erase your information and we are unable to do so, we will explain why not.
You have the right to ask us to stop using your information where: (i) the information we hold about you is inaccurate; (ii) we are unlawfully using your information; (iii) we no longer need to use the information; or (iv) we do not have a legitimate reason to use the information. Please note that we may continue to store your information, or use your information for the purpose of legal proceedings or for protecting the rights of any other person.
You have the right to ask us to transmit the information we hold about you to another person or company in a structured, commonly-used and machine-readable format. Please note that this right can only be exercised in certain circumstances and, if you ask us to transmit your information and we are unable to do so, we will explain why not.
Where we use/store your information because it is necessary for our legitimate business interests, you have the right to object to us using/storing your information. We will stop using/storing your information unless we can demonstrate why we believe we have a legitimate business interest which overrides your interests, rights and freedoms.
Where we use/store your data because you have given us your specific, informed and unambiguous consent, you have the right to withdraw your consent at any time.
You have the right to object to us using/storing your information for direct marketing purposes.
If you wish to exercise any of your legal rights, please contact us by writing to the address at the top of this policy, or by emailing us at email@example.com.
You also have the right, at any time, to lodge a complaint with the Information Commissioner’s Office if you believe we are not complying with the laws and regulations relating to the use/storage of the information you give us, or that we collect about you.
Changes to our policy
Any changes we make to our policy in the future will be posted on our website and, where appropriate, notified to you by email. Please check our website frequently to see any updates or changes to our policy.
Questions, comments and requests regarding this policy are welcomed and should be addressed to us by writing to the address at the top of this policy, or by emailing us at firstname.lastname@example.org.