Policy – Data Privacy Policy

AUTHORISED BY: Paul Hornby CEO
Written by: Angela Cox Financial Controller

The registered office is

Foilco Ltd Enterprise Way, Lowton St Mary’s, Warrington, Cheshire, WA3 2BP

 

Who we are

Foilco Limited is a company registered in England and Wales, company registration number 02140459, whose registered address is Enterprise Way, Lowton St Marys, Warrington, Cheshire, WA3 2BP (“we”, “us”, “our”) and is committed to protecting the privacy and security of personal information.  This privacy policy outlines how we use the information that we collect from you as one of our customers, suppliers or through your use of our website.  It makes you aware of how and why personal information will be used, namely for the purposes of the performance of our contract with our customers and how long it will usually be retained for.  It provides you with certain information that must be provided under the UK General Data Protection Regulation (“UK GDPR”).

This policy primarily covers how we use information relating to our customers, suppliers and users of our website.  It is important that you read this policy, together with any other privacy notice or privacy policy we may provide on specific occasions when we are collecting or processing personal information about you, so that you are aware of how and why we are using such information.

Our legal status

We are a “data controller” for the purposes of the Data Protection Act 2018 and the UK GDPR whilst providing our services to customers and users of our website and communicating with our suppliers.

What personal information do we collect?

We collect and process the following personal information about customers, prospective customers and users of our website:

Contact details such as your name, address, telephone numbers and email address;
Bank and transaction details such as details about payments you have made to us;
Details of the products you have purchased from us and/or details about products you have made enquiries about;
Records of your correspondence with us, either through our website, social media or by telephone, e-mail or post;
Telephone recordings;
Technical data including your 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 our website;
Details of your use of our website including, but not limited to, cookies, traffic data, location data and other communication data and the resources and services that you access via the website;
Details survey responses that we use for research purposes or any competitions you have entered; and
Details of your contact preferences, marketing preferences, interests and any survey responses.

We do not normally collect “special categories” of sensitive personal data from our customers or users of our website. In the event you provide us with any special category data, we will take extra care to ensure your rights are protected.

How do we collect your information?

We will collect personal information through different methods including:

Direct interactions with you via our website, social media, telephone, email or otherwise;
Through the service we provide to our customers;
From third party partners and suppliers;
From publicly available sources such as social media; and
Automated technologies or interactions.  As users interact with our website, we may automatically collect technical information about your equipment, browsing actions and patterns.  

How will we use information about you?

We have set out below a description of all the ways we plan to use your information, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.  We may process your information for more than one lawful ground depending on the specific purpose for which we are using your information.

Purpose/Activity

Type of Information

Lawful Basis for Processing Information

To register you as a new or prospective customer, supplier or partner

Contact details

Details of products purchased

 

Performance of a contract with you

To administer our products and services to you

Contact details

Details of products purchased

Performance of a contract with you

To process and operate our business including managing payments and charges and collecting any money owed to us

Contact details

Details of products purchased

Financial records

Telephone recordings

 

Performance of a contract with you

Necessary for our legitimate interests to recover any debts due to us

To manage our relationship with you which will include notifying you about changes to our terms or privacy policy and asking you to leave a review or take a survey and other market research activities

 

Contact details

Details of products purchased

Marketing and communications information

Performance of a contract with you

Necessary to comply with our legal obligations

Necessary for our legitimate interests to understand how our customers use our products and services to develop them and grow our business

To administer and protect our business and our website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)

Contact details

Technical data

Necessary to comply with our legal obligations

Necessary for our legitimate interests to run our business, provision of IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise

To use data analytics to improve our website, services, marketing, customer relationships and experiences

Technical data

Telephone recordings

Necessary for our legitimate interests to better understand our customers and their use of our services, to keep our website up to date, to develop our business and to inform our marketing strategy

To manage competitions and promotions you may take part in

 

Contact details

Marketing and communications information

 

Consent

Necessary for our legitimate interests to develop our products and to grow our business

To make suggestions and recommendations to you about our services and our business that may be of interest to you

 

Contact details

Technical data

Profile data

Marketing and communications information

Necessary for our legitimate interests to develop our products and to grow our business

To resolve any dispute or legal proceedings

 

Contact details

Details of products/services purchased

Records of correspondence

Telephone recordings

 

Necessary to comply with our legal obligations

Necessary for our legitimate interests to protect our business and resolve any disputes

Change of purpose

We will only use your personal information 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 information 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 information without your knowledge or consent, in compliance

with the above rules, where this is required or permitted by law.

Our marketing communications

We may use the personal information of customers and users of our website to contact you to inform you about services we believe might be of interest to you via email or text message (we call this marketing communications).  Users of our website may receive marketing communications from us unless you have opted out or unsubscribed to receiving that marketing.

You can ask us to stop sending you marketing communications at any by following the unsubscribe links on any marketing communications sent to you or by contacting us at any time.

Where you opt out of receiving these marketing communications, this will not apply to personal information provided to us as a result of the provision of our services and we will still be required to contact you in relation to the services we provide.

Failure to provide personal information

If you fail to provide certain information when requested either by law, or under the terms of a contract we have with you and you fail to provide that information when requested, we may not be able to perform the contract we have or are trying to enter into with you.

Data sharing

We may share personal information with third parties where required by law, where it is necessary to administer the working relationship with you or where we have another legitimate interest in doing so.   Third party providers we may share your information with include:

Business partners, suppliers and sub-contractors for the performance of any contract we enter into with them or you such as our card payment provider;
Advertisers and advertising networks that require the data to select and serve relevant adverts to you and others.  
Analytics and search engine providers that assist us in the improvement and optimisation of our website;
Auditors, accountants and financial organisations;
Insurers, solicitors, professional advisers and consultants;
HMRC;
Central and local government;
Local authorities;
Debt collection agencies;
Police forces, courts and tribunals; and
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 policy.

Any third parties will be bound by contractual provisions with us and only have access to personal data to perform the described purposes and may not use it for other purposes. Further, they must process the personal data in accordance with this privacy policy and as permitted by the UK GDPR and the Data Protection Act 2018.

Data retention

We will only retain personal information 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. Details of retention periods for different aspects of personal information are available upon request.  After this period, we will securely destroy personal information in accordance with data protection law.

International transfers of data

The personal information that we collect is stored within the United Kingdom (UK).  It may be necessary to transfer and store personal information at a destination outside the UK in order for us to fulfil our obligations to customers in regards to the provision of our services (e.g. to take orders from our customers).  We will take all steps reasonably necessary to ensure that personal information is treated securely and in accordance with this policy and, in the event that personal information is transferred outside the UK, shall ensure that this is carried out subject to the requirements of the UK GDPR.  This means that your personal information will be subject to one or more of the appropriate safeguards set out in data protection law to ensure your personal information is adequately protected.  Further details on the safeguards in place to protect your personal information when transferred outside the UK are available upon request.

Cookies

A “cookie” is a piece of information that is stored on your computer or mobile device to recognise your browser and which records how you have used a website.  This means that when you go back to that site, it can give you tailored options based on the information it has stored about your last visit. You can normally alter the settings of your browser to prevent it from accepting cookies.  We use cookies to improve the way the website works and to monitor how people use our site.  This helps us to understand how people use the website so we can develop and improve the design, layout and function of the website.

We use the following cookies:

Strictly necessary cookies – These are cookies that are required for the operation of our website. Strictly necessary cookies enable core functionality such as security, network management, and accessibility.
Analytical or performance cookies – These allow us to recognise and count the number of visitors and to see how visitors move around our website when they are using it. This helps us to improve the way our website works, for example, by ensuring that users are finding what they are looking for easily.
Functionality cookies – These are used to recognise you when you return to our website. This enables us to personalise our content for you and remember your preferences.
Targeting cookies – These cookies record your visit to our website, the pages you have visited and the links you have followed. We will use this information to make our website and the advertising displayed on it more relevant to your interests.

For more information on cookies and how to disable them please go to the Information Commissioner’s webpage on cookies: https://ico.org.uk/for-the-public/online/cookies. You can block cookies by activating the setting on your browser that allows you to refuse the setting of all or some cookies. However, if you use your browser settings to block all cookies (including essential cookies) you may not be able to access all or parts of the website.

Your rights

Under certain circumstances, by law you have the right to:

Right to request a copy of your information

You can request a copy of your information which we hold (this is known as a subject access request).

Right to correct any mistakes in your information

You can require us to correct any incomplete or inaccurate information.

Right to request erasure of your personal information

This enables you to ask us to delete or remove personal information where there is no good reason for us to continue to process it.

Right to object to processing

You have the right to object to processing 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.

You can ask us to stop contacting you for direct marketing purposes. If you would like to do this, please contact us using the details below.

Right to request the restriction of processing

You have the right to ask us to suspend the processing of personal information about you, for example if you want us to establish its accuracy or the reason for processing it.

Right to request the transfer of your personal information to another party

If you want to review, verify, correct or request erasure of your personal information, object to the processing of your personal information, or request that we transfer a copy of your personal information to another party, please contact us using the contact details below.  

Right to withdraw consent

In the limited circumstances where you may have provided consent to the collection, processing and transfer of personal information for a specific purpose has been provided, individuals have the right to withdraw consent for that specific processing at any time. To withdraw your consent, please contact us using the contact details below. Once we have received notification that you have withdrawn your consent, we will no longer process your information for the purpose or purposes you originally agreed to, unless we have another legitimate basis for doing so in law.

Please note, there are some specific circumstances where these rights do not apply and we can refuse to deal with your request.

We may need to request specific information from you to help us confirm your identity and ensure your right to access the information (or to exercise any of your other rights). This is another appropriate security measure to ensure that personal information is not disclosed to any person who has no right to receive it.

You will not have to pay a fee to access your personal information (or to exercise any of the other rights). However, we may charge a reasonable fee if your request for access is clearly unfounded or excessive.Alternatively, we may refuse to comply with the request in such circumstances.

Complaints

If you have a concern about the way we are collecting or using personal information, we would ask that you raise your concern with us in the first instance by e-mailing dpo@foilco.com.

Alternatively you can make a complaint to the Information Commissioner’s Office at https://ico.org.uk/concerns/ or write to Information Commissioner’s Office, Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF.

Contact details

If you have any questions about this privacy policy or how we handle personal information, please contact dpo@foilco.com.

Changes to this privacy policy

We reserve the right to update this privacy policy at any time, and we will provide you with a new privacy policy when we make any substantial updates.

 

                    SEC16    Issue 01       03.07.2024Page 1 of 6

 

This document is controlled & updated only if accessed on public folders

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