- Data Protection
From time to time, as part of running our business, we collect and use certain personal information about individuals with whom we have contact (we refer to such individuals in this policy as “you” or “your” or “contacts”). Broadly speaking, we collect personal information about 2 types of individuals:
- end buyers of our products (potential buyers and existing buyers); and
- our business contacts (suppliers and distributors).
Please see separate sub-headings below which explains the differences between how we treat these 2 categories.
Under data protection law, we have certain legal responsibilities about how we collect, use and share your personal information.
This policy explains our privacy practices and covers the following:
- The type of individuals whose personal information we collect
- What personal information about you we collect and use
- Sources of personal information
- How we use your personal information
- What marketing activity we undertake
- Who we share your personal information with
- How long we retain your personal information for
- Any transfers involving your personal information
- How we legally justify using your personal information
- Your legal rights in relation to your personal information
- Other relevant information, including how to contact us
1 Whose personal information do we collect
We collect and use personal information relating to the following types of individuals:
- Existing buyers – we hold personal information on existing buyers who have already purchased our products from our distributors. We sell our products (via distributors) to individual consumers and also to commercial buyers.
- Potential buyers – we collect information about people (or people at businesses) who are interested in our products, for example if you have telephoned us or have registered an interest via email or on our website, or you may attend an event where our products are displayed, such as a trade fair.
- Contacts at our distributors - we collect and use contact details of people whom we liaise with at companies who are distributors of our products.
- Contacts at our suppliers - we collect and use certain personal information about contacts who work at organisations who supply goods and services to us (e.g. delivery companies, IT service providers, accountancy firms, legal advisors etc.).
2 What personal information about you we collect and use
Depending on whose personal data we collect and use (as indicated above) the information will generally consist of:
(a) Potential and existing buyers (consumers): name, email address, personal phone number and home address.
(b) Potential and existing buyers (businesses): name, work email address, work phone number and place of work, job title.
For Business contacts
(c) Contacts at our distributors: name, job title, email address, phone number, place of work, relevant qualifications and work address.
(d) Contacts at our suppliers: name, job title, place of work, email address, phone number and work address.
We therefore do not collect any sensitive personal data about individuals, such as details of their health conditions, race, ethnicity, sexuality etc..
3 Sources of personal information
(a) Information you provide directly to us – when you get in touch with us, for instance by email, if you call us, or get in touch via our website, e.g. if you sign up for our newsletter.
(b) From events that you attend (potential buyers only) – we advertise our products at various trade fairs across the UK and Ireland – you may attend these and may pass on your contact details to us or a third party at the trade fair.
For example, you may pass your contact details to an Internorm distributor at the trade fair when you fill in a form. Alternatively, we may receive your personal information from the organiser of the event, e.g. if we scan in your pass at our stand, which means that your personal information is shared with us via the event organiser.
(c) From our distributors – for example if you are an existing buyer or potential buyer and you contact one of our distributors by telephone with a query, they may pass us your contact details along with details of your query, e.g. regarding a quote for certain products.
(e) Information from your employer – your employer may pass us your contact details, for instance if you are to act as a point of contact at a distributor (e.g. sales rep) or supplier.
(f) From you directly – you may pass us your contact details.
4 How we use your personal information
(a) Managing our relationship with existing buyers – we use personal information of existing buyers for managing our relationship with them; this is in our legitimate business interests as it is required for the following reasons:
(i) as part of the sales process;
(ii) for delivery of our products;
(iii) post sale, including handling warranty claims and processing enquiries received from buyers, and
(iv) other similar buyer support related purposes.
Potential Buyers (commercial only)
(b) Sales – we receive enquiries regarding the price of our products, which may involve us receiving, and responding to, an enquiry from a potential buyer e.g. to provide a quote (directly or via a distributor). This too is also in our legitimate business interests. For potential buyers who are consumers, this is done via the distributor only.
(c) Distributors – we use the personal information of contacts at our distributors, as part of our legitimate business interests, specifically in order to effectively manage and communicate with our distributors, to facilitate the effective promotion, sale and distribution of our products.
(d) Day to day relationships with suppliers – we need to communicate effectively and efficiently with our third party suppliers as part of our legitimate business interests, in order to enable them to provide services to us in a timely and effective manner. Therefore, we use personal information for day to day communications and the management of the relationship with such parties. Our communication methods include written correspondence, email, telephone, online video conferencing and face to face meetings.
(e) Managing accounts and other internal administrative purposes – it is in our legitimate business interests for us to process certain limited personal information for other internal administrative purposes, including in relation to setting up and managing accounts with our suppliers, paying invoices etc..
We also undertake various marketing activities – please see paragraph 5 below for more information on this.
5 Marketing activities
Newsletters to distributors
We send our newsletter to existing distributors by email. We rely on legitimate interests for these purposes.
e-marketing campaign – potential buyers
(a) As mentioned above under paragraph 3(d), it is possible for people to give us their personal information via our online pop up. We use this information for the following purposes:
(i) to send you our brochure by email (we will only collect your name and email address for this purpose); and/or
(ii) to pass your name, email address and phone number to one of our distributors for them to contact you regarding a potential sale of our products.
We will only use your personal information for the above purposes where you have given us your prior consent to do so.
You also have the right to opt out of direct marketing at any time – please see paragraph 10 below for more details of this right and your other rights.
6 Parties who we share your personal information with
Your personal information is shared with the following parties:
a) Internal Sharing – from time to time your personal information may be shared internally, with our parent company Internorm International GmbH, who are based in Austria and whose address is Ganglgutstr. 131, 4050, Traun, Austria.
a) With our Distributors (commercial buyers only) – we pass personal information of existing and potential commercial buyers to our distributors, for the distributors to handle the sale and subsequent relationship e.g. to deal with after sales services and warranty issues.
b) With our Suppliers (commercial buyers only) – we provide personal information of buyers to our delivery companies, who deliver the products.
c) With our IT service providers (buyers (commercial and consumer) and business contacts) – suppliers who provide IT systems to us, particularly our CRM software supplier, may occasionally have supervised access to parts of our IT systems which contain personal information, particularly for maintenance and support purposes.
Where we share personal information with third parties, where possible, we generally have contracts in place with such third parties, which ensures that they will protect your personal information and not use it for any purposes beyond delivering their services to us.
7 How long we retain your personal information for
The length of time that we retain your personal information for varies, according to the type of individual whose personal information we have collected, and what this is being used for:
Type of individual | Applicable retention period
Existing buyers | For 10 years from the date of purchase, since we offer warranties that last up to 10 years. See our warranty certificate for detailed information on the different warranty periods.
Potential buyers | For a maximum of 3 years – the justification being that in our experience, many potential buyers make an initial enquiry about purchasing our products and then come back to us only 2-3 years later, once they are in a position to go ahead with the purchase.
Contacts at our suppliers | For the duration of the contract which we have with a supplier plus 7 years.
Contacts at our distributors | For the duration of the contract which we have with a distributor plus 7 years.
8 Transfers of your personal information
We will not transfer your personal information outside the European Economic Area (EEA).
9 Legal grounds for processing your personal information.
Every use that we make of your information must meet a legal ground in the list set out by data protection law. Please see above in relation to the different uses, regarding which legal grounds which we rely on – depending on the use, this is either consent or in our legitimate business interests.
10 Your rights in relation to your personal information
If you have any questions in relation to our use of your personal information, you should first contact us using the contact details in paragraph 11 below. Under certain conditions, you may have the right to:
(a) require us to provide you with further details on the use we make of your personal information;
(b) require us to provide you with an electronic copy of personal information that you have provided to us;
(c) require us to update any inaccuracies in the personal information we hold;
(d) require us to transfer a copy of your personal information to another data controller, in a structured, machine readable and commonly used format;
(e) require us to delete any personal information that we no longer have a lawful ground to use;
(f) require us to restrict our use of your personal information;
(g) where the processing of your personal information is based on us receiving your consent, the right to withdraw your consent at any time;
(h) if we indicate that we use your personal information for direct marketing purposes, object to receiving any further direct marketing from us at any time;
(i) complain to the Information Commissioner at any time;
(j) object to our uses of your personal information which are based on the 'legitimate interests' legal ground, as indicated above. If any of our uses of your personal information based only on this legal ground is causing you undue harm, then we must cease using your personal information for that purpose.
Your exercise of these rights is subject to certain conditions and exemptions, for example to safeguard the public interest in investigating crimes, or protecting legal privilege. If you exercise any of these rights, we will check your entitlement and respond in most cases within a month.
If you are not satisfied with our use of your personal information or our response to you, you can complain to the contact listed at paragraph 11 below.
11 Other Information
We will use reasonable endeavours to ensure that your personal information is accurate. In order to assist us with this, you should notify us of any changes to your personal information, by contacting us as set out below.
We are required to employ adequate technical and organisational security measures to protect your personal information from any loss, destruction, damage or unlawful disclosure. However, no transmission of personal information can ever be guaranteed as secure. Consequently, please note that we cannot guarantee the security of any personal information which you transfer to us or which we transfer to you.
If you would like further information about the matters set out in this policy, please contact: firstname.lastname@example.org