Last Updated: 26 June 2023
This Policy applies only to personal data processed by Hallite UK. If you contract with or provide personal data to another company outside the United Kingdom in the Hallite Group of companies (“Hallite Group Companies”) those Hallite Group Companies have their own privacy policies which will apply to their processing of your personal data. If you submit an enquiry using the Contact Us web form your enquiry will be automatically sent to the Hallite Group company that services customers in your geographical location.
Wherever this Policy refers to us using personal data on the basis that it is in our “legitimate interests” to do so, this shall be subject to the proviso that such interests must not be overridden by your own interests or fundamental rights and freedoms.
You have the right to lodge a complaint with the Information Commissioner’s Office (“ICO”) if you have any concerns with regard to the way in which we process your personal data. We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.
We are registered as a data controller with the Information Commissioner’s Office and our ICO registration number is ZA579154.
1. Information We Collect
We may collect personally identifiable information about you, such as your full name, email address, telephone number, company name, country location or similar. You may provide us with your personal data in various ways including:
- When your organisation opens an account with us or purchases products or services from us
- When you subscribe to our e-newsletter
- When you contact us or request a quote using our Contact Us web form
- When you use our Custom Seal Builder web form
- When you provide us with any feedback
- When you download documents and files such as datasheets, brochures, white papers and CAD drawings
Where we need to collect personal data in connection with any products or services which you wish us to supply and you fail to provide that personal data when requested, we may not be able to supply such products and services or perform any related contract that we have or are trying to enter into with you.
2. How We Use Your Information
We use the personal data that we collect to supply our products and services, send you marketing communications where permission has been given, respond to your questions and concerns and to help our service providers improve their offerings.
(a) Contracts: We use personal data for performing any contract that we have with you.
(b) Operations: We use personal data where necessary for our legitimate interests to respond to comments and questions and to provide support to our customers.
(c) Improvements: We use the personal data where necessary for our legitimate interests in understanding and analysing the usage trends and preferences of users of our website and other platforms, to improve our service to our customers, and to develop new products, services, features, and functionality. If any of these purposes require us to process personal data it will only be used in anonymised or aggregated form.
(d) Communications: We may use a user’s email address or other personal data where necessary for our legitimate interests in contacting that user for administrative purposes such as to provide customer service and to address intellectual property infringement/right of privacy violations. In addition, we may (provided that we have the user’s consent where necessary) use their email address or other contact details to send you information about our products and services and about Hallite UK and Hallite Group Companies generally. You have the ability to unsubscribe / opt-out of receiving any promotional communications at any time through an automated online unsubscribe service as detailed in the footer of sent marketing messages and all electronic communications (or you may alternatively contact us using the details in section 13 below to unsubscribe).
We take measures to protect the technical information collected by our use of Google Analytics. The personal data collected will only be used on a need to know basis to resolve technical issues, administer our website and other platforms and identify visitor preferences; but in these cases, the personal data will be in non-identifiable form. We do not use any of the information to identify visitors or users.
3. How We Share Your Information
(a) Personally Identifiable Information: We will not rent or sell your personal data to others. We may disclose personal data to third parties who are directly involved in dealing with any request, enquiry, correspondence or contract involving you or who are otherwise processing your personal data on our behalf in accordance with our instructions. We may store personal data in locations outside the direct control of Hallite UK (for instance, on servers or databases co-located with hosting providers). Any personal data you elect to make publicly available on our website, such as posting comments on our blog page, will be available to others. If you remove information that you have made public on our website, copies may remain viewable in cached and archived pages of our website, or if other users have copied or saved that information.
(b) Non-Personally Identifiable Information: We may share non-personally identifiable information (such as anonymous usage data, referring/exit pages and URLs, platform types, number of clicks, etc.) with interested third parties to help them understand the usage patterns for our website and other platforms. Non-personally identifiable information may be stored indefinitely.
(c) Instances Where We Are Required Or Legally Permitted To Share Your Information: We will disclose your information where required to do so by law, if subject to subpoena or other legal proceedings or if we reasonably believe that such action is necessary for our legitimate interests (i) to comply with the law and the reasonable requests of law enforcement; (ii) in connection with any criminal investigations, legal proceedings or prospective legal proceedings, (iii) to enforce a contract; and/or (iv to exercise or protect the rights, property, or personal safety of Hallite, our users or others (including providing information to others for the purposes of fraud prevention). This may include disclosures to our professional advisers in connection with such purposes.
(d) What Happens In The Event Of A Change Of Control: We may buy or sell/divest/transfer the company (including any shares in the company), or any combination of its products, services, assets and/or businesses. Personal data such as customer names and email addresses may be among the items sold or otherwise transferred in these types of transactions. We may also assign or otherwise transfer such information in the course of corporate divestitures, mergers, acquisitions, bankruptcies, dissolutions, reorganisations, liquidations, similar transactions or proceedings involving all or a portion of the company. You will be notified via email and/or a notice on our website of any change in ownership or uses of your personal data, as well as any choices you may have regarding your personal data. Any such disclosures will be made where necessary for our legitimate interests and/or the third party in respect of the proposed transaction; however we will not transfer your personal data to any such third party unless we are satisfied that they are able to provide an adequate level of protection in respect of your personal data.
4. Storage and Processing
Your personal data may be stored and processed in Europe, the United States, or any other country in which we or our service providers maintain facilities. We may (where required in connection with any purpose described in section 3 above or otherwise permitted by law) transfer information that we collect about you, including personal data, to Hallite Group Companies or to other third parties outside the United Kingdom. Except in the case of temporary transfers mentioned in section 6 of this Policy we will only transfer your personal data outside the United Kingdom where we are authorised to do so and appropriate safeguards are in place. Where any personal data is disclosed by us to a third party (acting on our or their own behalf) based outside of the United Kingdom and European Economic Area, we will require the relevant third party to put in place appropriate technical and organisational data protection security measures (for example as part of any related contract with that third party).
Hallite UK complies with the DPA (Data Protection Act 2018) and the GDPR (General Data Protection Regulation) (including the ‘UK GDPR’ retained in domestic UK law).
6. How We Protect Your Information
We have implemented appropriate security measures to prevent personal data being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to personal data to those employees, agents, contractors and other third parties who have a business need to know that information. However, the Internet is global and we cannot ensure or warrant the security of any transmission of information that you disclose to us and we will not be responsible for any breach of security unless this is due to our breach of legislation, negligence or wilful default. When you enter personal data via our contact and sign-up forms, we encrypt that information. However, no method of transmission over the Internet or method of electronic storage, is 100% secure. It is also possible that personal data you provide to us will be temporarily transferred via a route outside the UK and European Economic Area as it passes between us. If you have any questions about security on our website and other platforms, you can contact us at firstname.lastname@example.org.
7. Compromise of Personal Information
We have put in place procedures to deal with any suspected data security breach. In the event that personal data is compromised as a breach of security, we will promptly comply with any applicable legal requirements to notify any applicable regulator and any affected customers.
8. Access to your information
You have a legal right to see a copy of the personal data that we keep about you and to correct any inaccuracies, subject to certain exemptions. In some circumstances you may also have the right to:
(a) request that we erase any personal data held about you;
(b) restrict our processing of your personal data (for example, to ask to suspend the processing of personal data to establish its accuracy or the reasons for processing it);
(c) data portability (i.e. to request the transfer of personal data to a third party); and
(d) object to our processing of your personal data where we are relying on a legitimate interest (or those of a third party).
Requests of the nature described above should be made in writing to the Data Protection Officer, Hallite Seals International, 130 Oldfield Road, Hampton, Middlesex, TW12 2HT or via email at email@example.com. Please contact the same address if you have any reason to believe that personal data we hold about you is inaccurate. We will respond to your request as soon as possible and, in any event, within one month from the date of receiving the request. Please note that we may, where legally permitted, reject any such request or limit the scope of our response (e.g. if, in the circumstances, the right does not apply to you).
In accordance with applicable data protection legislation, we follow security procedures in the storage and disclosure of your personal data. We may therefore request proof of your identity before disclosing certain information to you or complying with any other request of or a nature described above.
You will not generally have to pay a fee to exercise any of your rights described above. However, we may charge a reasonable fee if you make a request to see a copy of your personal data which is clearly unfounded or excessive. Alternatively we may refuse to comply with your request in such circumstances.
9. Retention and Destruction of your Personal Data
Any personal data held by us in relation to any of the purposes described in this Policy will be retained by us for as long as we need it to fulfil the purpose(s) for which it was collected. For example, if we are retaining personal data to comply with a legal obligation then we will retain it for as long as is necessary to comply with that legal obligation. Further details of our specific retention periods are available upon request.
For example, if you have consented to receiving any of our newsletters, your preferences in that regard will be retained by us unless and until:
(a) we cease producing our newsletter; or
(b) you withdraw your consent,
following which we will destroy or suppress such personal data without delay so that you no longer receive our newsletter.
Save for any contact preferences suppressed as described above, your personal data will be securely destroyed at the end of the relevant retention period described or otherwise referred to in this section 9.
Whilst taking into consideration our legal obligations, we will on an ongoing basis review the length of time that we retain your personal data, consider the purpose or purposes for which we hold the personal data in deciding whether (and for how long) to retain it for, securely delete personal data that is no longer needed for such purpose or purposes and update, archive or securely delete personal data if it goes out of date.
11. Links to Other Web Sites
We cannot control, and are not responsible for, the practices employed by websites or services linked to or from our website or other platforms, including the information or content contained therein. Please remember that when you use a link to go from our website or other platforms to another website or service, our Policy does not apply to third-party websites or services. Your browsing and interaction on any third-party website or service, including those that have a link on our website or other platforms, are subject to that third party’s own rules and policies (that third party will be the controller of any information that you provide to them and will assume corresponding responsibilities under applicable data protection legislation).
You acknowledge that any content that you post using our social media facilities will be considered non-confidential and non-proprietary, and that we have the right to monitor, remove, use, copy, distribute and disclose to third parties any such content for any purpose permitted by law.
You acknowledge that we will cooperate with any person, law enforcement authority or court order requesting or directing us to disclose the identity of anyone posting or sending material using any of our social media facilities in breach of any law (whether civil or criminal) or the legal rights of any party (including but not limited to intellectual property rights and rights to privacy).
13. Contact Us
If you have any questions about this Policy or your dealings with Hallite UK please contact us at firstname.lastname@example.org, or send mail to:
Data Protection Officer
Hallite Seals International Limited
130 Oldfield Road
Tel: 020 8941 2244