Updated for the EU’s General Data Protection Regulation (GDPR).

PURPOSE OF THIS PRIVACY POLICY

The security of your personal data is extremely important to Fassi (U.K.) Limited (“We” or “Fassi”). Fassi is committed to protecting and respecting your privacy.

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.

Please note our website is not intended for children and we do not knowingly collect data relating to children.

WHO WE ARE

For the purpose of the Data Protection Act 1998 as amended by the General Data Protection Regulation (EU) 2016/679 (the Data Protection Legislation), the data controller is Fassi (U.K.) Limited of The Exchange, Haslucks Green Road, Shirley, Solihull, West Midlands, B90 2EL.

We have appointed a data privacy manager who is responsible for overseeing questions in relation to this privacy policy. If you have any questions about this privacy policy, including any requests to exercise your legal rights, please contact the data privacy manager using the details set out at the end of this policy.

You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.

PERSONAL DATA WE COLLECT ABOUT YOU

Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).

We may collect, use, store and transfer different kinds of personal data about you including through our website which we have grouped together as follows:

• Identity and Contact Data includes first name, last name, email address and telephone numbers.
• Technical Data includes internet protocol (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 this website.
• Profile Data includes your username and password where you have been issued with a login to our website.
• Usage Data includes information about how you use our website, products or services.

We do not collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data).

HOW IS YOUR PERSONAL DATA COLLECTED?

We use different methods to collect data from and about you including through:

• Direct interactions. You may give us your Identity and Contact Data by filling in forms, logging in to our website, or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you request information regarding our products or services or log-in as a user to the website.
• Automated technologies or interactions. As you interact with our website, we may automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies and other similar technologies. We may also receive Technical Data about you if you visit other websites employing our cookies. Please see section below entitled “our use of cookies” for further details.
• Third parties or publicly available sources. We may receive personal data about you from various third parties and public sources such as Technical Data from analytics providers such as Google based outside the EU.

COOKIES

What are cookies?

Cookies are small text files that are placed on your computer, smartphone or other device when you access the internet.

Why are cookies essential to Fassi UK’s website?

This website, along with many others, uses cookies. Cookies let users navigate around sites and (where appropriate) let us tailor the content to fit the needs of our site’s visitors. Without cookies enabled we can’t guarantee that the website and your experience of it are as we intended it to be.

None of the cookies we use collect your personal information and they can’t be used to identify you.

Types of cookies

The length of time a cookie stays on your device depends on its type. We use two types of cookies on our websites.

Session cookies are temporary cookies which only exist during the time you use the website (or more strictly, until you close the browser after using the website). Session cookies help our websites remember what you chose on the previous page, avoiding the need to re-enter information.

Persistent cookies stay on your device after you’ve visited our website. A persistent cookie will be used so that the site remembers your choice the next time you use it. Persistent cookies help us identify you as a unique visitor but don’t contain information that could be used to identify you to another person.

At Fassi UK we use web analytics services from other companies to track how visitors reach our site and the path they take through it. These companies use cookies to help us improve our service to you.

The analytics services we use are:

Google Analytics, which uses cookies to help us analyse how our visitors use the site. Find out more about how these cookies are used on the Google privacy site

How to control and delete cookies

If you want to restrict or block the cookies we set, you can do this through your browser settings. The ‘help’ function within your browser should tell you how.

Alternatively, you could visit www.aboutcookies.org, which contains comprehensive information on cookies on a wide variety of browsers. You’ll also find details on how to delete cookies from your computer. To learn about controlling cookies on the browser of your mobile device please refer to your handset manual.

HOW WE USE YOUR PERSONAL DATA

We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:

• Where we need to perform the contract we are about to enter into or have entered into with you.
• Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests. Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give you the best service/product and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. 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). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us.
• Where we need to comply with a legal or regulatory obligation.

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.

PURPOSES FOR WHICH WE WILL USE YOUR PERSONAL DATA

We have set out below, in a table format, a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.

Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below.

USE OF YOUR PERSONAL DATA FOR MARKETING

We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising.

We may use your Identity, Contact, Technical, Usage and Profile Data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which products, services and offers may be relevant for you (we call this marketing).

You may receive paper marketing communications from us. We do not carry out any electronic marketing in respect of which we would need your consent.

DISCLOSURE OF YOUR PERSONAL DATA

Your details are not passed on to any third parties, other than as detailed in this privacy policy.

We may have to share your personal data with the parties set out below for the purposes set out in the table above.

• Any member of our group, which means our subsidiaries, our ultimate holding company and its subsidiaries, as defined in section 1159 of the UK Companies Act 2006.
•  Selected third parties including:

o    authorised distributors or authorised service points as referred to on our website https://www.fassiuk.com/network.html for the performance of any contract we enter into with them or you; and

o    analytics and search engine providers that assist us in the improvement and optimisation of our website.

We may also share your data with third parties in the event that we sell or buy any business or 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.

We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.

WHERE WE STORE YOUR PERSONAL DATA

All information you provide to us is stored on our secure servers which are located within the European Economic Area.

We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality. Where we have given you (or where you have chosen) a password which enables you to access certain parts of our website, you are responsible for keeping this password confidential. We ask you not to share a password with anyone.

We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

HOW LONG WE STORE YOUR PERSONAL DATA

We will only retain your personal data 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.

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.

In some circumstances you can ask us to delete your data: see “Request erasure” below for further information.

EXTERNAL LINKS

Our website may, from time to time, contain links to and from external websites and the websites of our partner networks, advertisers and affiliates.  If you follow a link to any of these websites, please note that these websites have their own privacy policies and that we do not accept any responsibility or liability for these policies. Please check these policies before you submit any personal data to these websites.

Clicking on any adverts will send you to the advertiser’s website through a referral program which may use cookies and will track the number of referrals sent from this website. This may include the use of cookies which may in turn be saved on your computer’s hard drive. Users should therefore note that they click on sponsored external links at their own risk. Fassi cannot be held liable for any damages or implications caused by visiting any external links mentioned.

Social Media Platforms

Communication, engagement and actions taken through external social media platforms which relate to Fassi are governed by the terms and conditions and privacy policies on each relevant social media platform.

Users are advised to use social media platforms wisely and exercise due care and caution in regard to their own privacy and personal details. This website and Fassi will not ask for personal or sensitive information through social media platforms and encourage users wishing to discuss sensitive details to contact them through primary communication channels such as telephone or email.

This website may use social sharing buttons which help share web content directly from web pages to a social media platform. Users are advised that they use such social sharing buttons at their own discretion. Users should note that the social media platform may track and save your request to share a web page through your social media account.

Shortened Links in Social Media

This website and/ Fassi may share web links to relevant web pages through their social media platform accounts. By default, some social media platforms shorten lengthy URLs (e.g. http://bit.ly/zyVUBo).

Users are advised to exercise caution before clicking on any shortened URLs published on social media platforms by this website / Fassi. Despite best efforts to ensure only genuine URLs are published many social media platforms are prone to spam and hacking and therefore this website / Fassi cannot be held liable for any damages or implications caused by visiting any shortened links.

YOUR RIGHTS

You have the right to:

• Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
• Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
• Object to processing of your personal data 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 as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
• Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios: (a) if you want us to establish the data’s accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
• Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.

You also have the right to ask us not to process your personal data for marketing purposes We will not process your personal data in this way without your express consent. You can exercise your right to prevent such processing by contacting us at Fassi UK, 26 Blick Rd, Heathcote Industrial Estate, Warwick CV34 6TA or mail@fassi.co.uk at any time.

ACCESS TO INFORMATION

You also have the right to your personal data (known as a “data subject access request”). This enables you to receive a copy of the personal data we hold about you and check that we are lawfully processing it.

You will not have to pay a fee to access your personal data (or to exercise any of the other rights), although we have the right to charge a reasonable fee if your request is clearly unfounded, repetitive ro 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 month. Occasionally it may take us longer than a 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.

If you wish to make a request for access to your information, please contact us at Fassi UK, 26 Blick Rd, Heathcote Industrial Estate, Warwick CV34 6TA or by email at mail@fassi.co.uk.

CHANGES TO OUR PRIVACY POLICY

Any changes we make to our Privacy Policy in the future will be posted on this page and, where appropriate, notified to you by e-mail. Please check back frequently to see any updates or changes to our Privacy Policy. This version was last updated on 11 May 2018.

CONTACT

Questions, comments and requests regarding this Privacy Policy are welcomed and should be addressed to Fassi UK Ltd, 26 Blick Rd, Heathcote Industrial Estate, Warwick CV34 6TA, for the attention of our Privacy Manager, Leigh Carter.

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