Welcome to the Office Watercoolers Ltd privacy notice.
Office Watercoolers Ltd respects your privacy and is committed to protecting your Personal Data. This privacy notice will inform you about how we look after your Personal Data and tell you about your privacy rights and how the law protects you.
You can download a pdf version of the policy here [LINK].
Please use the Glossary to understand the meaning of some of the terms used in this privacy notice.
2. Important information and who we are
Purpose of this privacy notice
This privacy notice aims to give you information on how Office Watercoolers Ltd collects and processes Personal Data, including, but not limited to, any data that may be provided through this website when people sign up to our newsletter, or submit an enquiry form.
This website is not intended for children and we do not knowingly collect data relating to children.
It is important that you read this privacy notice together with any other privacy notice or fair processing notice we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. This privacy notice supplements the other notices and is not intended to override them.
Office Watercoolers Ltd (collectively referred to as “the Company”, “we”, “us” or “our” in this privacy notice) is the Data Controller.
We have appointed a Data Privacy Officer who is responsible for overseeing both privacy within the Company and questions in relation to this privacy notice. If you have any questions about this privacy notice, including any requests to exercise your legal rights, please contact the Data Privacy Officer using the details set out below.
Our full details are:
Full name of legal entity: Office Watercoolers Ltd
Title of DPO: Director
Email address: firstname.lastname@example.org
Postal address: Data Privacy Officer, Waterloo House, 112-116 Anglesey Court, Towers Business Park, Rugeley, Staffs, WS15 1UL
Telephone number: 0845 6090902
You have the right to make a complaint relating to the privacy of Personal Data at any time to the Information Commissioner’s Office (ICO), (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.
Changes to the privacy notice and your duty to inform us of changes
This version of the Notice was last updated on 25 May 2018.
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.
This website may include links to third-party and other group company websites, plug-ins and applications. Clicking on those links or enabling those connections may allow other parties to collect or share data about you. We do not control third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy notice of every website you visit.
3. The 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 which we have grouped together follows:
- ïIdentity Data includes first name, maiden name, last name, username or similar identifier, marital status, title, date of birth and gender.
- ïContact Data includes billing address, delivery address, email address and telephone numbers.
- ïFinancial Data includes bank account and payment card details.
- ïTransaction Data includes details about payments to and from you and other details of products and services you have purchased from us.
- ïTechnical 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.
- ïUsage Data includes information about how you use our website, products and services.
- ïMarketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.
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). Nor do we collect any information about criminal convictions and offences.
If you fail to provide Personal Data
Where we need to collect personal data by law, or under the terms of a contract we have with you and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with goods or services). In this case, we may have to cancel a product or service you have with us but we will notify you if this is the case at the time.
4. 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, contact and financial data by filling in forms or by corresponding with us by post, phone, social media, SMS (text), email or otherwise. This includes personal data you provide when you:
- apply for our products or services;
- subscribe to our service or publications;
- request marketing to be sent to you;
- enter a competition, promotion or survey; or
- give us some feedback.
- 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.
- Third parties or publicly available sources. We may receive Personal Data about you from various third parties and public sources as set out below:
- omarketing agencies from whom we purchase business contact details.
- Technical Data from the following parties:
- (a) analytics providers, such as Google, whether based inside or outside the EU;
5. 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 or an organisation you represent.
- Where we need to comply with a legal or regulatory obligation.
- 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.
Click [here] to find out more about the types of lawful basis that we will rely on to process your personal data.
Generally we do not rely on consent as a legal basis for processing your personal data.
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 could use Personal Data, and, for each way, 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.
|Activity||Type of data||Lawful basis for processing including basis of legitimate interest|
|To register you as a new customer||(a) Identity
|(a) Performance of a contract with you|
|To process and deliver your order including:
(a) Manage payments, fees and charges
(b) Collect and recover money owed to us
|(a) Performance of a contract with you
(b) Necessary for our legitimate interests (to recover debts due to us)
|To enable you to partake in a prize draw, competition or complete a survey||(a) Identity
|(a) Performance of a contract with you
(b) Necessary for our legitimate interests (to study how customers use our products/services, to develop them and grow our business)
|To make suggestions and recommendations to you about goods or services that may be of interest to you||(a) Identity
|(a) Necessary for our legitimate interests (to develop our products/services and grow our business)|
|Sending you marketing communications via email by using the ‘Sign up to our newsletter’ function on the website
Providing your details via our ‘Contact Us’ form or ‘Request a Quote/Free Trial’ form on the Website
(d) Marketing and Communications
All communications we send are tailored to the products/services you have shown interest in and you have the option to ‘unsubscribe’ if you no longer wish to receive any communications from us.
We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising. We have established the following personal data control mechanisms.
Promotional offers from us
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 will receive marketing communications from us if you have requested information from us or purchased goods or services from us or if you provided us with your details when you register for a free trial or site survey and, in each case, you have not opted out of receiving that marketing.
You can ask us to stop sending you marketing messages at any time by following the opt-out links on any marketing message sent to you or by contacting us at any time.
Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of a product/service purchase.
Change of purpose
We will only use your Personal Data for the purposes for which we collected it.
We may need to use your Personal Data for another reason and we will only do this if that reason is compatible with the original purpose for which we collected your Personal Data.
If you would like an explanation about how the processing for the new purpose is compatible with the original purpose, please contact us.
If we need to use your Personal Data 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 Data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law or regulation.
6. Disclosures of your Personal Data
We may have to share your Personal Data with the parties set out below for the purposes set out in the table in paragraph 4 above.
- Internal Third Parties such as other companies within the South Staffordshire Plc group of companies;
- External Third Parties including financial institutions such as the direct debit bureau (Moorepay) and credit card payment services (Streamline).
- 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 notice.
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 and the law.
7. International transfers
We do not transfer your Personal Data outside the European Economic Area (EEA).
8. Data security
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 have access to it. They will only process your Personal Data on our instructions and they are subject to a duty of confidentiality.
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.
9. Data retention
How long will you use my Personal Data for?
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 or regulatory 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.
Details of retention periods for different aspects of your Personal Data are available in our retention policy which you can request from us by contacting us.
10. Your legal rights
Under certain circumstances, you have rights under data protection laws in relation to your Personal Data. You have the right to:
Request access to your Personal Data (commonly known as a “data subject access request”). This enables you to receive a copy of the Personal Data we hold about you and to check that we are lawfully processing it.
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 legitimate reason for us continuing to process it. You also have the right to ask us to delete or remove your Personal Data from our records 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 applicable laws. 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 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 (c) 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.
Withdraw consent at any time where we are relying on consent to process your Personal Data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.
No fee usually required
You will not have to pay a fee to access your Personal Data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.
What we may need from you
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.
Time limit to respond
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 exercise any of the rights set out above, please the Data Privacy Officer at email@example.com
Data Controller: means the person or organisation that determines when, why and how to process Personal Data. It is responsible for establishing practices and policies in line with the GDPR. We are the Data Controller of all Personal Data relating to our employees and Personal Data used in our business for our own commercial purposes.
Personal Data: means any information identifying a Data Subject or information relating to a Data Subject that we can identify (directly or indirectly) from that data alone or in combination with other identifiers we possess or can reasonably access. Personal Data includes Sensitive Personal Data and Pseudonymised Personal Data but excludes anonymous data or data that has had the identity of an individual permanently removed. Personal data can be factual (for example, a name, email address, location or date of birth) or an opinion about that person’s actions or behaviour.
Data Subject: means a living, identified or identifiable individual about whom we hold Personal Data.
Pseudonymisation or Pseudonymised: means replacing information that directly or indirectly identifies an individual with one or more artificial identifiers or pseudonyms so that the person, to whom the data relates, cannot be identified without the use of additional information which is meant to be kept separately and secure.
Sensitive Personal Data/Special Categories of Personal Data: information revealing racial or ethnic origin, political opinions, religious or similar beliefs, trade union membership, physical or mental health conditions, sexual life, sexual orientation, biometric or genetic data, and Personal Data relating to criminal offences and convictions.
12. LAWFUL BASIS
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 or regulation). 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.
Performance of Contract: means processing your data where it is necessary for the performance of a contract to which you are a party, or which you are arranging for someone else or for another organisation, or to take steps at your request before entering into such a contract.
Comply with a legal or regulatory obligation: means processing your Personal Data where it is necessary for compliance with a legal or regulatory obligation that we are subject to.