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Privacy & Cookie Policy

Introduction

 

Chaps IT Recycling Limited is committed to respecting and protecting your personal data in compliance with the Data Protection Act 2018. This privacy notice explains how we handle your personal information, outlines your privacy rights, and describes how the law safeguards you. It applies to data we collect from:

  • Users of our website;
  • Individuals who use our services;
  • Employees or representatives of organisations that engage our services or provide us with goods or services;
  • Individuals who contact us through various channels (e.g., via our website, postal mail, email, phone, or social media).

 

We encourage you to read this notice alongside any other privacy notices we may provide on specific occasions when collecting or processing your personal data. This ensures you understand how and why your information is being used. This privacy notice serves as a supplement to other notices and does not replace them.

  1. IMPORTANT INFORMATION AND WHO WE ARE

     

Controller and contact information

Chaps IT Recycling Limited is the controller and responsible for your personal data (collectively referred to as “CITR”, “we”, “us” or “our” in this privacy notice).

We have appointed a data privacy manager who is responsible for overseeing 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 manager using the details set out below:

Email address: dom.chappell@chapsitrecycling.co.uk

Postal address:, Chaps IT Recycling Limited, Unit 26, Thorncliffe Business Park, Sheffield,S35 2PH

Telephone number: +44 3450660101

Complaints

You have the right to lodge a complaint at any time with the Information Commissioner’s Office (ICO), the UK’s supervisory authority for data protection
matters (www.ico.org.uk). However, we would value the opportunity to address your concerns directly before you contact the ICO, so we encourage you to reach out to us first.

 

Updates to This Privacy Notice and Your Obligation to Keep Us Informed

We may update this privacy notice from time to time. Any changes will be posted, and where appropriate, notified to you.

It is essential that the personal data we hold about you is accurate and up to date. Please inform us promptly of any changes to your personal data during your relationship with us.

Third-party links

Our website may contain links to third-party websites, plug-ins, and applications. Interacting with these links or enabling such connections may allow third parties to collect or share data about you. Please note that we do not control these third-party websites and are not responsible for their privacy practices. We strongly encourage you to review the privacy policies of any websites you visit after leaving ours

 

2.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:

  • Identity Data includes [first name, maiden name, last name, username or similar identifier, marital status, title, date of birth and gender].
  • Contact Data includes [billing address, delivery address, email address and telephone numbers].
  • Financial Data includes [bank account and payment card details].
  • Transaction Data includes [details about payments to and from you and other details of products and services you have purchased from us].
  • 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, purchases or orders made by you, your interests, preferences, feedback and survey responses].
  • Usage Data includes [information about how you use our website, products and services].
  • Marketing and Communications Data includes [your preferences in receiving marketing from us and our third parties and your communication preferences].
  • Unknown Data includes data on devices received for erasure and destruction services, where we do not access or record the data and simply erasure/destroy in accordance with the service agreement

We may also collect, use, and share Aggregated Data, such as statistical or demographic information, for various purposes. Aggregated Data is derived from your personal data but is not legally classified as personal data, as it does not directly or indirectly identify you. For example, we might aggregate Usage Data to determine the percentage of users engaging with a specific feature on our website.

 

However, if we combine or link Aggregated Data with your personal data in a way that enables identification, we will treat the combined information as personal data and handle it in line with this privacy notice.

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.

We may collect Special Categories of Personal Data about our employees. These categories could include information about staff health as part of return to work arrangements, identification of vulnerable staff in the event of a pandemic, biometric information for the access system, information for workstation assessment/adjustments, information on criminal convictions as part of the vetting process and driving convictions/points as part of our policy.

If you fail to provide personal data that we are required to collect by law or under the terms of a contract with you, and you do not provide this data when requested, we may be unable to fulfill the contract we have with you or are attempting to establish (for example, providing goods or services). In such cases, we may need to cancel a product or service you have with us. If this occurs, we will inform you at the time

 

3.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, email or otherwise. This includes personal data you provide when you
  • apply for our products or services;
  • create an account on our customer portal;
  • subscribe to our service or publications;
  • request marketing to be sent to you;
  • enter a competition, promotion or survey; or
  • give us some feedback.
  • When you interact with our website, we may automatically collect Technical Data about your device, browsing behavior, and patterns. This data is collected through cookies and similar technologies. Additionally, we may receive Technical Data about you when you visit other websites that use our cookies.
  • Third parties or publicly available sources. We may receive personal data about you from various third parties and public sources as set out below:
  • Technical Data from the following parties:
    • analytics providers such as Google based outside the EU;
    • search information providers Linked In based inside the EU.
  • Identity and Contact Data from publicly availably sources such as Companies House and the Electoral Register based inside the EU

    4.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), by which we mean in 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.

Generally we do not rely on consent as a legal basis for processing your personal data other than in relation to sending third party direct marketing communications to you via email or text message. You have the right to withdraw consent to marketing at any time by:

  • changing your marketing preferences via the customer portal;
  • making use of the “unsubscribe” link in emails and/or
  • contacting us via any of the methods referred to in paragraph 1 above.

We have outlined below, in a table format, a summary of how we intend to use your personal data, along with the legal bases we rely on for each purpose. Where relevant, we have also specified our legitimate interests.

 

Please note that, depending on the specific purpose for processing your data, we may rely on more than one legal basis. If you require further details about the specific legal basis we are using for a particular activity, where multiple grounds are applicable, please feel free to contact us.

 

 

 

Purpose/Activity

Type of data

Lawful basis for processing including basis of legitimate interest

To deliver asset management, data erasure and destruction services

(a) Unknown: We do not access or record the data as part of the standard erasure or destruction service provision.

(a) Performance of a contract with you(b) Necessary for our legitimate interests (to provide services to client)

To register you as a new customer

(a) Identity (b) Contact

Performance of a contract with you

To process and fulfill your order, including:

(a) Managing payments, fees, and charges;

(b) Collecting and recovering money owed to us.

(a) Identity(b) Contact(c) Financial(d) Transaction(e) Marketing and Communications

(a) Performance of a contract with you(b) Necessary for our legitimate interests (to recover debts due to us)

To manage our relationship with you  or your organisation which will include:(a) Notifying you about changes to our terms or privacy policy(b) Asking you to leave a review or take a survey

(a) Identity(b) Contact(c) Profile(d) Marketing and Communications

(a) Performance of a contract with you(b) Necessary to comply with a legal obligation(c) Necessary for our legitimate interests (to keep our records updated and to study how customers use our products/services)

To enable you to participate in a competition, prize draw, or complete a survey

(a) Identity(b) Contact(c) Profile(d) Usage(e) Marketing and Communications

(a) Performance of a contract with you;

(b) Necessary for our legitimate interests (to analyse how customers use our products/services, to improve them, and to grow our business).

To administer and protect our business and this website, including troubleshooting, data analysis, testing, system maintenance, support, reporting, and data hosting.

(a) Identity(b) Contact(c) Technical

(a) Necessary for our legitimate interests (for running our business, providing administration and IT services, ensuring network security, preventing fraud, and in the context of a business reorganization or group restructuring exercise);

(b) Necessary to comply with a legal obligation.

To deliver relevant website content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you

(a) Identity(b) Contact(c) Profile(d) Usage(e) Marketing and Communications(f) Technical

Necessary for our legitimate interests (to study how customers use our products/services, to develop them, to grow our business and to inform our marketing strategy)

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

(a) Technical(b) Usage

Necessary for our legitimate interests (to define types of customers for our products and services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy)

To enable us to carry out specific tasks for our employees:
(a) Biometric access data used for payments, holidays and attendance
(b) DSE assessments for potential adjustments needed for workstations
(c) Vetting purposes to carry out specific tasks

(a) Identity
(b) Contact
(c) Special

Necessary for our legitimate interests.

To make suggestions and recommendations to you about goods or services that may be of interest to you

(a) Identity(b) Contact(c) Technical(d) Usage(e) Profile

Necessary for our legitimate interests (to develop our products/services and grow our business)

 

 

 

Marketing

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

Third-party marketing

We will get your express opt-in consent before we share your personal data with any company for marketing purposes.

Opting out

You can ask us or third parties to stop sending you marketing messages at any time by emailing info@chapsitrecycling.co.uk to adjust your marketing preferences or by following the opt-out links on any marketing message or emails sent to you at any time.

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 services from us, and in each case, you have not opted out of receiving such marketing.

If you opt out of receiving marketing messages, this will not affect personal data provided to us as a result of a service purchase, product/service experience, or other transactions.

Cookies

We will only use your personal data for the purposes for which it was collected, unless we reasonably determine that it is necessary to use it for another purpose that is compatible with the original purpose.

 

You can configure your browser to refuse all or some cookies, or to alert you when websites set or access cookies. Please note that if you disable or refuse cookies, some parts of this website may become inaccessible or may not function properly

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

 

5. DISCLOSURES OF YOUR PERSONAL DATA

We may need to share your personal data with the parties listed below for the purposes outlined in the table above:

  • Service providers acting as processors, based in England and Wales, who provide IT and system administration services, logistics services, and downstream processing.
  • Professional advisers acting as processors or joint controllers, including lawyers, bankers, auditors, and insurers, based in England and Wales, who provide consultancy, banking, legal, insurance, and accounting services.
  • HM Revenue & Customs, regulators, and other authorities acting as processors or joint controllers, based in the United Kingdom, who require reporting of processing activities in certain circumstances.
  • Third parties to whom we may choose to sell, transfer, or merge parts of our business or assets. Alternatively, we may seek to acquire other businesses or merge with them. In the event of a change in our business, the new owners may use your personal data in the same way as described 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, in line with our instructions.

A full list of these providers can be supplied on request by contacting us

 

6. INTERNATIONAL TRANSFERS

We do not transfer your personal data outside the European Economic Area (EEA)

 

7. DATA SECURITY

We have implemented appropriate security measures to protect your personal data from being accidentally lost, used, accessed without authorization, altered, or disclosed. Furthermore, access to your personal data is restricted to employees, agents, contractors, and other third parties who have a legitimate business need to know. They will only process your personal data in accordance with our instructions and are bound by confidentiality obligations.

 

We have established procedures to address any suspected personal data breaches. If a breach occurs and we are legally required to do so, we will notify you and any relevant regulatory authorities.

 

8. DATA RETENTION

How long will you use my personal data for?

We will retain your personal data only for as long as necessary to fulfill the purposes for which it was collected, including to meet any legal, accounting, or reporting obligations.

 

To determine the appropriate retention period, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorized use or disclosure, the purposes for which we process your data, and whether we can achieve those purposes through other means, as well as applicable legal requirements.

 

For tax purposes, we are legally required to retain basic customer information (including Contact, Identity, Financial, and Transaction Data) for six years after you cease being a customer.

 

In certain cases, you may request that we delete your personal data. Please refer to the “Request erasure” section for more details.

 

Additionally, in some cases, we may anonymize your personal data so that it can no longer be linked to you. This anonymized data may be used indefinitely for research or statistical purposes without further notice to you

 

9.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 allows you to receive a copy of the personal data we hold about you and verify that we are processing it lawfully.
  • Request correction of the personal data we hold about you. This gives you the right to have any incomplete or inaccurate data we hold corrected, though we may need to verify the accuracy of the new data you provide.

    Object to processing of your personal data when we are relying on a legitimate interest (or that of a third party) and there is something specific about your situation that makes you want to object to processing on this basis, as you believe it affects your fundamental rights and freedoms. You also have the right to object if we are processing your personal data for direct marketing purposes. In some cases, we may be able to demonstrate that we have compelling legitimate grounds to process your data, which override your rights and freedoms.

  • Request erasure of your personal data. You can ask us to delete or remove your personal data if there is no valid reason for us to continue processing it. You also have the right to request erasure if you have successfully objected to processing, if we have processed your data unlawfully, or if we are legally required to erase it. However, please note that we may not always be able to fulfill your erasure request due to specific legal reasons, which we will inform you of, if applicable, at the time of your request.
  • 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.
  • 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.

If you wish to exercise any of the rights set out above, please Contact Us.

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.

You will not be required to pay a fee to access your personal data (or to exercise any of your 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 such cases.

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.

What we may need from you

In order to confirm your identity and ensure that you have the right to access your personal data (or exercise any of your other rights), we may need to request specific information from you. This is a security measure to prevent your personal data from being disclosed to individuals who are not authorized to receive it. Additionally, we may contact you for further information related to your request to help expedite the process.