Introduction

This privacy policy is provided by Construction Fixing Systems Ltd (trading as CFS), a company registered in England and Wales under company number: 02567516 with its registered office at Unit 2a Westfield Estate Henley Road, Medmenham, Marlow, Buckinghamshire, SL7 2TA (we, our or us) and sets out how we process personal data in connection with our business, including the provision of our website https://cfsfixings.com/, the goods and services we offer, recruitment and our relationship with you (Services).

We take your privacy very seriously. Please read this privacy policy carefully as it contains important information on how and why we collect, store, use and share any information relating to you (your personal data).

It also explains your rights in relation to your personal data and how to contact us or the relevant regulator in the event you have a complaint. Our collection, storage, use and sharing of your personal data is regulated by law, including under the UK General Data Protection Regulation (UK GDPR).

We are the controller of personal data obtained via the Services, meaning we are the organisation legally responsible for deciding how and for what purposes it is used.

What and who this policy applies to

This privacy policy relates to your use of the Services only and applies to the following people:

• candidates - if you contact us, or we otherwise engage with you, regarding a job vacancy, we will process your personal data in connection with your job application;
• customers - if you work for one of our customers and have responsibility for registering an account with us or you handle orders within your organisation for our goods or services, we will process your personal data in connection with your organisation’s relationship with us and facilitating the supply of goods or services to your organisation;
• people who contact us with enquiries - if you contact us with an enquiry through our website, submit a complaint or provide any feedback to us, we will collect and process your personal data in connection with your interaction with us and the website;
• site visitors – if you browse our website, we will collect and process your personal data in connection with your interaction with us and the website.

We may link to or rely on other apps, websites, APIs or services owned and operated by us or by certain trusted third parties to enable us to provide you with Services. These other apps, websites, APIs or services may also gather information about you in accordance with their own separate privacy policies. For privacy information relating to these other apps, websites or services, please consult their privacy policies as appropriate. For more information see the section ‘Who we share your personal data with’ below.

Personal data we collect about you

The personal data we collect about you depends on the particular activities carried out through the Services and our relationship with you.

The type of personal data we collect may include, but is not limited to, the following categories of data:

• Identification - name, title, date and place of birth, gender, photograph, nationality, identification documents such as copies of passport and government identification numbers.
• Contact details - phone number, email address, address.
• Customer account information - VAT number, customer account number, purchase/order history and details, financial information required for billing.
• Employment related information - job title, company, business contact information, CV/employment history and employment application, eligibility to work, qualifications and educational history, driving licence information.
• Messages - content you may share when communicating with us e.g. when you submit an enquiry via the website.
• Location data - location data through your IP address.
• Preferences - information about which of our services you are interested in and the services and/or products you wish to be updated on, marketing preferences and service communication preferences.
• Opinions - where you choose to take part in voluntary services or you otherwise provide us with feedback, we will collect the information you provide about the Services or potential new services we may offer.

If you do not provide personal data we ask for where it is required, it may prevent us from providing services to you.

We collect and use this personal data for the purposes described in the section ‘How and why we use your personal data’ below.

Sensitive data

Sensitive personal data (also known as special category data) means information related to personal data revealing racial or ethnic origin; political opinions; religious or philosophical beliefs; trade union membership; genetic data; biometric data (where used for identification purposes); data concerning health; data concerning a person’s sex life; and data concerning a person’s sexual orientation.

Please note that we do not knowingly or intentionally collect sensitive personal data or information about criminal convictions from individuals and that you should not submit sensitive data to us.

Sensitive data requires a higher level of protection under data protection laws and we will let you know if we need to collect such data from you and the purposes for which it will be used.

How your personal data is collected

We collect personal data from you directly; for example, you may give us personal data when you fill in forms on our website or by corresponding with us by phone, email or otherwise. We may also collect personal data from you indirectly, such as your activity while using our website.

We may also obtain personal data about you from third parties, including service providers who may collect information on our behalf; for example, companies who support our website, recruitment agencies, and publicly available resources including online sources. Any information we receive from third parties will be treated in accordance with this policy. We are not responsible for the accuracy of any information provided to us by third parties and we are not responsible for any third party’s policies.

How and why we use your personal data

We collect, use and share your personal data for different purposes. Under data protection law, we can only use your personal data if we have a legal ground for doing so. The legal grounds we commonly rely on include:

1. Where you have given consent.
2. To comply with our legal and regulatory obligations.
3. For the performance of a contract with you or to take steps at your request before entering into a contract.
4. For our legitimate interests or those of a third party.

A legitimate interest is when we have a business or commercial reason to use your information, so long as this is not overridden by your own rights and interests. We will carry out an assessment when relying on legitimate interests, to balance our interests against your own. You can obtain details of this assessment by contacting us (see ‘How to contact us’ below).

The text below explains the purposes that we use your personal data for, the types of personal data processed and the associated legal grounds.

Purpose we use your personal data for

Type of personal data processed

Legal ground: For the performance of our contract with you, or to take steps at your request before entering into a contract.

Performing our obligations under our contract to which you are a party (e.g. creating and managing your account with us in order to provide goods or services to you).

• Identification
• Contact details
• Customer account information

When you apply for a job vacancy advertised with us.

• Identification
• Contact details
• Employment related information

Legal ground: To comply with our legal and regulatory obligations.

To enforce legal rights or defend or undertake legal proceedings (e.g. in connection with civil, commercial, criminal matters, regulatory matters, corporate and taxation matters, or to exercise our legal rights in relation to a violation of any of our terms or policies).

• Identification
• Contact details
• Location data
• Preferences
• Employment related information

Legal ground: For our legitimate interests or those of a third party.

Communications with you not related to marketing (e.g. we use certain information to send you administrative or account-related information including about changes to our terms or policies or changes to the services or other important notices).

• Identification information
• Contact details
• Customer account information
• Preferences

Hiring and recruitment and the processing of job applications including reference and qualifications checks.

• Identification
• Contact details
• Employment related information

Sending you information on promotional content (you can always ask us not to process your personal data for marketing purposes; for more information, see the ‘Your rights’ section below).

• Identification
• Contact details
• Location data

See ‘Who we share your personal data with’ for further information on the steps we will take to protect your personal data where we need to share it with others.

Who we share personal data with

We routinely share personal data with service providers we use to help us run our business or provide the services or functionalities in the Services e.g. we use Netsuite for our cloud business management solution.

We only allow service providers to handle your personal data if we are satisfied they take appropriate measures to protect your personal data.

We also routinely share personal data with other companies in our group.

We or the third parties mentioned above may occasionally also need to share your personal data with:

• external auditors, e.g. in relation to the audit of our accounts and our company - the recipient of the information will be bound by confidentiality obligations;
• professional advisors (such as lawyers and other advisors) - the recipient of the information will be bound by confidentiality obligations;
• law enforcement agencies, courts or tribunals and regulatory bodies to comply with legal and regulatory obligations;
• other parties in connection with a significant corporate transaction or restructuring, including a merger, acquisition, asset sale, initial public offering or in the event of our insolvency - usually, information will be anonymised but this may not always be possible, however, the recipient of the information will be bound by confidentiality obligations.

If you would like more information about who we share our data with and why, please contact us (see ‘How to contact us’ below).

How long your personal data will be kept

We retain your personal data only for as long as necessary to fulfil the purposes for which it was collected. The actual retention periods may vary based on the nature and context of the personal data, the purposes for processing, and applicable legal requirements. In determining the appropriate retention period, we consider factors such as the sensitivity of the data, the potential risk of harm from unauthorised use or disclosure, the purposes for which we process the data, and whether we can achieve those purposes through other means. After the applicable retention period, we will securely delete or anonymise your personal data. Please note that certain data may be retained for a longer period if required by law or if necessary for the establishment, exercise, or defence of legal claims.

Transferring your personal data out of the UK

At this point in time, we do not transfer your personal data outside of the UK. If this changes, we would comply with applicable UK laws designed to ensure the continued protection and privacy of your personal data. Any updated destinations to which we send your personal data, would be indicated in the present section and notified to you in accordance with the section on ‘Changes to this privacy policy’ below.

Furthermore, under UK data protection laws, we can only transfer your personal data to a country outside the UK where: the UK government has decided the particular country ensures an adequate level of protection of personal data (known as an ‘adequacy regulation’) further to Article 45 of the UK GDPR; there are appropriate safeguards in place, together with enforceable rights and effective legal remedies for you; or a specific exception applies under relevant data protection law.

Accordingly, if we were to start transferring your personal data from the UK to:

• the EEA: we would rely on the adequacy finding granted by the UK to the EU under the Withdrawal Agreement to do; for any transfers from the EU to the UK, we would rely on the adequacy regulation granted to the UK under the Adequacy Decision.
• any country located outside the UK/EEA: we would rely on appropriate safeguards under the UK GDPR, such as by including the relevant Standard Contractual Clauses in our data processing agreements.

In the event we could not or choose not to continue to rely on either of those mechanisms at any time we would not transfer your personal data outside the UK unless we could do so on the basis of an alternative mechanism or exception provided by UK data protection law.

Your rights

You generally have the following rights, which you can usually exercise free of charge. For more information regarding these rights, please visit the ICO website here.

Access to a copy of your personal data

The right to be provided with a copy of your personal data.

Correction (also known as rectification)

The right to require us to correct any mistakes in your personal data.

Erasure (also known as the right to be forgotten)

The right to require us to delete your personal data - in certain situations.

Restriction of use

The right to require us to restrict use of your personal data in certain circumstances, e.g. if you contest the accuracy of the data.

Data portability

The right to receive the personal data you provided to us, in a structured, commonly used and machine-readable format and/or transmit that data to a third party - in certain situations.

To object to use

The right to object:

• at any time to your personal data being used for direct marketing (including profiling)
• in certain other situations to our continued use of your personal data, e.g. where we use your personal data for our legitimate interests.

Not to be subject to decisions without human involvement

The right not to be subject to a decision based solely on automated processing (including profiling) that produces legal effects concerning you or similarly significantly affects you.

We do not make any such decisions based on data collected by the Services.

For further information on each of those rights, including the circumstances in which they do and do not apply, please contact us (see ‘How to contact us’ below). You may also find it helpful to refer to the guidance from the UK’s Information Commissioner on your rights under the UK GDPR.

If you would like to exercise any of those rights, please email us - see below: ‘How to contact us’. When contacting us please:

• provide enough information to identify yourself (e.g., your full name) and any additional identity information we may reasonably request from you, and
• let us know which right(s) you want to exercise and the information to which your request relates.

Keeping your personal data secure

We have appropriate security measures to prevent personal data from being accidentally lost, or used or accessed unlawfully. We limit access to your personal data to those who have a genuine business need to access it.

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

If you want detailed information from Get Safe Online on how to protect your information and your computers and devices against fraud, identity theft, viruses and many other online problems, please visit www.getsafeonline.org. Get Safe Online is supported by HM Government and leading businesses.

How to complain

Please contact us if you have any queries or concerns about our use of your information (see below ‘How to contact us’). We hope we will be able to resolve any issues you may have.

You also have the right to lodge a complaint with the Information Commissioner.

The Information Commissioner can be contacted at https://ico.org.uk/make-a-complaint or telephone: 0303 123 1113.

Changes to this privacy policy

We may change this privacy policy from time to time. Please check this page on our website for any changes.

How to contact us

You can contact us via the ‘Contact’ page on our website if you have any questions about this privacy policy or the information we hold about you, to exercise a right under data protection law or to make a complaint.