About this Policy
Our websites are not intended for children and we do not knowingly collect data relating to children.
Our status and details
By using our Websites and our services, including requests for pricing, you consent to this policy. We are registered with the Information Commissioner’s Office for this purpose under registration number ZB325758.
You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK regulator 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.
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.
Information we collect
We may collect, use, store and transfer different kinds of personal data but only if it is directly provided to us by you. You may do this in your capacity as the user of our websites, by enquiring in relation to our goods or services, becoming a customer or supplier, or potential supplier. 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). Below are examples of the type of data that this may include:
- Identity Data including title, first name, last name, maiden name, date of birth, gender, marital status, and username or similar identifier.
- Contact Data may include invoicing; purchase order; home or work address, email address and telephone numbers, personal or job title and position.
- Financial Data may include bank account and payment card details.
- Transaction Data may include payments made for products and services you have purchased from us, or in relation to payments that we have made to you.
- Technical Data may include internet protocol (IP) address, 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 used to access our websites.
- Profile and Usage Data may include enquiries submitted by you, purchases information, feedback and survey responses, and how you use our website, products and services.
- Marketing and Communications Data may include details of any preference that you have advised us of in relation to marketing communications from us and/or third parties and your communications 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.
How do we collect your personal data?
A range of different methods may be used to collect data, which may include the following methods:
- Direct interactions with us in person, by post, phone, email or otherwise. For example, you might give us your Identity, Contact and Financial Information in this way.
- Automated technologies or interactions with our website, by using the web enquiry form – for example you might give us your Identity and Contact Information in this way.
- Third parties or publicly available sources (third parties may be used in processing Identity, Contact and Financial categories of personal data), such as:
- Technical Data from the following parties:
- analytics providers such as Google based outside the UK;
- advertising networks based inside or outside the UK; and
- search information providers based inside or outside the UK.
- Identity and Contact Data from data brokers or aggregators based inside or outside the UK.
- Identity and Contact Data from publicly available sources.
- Technical Data from the following parties:
It is important that the data that we hold about you is accurate and up-to-date. In the event that your data changes, please notify us, so that we can update our records.
Use of your information
We will only use your personal data when the law allows us to. We will only use your personal data for a reason other than the purpose for which it was originally obtained if we reasonably consider that we need to use it for that other purpose, that reason is compatible with the original purpose and we have a legitimate interest in doing so. If you wish to get an explanation as to 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. The Lawful Basis may include:
Legitimate Interest which 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;
Performance of Contract which means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract; or
Comply with a legal obligation which means processing your personal data where it is necessary for compliance with a legal obligation that we are subject 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 to provide our goods or services to you, to communicate with you and to meet our contractual commitments to you. This may include Identity, Contact, Financial and Transactional data.
- To notify you about any changes to our business, such as improvements to our Website or service/product changes, that may affect our service or relationship with you. This may include Identity and Contact data.
- If you are an existing customer, we may contact you with information about goods and services similar to those that were the subject of a previous sale to you. This may include Identity and Contact data.
- Where you have consented to receive such information, to provide information on other parties’ products or services that we feel may be of interest to you. This may include Identity, Contact and Marketing data.
- Where you have consented to receive our e-newsletters to provide that to you. This may include Identity and Contact data.
- Where we need to comply with a legal obligation. This may include Identity, Contact and Transactional data.
- 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. This may include all types of data.
Generally, we do not rely on consent as a legal basis for processing your personal data. Where we collect your data for marketing purposes, we will always request your consent at the point the data is collected, to use your data for that purpose and before sending third party direct marketing communications to you via email or text message.
We will also obtain your consent prior to sharing your personal data with any third party for their marketing purposes. This may be to enable relevant third parties to advise you of products or services that may be of interest to you.
Where we rely on consent as the legal basis for processing your data, you can revoke or vary that consent at any time. If you do not want us to use your data or want to vary the consent that you have provided, you can write to us at the address detailed above or email us at email@example.com at any time.
You can also ask us or third parties 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, product/service experience or other transactions.
Disclosure of your information
There are a range of circumstances where we may disclose your data to third parties. These include:
- Regulatory bodies. We may disclose your data to regulatory bodies to enable us to comply with the law, to assist fraud protection and to minimise credit risk. This may include Identity, Contact and Transactional data.
- Our suppliers. We may disclose your data to third parties that are involved in the fulfilment of our services to you. This may include Identity, Contact and Transactional data.
- Third party marketing. Where you have consented for us to do so, we may provide your data to selected third parties who may contact you about their goods or services that you may be interested in. This may include Identity, Contact and Marketing data.
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. The relevant third-parties are as follows:
Internal Third Parties
Other companies in the Projection Artworks Limited Group acting as joint controllers or processors and who are based UAE and provide sales and account management services and undertake leadership reporting.
External Third Parties
- Service providers acting as processors based inside or outside the UK who provide IT and system administration services.
- Professional advisers acting as processors or joint controllers including lawyers, bankers, auditors and insurers based inside and outside the UK 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.
Data storage and the transfer of your data
As part of the services offered to you, the information you provide to us may be transferred to and stored in countries outside of the UK. We use remote website server hosts to provide our websites and some aspects of our service, which may be based outside of the UK, or use servers based outside of the UK – this is generally the nature of data stored in “the Cloud”. It may also be processed by staff operating outside the UK who work for one of our suppliers, e.g. our website server host, payment processing provider, or work for us when temporarily outside of the UK.
A transfer of your personal data may therefore happen if any of our servers are located in a country outside of the UK or one of our service providers is located in a country outside of the UK.
If we transfer or store your personal data outside the UK in this way, we will take steps to ensure that a similar degree of protection is afforded it by ensuring at least one of the following safeguards is implemented:
- We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data; or
- Where we use certain service providers, we may use specific contracts approved for use in the UK which give personal data the same protection it has in the UK.
Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the UK.
The transmission of information via the Internet or email is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of data while you are transmitting it to our servers: any such transmission is at your own risk.
We have put in place appropriate security measures to prevent your 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.
In the event of a suspected data breach, we have in place procedures to deal with this and will notify the ICO and also yourself where we are legally required to do so.
We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.
The length of time that we retain and store data depends on the purpose for which it was collected. 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, regulatory, tax, accounting or other requirements.
By law we have to keep basic information about our customers and suppliers for at least six years after they cease being customers/suppliers for tax purposes. The type of data kept includes Contact, Identity, Financial and Transaction data.
Where you have requested that we provide you with marketing materials, we will retain your data for the duration of the consent period after which we will contact you to renew your consent or delete your personal data. You have the right to withdraw your consent at any time.
In some circumstances you can ask us to delete your data: see your legal rights below for further information. In some circumstances we may anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes, in which case we may use this information indefinitely without further notice to you.
We may also gather information about your general Internet use by using a cookie file. Where used, these cookies are downloaded to your computer automatically. This cookie file is stored on the hard drive of your computer, as cookies contain information that is transferred to your computer’s hard drive. They help us to improve our Website and the service that we provide to you.
All computers have the ability to decline cookies. This can be done by activating the setting on your browser which enables you to decline the cookies. Please note that should you choose to decline cookies, you may be unable to access particular parts of our Website.
The UK GDPR gives you a range of rights in relation to the personal data that we collect from. You have the right to:
- Request Access to your personal data. This right is commonly known as the ‘data subject access request’ and 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 we hold about you. This enables you to have any incomplete or inaccurate data corrected, although 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. 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.
- Restrict the processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios:
- If you want us to establish the data’s accuracy.
- Where our use of the data is unlawful but you do not want us to erase it.
- 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.
- 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 that 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.
You can exercise these rights at any time by writing to us at the address detailed above, or by email to firstname.lastname@example.org.
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 could 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 could 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.
Changes to this policy
We may update this policy to reflect changes to the law, our websites and customer feedback. Please regularly review this policy to be informed of how we are protecting your personal data.
Version: May 2023