Privacy Policy.

We will comply with data protection law which requires that personal data we hold about you is:

• Used lawfully, fairly and in a transparent way;
• Collected only for valid purposes that we have clearly explained to you and not used in any way incompatible with those purposes;
• Relevant to the purposes we have told you about and limited only to those purposes;
• Accurate and kept up to date;
• Kept only as long as necessary for the purposes we have told you about; and
• Kept securely.

This privacy notice will, therefore, inform you as to who we are, what personal data we collect, the purposes for which we use it, for how long we retain it and how we keep it secure, your rights in relation to your personal data and how you can contact us to discuss, query or obtain details of the personal data we hold about you.

1. Who we are

Anopol Limited is registered in England and Wales and has its registered office at 70 Bordesley Street, Birmingham, B5 5QA.

Anopol Limited is a data controller and registered with the Information Commissioner’s Office (ZA370115).

Anopol Limited supplies equipment, chemicals and services globally for electropolishing, pickling, passivating and other metal finishes.

2. Whose personal data we process

We collect and process personal data about our:

• Customers;
• Suppliers and service providers;
• Advisers, consultants and other professional experts;
• Employees and prospective employees; and
• Enquirers and complainants.

3. Why we process your personal data

We collect and process personal data:

• With your consent; and/or
• To perform the contract we have entered into with you, or discharge other contractual obligations; and/or
• To comply with our legal obligations; and/or
• To pursue our legitimate interests, provided your rights do not override our interests.

4. Personal data sources

We can collect personal data from any number of sources including:

• Publicly available information such as Companies House, LinkedIn and search engines such as Google; and
• Third party providers such as debt recovery or Government agencies, contractors and business introducers.

5. How we will inform you about our privacy notice

You can request a free hard copy of this privacy notice by contacting us using the details set out above.

Where we obtain your personal data indirectly, for example from a business contact or website, we will inform you where you can access this privacy notice within one month of obtaining that data.

We will not use your personal data for any purposes other than those set out below without first informing you. Changes made to this privacy notice will be updated on our website.

6. The purposes for which your personal data is collected and processed

We collect personal data with the overall aim of providing a better service to all of our customers and industry partners.

We will not collect sensitive personal data from you. For example, we will never ask for or process data relating to race, religion or ethnicity.

The personal data categories identified below are relevant and specific for the products and services that we offer or obtain. The listing also describes how and why we process them.

6.1 Name, address and contact details

This includes company details, contact names, telephone numbers and email addresses. This data allows us:

• To carry out our obligations arising from any contracts entered into between you and us, including delivery of product, invoicing and reporting; and
• To provide you with information on products and/or services you specifically request from us or which we believe may be of interest to you.

If you are an existing customer we will only contact you by email with information about products and/or services similar to those which we have previously supplied to you and/or if you have given us consent to do so.

If you are a new customer, and where we permit selected third parties to use your data, we or they will contact you by email and only with your consent.

On occasions we will share your contact details with our agents, such as third party suppliers, who may need to contact you to arrange, for example, the delivery of your orders or the supply of other associated products and services on our behalf.

Most contact details will be provided by you at the point that you make an online enquiry or request or provide a quotation. In some cases, we may need to obtain alternative contacts who may be best suited to assist us should we have a specific query. Where we have no contact details, we may sometimes take proactive steps to collect data using desktop research, such as internet searches.

There may be an impact on the level of service we provide should we have only limited or inaccurate contact details.

6.2 Employment and education details

This data allows us to carry out recruitment. We will dispose of all unsuccessful candidates’ data securely unless we are asked to retain the CV on file.

6.3 Bank and payment details

This data may be provided to us at the start of or at any time during our business relationship with you.

We also process credit and debit card payments and refunds over the telephone and may ask you to confirm your card details in this instance. The data will be destroyed after being processed.

6.4 Telephone call recordings

External telephone calls are recorded for training, security and auditing purposes.

6.5 Electronic and hardcopy correspondence and other documentation

We may collect and process electronic and hardcopy correspondence and other documentation, such as emails, invoices, contracts, tenders and letters, as part of either a contractual obligation or a wider legitimate interest.

When you contact Anopol Limited for any reason, we may keep a record of our communication to help us deal with any queries and/or to support our customer service delivery operation.

6.6 IP addresses and cookies

When you access our website and web portal we may collect data relating to your computer including its IP address. Such data is anonymous in its form and only allows us to carry out statistical analysis of browsing behaviour.

Our website uses cookies such as Google Analytics to collect information about how you use our website. A cookie is a small text file that is placed on your hard disk by a web page server. Cookies are uniquely assigned to you and can only be read by a web server in the domain that issued the cookie to you.

The cookies provide us with anonymous information showing us the number of visitors to our website, the device used to access it and which web browser they are viewing it on. This data allows for statistical analysis and helps us understand our customer behaviour better and optimise your online experience. Cookies also provide a convenience feature to save you time.

For further information visit www.aboutcookies.org or www.allaboutcookies.org.

You can set your browser not to accept cookies and the above websites tell you how to remove cookies from your browser. However, in a few cases some of our website features may not function as a result.

7. Who we will share your personal data with

We may share your personal data with:

• Regulatory authorities, Government departments or the police in order to comply with any legal obligations or to assist in fraud prevention and detection;
• Credit agencies and professional advisers to enforce or apply the terms of any contracts between us and you;
• Third party suppliers where we have subcontracted to them the performance of any or all of our obligations under our contract with you;
• The buyer and its professional advisers should we wish to sell any or all of our business and/or our assets; and
• Other third parties where we reasonably believe such action is necessary to comply with a legal obligation, protect our rights and property, or act in urgent circumstances to protect personal safety.

8. Safeguarding your personal data

Anopol Limited takes all reasonable steps to ensure that appropriate safeguards are in place to protect your personal data. We have policies in place dealing with information security, both physical and digital, and data breaches. We ensure that our staff are properly trained so that they can process your data securely and safely.

Risk assessments are conducted and reviewed by senior management as part of our Data Protection Impact Assessments, which set out how we aim to preserve the confidentiality, integrity and availability of personal data we hold.

9. How long we retain your personal data

Your personal data will be retained by us for as long as there remains a valid lawful basis for retaining it. We will keep data retention under regular review.

Accounting information, such as invoices, will be retained for at least six years in line with current tax legislation. Contractual documentation will be held for at least six years.

10. Your rights as a data subject

To ensure fair and transparent processing it is important that we inform you of your rights with regard to how your personal data is processed. Where you wish to exercise a right, we have signposted the best contact details for you to get in touch with us. We will need to confirm your identity before your request can be processed.

10.1 Your right to be informed

This privacy statement informs you of who we are, why we are processing your personal data, with whom we share your personal data and how we have collected it.

If you would like to discuss this privacy notice or suggest ways in which we could improve the content or its communication, please contact a member of staff on 0121 632 6888, who will put you in contact with the data protection processor, or email data.privacy@anopol.com.

10.2 Your right to access

As a data subject you have the right to access the personal data we hold about you and check that we are lawfully processing it.

To make a data subject access request, known as a DSAR, is free and can be done in writing by emailing data.privacy@anopol.com or writing to:

Data Protection Controller
Anopol Limited
70 Bordesley Street
Birmingham
B5 5QA

Once we receive your request we will ask you to verify your identity and ask you to specify the data or processing activity that you require so that we can confirm your expectations and respond within one month.

10.3 Your right to rectification

Where personal data is inaccurate or incomplete you have the right for it to be rectified on our systems. In such cases we will act promptly to put things right.

If you require your personal data to be rectified you can speak to a member of staff on 0121 632 6888 or email data.privacy@anopol.com.

10.4 Your right to erasure

This enables you to ask us to delete or remove personal data where there is no good reason for us to continue to process it. Sometimes, however, we may refuse a request to erase such data in order, for example, to comply with a legal obligation.

If you require your personal data to be erased you can speak to a member of staff on 0121 632 6888 or email data.privacy@anopol.com.

10.5 Your right to restricted processing

This enables you to ask us to restrict the processing of your personal data. If you wish for restricted processing to be applied to your personal data, please call 0121 632 6888 or email data.privacy@anopol.com.

10.6 Your right to data portability

To help strengthen your control over your data, you have the right, in certain circumstances, to receive personal data from us in a format which allows you to easily access it.

Should you wish to exercise your right to data portability you can speak to a member of staff on 0121 632 6888 or email data.privacy@anopol.com.

10.7 Your right to withdraw consent

In circumstances where you may have provided your consent to the processing of your personal data for a specific purpose, you have the right to withdraw your consent for that specific processing activity at any time.

To withdraw your consent, please call 0121 632 6888 or email data.privacy@anopol.com.

10.8 Your rights relating to automated decision making

Details of what automated decision-making activities we carry out are described below in paragraph 12. If you wish to speak to a member of our team to understand the decision made, obtain an explanation of the decision and challenge it, you can speak to a member of staff on 0121 632 6888 or email data.privacy@anopol.com.

11. Reporting a concern to us or to the Information Commissioner’s Office

If you have a concern regarding how we handle your personal data, we kindly request that you inform us about it first so that we can work with you in an effort to resolve it.

You can report a concern or raise a complaint with us initially by contacting your usual contact, speaking to a member of staff on 0121 632 6888, or emailing data.privacy@anopol.com.

Alternatively, you can write to:

Data Protection Controller
Anopol Limited
70 Bordesley Street
Birmingham
B5 5QA

We aim to acknowledge your complaint within two business days and provide a resolution within 28 days. If we are unable to meet this timescale we will write to notify you in advance.

If you are not satisfied with our proposed resolution to your complaint you can raise the matter directly with the Information Commissioner’s Office. Details as to how to get in touch with the ICO or report a concern can be found at https://ico.org.uk/concerns/.

Anopol Limited is registered with the Information Commissioner’s Office (ZA370115).

12. The automated decision-making processes we operate

There are some automated decision processes that we operate to which we should draw your attention. The purpose of this automation is necessary for us to agree a contract with you or to allow us to meet a contractual obligation.

Automated decision making can include credit checks. Where we process your data for the purposes of a contract we are not compelled to explain the decision made. However, to show good customer service we will try and provide you with an explanation where we can within a reasonable time.

13. Other websites

Our website contains links to other websites. This privacy statement only applies to us, so when you link to other websites you should read their own privacy statement.

14. Getting in touch with us

If you would like to discuss this privacy notice or suggest ways in which we could improve the content or its communication, please contact us on 0121 632 6888 or email data.privacy@anopol.com.