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We will only Process your Data if there is a lawful basis for such Processing. The lawful basis for Processing Personal Data will be one of the following:
For the purpose of data protection legislation, the data controller is The Consortium for Purchasing and Distribution Ltd (which includes the trading entity West Mercia Supplies) ("The Consortium") which has its registered office at: 140 Eastern Avenue, Milton Park, Abingdon, Oxon. OX14 4SB.
Collaboroo uses the following definitions in relation to data:
Personal Data (GDPR, Rec.26; Art.4(1)):
"Personal data" means any information relating to an identified or identifiable natural person ("data subject"); an identifiable person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that person.”
Special Categories of Personal Data (GDPR, Rec.10, 34, 35, 51; Art.9(1)):
"Sensitive Personal Data" are personal data, revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, trade-union membership; data concerning health or sex life and sexual orientation; genetic data or biometric data. Data relating to criminal offences and convictions are addressed separately (as criminal law lies outside the EU's legislative competence).”
Data Controller (GDPR, Art.2(d)):
"Controller" means the natural or legal person, public authority, agency or any other body which alone or jointly with others determines the purposes and means of the processing of personal data; where the purposes and means of processing are determined by EU or Member State laws, the controller may be designated by those laws.”
Data Processor (GDPR, Art.2(e)):
“Processor" means a natural or legal person, public authority, agency or any other body which processes personal data on behalf of the controller.”
Information you give us
This is information about you that you give us:
The information you give us may include your name, address, e-mail address and phone number, organisation, job role or title, financial and credit card information and some interests / preferences.
Information we collect about you
Visits to websites
With regard to each of your visits to our websites we will automatically collect the following information:
Completion of forms
Our site uses various forms to help us manage requests and enter you into competitions. We collect contact information (like names and email addresses). Contact information is used to respond to enquiries, or get in touch with you when necessary. If you have given us your consent to do so, we sometimes use this contact information to send you information about our company and our products and services by phone, email or post.
Information we receive from other sources
This is information we receive about you if you use any of the websites we operate or other services we provide. In these cases we will have informed you when we collected that data if we intend to share those data internally and combine it with data collected on our websites. We will also have told you for what purpose we will share and combine your data.
We work closely with third parties (including, for example, business partners, sub-contractors in technical, payment and delivery services, advertising networks, analytics providers, search information providers, credit reference agencies).
Information you give us
Use of the information
We will use the information you give us:
We collate the information collected about you in order to offer you a more tailored marketing experience.
We will use the information we collect about you:
For marketing purposes, we may collect, store and use the following kinds of personal data:
We will use this information to send to you marketing communications relating to our business which we think may be of interest to you by post or by email (if you are an individual, we will have specifically obtained your consent for this) or similar technology. You can inform us at any time if you no longer require marketing communications.
The Internet protocol (IP) address used to connect your computer to the Internet. We use your IP address for the following purposes:
We (or third-party data processors acting on our behalf) may collect, store, and use your personal information for individual website experience improvement.
Sharing your personal information
You agree that we have the right to share your personal information with:
Disclosure to third parties
We will disclose your personal information to third parties:
The data that we collect from you will be transferred to, and stored at:
All websites have security measures in place to protect the loss, misuse and alteration of the information under our control. Where necessary RM will inform law enforcement agencies or other relevant organisations regarding misconduct.
All information you provide to us is stored on our secure servers. Any payment transactions will be encrypted and utilise technologies to ensure PCI DSS compliance. Where we have given you (or where you have chosen) a password which enables you to access certain parts of our websites, you are responsible for keeping this password confidential. We ask you not to share a password with anyone.
Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted to our websites; any transmission is at your own risk. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorised access.
We keep your information only so long as you are a member of Collaboroo. When you cease being a member, we delete your information.
In accordance with data protection legislation, Collaboroo recognises that data subjects have specific rights that must be protected and observed.
Right to be informed
Collaboroo provides members with information about how personal data is collected, processed and managed. RM seeks to provide this information in language that is clear, concise and intelligible. This information is intended to be easily accessible for internal and external users.
Right of access
Collaboroo provides data subjects with access to the personal data that it manages as a data controller. A Subject Access Request (SAR) process has been defined (see paragraph 8 below) and communicated. Data subjects for whom RM is not the data controller but may process their personal data, should – in the first instance – contact the data controller directly when requesting such access.
Right to rectificationCollaboroo recognises the right of individuals to have inaccurate or incomplete data to be amended. Data subjects for whom Collaboroo is not the data controller, should – in the first instance – contact the data controller when making a data rectification request.
Right to erasure
Collaboroo recognises the right of individuals to request for their data to be deleted or removed where there is no compelling reason for its continued processing. Collaboroo will, in all cases, follow the ICO’s guidance on how and when such a request should be observed.
Right to data portability
Where the right of portability applies, as defined by the ICO, Collaboroo will provide data in a form that is structured, commonly used and in a machine readable form. In most cases, this will be the CSV format.
Right to object
Collaboroo recognises the right of individuals to object to the processing of their personal data, where such objections are allowable under data protection legislation.
Rights related to automated decision making including profiling
Collaboroo does not use automated decision making where such decisions have a significant effect on data subjects.
You have the right to ask us not to process your personal data for marketing purposes. We will usually inform you (before collecting your data) if we intend to use your data for such purposes or if we intend to disclose your information to any third party for such purposes. You can exercise your right to prevent such processing by checking certain boxes on the forms we use to collect your data.
Right of complaint to the ICO
Should you have a concern about Collaboroo’s information rights practices, please report it to us for investigation. If, following our internal review, you are not satisfied, you can report the matter to the Information Commissioner’s Office.
The Data Protection Legislation gives you the right to access information held about you. Your right of access can be exercised in accordance with such legislation.
Upon receipt of a written request to our Data Protection Officer (see below for contact details), Collaboroo will within thirty (30) days:
If the request is particularly complex or numerous, Collaboroo may extend the period for repose by up to two (2) months.
If the request is manifestly unfounded or excessive, Collaboroo may charge a fee or refuse to respond.
If disclosing the personal data will adversely affect the rights and freedoms of others, Collaboroo may withhold such personal data. This may extend to intellectual property and trade secrets.
RM Data Protection Officer
140 Eastern Avenue
Telephone: +44 (0) 8450 700300
Fax: +44 (0) 8450 700400