PRIVACY NOTICE

Adler & Allan is committed to protecting and respecting your privacy. We take your privacy very seriously and we ask that you read this Privacy Notice carefully as it contains important information on:

• the personal data we collect about you
• how we look after your personal data when you visit our website (regardless of where you visit from)
• with whom your personal data might be shared
• your privacy rights and how the law protects you.

Who we are

The Adler & Allan Group is made up of different legal entities, This Privacy Notice is issued on behalf of the Group so when we mention "we", "us" or "our" in this Privacy Notice, we are referring to the relevant company in the Adler & Allan Group responsible for processing your data. We will let you know which entity will be the controller for your data when you purchase a product or service with us. Adler & Allan Ltd is the controller and responsible for this website. Our group companies which act as data controllers are registered as such with the Information Commissioner's Office (the ICO).

THE GROUP

Adler & Allan Ltd (Company No. 00318460) – ICO registration No: Z7725395

E&S Environmental Services Ltd (Company No. 05288826) – ICO registration No: ZA063949

Worcester Electrical Services (WES) (which is a trading name of E&S Environmental Services Ltd)

OHES Environmental Ltd (Company No. 04320201) – ICO registration No: ZA143726

Personal data which we collect

Personal data provided by you

We collect personal data about you when you:

• contact us through our website
• apply for a job with us
• complete customer feedback or surveys
• email enquiries
• verbally (in person, trade shows, exhibitions and telephone)
• visit our website

Please note that we require certain personal data (name, address, contact details, for example) to be able to provide you with our products or services. If you do not provide such information, this may limit our ability to provide our services.

The personal data collected in the above manner may include your:

• full name
• Job Title
• postal address
• email address
• telephone number
• IP Address (Cookies)
• Location (Cookies)

Special categories of personal data

We do not seek to collect special category personal data via our website. However, our website does include text boxes which are designed for you to provide us with certain information and you should be aware that information you freely submit in these boxes may reveal to us certain information that may be considered as special category personal information.

Personal data about other individuals

If you give us information on behalf of someone else, you confirm that the other person has appointed you to act on his/her behalf and has agreed that you can:

• give consent on his/her behalf to the processing of his/her personal data;
• receive on his/her behalf any data protection notices;
• give consent to the transfer of his/her personal data outside the European Economic Area.

If you are an individual, sole trader or partnership and you ask us to provide you with credit to pay for our services, we may collect personal data from you and from searches of Credit Reference Agencies (CRAs) and Fraud Prevention Agencies (FPAs) of their records relating to you and other people with whom you are linked financially, from public records, e.g. the electoral roll and third parties such as credit brokers where you have provided information to them and consented for it be passed to us.

Monitoring and recording communications

We may monitor and record communications with you (such as telephone conversations and emails) for the purpose of legal requirements, training and contractual reasons.

How we use your personal data

Overview

We collect information about you so that we can:

• identify you for contractual reasons
• process any work you have with us
• assist you with your queries in relation to our business
• review any job applications you submit to us
• detect and prevent fraud (including reporting to CRAs and FPAs)
• customise our website and its content
• notify you of any changes to our services that may affect you
• carry out security vetting (including DBS Checks)
• improve our services using Cookies

Marketing

We would like to send you information by post, email, telephone, text message (SMS) or automated call about our products and services and special offers which may be of interest to you.

If you provide us with consent, we will share your details with the Group who may also send you similar marketing messages.

We will send you marketing messages in two circumstances:

• where you have subscribed to receive direct marketing from us and have therefore provided your consent to us contacting you; or
• where you have previously engaged with us and we have obtained your contact details in the course of the sale or negotiations for our service and we think that you will be interested in receiving further information about other products and services which we think might be relevant to you.

You can opt out at any time by using the unsubscribe function on each of our emails or by contacting us using the email address [email protected].

Credit checking

Where you are an individual, sole trader or partnership, upon completing an enquiry to our business, this may lead to having to perform credit checks with Credit Reference Agencies or using the information you have provided, if services are to be rendered.

When CRAs receive a search from us they place a search “footprint” on your credit file whether or not the application proceeds. Records remain on file with CRAs and FPAs for 6 years after they are closed, whether settled by you or defaulted.

More information about CRAs and how they use personal information is available at http://www.experian.co.uk/crain/index.html or you can contact the agencies below:

Callcredit Consumer Services Team, PO Box 491, Leeds, LS3 1WZ Tel: 0330 024 7579 or visit www.callcredit.co.uk

Equifax PLC Credit File Advice Centre, PO Box 3001, Bradford, BD1 5US Tel: 0870 010 0583 or visit www.myequifax.co.uk

Experian Consumer Help Service, PO Box 8000, Nottingham, NG80 7WF Tel: 0870 241 6212 or visit www.experian.co.uk

We may use your information to:

• make credit decisions about you (such decisions will not be automated and will be considered on a case by case basis)
• prevent and detect fraud and money laundering

If you do not provide us with information to enable us to undertake a credit check, we may not be able to provide you with credit. If you provide false or inaccurate information to us and we suspect fraud, we will record this and may pass it on to FPAs or the police where we deem it appropriate. You have the right to be informed which CRAs we have used and obtain a copy of your file from that CRA.

Our legal basis for processing your personal data

Where our customers are individuals, sole traders or partnerships, the legal basis on which we rely for processing your personal data is that it is necessary for the performance of a contract or in order to take steps at your request prior to entering into a contract (for example if you request a free trial).

Where our customers are corporate entities, we process the personal data of our contacts at the company on the basis that we have a legitimate interest for this processing. Our legitimate interest is in ensuring that we maintain an appropriate relationship with our customer and so that we are able to provide the customer with excellent customer services.

In relation to direct marketing, we will process your personal data on the basis that you have provided us with consent or that we have a legitimate interest in respect of such processing based on the fact that you have previously engaged with us for services.

DBS may be performed following a successful job application for specific job roles in the company. These checks are only made if you provide explicit consent and are processed for legal and contractual reasons. In respect of credit checks, we rely upon our legitimate interests of promoting responsible lending.

Sharing your personal data with third parties

We do not, and will not, sell any of your personal data to any third party. We want to earn and maintain your trust, and we believe this is essential in order do that.

As an essential part of being able to provide our services to you, we do share your data with the following categories of third parties:

• other companies within the group, as different companies within our group are responsible for different services;
• professional advisers including lawyers, auditors and insurers who provide advice to us when we require it;
• law enforcement agencies in connection with any investigation to help prevent unlawful activity;
• CRAs and FPAs to which we may report positive, delinquent and default data about your account(s) on a regular (minimum monthly) basis. This information may be supplied to other organisations which search your credit record.

We may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out 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 and in accordance with our instructions. If you would like any more information about the third parties which we work with to provide our services to you, please contact us on the contact details provided later in this Privacy Notice.

How we ask for Consent

In those cases where we need your consent to hold and process your personal data, we will ask you to check a box on any form requiring consent. By checking these boxes you are confirming that you have been informed as to why we are collecting the information, how this information will be used, for how long the information will be kept, who else will have access to this information and what your rights are as a data subject (all of which is set out in this Privacy Notice). Where we process your personal data on the basis that you have provided us with your consent, you have the right to withdraw such consent at any time by contacting us using the details set out below. This shall not affect the lawfulness of any processing that was based on your consent before you withdrew it.

How we keep your personal data secure

To protect your information, we have policies and procedures in place to make sure that only authorised personnel can access the information, that information is handled and stored in a secure and sensible manner, and all systems that can access the information have the necessary security measures in place.

All employees, contractors and sub-contractors receive the necessary training and resources to ensure they understand their responsibilities in relation to all of our policies and procedures.

In additional to these operational measures we also use a range of technologies and security systems to reinforce the policies and procedures, including ensuring that:

• access to personal data is strictly restricted to those employees who need access this information as part of their role
• we store your personal data on secure servers and unauthorised external access to personal data is protected through the use of a firewall
• payment details comply with the PCI-DSS

To make sure that these measures are suitable, we run regular vulnerability tests and have annual Cyber Security checks as part of the Cyber Essentials scheme. Routinely scheduled audits are performed to identify areas of weakness and non-compliance.

How long do we keep your personal data

We shall only retain your information for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements. If you would like more information about how long we retain specific types of your information, please contact us on the contact details provided later in this Privacy Notice.

Transfers of your personal data out of the EEA

Some of the data that we collect from you may be transferred to and stored at a destination outside the European Economic Area via third parties we use to provide us with services like Dropbox; Dropbox Business is certified as being compliant with the most widely accepted security and privacy standards and regulations in the world, such as ISO 27001/2, ISO27018/17 and SOC 2.

Our cloud marketing platforms store your personal data within the UK.

Your rights

The right to access information we hold about you

At any point you can contact us to request the information we hold about you. Once we have received your request, we will respond within one month.

The right to correct and update the information we hold about you

If the information we hold about you is out of date, incomplete or incorrect, you can inform us and we will ensure that it is updated.

The right to have your information erased

If you feel that we should no longer be using your information or that we are illegally using your information, you can request that we erase the information we hold. When we receive your request, we will confirm whether the information has been deleted or tell you the reason why it cannot be deleted.

The right to object to processing of your information

You have the right to request that we stop processing your information. Upon receiving the request, we will contact you to tell you if we are able to comply or if we have legitimate grounds to continue. If data is no longer processed, we may continue to hold your information to comply with your other rights.

The right to ask us to stop contacting you with direct marketing

You have the right to request that we stop contacting you with direct marketing. You can do this by clicking the unsubscribe link at the bottom of any of our emails or by contacting us by email or post.

The right to data portability

You have the right to request that we transfer your information to another controller. Once we have received your request, we will comply where it is feasible to do so.

For your security we may need to verify your identity before we process your instructions above.

Cookies and tracking

What is a cookie?

Cookies are small text files containing small amounts of information which are sent to and stored on your computer, smartphone or other device when you access a website. Cookies are then sent back to the originating website on each subsequent visit or to another website that recognises that cookie. Cookies are useful because they allow a website to recognise a user’s device.

Use of cookies

Cookies are used on the Website for a number of reasons. This includes the following:

• to monitor and collect information about transactions placed on the Website
• to allow users to log-in to their client account
• for fraud prevention purposes and to generally safeguard privacy.

We use the following cookies:

• Strictly necessary cookies – these are cookies that are required for the operation of our Website. They include, for example, cookies that enable you to log into your client account and use the shopping basket;
• Analytical/performance cookies – they allow us to recognise and count the number of visitors and to see how visitors move around our Website when they are using it. This helps us to improve the way our Website works;
• Functionality cookies – these are used to recognise you when you return to our Website. This enables us to personalise our content for you; and
• Targeting cookies – these cookies record your visit to our Website, the pages you have visited and the links you have followed. We will use this information to make our Website and the advertising displayed on it more relevant to your interests. We may also share this information with third parties for this purpose.

Consent to cookies

Our website has cookie consent and preference settings to enable you to be in control of how cookies are used. Look for the cookie alert when you first enter our website or you can locate these settings by clicking on the “C” icon to the bottom left of the webpage.

Turning off cookies

If you do not want to accept cookies, you can change your browser settings so that cookies are not accepted or set your own preferences using the onscreen instructions located to the bottom left of the website. If you do this, please be aware that you may lose some of the functionality of this website. For further information about cookies and how to disable them please go to the Information Commissioner’s webpage on cookies: https://ico.org.uk/for-the-public/online/cookies/ or visit http://www.allaboutcookies.org/.

Contacting us

If you have any queries about this Privacy Notice, need further information about how we use your personal data or wish to lodge a complaint, please contact us by any of the following means:

Email: [email protected]

Post: Data Controller, Adler & Allan Ltd, 80 Station Parade, Harrogate, North Yorkshire, HG1 1HQ.

You also have the right to lodge a complaint with a supervisory authority. In the UK, the relevant supervisory authority is the ICO. Further information, including contact details, is available at https://ico.org.uk.

Changes to this Privacy Notice

Any changes we may make to this privacy notice in the future will be posted on this page and, where appropriate, may be notified to you by e-mail. However, we advise that you check this page regularly to keep up to date with any necessary changes. We will inform you should we process your personal data for a purpose other than the purpose for which it was obtained.

This Privacy Notice was last updated April 2019