Privacy Notice
BACKGROUND:
TES Enterprise Solutions Ltd (“TES”) understands that your privacy is important to you and that you care about how your personal data is used. We respect and value the privacy of all of ourcustomers, suppliers, employees and consultants (whether potential or actual) and will only collect and use personal data in ways that are described here, and in a way that is consistent with our obligations and your rights under the law.
We recognise the importance of protecting your personal information and are committed to processing it responsibly and in compliance with applicable data protection laws.
1. Information About Us
TES Enterprise Solutions, a limited company, registered in England and Wales under company number 08308394.
Registered address: 10 Western Road, Romford, Essex, England, RM1 3JT
Main trading address: West Lancashire Investment Centre, Maple View, White Moss Business Park, Skelmersdale, England, WN8 9TG
VAT number: 151990303
Data Protection Officer: Ron Argent (ron.argent@tes-es.com or 07999576926).
2. What Does This Notice Cover?
This Privacy Statement describes TES’s general privacy practices that apply to personal information we collect, use and share about our clients, business partners, supplier and other organisations with which TES has or contemplates a business relationship as well as the individuals working for them.
This Privacy Information explains how we use your personal data: how it is collected, how it is held, and how it is processed. It also explains your rights under the law relating to your personal data.
This Privacy Notice is supplemented by the TES Online Privacy Statement, which provides more information in the online context. We may provide additional or more specific information on the collection or use of personal information on websites or related to a specific product or service.
3. What is Personal Data?
Personal data is defined by the UK GDPR and the Data Protection Act 2018 (collectively, “the Data Protection Legislation”) as ‘any information relating to an identifiable person who can be directly or indirectly identified in particular by reference to an identifier’.
Personal data is, in simpler terms, any information about you that enables you to be identified. Personal data covers obvious information such as your name and contact details, but it also covers less obvious information such as identification numbers, electronic location data, and other online identifiers.
The personal data that we use is set out in Part 5, below.
4. What Are My Rights?
Under the Data Protection Legislation, you have the following rights, which we will always work to uphold:
a) The right to be informed about our collection and use of your personal data. This Privacy Notice should tell you everything you need to know, but you can always contact us to find out more or to ask any questions using the details in Part 11.
b) The right to access the personal data we hold about you. Part 10 will tell you how to do this.
c) The right to have your personal data rectified if any of your personal data held by usis inaccurate or incomplete. Please contact us using the details in Part 11 to find out more.
d) The right to be forgotten, i.e. the right to ask usto delete or otherwise dispose of any of your personal data that we hold. Please contact us using the details in Part 11 to find out more.
e) The right to restrict (i.e. prevent) the processing of your personal data.
f) The right to object to us using your personal data for a particular purpose or purposes.
g) The right to withdraw consent. This means that, if we are relying on your consent as the legal basis for using your personal data, you are free to withdraw that consent at any time.
h) The right to data portability. This means that, if you have provided personal data to us directly, we are using it with your consent or for the performance of a contract, and that data is processed using automated means, you can ask us for a copy of that personal data to re-use with another service or business in many cases.
i) Rights relating to automated decision-making and profiling. We do not use your personal data in this way.
For more information about our use of your personal data or exercising your rights as outlined above, please contact us using the details provided in Part 11.
It is important that your personal data is kept accurate and up-to-date. If any of the personal data we hold about you changes, please keep us informed as long as we have that data.
Further information about your rights can also be obtained from the Information Commissioner’s Office or your local Citizens Advice Bureau.
If you have any cause for complaint about our use of your personal data, please contact us using the details provided in section 11 and we will do our best to solve the problem for you. If we are unable to help, you also have the right to lodge a complaint with the UK’s supervisory authority, the Information Commissioner’s Office on 0303 123 1113.
5. What Personal Data Do You Collect?
We may collect some or all of the following personal data (this may vary according to your relationship with us):
- Name;
- Date of birth;
- Gender;
- Address;
- Email address;
- Telephone number;
- Business name;
- Job title;
- Profession;
- Payment information;
- Information about purchase history and technical specifications;
- Non-disclosure agreements;
- Demographic information such as post code, employment;
- Preferences and interests;
- Supplying you with information by email, post or via social media that you have opted-in to;
- Passwords, IP address and browser settings;
- Any other information which you may share with the Company for the performance of any contractual obligations.
Your personal data (name, email address, contact number, business name, job title) may be obtained from the following third parties:
- Our Suppliers
- Our Distributors
- Our Partners and Collaborators
- Our Customers
Your personal data (name, email address, contact number, business name, job title) may also be obtained from:
- Our Marketing Campaigns
- Our website ‘Contact Us’ form
A detailed list is available on request – please contact us using the details provided in Part 11.
6. How Do You Use My Personal Data?
Under the Data Protection Legislation, we must always have a lawful basis for using personal data. This may be because the data is necessary for our performance of a contract with you, because you have consented to our use of your personal data, or because it is in our legitimate business interests to use it. Your personal data may be used for the following purposes:
- Administering our business.
- Providing and managing your account. Your personal details are required to access and/or use certain areas and/or features of our site and any contract held by us;
- Supplying our products and services to you. Your personal details are required in order for us to enter into a contract with you;
- Personalising and tailoring our products and services for you. This will include information necessary to fulfil your request, to grant you access to the product or service, to provide you with support and to be able to contact you. We retain such information for administrative purposes, defending our rights, and in connection with our relationship with you;
- Discussing technical or commercial requirements;
- Managing payments for our products and services.
- Communicating with you. This may include responding to emails or calls from you;
- Access and use of websites or other online service. This may include information necessary to provide you with access, for the operation of the website and for us to comply with security and legal requirements in relation to operating our site, such as passwords, IP address and browser settings. We may also collect information about your activities during your visit in order to personalise your website experience, such as recording your preferences and settings, and to collect statistics to help us improve and further develop our websites, products and services;
- Contacting employees of our clients, prospects, partners and suppliers. This is for purposes such as contract management, fulfilment, delivery of products and services, provision of support, invoicing and management of the services or the relationship.
- Marketing. Most information we collect about you comes from our direct interactions with you. When you register for an event, we may collect information (online or offline) in relation to the event organisation, and during an event, such as participation in sessions and survey results. We combine the personal information we collect to develop aggregate analysis and business intelligence for conducting our business and for marketing purposes. You can choose to receive information about our products and services. This may be in the form of emails, telephone calls or postal mail. When visiting our websites or using our services we may provide you with personalised information. You can always opt out from receiving personalized communication from TES by clicking on the unsubscribe link at the bottom of our emails, indicating so when we call you, or by contacting us at info@tes-es.com. You can unsubscribe from seeing posts on social media platforms via your individual settings.
- Where your personal information is used in connection with a request, order, transaction or agreement (or preparing for the same), or to provide you with services that you requested, we do this because it is necessary for the performance of an agreement with you.
- Where personal information is used in relation to marketing, improvement or development of our products or services, for reasons of safety and security, or regulatory requirements other than in connection with your agreement or request, we do this on the basis of our or a third party’s legitimate interests, or with your consent. When we collect and use your personal information subject to the EU Privacy Legislation this may have consequences for your rights.
- In some circumstances, where permitted or required by law, we may process your personal data without your knowledge or consent. This will only be done within the bounds of the Data Protection Legislation and your legal rights.
7. How Long Will You Keep My Personal Data?
We will not keep your personal data for any longer than is necessary to fulfil the purpose(s) for which it is processed, including the security of our processing complying with legal and regulatory obligations (e.g. audit, accounting and statutory retention terms), handling disputes, and for the establishment, exercise or defense of legal claims.
Because the circumstances may vary depending on the context and the services, the information provided in Online Privacy Statement or provided in a specific notice may provide more detailed information on applicable retention terms.
8. How and Where Do You Store or Transfer My Personal Data?
We will store most of your personal data in the UK. This means that it will be fully protected under the Data Protection Legislation.
We will store some of your personal data within the European Economic Area (the “EEA”). The EEA consists of all EU member states, plus Norway, Iceland, and Liechtenstein. This means that your personal data will be fully protected under the EU GDPR and/or to equivalent standards by law. Transfers of personal data to the EEA from the UK are permitted without additional safeguards.
We may store some or all of your personal data in countries outside of the UK. These are known as “third countries”. We will take additional steps in order to ensure that your personal data is treated just as safely and securely as it would be within the UK and under the Data Protection Legislation.
We may share your personal data withother companies in our group. Where this involves the transfer of personal data outside the European Economic Area (EEA), our group ensures that personal data is protected by requiring all companies within the group to follow the same rules with respect to personal data usage. These are known as “binding corporate rules”. More information on binding corporate rules is available from the European Commission.
The security of your personal data is essential to us, and to protect your data we take a number of important measures, including the following:
a) Locked filing cabinet
b) Secure online systems
c) Various physical, electronic and managerial procedures to safeguard and secure the information we collect.
9. Do You Share My Personal Data?
We may share your personal data with other companies in our group related to supplying products and/or services to you. This includes subsidiaries.
We may sometimes contract with trusted third parties to supply productsand/or services to you on our behalf. The trusted third parties include:
- Our Suppliers
- Our Distributors
- Our Partners and Collaborators
- Our Customers
A detailed list is available on request (see section 11)
The personal data shared may include details required for payment processing, delivery, and marketing. In some cases, the third parties may require access to some or all of your personal data that we hold.
If any of your personal data is shared with a third party, as described above, we will take steps to ensure that your personal data is handled safely, securely, and in accordance with your rights, our obligations, and the third party’s obligations under the law, as described above in Part 8.
If any personal data is transferred outside of the EEA, we will take suitable steps in order to ensure that your personal data is treated just as safely and securely as it would be within the UK and under the Data Protection Legislation, as explained above in Part 8.
In some limited circumstances, we may be legally required to share certain personal data, which might include yours, if we are involved in legal proceedings or complying with legal obligations, a court order, or the instructions of a government authority.
10. How Can I Access My Personal Data?
If you want to know what personal data we have about you, you can ask us for details of that personal data and request a copy of it (where any such personal data is held). This is known as a “Subject Access Request (SAR)”.
All SARs should be made in writing and sent to the email or postal address shown in Part 11. To make this as easy as possible for you, a Subject Access Request Form is available for you to use (Appendix 1). You do not have to use this form, but it is the easiest way to tell us everything we need to know to respond to your request as quickly as possible.
There is not normally any charge for a SAR. If your request is ‘manifestly unfounded or excessive’ (for example, if you make repetitive requests) a fee may be charged to cover ouradministrative costs in responding.
We will respond to your subject access request within one month of receiving it, unless additional steps are required in order to verify your identity, or, if the Company is processing a large amount of personal data about you, to clarify your request (ie to specify the personal data, or processing, to which your SAR relates). If additional information is required, the time limit for responding to a SAR does not begin until that information is received. Normally, we aim to provide a complete response, including a copy of your personal data within that time. In some cases, however, particularly if your request is more complex, more time may be required up to a maximum of three months from the date we receive your request. You will be kept fully informed of our progress.
11. How Do I Contact You?
To contact us about anything to do with your personal data and data protection, including to make a subject access request, please use the following details:
Email address: info@tes-es.com
Postal Address: 10 Western Road, Romford, Essex, England, RM1 3JT.
12. Changes to this Privacy Notice
We may change this Privacy Notice from time to time. This may be necessary, for example, if the law changes, or if we change our business in a way that affects personal data protection.
Any changes will be made available on the Company website www.tes-es.com
We encourage you to check back periodically for any changes or updates.
13. Roles and Responsibilities
The Company’s Chief Executive Officer has overall responsibility for the company policies and procedures
14. Implementation of Privacy Notice
This Privacy Notice shall be deemed effective as of August 2023. No part of this Privacy Notice shall have retroactive effect and shall thus apply only to matters occurring on or after this date.
Appendix 1
[Your full address]
[Phone number]
[The date]
TES Enterprise Solutions Ltd
10 Western Road
Romford
Essex
RM1 3JT
Dear Sir or Madam
Subject access request
[Your full name and address and any other details to help identify you and the information you want.]
Please supply the information about me I am entitled to under the Data Protection Act 1998 relating to: [give specific details of the information you want, for example
- your personnel file;
- emails between ‘A’ and ‘B’ (between 1/6/11 and 1/9/11);
- copy of statement of account]
If you need any more information from me, or a fee, please let me know as soon as possible.
It may be helpful for you to know that a request for information under the Data Protection Act 1998 should be responded to within 40 days.
If you do not normally deal with these requests, please pass this letter to your Data Protection Officer. If you need advice on dealing with this request, the Information Commissioner’s Office can assist you and can be contacted on 0303 123 1113 or at ico.org.uk
Yours faithfully
[Signature]