Privacy Policy

CKF SYSTEMS LIMITED DATA PRIVACY POLICY

IN COMPLIANCE WITH THE EU GENERAL DATA PROTECTION REGULATION (GDPR)

INTRODUCTION

1.1 CKF Systems Limited committed to safeguarding the privacy of our customers, suppliers and employees.

1.2 This policy will apply where CKF Systems Limited are acting as a data controller with respect to personal data of our customers, suppliers and employees; that is where we determine the purposes and means of the processing of that personal data.

1.3 In this policy, “we”, “us” and “our” refer to CKF Systems Limited. For more information about us, see Section 8.

HOW WE USE YOUR PERSONAL DATA

2.1 In this Section we have set out:

(a) the general categories of personal data that we may process;

(b) In the case of personal data that we did not obtain directly from you, the source and specific categories of that data.

(c) the purposes for which we may process personal data; and

(d) the legal bases of the processing.

2.2 We may process information contained in any enquiry you submit to us regarding goods and/or services referred to as enquiry data. The source of the enquiry data is you or your employer. The enquiry data may be processed for the purposes of offering, marketing and selling relevant goods and/or services to you. The legal basis for this processing is consent.

2.3 We may process information relating to our suppliers, including supplier contact information, referred to as supplier relationship data. The supplier relationship data may include your name, your employer, your job title or role, your contact details, and information contained in communications between us and you or your employer. The source of the supplier relationship data is you or your employer. The supplier relationship data may be processed for the purposes of managing our relationships with our suppliers, communicating with suppliers, keeping records of those communications and receiving promotions, support and services from our supplier. The legal basis for this processing is our legitimate interests, namely the proper management of our supplier relationships.

2.4 We may process information relating to our customer relationships, including customer contact information, referred to as customer relationship data. The customer relationship data may include your name, your employer, your job title or role, your contact details, and information contained in communications between us and you or your employer. The source of the customer relationship data is you or your employer. The customer relationship data may be processed for the purposes of managing our relationships with our customers, communicating with customers, keeping records of those communications and promoting our products and services to customers. The legal basis for this processing is our legitimate interests, namely the proper management of our customer relationships.

2.5 We may process information relating to transactions, including purchases of goods and services, which you enter into with us. This information is referred to as Transaction data. The transaction data may include your name, your employer, your job title or role, your contact details, information contained in communications between us and you or your employer, and the transaction details (Normally a formal contract of supply / purchase order). The source of the transactional data is you or your employer. The transaction data may be processed for the purpose of supplying the purchased goods and services and keeping proper records of those transactions. The legal basis for this processing is the performance of a contract between your employer and us and/or taking steps, at your request, to enter into such a contract and our legitimate interests, namely the proper administration of our business.

2.6 We may process information that you provide to us for the purpose of subscribing to our email notifications and/or newsletters. This information is referred to as notification data. The source of the notification data is you or your employer. The notification data may be processed for the purposes of sending you the relevant notifications and/or newsletters. The legal basis for this processing is your or your employers consent.

2.7 We may process information contained in or relating to any communication that you send to us. This information is referred to as correspondence data. The correspondence data may include the communication content associated with the communication. The source of the correspondence data is you or your employer. The correspondence data may be processed for the purposes of communicating with you and record-keeping. The legal basis for this processing is our legitimate interests, namely the proper administration of our business and communications with our customers, suppliers and employees.

2.8 We may process employment information. This information is referred to as employment data. This data may include name, home address, home phone number, personal mobile phone number, personal e-mail, qualifications, work history and other data contained in your CV. The source of the employment data is you or your appointed agent. This data is received in the form of your CV’s and recruitment agencies communications (with whom we have data processor agreements). This data may be processed for the purposes of employment. The legal basis for this processing is our legitimate interests, namely staff recruitment and potential contract of employment.

2.9 We may process any of your personal data identified in this policy where necessary for the establishment, exercise or defence of legal claims, whether in court proceedings or in an administrative or out-of-court procedure. The legal basis for this processing is our legitimate interests, namely the protection and assertion of our legal rights, your legal rights and the legal rights of others.

2.10 We may process any of your personal data identified in this policy where necessary for the purposes of obtaining or maintaining insurance coverage, managing risks, or obtaining professional advice. The legal basis for this processing is our legitimate interests, namely the proper protection of our business against risks.

2.11 In addition to the specific purposes for which we may process your personal data set out in this Section, we may also process any of your personal data where such processing is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person.

2.12 Please do not supply any other person’s personal data to us, unless we request you to do so.

PROVIDING YOUR PERSONAL DATA TO OTHERS

3.1 We may disclose your personal data to our insurers and/or professional advisers and / or government departments insofar as reasonably necessary for the purposes of obtaining or maintaining insurance coverage, managing risks, obtaining professional advice, or the establishment, exercise or defence of legal claims, whether in court proceedings or in an administrative or out-of-court procedure.

3.2 We may disclose your enquiry data to one or more of those selected third party suppliers of goods and services identified in our proposals for the purpose of enabling them to offer market and supply relevant goods and/or services. Each such third party will act as a data controller in relation to the enquiry data that we supply to it; and upon contacting you, each such third party should supply to you a copy of its own privacy policy, which will govern that third party’s use of your personal data.

3.4 In addition to the specific disclosures of personal data set out in this Section 4, we may disclose your personal data where such disclosure is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person. We may also disclose your personal data where such disclosure is necessary for the establishment, exercise or defence of legal claims, whether in court proceedings or in an administrative or out-of-court procedure.

INTERNATIONAL TRANSFERS OF YOUR PERSONAL DATA

4.1 We do not normally provide personal data to countries outside the European Economic Area (EEA).

Should the need arise for us to transfers personal information outside the EU, we have procedures and safeguarding measures in place to secure, encrypt and maintain the integrity of the data. Our procedures include a review of the countries with sufficient adequacy decisions (Art. 45), as well as provisions for binding corporate rules; standard data protection clauses or approved codes of conduct for those countries. We will carry out strict due diligence checks with all recipients of personal data to assess and verify that they have appropriate safeguards in place to protect the information, ensure enforceable data subject rights and have effective legal remedies for data subjects where applicable.

RETAINING AND DELETING PERSONAL DATA

5.1 This Section sets out our data retention policies and procedure, which are designed to help ensure that we comply with our legal obligations in relation to the retention and deletion of personal data.

5.2 Personal data that we process for any purpose or purposes shall not be kept for longer than is necessary for that purpose or those purposes.

5.3 We will retain your personal data as follows:

Enquiry data will be retained for a minimum period of one year and for a maximum period of six years following the fulfilment / termination of the enquiry or on receiving a request to destroy personal data by the data subject and there are no legal reasons to retain that data, it will be destroyed within 24 working hours.

Supplier relationship data will be retained for a minimum period of one year and for a maximum period of six years following the closure or inactivity of the supplier account or on receiving a request to destroy personal data by the data subject and there are no legal reasons to retain that data, it will be destroyed within 24 working hours.

Customer relationship data will be retained for a minimum period of one year and for a maximum period of six years following the closure or inactivity of the customer account or on receiving a request to destroy personal data by the data subject and there are no legal reasons to retain that data, it will be destroyed within 24 working hours.

Transaction data will be retained for a minimum period of one year and for a maximum period of six years following the closure or inactivity of the account or on receiving a request to destroy personal data by the data subject and there are no legal reasons to retain that data, it will be destroyed within 24 working hours.

Notification data will be retained for a minimum period of one year and for a maximum period of six years following the closure or inactivity of the account or on receiving a request to destroy personal data by the data subject and there are no legal reasons to retain that data, it will be destroyed within 24 working hours.

Correspondence data will be retained for a minimum period of one year and for a maximum period of six years following the closure or inactivity of the account or on receiving a request to destroy personal data by the data subject and there are no legal reasons to retain that data, it will be destroyed within 24 working hours.

Employment data will be retained for a minimum period of six year and for a maximum period of ten years following the termination of employment or on receiving a request to destroy personal data by the data subject and there are no legal reasons to retain that data, it will be destroyed within 24 working hours.

5.4 Notwithstanding the other provisions of this Section, we may retain your personal data where such retention is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person.

AMENDMENTS

6.1 We may update this policy from time to time by publishing a new version on our website.

6.2 You should check this page to ensure you are happy with any changes to this policy.

YOUR RIGHTS

7.1 In this Section, we have summarised the rights that you have under data protection law. Some of the rights are complex, and not all of the details have been included in our summaries. Accordingly, you should read the relevant laws and guidance from the regulatory authorities for a full explanation of these rights.

7.2 Your principal rights under data protection law are:

(a) The right to access;

You have the right to confirmation as to whether or not we process your personal data and, where we do, access to the personal data, together with certain additional information. That additional information includes details of the purposes of the processing, the categories of personal data concerned and the recipients of the personal data. Providing the rights and freedoms of others are not affected, we will supply to you a copy of your personal data. The first copy will be provided without charge, in a machine readable format, however additional copies may be subject to a reasonable charge.

(b) The right to rectification;

You have the right to have any inaccurate personal data about you rectified and, taking into account the purposes of the processing, to have any incomplete personal data about you completed.

(c) The right to erasure;

In some circumstances you have the right to the erasure of your personal data without undue delay. Those circumstances include: the personal data are no longer necessary in relation to the purposes for which they were collected or otherwise processed; you withdraw consent to consent-based processing; you object to the processing under certain rules of applicable data protection law; the processing is for direct marketing purposes; and the personal data have been unlawfully processed. However, there are exclusions of the right to erasure. The general exclusions include where processing is necessary: for exercising the right of freedom of expression and information; for compliance with a legal obligation; or for the establishment, exercise or defence of legal claims.

(d) The right to restrict processing;

In some circumstances you have the right to restrict the processing of your personal data. Those circumstances are: you contest the accuracy of the personal data; processing is unlawful but you oppose erasure; we no longer need the personal data for the purposes of our processing, but you require personal data for the establishment, exercise or defence of legal claims; and you have objected to processing, pending the verification of that objection. Where processing has been restricted on this basis, we may continue to store your personal data. However, we will only otherwise process it: with your consent; for the establishment, exercise or defence of legal claims; for the protection of the rights of another natural or legal person; or for reasons of important public interest.

(e) The right to object to processing;

You have the right to object to our processing of your personal data on grounds relating to your particular situation, but only to the extent that the legal basis for the processing is that the processing is necessary for: the performance of a task carried out in the public interest or in the exercise of any official authority vested in us; or the purposes of the legitimate interests pursued by us or by a third party. If you make such an objection, we will cease to process the personal information unless we can demonstrate compelling legitimate grounds for the processing which override your interests, rights and freedoms, or the processing is for the establishment, exercise or defence of legal claims.

You have the right to object to our processing of your personal data for direct marketing purposes (including profiling for direct marketing purposes). If you make such an objection, we will cease to process your personal data for this purpose.

You have the right to object to our processing of your personal data for scientific or historical research purposes or statistical purposes on grounds relating to your particular situation, unless the processing is necessary for the performance of a task carried out for reasons of public interest.

(f) The right to data portability;

(g) The right to complain to a supervisory authority

If you consider that our processing of your personal information infringes data protection laws, you have a legal right to lodge a complaint with a supervisory authority responsible for data protection. You may do so in the EU member state of your habitual residence, your place of work or the place of the alleged infringement.

(h) The right to withdraw consent.

To the extent that the legal basis for our processing of your personal information is consent, you have the right to withdraw that consent at any time. Withdrawal will not affect the lawfulness of processing before the withdrawal.

7.3 To the extent that the legal basis for our processing of your personal data is:

(a) consent; or

(b) that the processing is necessary for the performance of a contract to which you are party or in order to take steps at your request prior to entering into a contract,

you have the right to receive your personal data from us in a structured, commonly used and machine-readable format. However, this right does not apply where it would adversely affect the rights and freedoms of others.

7.4 You may exercise any of your rights in relation to your personal data by written notice to us, in addition to the other methods specified in this Section 8.