We do not collect any Special Categories of Personal Data about you which relate to details about your race or ethnicity, religious or philosophical beliefs, sexual orientation, political opinions, trade union membership, genetic and biometric data.

Where we need to collect Personal Data by law, or under the terms of a contract we have with you, and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with goods or services). In this case, we may have to cancel a product or service you have with us but we will notify you if this is the case at the time.

Marketing
We will never sell or provide your Personal Data to third parties for marketing purposes.
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Who we may share your Personal Data with
We may share your Personal Data with external organisations solely to carry out services on our behalf and for the purposes described above. We and they are legally obliged to process your Personal Data in accordance with our instructions and data protection obligations, and to put in place contractual and other security measures that protect your Personal Data. They cannot use any of your Personal Data for their own purposes, including marketing.

The main functions that are or may be carried out by external organisations are as follows:

• Installation of our products
• Inspection of our installations and products
• Payment processing
• Web hosting, online content services and data storage
• Data analytics and data cleansing
• Legal and compliance-related services
• Debt collection
• Provision of an Insurance Backed Guarantee (IBG)
• Provision of FENSA certification

How long we will use your Personal Data for
Whenever we collect or process your Personal Data, we’ll only keep it for as long as is reasonably necessary for the purpose for which it was collected, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your Personal Data for a longer period in the event of a complaint, or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.

To determine the appropriate retention period for Personal Data, we consider the amount, nature and sensitivity of the Personal Data, the potential risk of harm from unauthorised use or disclosure of your Personal Data, the purposes for which we process your Personal Data and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements.

At the end of that retention period, your data will either be deleted completely or anonymised, for example by aggregation with other data, so that it can be used in a non-identifiable way for the purposes of statistical analysis and business planning.

By law, we have to keep basic information about our customers for six years after they cease being customers for tax purposes.

In some circumstances you can ask us to delete your data: see your legal rights below for further information. In some circumstances, we will anonymise your Personal Data (so that it can no longer be associated with you) for research or statistical purposes, in which case we may use this information indefinitely without further notice to you. In all circumstances, we will retain your personal data for at least the period of any guarantee that you have with us, to enable us to comply with the terms of the guarantee. The length of time that your guarantee is valid for is dependant upon the type of product and is detailed on your guarantee document. You can also request this information at any time.

How we protect your Personal Data
We have put in place appropriate security measures to prevent your Personal Data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your Personal Data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your Personal Data on our instructions and they are subject to a duty of confidentiality.
We have put in place procedures to deal with any suspected Personal Data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.
We always hold your Personal Data securely and to prevent unauthorised disclosure or access to your Personal Data, we have implemented strong security safeguards including operating our website over the https protocol. We also follow stringent procedures to ensure we work with all Personal Data in line with current data protection legislation.

Your legal rights
It is important that the Personal Data we hold about you is accurate and current. Please keep us informed if your Personal Data changes during your relationship with us.

Your rights over your Personal Data
Under certain circumstances, you have rights under data protection laws in relation to your personal data.

You have the right to:

• Request access to your personal data (commonly known as a “data subject access request”). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
• Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
• Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
• Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
• Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios:
• If you want us to establish the data’s accuracy.
• Where our use of the data is unlawful but you do not want us to erase it.
• Where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims.
• You have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
• Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
• Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent in relation to our use of personal data to provide our services, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.

If you wish to exercise any of the rights set out above, please contact our Data Protection Team using the contact details above.

We try to respond to all legitimate requests within one month.