Privacy Policy

1. GENERAL

We take your privacy seriously. Glen Dimplex Professional Appliances, trading as Lec Medical is a division of Glen Dimplex Home Appliances Limited (company number 2692306), whose registered office is at Stoney Lane, Prescot, Merseyside, L35 2XW. Glen Dimplex Home Appliances, Limited (“we” “us” “our”) is a ‘data controller’ under data protection laws and are committed to protecting and respecting your privacy. For the purposes of data protection legislation, we are the data controller and you are the data subject. We will process your personal data in accordance with Retained Regulation (EU) 2016/679 (the “UK GDPR”) and the Data Protection Act 2018. We are also subject to the EU General Data Protection Regulation (“EU GDPR”). Please read the following carefully to understand our views and practices regarding your personal data and how we will treat it.

PERSONAL DATA WE COLLECT ABOUT YOU

The type of data we may collect about you depends on whether you use our goods and/or services, visit our website or subscribe to marketing. Most of this data comes directly from you, however sometimes we obtain personal data from third parties. We have set out some more detail below:

2. VISITORS TO OUR WEBSITE AND APPLICATIONS

2.1 When you visit our website (“Site”) or use our applications (“Apps”) we will collect and use the following personal data about you:

2.1.1 Upon registration or completing forms on our Site and Apps for marketing purposes or to make an order or enquire about our goods and/or services or to register to use one of our Apps, your name and contact information, including email address and telephone number, as well as your postal address;

2.1.2 Correspondence between you and us when you make a complaint, an enquiry or any other contact through our Site or Apps;

2.1.3 Data associated with your visits to and use of our Site and Apps, including traffic data, location data, weblogs and other communication data;

2.1.4 Information about your device for fraud protection, system administration and to report aggregated information to our advertisers as internet protocol (IP) addresses, operating system and browser type data – this is statistical data about our users’ browsing actions and patterns and does not identify any individual; and

2.1.5 Cookies and similar technologies to distinguish you from other users of our Site and Apps. This helps us to provide you with a good experience when you browse or otherwise use our Site and/or Apps and also allows us to improve our Site and Apps. For detailed information on the cookies we use and the purposes for which we use them see our Cookie Policy.

2.2 Our Site and Apps may, from time to time, contain links to and from the websites of third parties. Please note that if you follow a link to any of these websites, such websites will apply different terms to the collection and privacy of your personal data and we do not accept any responsibility or liability for these policies. When you leave our Site and Apps, we encourage you to read the privacy notice/policy of every website you visit.

3. CUSTOMERS

3.1 When you order goods or services from us either via our Site, correspond with us via telephone, email, SMS, live chat or other media, when you enter a competition or promotional survey, when you report a problem to us or when you register a product warranty, we will collect the following details from you:

3.1.1 Your name and contact information, including email address and telephone number, as well as your postal address;

3.1.2 your billing information, transaction and payment information; and

3.1.3 information to enable us to perform credit or other financial checks on you (please see paragraph 3.3 below for more detail).

3.2 We may also advertise your feedback on our website and marketing materials subject to obtaining your prior consent where necessary. Where you indicate you would like to receive marketing correspondence from us, subscribe to our mailing lists or newsletters, enter into any of our competitions or provide us with your details at networking events we may use your personal data in order to provide you with details about our goods, services, business updates and events which we think may be of interest

3.3 Pursuant to Article 22 of each of the UK GDPR and the EU GDPR, you have the right not to be subject to automated individual decision making. In accordance with the relevant Article 22 (2)(a), we use automated processing insofar as it is necessary for the performance of your contract with us and to offer you goods and services that may be of interest to you. We may carry out a credit check on our customers:

3.3.1 so that we can make credit decisions about you; and

3.3.2 to prevent fraud and money laundering.

Our search won’t be recorded on the files of the credit reference agency. If further to undertaking a credit check you receive a low credit score, we reserve the right not to supply you with goods or services on credit and/or require upfront payment for the goods or services you wish to purchase. If you provide false or inaccurate information and we suspect fraud, we will record this.

3.4 We may monitor and record communications with you (such as telephone communications and emails) for the purpose of quality assurance, training, fraud prevention and compliance.

4. SUPPLIERS

4.1 We will collect details such as name, postal address, telephone number and email address in order to contact you about goods or services ordered with you, to place further orders and to pay you for the goods and/or services supplied.

We collect and use this personal data for the purposes described in the section ‘How and why we use your personal data’ below. If you do not provide personal data we ask for, it may delay or prevent us from providing goods or services to you. We will notify you if this is the case.

HOW AND WHY WE USE YOUR PERSONAL DATA

Under Article 6 of each of the UK GDPR and the EU GDPR, we can only use your personal data if we have a proper reason, such as:

· where you have given consent;

· to comply with our legal and regulatory obligations;

· for the performance of a contract with you or to take steps at your
request before entering into a contract; or

· for our legitimate interests or those of a third party.

A legitimate interest is when we have a business or commercial reason to use your personal data, so long as this is not overridden by your own rights and interests. We will carry out an assessment when relying on legitimate interests, to balance our interests against your own.

The table below explains what we use your personal data for and why.

What we use your personal data for Our reasons
Providing goods and services to you To perform our contract with you or to take steps at your request before entering into a contract
Preventing and detecting fraud against you or us For our legitimate interest, i.e. to minimise fraud that could be damaging for you and/or us
Conducting checks to identify our customers and verify their identity and financial situation To comply with our legal and regulatory obligations
To enforce legal rights or defend or undertake legal proceedings Depending on the circumstances:

—to comply with our legal and regulatory obligations;

—in other cases, for our legitimate interests, i.e. to protect our business, interests and rights

Gathering and providing information required by or relating to audits, enquiries or investigations by regulatory bodies To comply with our legal and regulatory obligations
Ensuring business policies are adhered to, e.g. policies covering security and internet use For our legitimate interests, i.e. to make sure we are following our own internal procedures so we can deliver the best service to you
Operational reasons, such as improving efficiency, training and quality control For our legitimate interests, i.e. to be as efficient as we can so we can deliver the best goods and services to you
Ensuring the confidentiality of commercially sensitive information Depending on the circumstances:

—for our legitimate interests, i.e. to protect trade secrets and other commercially valuable information;

—to comply with our legal and regulatory obligations

Statistical analysis to help us manage our business For our legitimate interests, i.e. to be as efficient as we can so we can deliver the best goods and services to you
Preventing unauthorised access and modifications to systems Depending on the circumstances:

—for our legitimate interests, i.e. to prevent and detect criminal activity that could be damaging for you and/or us;

—to comply with our legal and regulatory obligations

Protecting the security of systems and data used to provide the goods and services To comply with our legal and regulatory obligations

We may also use your personal data to ensure the security of systems and data to a standard that goes beyond ou legal obligations, and in those cases our reasons are for our legitimate interests, i.e. to protect systems and data and to prevent and detect criminal activity that could be damaging for you and/or us

Updating and enhancing customer records Depending on the circumstances:

—to perform our contract with you or to take steps at your request before entering into a contract;

—to comply with our legal and regulatory obligations;

—for our legitimate interests, e.g. making sure that we can keep in touch with our customers about existing orders and new goods and services

Statutory returns To comply with our legal and regulatory obligations
Ensuring safe working practices, staff administration and assessments Depending on the circumstances:

—to comply with our legal and regulatory obligations;

—for our legitimate interests, e.g. to make sure we are following our own internal procedures and working efficiently so we can deliver the best service to you

Marketing our goods and services to:

—existing and former customers;

—third parties who have previously expressed an interest in our goods and services;

—third parties with whom we have had no previous dealings.

For our legitimate interests, i.e. to promote our business to existing and former customers
Credit reference checks via external credit reference agencies For our legitimate interests, i.e. to ensure our customers are likely to be able to pay for our goods and services
External audits and quality checks, e.g. for the audit of our accounts Depending on the circumstances:

—for our legitimate interests, i.e. to maintain our accreditations so we can demonstrate we operate at the highest standards;

—to comply with our legal and regulatory obligations

To share your personal data with members of our group and third parties that will or may take control or ownership of some or all of our business (and professional advisors acting on our or their behalf) in connection with a corporate transaction or restructuring, including a merger, acquisition, asset sale, initial public offering or in the event of our insolvencyIn such cases information will be anonymised where possible and only shared where necessary Depending on the circumstances:

—to comply with our legal and regulatory obligations;

—in other cases, for our legitimate interests, i.e. to protect, realise or grow the value in our business and assets

MARKETING

Where you indicate you would like to receive marketing correspondence from us, subscribe to our mailing lists or newsletters, enter into any of our competitions or provide us with your details at networking events for marketing purposes, we will use your personal data to send you updates (by email, text message, telephone or post) about our goods and services, including exclusive offers, promotions or new goods and services. For customers we may market similar and goods and services from you from time to time, but only where permitted by data protection laws. We will keep your data for marketing purposes for up to 5 years.

You have the right to opt-out of receiving such information at any time by:

· clicking the unsubscribe button contained in any such communication received; or

· emailing us at dataprivacy@gdha.com or calling 0344 815 3742 providing us with your name and contact details.

We may ask you to confirm or update your marketing preferences if you ask us to provide further goods and services in the future, or if there are changes in the law, regulation, or the structure of our business.

We will always treat your personal data with respect and never share it with organisations other than the Glen Dimplex Group for marketing purposes.

WHO WE SHARE YOUR PERSONAL DATA WITH

We routinely share personal data with:

· companies within the Glen Dimplex Group;

· third parties we use to help deliver our goods and services to you, e.g. payment service providers, wholesalers, distributors, mailing service providers, companies that help us with products services and repairs, warehouses and delivery companies;

· other third parties we use to help us run our business, e.g. marketing agencies, website hosts and social media providers;

· IT software providers that host our website, apps and platforms, provide technology services to us and/or store data on our behalf; and

· credit reference agencies, companies providing financial or audit service and insurance claims providers.

We only allow those organisations to handle your personal data if we are satisfied they take appropriate measures to protect your personal data. We also impose contractual obligations on them to ensure they can only use your personal data to provide services to us and to you.

We or the third parties mentioned above occasionally also share personal data with:

· our and their external auditors, e.g. in relation to the audit of our or their accounts, in which case the recipient of the information will be bound by confidentiality obligations;

· our and their professional advisors (such as lawyers and other advisors), in which case the recipient of the information will be bound by confidentiality obligations;

· law enforcement agencies, courts, tribunals and regulatory bodies to comply with our legal and regulatory obligations;

· other parties that have or may acquire control or ownership of our business (and our or their professional advisers) in connection with a corporate transaction or restructuring, including a merger, acquisition, asset sale, initial public offering or in the event of our insolvency—usually, information will be anonymised but this may not always be possible. The recipient of any of your personal data will be bound by confidentiality obligations.

We will not sell your personal data to other organisations.

WHERE YOUR PERSONAL DATA IS HELD

Personal data may be held at our offices and those locations (including cloud/server locations) of our group companies, third party agencies, service providers, representatives and agents as described above (see above: ‘Who we share your personal data with’).

Some of these third parties may be based outside the UK/European Economic Area (“EEA”). For more information, including on how we safeguard your personal data when this happens, see below: ‘Transferring your personal data out of the UK and EEA’.

HOW LONG YOUR PERSONAL DATA WILL BE KEPT

We will keep your personal data while we are providing goods and/or services to you and otherwise while you have an account with us. Thereafter, we will keep your personal data for as long as necessary:

· to respond to any questions, complaints or claims made by you or on your behalf;

· to show that we have treated you fairly;

· to keep records required by law and to protect our legal interests.

We will not keep your personal data for longer than we need it for the purpose for which it is used (as set out in this policy). Different retention periods apply for different types of personal data. Details on our retention policy and the periods which apply are available on request.

Following the end of the of the relevant retention period, we will delete or anonymise your personal data.

TRANSFERRING YOUR PERSONAL DATA OUT OF THE UK AND EEA

The EEA, UK and other jurisdictions have differing data protection laws, some of which may provide lower levels of protection of privacy.

It is sometimes necessary for us to transfer your personal data to countries outside the UK and EEA. In those cases we will comply with applicable UK laws designed to ensure the privacy of your personal data.

We may transfer your personal data to: (a) our service providers located outside the UK, for example, to Italy; and (b) other jurisdictions outside of the UK and EEA.

Under data protection law, we can only transfer your personal data to a country outside the UK /EEA where:

· in the case of transfers subject to UK data protection law, the UK government has decided the particular country ensures an adequate level of protection of personal data (known as an ‘ adequacy regulation’) further to Article 45 of the UK GDPR. A list of countries the UK currently has adequacy regulations in relation to is available here;

· in the case of transfers subject to EEA data protection laws, the European Commission has decided that the particular country ensures an adequate level of protection of personal data (known as an ‘ adequacy decision’) further to Article 45 of the EU GDPR. A list of countries the European Commission has currently made adequacy decisions in relation to is available here;

· there are appropriate safeguards in place, together with enforceable rights and effective legal remedies for you; or

· a specific exception applies under relevant data protection law.

Where we transfer your personal data outside the UK, we do so on the basis of an adequacy regulation or (where this is not available) standard contractual clauses issued further to Article 46(2) of the UK GDPR as amended, replaced or superseded from time to time. In the event we cannot or choose not to continue to rely on either of those mechanisms at any time, we will not transfer your personal data outside the UK unless we can do so on the basis of an alternative mechanism or exception provided by UK data protection law and reflected in an update to this policy.

Where we transfer your personal data outside the EEA we do so on the basis of an adequacy decision or (where this is not available) standard data protection clauses issued further to Article 46(2) of the EU GDPR. In the event we cannot or choose not to continue to rely on either of those mechanisms at any time we will not transfer your personal data outside the EEA unless we can do so on the basis of an alternative mechanism or exception provided by applicable data protection law and reflected in an update to this policy.

Any changes to the destinations to which we send personal data or in the transfer mechanisms we rely on to transfer personal data internationally will be notified to you in accordance with the section on ‘ Changes to this privacy policy’ below.

If you would like further information about data transferred outside the UK/EEA, please contact our appointed Data Lead at dataprivacy@gdha.com .

YOUR RIGHTS

You have the following rights, which you can exercise free of charge:

Access The right to be provided with a copy of your personal data
Rectification The right to require us to correct any mistakes in your personal data
Erasure (also known as the right to be forgotten) The right to require us to delete your personal data—in certain situations
Restriction of processing The right to require us to restrict processing of your personal data in certain circumstances, e.g. if you contest the accuracy of the data
Data portability The right to receive the personal data you provided to us, in a structured, commonly used and machine-readable format and/or transmit that data to a third party—in certain situations
To object The right to object:

—at any time to your personal data being processed for direct marketing (including profiling);

—in certain other situations to our continued processing of your personal data, e.g. processing carried out for the purpose of our legitimate interests unless there are compelling legitimate grounds for the processing to continue or the processing is required for the establishment, exercise or defence of legal claims

Not to be subject to automated individual decision making The right not to be subject to a decision based solely on automated processing (including profiling) that produces legal effects concerning you or similarly significantly affects you
The right to withdraw consents If you have provided us with a consent to use your personal data you have a right to withdraw that consent easily at any timeWithdrawing a consent will not affect the lawfulness of our use of your personal data in reliance on that consent before it was withdrawn

For more information on each of those rights, including the circumstances in which they apply, please contact us (see ‘ How to contact us’ below) or see the Guidance from the UK Information Commissioner’s Office on individuals’ rights.

If you would like to exercise any of those rights, please contact our appointed Data Lead at dataprivacy@gdha.com.

KEEPING YOUR PERSONAL DATA SECURE

We have appropriate security measures to prevent personal data from being accidentally lost, or used or accessed unlawfully. We limit access to your personal data to those who have a genuine business need to access it. Those processing your personal data will do so only in an authorised manner and are subject to a duty of confidentiality.

We also have procedures to deal with any suspected data security breach. We will notify you and any applicable regulator of a suspected data security breach where we are legally required to do so.

If you want detailed information from Get Safe Online on how to protect your personal data and other information and your computers and devices against fraud, identity theft, viruses and many other online problems, please visit www.getsafeonline.org. Get Safe Online is supported by HM Government and leading businesses.

HOW TO COMPLAIN

Please contact us if you have any queries or concerns about our use of your personal data (see below ‘How to contact us’). We hope we will be able to resolve any issues you may have.

You also have the right to lodge a complaint with the Information Commissioner.

The UK’s Information Commissioner may be contacted using the details at https://ico.org.uk/make-a-complaint or by telephone: 0303 123 1113.

CHANGES TO THIS PRIVACY POLICY

This privacy notice was published and last updated on 24th March 2022.

We may change this privacy notice from time to time—when we do, we will notify you on our website or other means of contact such as email if there are any changes to this policy that materially affect how we collect, store or process your personal data. If we would like to use your previously collected personal data for different purposes than those we notified you about at the time of collection, we will provide you with notice and, where required by law, seek your consent, before using your personal data for a new or unrelated purpose. We may process your personal without your knowledge or consent where required by applicable law or regulation.

HOW TO CONTACT US

You can contact our Data Lead by email if you have any questions about this privacy policy or the information we hold about you, to exercise a right under data protection law or to make a complaint.

You can contact our Data Lead at dataprivacy@gdha.com