- IMPORTANT INFORMATION AND WHO WE ARE
This website is not intended for children, and we do not knowingly collect any data relating to children.
We are Master Finish by APS, which is a trading name of Advanced Product Supplies (APS) Limited, a company incorporated and registered in England and Wales under company number 08965315 and with its registered office at Unit 5 Jupiter Drive, Chester West Employment Park, Chester, Cheshire, CH1 4QS. We are the controller of your personal data and are responsible to you for its protection. We have paid the data protection fee and are entered on the data protection register of the Information Commissioner’s Office under registration number ZA452463.
Our full contact details are:
Full name of legal entity: Advanced Product Supplies (APS) Limited, t/a Master Finish by APS
Email address: firstname.lastname@example.org
Postal address: Unit 19 Europa Court, Dee View Boulevard, Chester, Cheshire, CH1 4NP
(marked for the attention of the Data Privacy Manager).
Telephone number: 01244 375029
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 and we will update our records accordingly.
Our website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow those third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website via one of these links, we encourage you to read the privacy notice(s) of the website(s) that you visit. Please note that if you interact with us via any of our social media accounts, such interaction is governed by the privacy notices and statements of that social media organisation and not by this policy.
- THE PERSONAL DATA THAT WE COLLECT ABOUT YOU
This policy covers the personal data that we collect from both our customers and our suppliers. In most cases, the provisions of this policy apply to both customer personal data and supplier personal data. However, where a provision in this policy concerns either customer personal data or supplier personal data (but not both), this will be made clear.
Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).
We may collect, use, store and transfer different kinds of personal data about you, which we have grouped together as follows:
Identity Data. This is the full name and title of any individual customer, customer contact, supplier or supplier contact. Where you are part of a company, this would include the full name and title of directors, managers, owners and other key personnel, together with the full name and title of any other employees of yours with whom we might work.
Contact Data. This is the postal address, billing address (if different from the postal address) email address and telephone numbers for a customer business or supplier business, or for those people for whom we hold Identity Data (see above), if applicable. This also includes your communication preferences, including for things like marketing that we may look to send to you in accordance with those preferences.
Finance Data. This is your bank account and/or payment card information (for the payment of our or your fees and charges as applicable) and information (including trade references) pertaining to checks of your credit history and creditworthiness (only if you have a credit account with us).
Engagement Data. This is the detail about our relationship with you and/or your company and the products and services that we have bought from, or sold to, you and/or your company. This includes things like: the address where we have delivered our products; the extent of any services that you require from us; the details of the products or services that we have requested from you; and all documentation prepared by, or issued to, us in respect of the provision or receipt of products and services (such as health and safety risk assessments
and pre-qualification questionnaires and any maintenance guides, user guides or manuals). This also includes information about fees charged and paid over the course of our relationship with you and/or your company.
Profile Data. This is for customers only and covers your username and password for your online account with us, together with information concerning previous orders submitted by you and any feedback you may have given us in the past. It may also include your communication preferences.
We do not collect any Special Categories of Personal Data (i.e. details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data). Nor do we collect any information about criminal convictions and offences.
IF YOU FAIL TO PROVIDE PERSONAL 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, or provide incomplete or inaccurate data, we may not be able to perform the contract we have, or are trying to enter into, with you. In this case, we may have to cancel the applicable arrangement, but we will notify you if this is the case at the time.
- HOW WE COLLECT YOUR PERSONAL DATA
We use different methods to collect data from and about you as set out in this section:
Direct interactions. You may give us Identity, Contact, Finance and Engagement Data by filling in and submitting forms online, engaging with us to provide or receive products or services, or otherwise corresponding with us. This includes personal data provided when you:
o create an account on our website;
o buy products from us via our website or via the website of a third party (e.g. Amazon or eBay);
o otherwise engage us to supply products and/or services to you (either in person, via our website (or that of a third party), or over email/the telephone);
o enquire about our products and/or services (either in person, via the website or over email/the telephone);
o give us information or documentation related to the provision of products or services by us or to us, such as supplier account forms, credit account application forms, pre-qualification questionnaires and other similar documents;
o give us some feedback; and
o provide products or services to us.
Third party sources. We may receive personal data about you from various third parties who are authorised to share it with us, as set out below:
o Technical and Usage Data from analytics providers (we use Google Analytics – please see sections 5 and 6 below for more information);
o Contact, Identity, Financial and Engagement Data from providers of professional and credit checking services linked to your contract with us – please see section 5 for more information;
o Identity and Contact Data from publically available and accessible websites and other sources, such as Companies House and your website and social media pages (in particular Facebook, Instagram and Twitter);
o in the case of customer personal data only, Identity, Contact, Financial and Engagement Data from third party providers of technical, payment and delivery services – please see section 5 for more information; and
o in the case of supplier personal data only, Identity and Contact Data from third parties recommending you to us.
- HOW WE USE YOUR PERSONAL DATA
We can only use your personal data when the law allows us to – the “lawful bases”. The lawful bases are as follows:
- You have consented to such use.
- The use is necessary for the performance of a contract with you.
- The use is necessary for compliance with a legal obligation that we owe.
- The use is necessary to protect your vital interests or those of another person.
- The use is necessary for the performance of a task carried out in the public interest, or in the exercise of official authority.
- The use is necessary for the purposes of our legitimate interests or those of a third party (except where such interests are overridden by your fundamental rights and interests).
For more information on what some of these lawful bases mean, please see the Glossary in section 10. Most commonly, we will use your personal data under the lawful bases identified in 2, 3 and 6 above.
Generally, we do not rely on consent as a legal basis for processing your personal data other than in relation to sending direct marketing communications to you via email. You have the right to withdraw consent to marketing at any time by contacting us using the details given above.
PURPOSES FOR WHICH WE WILL USE YOUR PERSONAL DATA
We have set out below, in a table format, a description of the all the ways that we may want to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.
Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below.
To register you as a customer or supplier
(a) Performance of a contract
(b) Legitimate interests (to reduce the risk of non-payment of our fees and charges)
To store your contact and engagement information on our secure server
Legitimate interests (to enable us to have an accurate record of all our customer and supplier relationships for easier management)
To process and perform our contract with you. This includes managing payments, fees and charges; engaging third parties (if necessary); and collecting money owed
(a) Performance of a contract
(b) Legitimate interests (to recover debts due to us and to ensure that our business is as efficient and responsive as it can be)
To inform you, based on the preferences that you have notified to us, of services, products and promotional offers of ours, and those of third parties, that we think may be of interest to you.
(a) Legitimate interests (to develop our products and services and grow our business)
To comply with our legal obligations (for example in respect of health and safety). This includes completing health and safety risk assessments, method statements and pre-qualification questionnaires
(a) Performance of a contract
(b) Compliance with a legal obligation
(c) Legitimate interests (to ensure the health and safety of our employees and agents)
(a) Performance of a contract
(b) Compliance with a legal obligation
(c) Legitimate interests (to keep our records updated, to ensure quality control of our products and to study how customers use our products/services)
To administer and protect our business and this website. This includes website troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data
(a) Legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise)
(b) Compliance with a legal obligation
To use data analytics to improve our website, products/services, marketing, customer relationships and experiences
Legitimate interests (to define types of customers for our products and services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy)
MARKETING AND PROMOTIONS
We may use your Identity, Contact, Technical, Usage and Profile Data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which products, services and offers may be relevant for you (we call this marketing).
You may receive marketing communications from us if you have requested information from us or purchased goods or services from us in the past and have not opted out of receiving that marketing. We will get your express opt-in consent before we share your personal data with any company outside of Master Finish for marketing purposes.
You can ask us or third parties to stop sending you marketing messages at any time by contacting us. Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of your engagement of us.
CHANGE OF PURPOSE
We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us using the details given above.
If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.
Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.
- DISCLOSURES OF YOUR PERSONAL DATA
We may have to share your personal data with the parties set out below for the purposes set out in the table in section 4 above. If any of these organisations are based, or have group or affiliated companies that are based, outside of the European Economic Area, then section 6 below sets out the legal basis on which your personal data is transferred to them.
We may share personal data with our sister company Laminate Solutions Limited. This will typically be Identity and Contact Data in order to facilitate a referral of work between us. Laminate Solutions do not carry out any processing of your personal data on our behalf and will be acting as a controller in its own right.
We work with professional advisers, acting as processors or joint controllers (as necessary), to provide certain professional services to us. As part of this, we may disclose to them some of your personal data. In this category we include lawyers, bankers, accountants, auditors and insurers based in the United Kingdom.
If you apply to open a credit account with us, we will conduct checks of your credit history using a service offered by one or more of Experian plc, Equifax Limited or Callcredit Information Group Limited (part of the TransUnion Information Group). We will disclose Identity, Contact and some Finance Data to these companies in order to check your suitability for a credit account with us.
From time to time we may need to disclose personal data to HM Revenue & Customs, the Health and Safety Executive, regulators and other public authorities acting as processors or joint controllers (as necessary) based in the United Kingdom who require reporting of processing activities in certain circumstances.
We may have to pass some limited supplier personal data (typically Identity and Contact Data) to accreditation and pre-qualification organisations in order to secure and maintain our authorisations, accreditations and certifications.
For customer personal data, we use an online payment system developed and provided by Worldpay, Inc., a company incorporated in the United States. We do not store any debit or credit card details on our systems. This system allows for you to use a PayPal account to pay for products or services, but again we do not collect or hold this data ourselves.
Also for customer personal data, we may sell our products via online marketplaces such as Amazon and eBay, which are both ultimately owned by companies based in the United States (Amazon.com, Inc. and eBay, Inc. respectively), or engage with our own suppliers to deliver your order to you themselves. When receiving, processing and/or delivering orders, it may be necessary to disclose Identity, Contact and Engagement Data.
We work with certain other service providers, acting as processors, to help us operate and manage our business. This includes providers of IT, software and archiving services (such as our website developers, accounting software and IT consultants) and courier services (currently provided by UK Mail Limited (part of the Deutsche Post DHL Group of companies) and Hermes Parcelnet Limited).
Google, Inc, which is a company incorporated and registered in the USA. We use analytics services provided by Google in the management of the website.
We recommend that for the named third parties set out above, you visit their respective websites and read their privacy policies, which will set out in more detail these organisations’ own approach to the protection of your personal data and privacy.
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. All disclosures are subject to confidentiality and non-disclosure obligations, whether arising under contract, law or professional conduct rules.
- INTERNATIONAL TRANSFERS
Some of the third parties identified in section 5 above are based outside the European Economic Area (EEA), or have group or affiliated companies based outside of the EEA, so their processing of your personal data may involve a transfer of data outside the EEA.
Whenever we transfer your personal data out of the EEA, we ensure a similar degree of protection afforded to it by ensuring that at least one of the following safeguards is implemented:
We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data by the European Commission. For further details, see European Commission: Adequacy of the protection of personal data in non-EU countries.
Where we use certain service providers, we may use specific contracts approved by the European Commission which give personal data the same protection it has in the EEA. For further details, see European Commission: Model contracts for the transfer of personal data to third countries.
Where we use providers based in the US, we may transfer data to them if they are part of the EU-US Privacy Shield framework, which requires them to provide similar protection to personal data shared between Europe and the US. For further details, see European Commission: EU-US Privacy Shield. Google, Amazon, Worldpay, Facebook (which includes Instagram) and Twitter are all part of the EU-US Privacy Shield.
eBay is not a member of the EU-US Privacy Shield framework, but does use a set of approved Binding Corporate Rules within its group of companies that ensure the protection of data transferred within the group. For further details, see European Commission: Binding Corporate Rules.
Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the EEA.
- DATA SECURITY
We have put in place appropriate technical and security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed, including using firewalls, password protection and the use of encryption software where appropriate. All our data is held on an encrypted, cloud-based server. Access to this server is password protected and only a limited number of authorised people are given access to it, and even then only for a specific business requirement and only to the data that they need to see for that purpose. In the case of third parties, they will only process your personal data on our written 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 the breach promptly where we are legally required to do so.
- DATA RETENTION
HOW LONG WILL YOU USE MY PERSONAL DATA FOR?
We will only retain your personal data for as long as necessary to fulfil the purposes for which we originally collected it, including for the purposes of satisfying any legal, accounting, or reporting requirements.
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 requirements.
By law we have to keep certain categories of information for a certain minimum period of time. This includes:
Basic information about our customers and suppliers (including Contact, Identity and Engagement Data and some Finance Data) for 6 years after they cease being customers or suppliers;
VAT and other tax records for 7 years after the applicable return was filed with HMRC; and
Certain health and safety information for up to 40 years.
After the relevant retention period has expired we will securely delete or destroy your personal data and ensure that any third parties to whom we may have disclosed your personal data does so too.
In some circumstances you can ask us to delete your data before the retention period has expired – the Right to Erasure. Please see section 9 below for more information.
- YOUR LEGAL RIGHTS
Under certain circumstances, you have rights under data protection laws in relation to your personal data. These rights are to:
Request access to your personal data;
Request correction of your personal data;
Request erasure of your personal data;
Object to processing of your personal data;
Request restriction of processing of your personal data;
Request transfer of your personal data;
Right to withdraw consent.
If you wish to exercise any of the rights set out above, please contact us using the contact details given above.
NO FEE USUALLY REQUIRED
You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.
WHAT WE MAY NEED FROM YOU
We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.
TIME LIMIT TO RESPOND
We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.
You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO, so please contact us in the first instance
Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give you the best service/product and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess out legitimate interests against any potential impact on you in respect of specific activities by contacting us using the details given above.
Performance of a Contract means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.
Comply with a legal or regulatory obligation means processing your personal data where it is necessary for compliance with a legal or regulatory obligations to which we are subject.
YOUR LEGAL RIGHTS
You have the right to:
Request access to your personal data (commonly known as a “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 that may be incomplete or inaccurate. Please note that 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: (a) if you want us to establish the data’s accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) 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; or (d) 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, 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.