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BACKGROUND:

Brooktherm Refrigeration Limited understands that your privacy is important to you and that you care about how your personal data is used and shared online. We respect and value the privacy of everyone who visits this website, http://brooktherm.co.uk (“Our Site”) and will only collect and use personal data in ways that are described here, and in a manner that is consistent with Our obligations and your rights under the law.

Please read this Privacy Policy carefully and ensure that you understand it. Your acceptance of Our Privacy Policy is deemed to occur upon your first use of Our Site. If you do not accept and agree with this Privacy Policy, you must stop using Our Site immediately.

 

  1. Definitions and Interpretation

In this Policy the following terms shall have the following meanings:

“Account” means an account required to access and/or use certain areas and features of Our Site;
“Cookie” means a small text file placed on your computer or device by Our Site when you visit certain parts of Our Site and/or when you use certain features of Our Site. Details of the Cookies used by Our Site are set out in section 12, below;
“Cookie Law” means the relevant parts of the Privacy and Electronic Communications (EC Directive) Regulations 2003;
“Personal Data” means any and all data that relates to an identifiable person who can be directly or indirectly identified from that data. In this case, it means personal data that you give to Us via Our Site. This definition shall, where applicable, incorporate the definitions provided in the Data Protection Act 2018 (“DPA”) and EU Regulation 2016/679 – the General Data Protection Regulation (“GDPR”); and
“We/Us/Our” means Brooktherm Refrigeration Limited, a limited company registered in England under company number 02422487, whose registered address is 3 Kelvin Park, Birkenhead, Wirral CH41 1LT, and whose main trading address is 3 Kelvin Park, Birkenhead, Wirral CH41 1LT.

 

  1. Information About Us 
    • Our Site is owned and operated by Brooktherm Refrigeration Limited, a limited company registered in England under company number 02422487, whose registered address is 3 Kelvin Park, Birkenhead, Wirral CH41 1LT, and whose main trading address is 3 Kelvin Park, Birkenhead, Wirral CH41 1LT.
    • Our VAT number is 539 4956 93.
    • Brooktherm Refrigeration Limited is the controller and responsible for your personal data (collectively referred to as “we”, “us” or “our” in this Privacy Policy).
    • We have appointed a Data Protection Officer (DPO) who is responsible for overseeing questions in relation to this Privacy Policy. Our DPO is Jessica Charlesworth who can be contacted by email at info@brooktherm.co.uk, by telephone on our main telephone number +44 (0)151 650 1070, or by post at 3 Kelvin Park, Birkenhead, Wirral CH41 1LT.
  1. What Does This Policy Cover?

This Privacy Policy applies only to your use of Our Site. Our Site may contain links to other websites. Please note that We have no control over how your data is collected, stored, or used by other websites and We advise you to check the privacy policies of any such websites before providing any data to them.

 

  1. Your Rights 

As a data subject, you have the following rights under the GDPR, which this Policy and Our use of personal data have been designed to uphold: 

    • The right to be informed about Our collection and use of personal data;
    • The right to request access to the personal data We hold about you;
    • The right to request correction if any personal data We hold about you is inaccurate or incomplete (please contact Us using the details set out below);
    • The right to be forgotten – i.e. the right to ask Us to delete any personal data We hold about you where there is no good reason for us continuing to process it (We only hold your personal data for a limited time, as explained in this policy but if you would like Us to delete it sooner, please contact Us using the details set out below);
    • The right to restrict (i.e. prevent) the processing of your personal data;
    • The right to request the transfer of your personal data to you or to a third party. Note that this 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;
    • The right to object to Us processing your personal data where we are relying on a legitimate interest (or those of a third party) for particular purposes; and
    • The right to withdraw consent at any time where we are relying on consent to process your personal data.
    • Rights with respect to automated decision making and profiling.

If you have any cause for complaint about Our use of your personal data, please contact Us using the details provided below 14 and We will do Our best to solve the problem for you. If We are unable to help, you also have the right at any time to lodge a complaint with the UK’s supervisory authority, the Information Commissioner’s Office (ICO) (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

For further information about your rights, please contact the ICO or your local Citizens Advice Bureau.

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 in clearly unfounded, repetitive or excessive. Alternatively, we could 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 could 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.

What Data Do We Collect?

Depending upon your use of Our Site, We may collect, use, store and transfer different kinds of  Personal Data and non-personal data (please also see section 12 on Our use of Cookies and similar technologies and Our Cookie Policy) which we have grouped together as follows:

  • Identity Data includes first name, maiden name, last name, username or similar identifier, marital status, title, date of birth and gender.
  • Contact Data includes business/company name, job title, profession, billing address, delivery address, email address and telephone numbers.
  • Technical Data includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, other technology on the devices you use to access Our Site and a list of URLs starting with a referring site, your activity on Our Site, and the site you exit to.
  • Profile Data includes your username and password, purchases or orders made by you, your interests, preferences, feedback and survey responses.  
  • Usage Data includes information about how you use Our Site, products and services. 
  • Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.
  • Aggregated Data such as statistical or demographic information such as post code, preferences, and interests;

We do not collect any Special Categories of Personal Data about you (this includes 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.

  1. How is your personal data collected?

We use different methods to collect data from and about you, including through:

    • Direct interactions. You may give us your Identity and Contact Data by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:
      • apply for our products or services;
      • create an Account on Our Site;
      • subscribe to our service or publications; 
      • request marketing to be sent to you;
      • enter a competition, promotion or survey; or
      • give us feedback or contact us. 
    • Automated technologies or interactions. As you interact with our website, we will automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies, server logs and other similar technologies. We may also receive Technical Data about you if you visit other websites employing our cookies. Please see our cookie policy for further details.
    • Third parties or publicly available sources. We will receive personal data about you from various third parties and public sources as set out below: 
      • Technical Data from the following parties:
        1. analytics providers; 
        2. advertising networks; and
        3. search information providers.
      • Identity and Contact Data from data brokers or aggregators.
      • Identity and Contact Data from publicly available sources such as Companies House and the Electoral Register based inside the EU.
  1. How Do We Use Your Data? 
    • All personal data is processed and stored securely, for no longer than is necessary in light of the reason(s) for which it was first collected. We will comply with Our obligations and safeguard your rights under the DPA and GDPR at all times.
    • We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:
    • where it is necessary for Our performance of a contract we are about to enter into or have entered into with you;
    • where you have consented to Our use of your personal data (e.g. by subscribing to emails); or 
    • Where it is necessary for Our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests; or
    • Where we need to comply with a legal obligation. 

We set out below details of the types of lawful basis that we will rely on to process your personal data.

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 our legitimate interests against any potential impact on you in respect of specific activities by contacting us.

Performance of 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 obligation means processing your personal data where it is necessary for compliance with a legal obligation that we are subject to.

Generally, we do not rely on consent as a legal basis for processing your personal data although we will get your consent before sending third party direct marketing communications to you via email or text message. You have the right to withdraw consent to marketing at any time by contacting us.

  1. Purposes for which we will use your personal data

We have set out below a description of all of the ways we plan 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. 

Purpose/activity Type of data Lawful basis for processing including basis of legitimate interest
To register your Account (a) Identity

(b) Contact

(a) Performance of a contract with you

(b) Necessary for our legitimate interests (to keep our records updated and accurate)

To manage our relationship with you which will include:

(a) notifying you of changes to our terms or privacy policy

(b) manage your Account

(c) manage your access to Our Site

(d) communicate with you

(a) Identity

(b) Contact

(c) Profile

(d) Marketing and Communications

(a) performance of a contract with you

(b) necessary to comply with legal obligations

(c) Necessary for our legitimate interests (to keep our records updated)

To administer and protect our business and our Website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data). (a) Identity

(b) Contact

(c) Technical

(a) Necessary for our 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) Necessary to comply with a legal obligation

To personalise and deliver relevant website content to you and measure or understand the effectiveness of Our Site (a) Identity

(b) Contact

(c) Profile

(d) Usage

(e) Marketing and Communications 

(f) Technical

Necessary for our legitimate interests (to study how customers use our Site, products/services, to develop them, to grow our business and to inform our marketing strategy)
To personalise and tailor our services for you (including to make suggestions and recommendations to you about good or services that may be of interest to you) (a) Identity

(b) Contact

(c) Technical

(d) Usage

(e) Profile

(f) Marketing and Communications

(a) performance of a contract with you

(b) Necessary for our legitimate interests (to study how customers use our Site, products/services, to develop them, to grow our business and to inform our marketing strategy)

To supply our services to you (a) Identity

(b) Contact

(c) Profile

Performance of a contract with you
To contact you with marketing communications  (a) Identity

(b) Contact

(c) Profile

(d) Usage

(e) Marketing and Communications

(f) Technical

Necessary for our legitimate interests
To use data analytics to improve Our Site, products/services, marketing, customer relationships and experiences (a) Technical

(b) Usage

Necessary for our legitimate interests (to keep Our Site updated and relevant, to develop our business and inform our marketing strategy). 

 

Marketing 

Promotional offers from us – You will receive marketing communications from us if you have requested information from us or purchased goods or services from us and you have not opted out of receiving that marketing. 

Third party marketing – We will get your express opt-in consent before we share your personal data with any third party for marketing purposes. 

Opting out – you may unsubscribe or opt-out of marketing messages at any time by contacting us at any time (including by email to info@brooktherm.co.uk with a request to be removed from our mailing list).

  1. How and Where Do We Store Your Data? 
    • We only keep your personal data for as long as We reasonably need to in order to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. 
    • In some circumstances you can ask us to delete your data.
    • Data security is very important to Us, and to protect your data We have taken appropriate security measures to safeguard and secure data collected through Our Site.
    • 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.

 

  1. Do We Share Your Data? 
    • We may share your personal data with the parties set out below for the purposes set out in the table above (Purposes for which we will use your personal data):
Third Parties
Internal – Other companies within Our group
External – service providers who provide IT and system administration services
Professional advisers – including lawyers, bankers, auditors and insurers 
HM Revenue & Customs, regulators and other authorities based in the United Kingdom 
Parties to whom we may choose to sell, transfer or merge parts of our business or assets.
    • In certain circumstances, We may be legally required to share certain data held by Us, which may include your personal data, for example, where We are involved in legal proceedings, where We are complying with legal obligations, a court order, or a governmental authority.
    • 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. 
    • We do not transfer your personal data outside the European Economic Area.
  1. How Can You Control Your Data? 
    • In addition to your rights under the GDPR, set out above, when you submit personal data via Our Site, you may be given options to restrict Our use of your data. In particular, We aim to give you strong controls on Our use of your data for direct marketing purposes (including the ability to opt-out of receiving emails from Us which you may do by unsubscribing using the links provided in Our emails and at the point of providing your details).
    • You may also wish to sign up to one or more of the preference services operating in the UK: The Telephone Preference Service (“the TPS”), the Corporate Telephone Preference Service (“the CTPS”), and the Mailing Preference Service (“the MPS”). These may help to prevent you receiving unsolicited marketing. Please note, however, that these services will not prevent you from receiving marketing communications that you have consented to receiving.
  1. Your Right to Withhold Information 
    • You may access certain areas of Our Site without providing any data at all. However, to use all features and functions available on Our Site you may be required to submit or allow for the collection of certain data.
    • You may restrict Our use of Cookies. For more information, see section 12 and Our Cookie Policy.
  1. Our Use of Cookies

Our Site may place and access certain Cookies on your computer or device. We use Cookies to facilitate and improve your experience of Our Site and to provide and improve Our services. For more details, please refer to Our Cookie Policy.

  1. Contacting Us

If you have any questions about Our Site or this Privacy Policy, please contact Us by email at info@brooktherm.co.uk, by telephone on our main telephone number +44 (0)151 650 1070 or by post at Brooktherm Refrigeration Limited, 3 Kelvin Park, Birkenhead, Wirral CH41 1LT. Please ensure that your query is clear, particularly if it is a request for information about the data We hold about you.

  1. Changes to Our Privacy Policy

We may change this Privacy Policy from time to time (for example, if the law changes). Any changes will be immediately posted on Our Site and you will be deemed to have accepted the terms of the Privacy Policy on your first use of Our Site following the alterations. We recommend that you check this page regularly to keep up-to-date.