PORTKABIN LIMITED & SUBSIDIARIES

CUSTOMER PRIVACY NOTICE

  • The Purpose of this Document
    • We take your privacy seriously. This notice details your privacy rights and how we gather, use and share personal data about you during and after your relationship with us, in accordance with data protection legislation (including the General Data Protection Regulation (EU) 2016/679 and its implementation into local law).
    • It is important that you read this notice, together with any other privacy notice we may provide on specific occasions when we are collecting or processing personal data about you, so that you are aware of how and why we are using such information. We will update this notice if we make any significant changes affecting how we use your personal data, and if so we will contact you to let you know about the change.
  • About us
    • We are what is known as the 'controller' of personal data we gather and use.
    • When we say 'we' or 'us' in this notice, we mean Portakabin Limited, Portakabin (Scotland) Limited, Portakabin (Site Accommodation) Limited and Portakabin (Refurbished) Limited.
    • This notice does not form part of your contract and it may be amended by us at any time.
  • Your Privacy Rights
    • You have various rights in respect of the personal data we hold about you – these are set out in more detail below. If you wish to exercise any of these rights, please contact us using the following email address: datacontroller@portakabin.com
    • Right to object: You can object to our 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. Please contact us as noted above, providing details of your objection.
    • Access to your personal data: You can request access to a copy of your personal data that we hold, along with information on what personal data we use, why we use it, who we share it with, how long we keep it for and whether it has been used for any automated decision making. You can make a request for access free of charge. Please make all requests for access in writing, and provide us with evidence of your identity.

Consent: Most of the time, we won't need your consent to use your personal data as we will be using it only to fulfil our obligations and exercise our rights as a supplier. If you have given us your consent to use personal data, you can withdraw your consent at any time.

  • Rectification: You can ask us to change or complete any inaccurate or incomplete personal data held about you.
  • Erasure: You can ask us to delete your personal data where it is no longer necessary for us to use it, you have withdrawn consent, or where we have no lawful basis for keeping it.
  • Portability: You can ask us to provide you or a third party with some of the personal data that we hold about you in a structured, commonly used, electronic form, so it can be easily transferred.
  • Restriction: You can ask us to restrict the personal data we use about you where you have asked for it to be erased or where you have objected to our use of it.
  • No automated-decision making: Automated decision-making takes place when an electronic system uses personal data to make a decision without human intervention. You have the right not to be subject to automated decisions that will create legal effects or have a similar significant impact on you, unless you have given us your consent, it is necessary for a contract between you and us or is otherwise permitted by law.  You also have certain rights to challenge decisions made about you based solely on automated-decision making. Please note that decisions in respect to you as our customers are not based solely on automated decision-making. We will inform you if this changes and will let you know what categories of data are subject to automated decision-making. Please note that you're interaction with us in other ways may include automated decision-making and if that is the case will be as set out in the relevant policy notice governing that relationship.
  • What Kinds of Personal Data we Use
    • In the course of our relationship with you, we will collect, store, and use the following categories of personal data about you:
  • your name, work address and work contact details, including email address and telephone number, and job title;
  • your function (e.g. job title, position and name of company);
  • information about you in relation to your project (if you choose to provide it);
  • for customers who are individuals / natural persons, your financial information (i.e. bank account details). Please note that we do not collect any information in relation to your payment information, such as credit / debit card details.
  • How We Gather your Personal Data
    • We will obtain your personal data in different ways:
  • directly from you, for example when you contact us by letter, email or telephone and provide your contact details;
  • from monitoring emails, internet and telephone usage and when we use CCTV in line with our IT and Security policy. For further information about our IT and Security policy, please contact us at datacontroller@portakabin.com.
  • when you contact us with queries, complaints, comments or praise, or information that you post about yourself on public areas of various social media platforms ("Voluntary Data").
    • From time to time, we may also collect some data about you from third parties ("Third Party Data"). This includes:
  • other companies who have obtained your permission to share data with us, such as advertisers or other companies you have bought associated products or services from;
  • research panels who carry out market research for us, which may involve collecting personal data in order to conduct the research. This data collection will be subject to the privacy policies of the research panels. The information that is provided to us by the research panels is usually provided on an anonymous basis. We use the data from this research to: 
    • inform the evaluation of our performance and to develop our products and services including advertising;
    • inform our marketing and promotional activities;
  • reputable third-party data providers, such as Mint UK (Bureau Van Dijk), who we have vetted. The data we obtain from these providers has been collected by them through publicly available records such as the electoral roll, or, with your consent, from surveys or other brands and companies that you engage with. Where these third-parties hold such information, it may include data such as: 
    • name;
    • job title;
    • company name and address;
    • location;
    • email address;
    • telephone numbers.
    • We may also collect information about you as follows:
  • information in relation to customers registered on our system collected directly as a result of our relationship with you (e.g. information such as your phone number and email address, collected through conversations and interactions with you) and through our use of third party analytics software. This software collects information relating to your website and page visits, email opens and click-through information to our website;
  • information collected based on your use of our website as described in our Website Privacy Policy, available here portakabin.com/privacy-policy; and
  • publicly available information about you collected from social networking sites such as Twitter, LinkedIn and Facebook. This information is not collected on an individual basis so we cannot see who has posted the information. From time to time we may be able to identify individuals however this will only be for our internal analysis purposes only and we would never use this information to contact you directly.

 

 

  • How We Use your Personal Data
    • To summarise, we process your personal data for the following key purposes:
  • primarily, in order to take the necessary steps in preparation of, or to fulfil our obligations under a booking contract to:
    • fulfil orders placed by you;
    • process any other transactions authorised by you
  • in order to take the necessary steps in preparation of, or to fulfil our obligations under a competition in which you have entered, for example contacting you to let you know you have won a prize and using your address to send your prize to you. This data is only used for the purposes of the relevant competition and will be subject to the terms and conditions of that competition, which will be notified to you when you enter the competition.
    • Where you are an individual customer, we will use your personal data with your consent to:
  • inform you of special offers;
  • provide marketing information to you which we think you may find of interest;
    • We may use your personal data in our legitimate interest* to:
  • undertake a product or customer research/development (by email, phone, fax or mail). We use the personal data to review your response to our surveys for the purposes of analysing insights and information to enable us to improve our products and services (including customising our website according to your interests);
  • where you are a business:
    • to inform you of special offers;
    • to provide marketing information to you which we think you may find of interest;
  • respond to a comment or question submitted to us via the Contact Us page on our website;
  • build up a picture of you and the types of products and services which might be of interest to you ("your Profile"). We use your personal data in combination with information collected about your from your engagement with our website (please see our Website Privacy Policy, here portakabin.com/privacy-policy, for more details on this). We may use profiling to create your Profile in order to provide you with a more customised and tailored experience on our website and to inform the advertising/information that is displayed to you;
  • archive data that may be of historical or statistical value. This data may then be used at a future time for internal purposes or third parties may be allowed access to this data for research purposes ("Historical Data"). This may include any of the Voluntary Data that you have provided. We will only ever capture personal data that has already been made publicly available on our website in this way and for these purposes. Where possible, when copies the website are archived we anonymise or remove personal data. From time to time the data that we keep in our archive is reviewed and any data that is no longer considered of interest will be deleted or anonymised in line with our record retention policy. For further information about our retention policy, please contact us at datacontroller@portakabin.com.

*any reliance on a legitimate interest shall not prejudice your interest or fundamental rights and freedoms.

 

  • How we use anonymised data
    • We use aggregated and anonymised data for certain purposes, such as to help us understand what type of content users like and to share with advertisers so that they know how effective their advertising is. When used for these purposes, this data does not enable you or any other individual user to be identified.
    • More detail about how we use your personal data, as well as the categories of personal data involved, is set out in the Appendix.
  • Monitoring
    • It is necessary for us monitor visitors to our business premises (including our customers) in order to ensure safety and security. We monitor visitors in the following ways:
      • Visitors may be captured by CCTV systems which we use for security purposes (in accordance with our IT and security policy;
    • In addition, we may request / and or be provided with CCTV footage obtained by customers or suppliers which captures images of you at a customer or supplier premises. We will not request such footage unless it is necessary for security purposes.
    • We only carry these activities to the extent it is necessary and proportionate and it is permitted by law (please see the Appendix for more information).
    • If you have any concerns in relation to monitoring, please contact datacontroller@portakabin.com.
  • Marketing
    • Email and postal marketing:
  • Where you are an individual customer and have specifically signed up to receive email marketing from us, where you have not informed us that you do not want to receive postal marketing from us (or not on a preference services list) or where you are a business and have not informed us that you do not want to receive marketing from us, we will use your email or postal address (as appropriate) to send you information such as newsletters, information about products and services, industry news and competitions as well as any other relevant information which we believe you may find interesting and / or will improve our offering to you. You can opt out of receiving this marketing at any time by either following the instructions to unsubscribe in any of our email or postal marketing communications or by sending an e-mail to webmaster@portakabin.com.
  • It may take up to 30 days for your change in preference for marketing to take effect as the request may not be processed in time to affect any marketing campaigns already been scheduled to be sent in the future. Please let us know the channels of marketing from which you wish to unsubscribe as we may consider that you wish to continue to receive postal marketing if you only unsubscribe from email marketing. Please also note that if you opt out of marketing, we may still need to send you service communications by email occasionally, such as information about changes to our services.

 

 

  • Use of other platforms to promote our products and services:
  • Our content might appear on third party sites based solely on your behaviours on these sites (for example, after liking our brand or its content on LinkedIn, or having been to our sites and then seeing our display advertising on other website platforms), or the behaviours of those within your networks (for example, a contact within your LinkedIn network likes our brand or its content on LinkedIn, so it appears in your News Feed). These branded messages are controlled by the third-party site, but you may be able to update your preferences within the third-party platform to stop these messages appearing in future.
  • Customer enquiries
    • When contacted with an enquiry, Portakabin Limited will hold the entity name and contact details only for the purposes of handling the enquiry.
    • Calls made to us may be recorded to protect the interests of all parties. Call records are deleted after 28 days unless needed for on-going actions.
  • Our Legal Basis for Using your Personal Data
    • We only use your personal data where it is permitted by the laws that protect your privacy rights. To find out more about the legal bases we rely on to use your personal data, please see the Appendix.
    • We do not need your consent to use your personal data where the law otherwise allows us to use it. In limited circumstances, we may approach you for your consent to allow us to process certain personal data.  If we do so, we will provide you with full details of the information that we would like and the reason we need it, so that you can consider whether you with to consent.  You may withdraw your consent at any time.
  • Sharing your Personal Data With Others
    • We will share your personal data with third parties where required by law, or where it is necessary to administer the working relationship with you or where we have a legitimate interest. We will only share your personal data to the extent needed for those purposes.
    • We share personal data for these purposes with:
  • third-party service providers (including analytics companies and cloud providers, as detailed in our Website Privacy Policy, available here at datacontroller@portakabin.com, who help us to manage our customer database and enquiry forms process; 
  • other service providers such as information security service providers who help us to manage our IT systems and ensure that they are secure; and
  • third-party marketing and advertising agencies to ensure our marketing and advertising is delivered effectively in accordance with this Customer Privacy Notice.

 

 

  • We will also share your personal data with the following categories of recipients for the following purposes: 
  • external third-party platforms to enable us to send you recommendations for our content and services through those platforms, as described in the "Use of other platforms to promote our products and services" section at paragraph 8 of this Customer Privacy Notice above; and
  • third-party media agencies, in which case data will be shared in a pseudonymised form as described in the "How we use your personal data" section of this Customer Privacy Policy at paragraph 6 above.
    • We will also share your personal data with third parties in the following circumstances: 
  • where you have specifically consented to us sharing your data with a particular third party;
  • where we are required or permitted to do so by law or to protect or enforce our rights or the rights of any third party.
    • We may also share your personal data with our Group Companies, when you are registered as a customer on our system, to allow us to fulfil our contract with you and for internal business purposes (such as business improvement and customer service).
  • If you share content from www.portakabin.com on social media, via the social media share buttons on our site, the relevant social media platform will know what page you are on in order to share that content. The use of that information will be governed by the social media platform's own privacy policy and clicking the "share" buttons does not result in any other personal data being shared between Portakabin and the platform.
  • Data Retention

We will hold your personal data for as long as necessary to fulfil the purpose for which it was collected or to comply with legal and regulatory requirements.

For further information in relation to specific retention periods. Please contact datacontroller@portakabin.com

  • Transfers Outside the UK
    • We may need to transfer your personal data to organisations in countries where data protection legislation may not provide the same level of protection as those in the United Kingdom (for example where suppliers we use are based outside the UK). (This includes the European Economic Area (“EEA”).)
    • We will only transfer your personal data outside of the United Kingdom and the EEA where:
      • the transfer is to a country which the UK Government has decided ensures an adequate level of protection for your personal data, or
      • we have put in place our own measures to ensure adequate security as required by data protection law; or
      • you have consented to the transfer; or
      • the transfer is necessary for one of the reasons set out in Data Protection Legislation, including the performance of a contract between us, or to protect your vital interests; or
      • the transfer is legally required on important public interest grounds or for the establishment, exercise or defence of legal claims.
    • Right to Complain

You can make a complaint to us by contacting us via datacontroller@portakabin.com or to the data protection supervisory authority – in the UK, this is the Information Commissioner's Office, at https://ico.org.uk/.

  • How can you contact us?

If you have any queries about this Privacy Policy and/or our processing of your data, or you would like to exercise any of the above rights, you can get in touch with our Data Protection Officer by emailing datacontroller@portakabin.com

  • Keeping You Up to Date

We reserve the right to change this notice at any time. The latest version of this notice will be available on our website, but where we make any substantial changes which affect your rights, we will notify of these changes via email.

APPENDIX

 

 

 

Purpose for Processing

 

Categories of Personal Data

 

Legal Basis

 

1.     

To fulfil orders placed by you and to process any other transactions authorised by you

Your name, work address and work contact details, including email address and telephone number, and job title

In order to take the necessary steps in preparation of, or to fulfil our obligations under a booking contract and to exercise our legal rights

 

2.     

To fulfil our obligations under any competition  you have entered into

You name, address and contact details, including email address and telephone number

In order to take the necessary steps in preparation of, or to fulfil our obligations under the terms and conditions of the competition which you have entered,

3.     

To inform you of special offers and to provide marketing information to you which we think you may find of interest

Your name, work address and work contact details, including email address and telephone number, and job title

 

With your consent

4.     

To undertake product or customer research and development

Your name, work address and work contact details, including email address and telephone number, and job title

 

In our legitimate interest to improve our services