Affordablewarmthsolutions.org.uk (the “Website”) is a site owned and operated by Affordable Warmth Solutions CIC and the expressions “we” and “us” and “our” mean Affordable Warmth Solutions. Our address is Affordable Warmth Solutions, Radcliffe House, Blenheim Court, Solihull, B91 2AA.
1.1. Affordable Warmth Solutions respects your privacy and is committed to protecting your personal data. This privacy notice will inform you as to how we look after your personal data when you visit our website (regardless of where you visit it from) and tell you about your privacy rights and how the law protects you.
1.2. This privacy notice aims to explain how Affordable Warmth Solutions collects and processes your personal data through your use of this website, including any data you may provide through this website when you sign up to receive any information, request a product or service or take part in a survey.
1.3. This website is not intended for children and we do not knowingly collect data relating to children.
1.5. Affordable Warmth Solutions is the controller and responsible for your personal data (referred to as, "we", "us" or "our" in this privacy notice).
1.6. We have appointed a data privacy manager who is responsible for overseeing questions in relation to this privacy notice. If you have any questions about this privacy notice, including any requests to exercise your legal rights, please contact the data privacy manager using the details set out below.
Jeremy Nesbitt, Managing Director
Affordable Warmth Solutions CIC
2. THE INFORMATION WE COLLECT
2.1. 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).
2.2. When you visit, register or use the Website you may be asked to provide certain information about yourself including your name and contact details. We may also collect information about e-mails or letters you send to us.
2.3. We may collect, use, store and transfer different kinds of personal data about you which we have grouped together follows:
2.3.1. Identity Data includes first name, maiden name, last name, username or similar identifier, marital status, title, date of birth and gender.
2.3.2. Contact Data includes postal address, e-mail address and telephone numbers.
2.3.3. Financial Data includes bank account and payment card details.
2.3.4. Transaction Data includes details about payments to and from.
2.3.5. Technical Data includes internet protocol (IP) address, your login data, browser type and version, time zone settings and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access this website.
2.3.6. Profile Data includes your username and password, enquiries made by you, your interests, preferences, feedback and survey responses.
2.3.7. Usage Data includes information about how you use our website, and services.
2.3.8. Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.
2.4. We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data may be derived from your personal data but is not considered personal data in law as this data does not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy notice.
2.5. 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.
2.6. Where we need to collect personal data by law, or under the terms of a contract we have with you and you fail to provide that data when requested, we may not be able to perfrom the contract we have or are trying to enter into with you. In this case, we may have to cancel a product or service you have with us but we will notify you if this is the case at the time.
3. HOW DO WE USE THE DATA WE COLLECT?
We use different methods to collect data from and about you including through:
3.1. Direct interactions. You may give us your Identity, Contact and Financial Data by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:
3.1.1. create an account on our website;
3.1.2. conduct transactions with us;
3.1.3. subscribe to our service or publications;
3.1.4.request information to be sent to you;
3.1.5.participate in a survey; or
3.1.6.provide us with feedback.
3.3. Third parties or publicly available sources. We may receive personal data about you from various third parties and public sources as set out:
3.3.1.Technical Data from analytics providers or search information providers, based inside the EU.
3.3.2.Contact, Financial and Transaction Data from providers of technical, payment and delivery services.
3.3.3.Identity and Contact Data from data brokers or aggregators based inside the EU.
3.3.4.Identity and Contact Data from publicly availably sources [such as Companies House and the Electoral Register based inside the EU.
4. HOW WE USE YOUR PERSONAL DATA
4.1. 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:
4.1.1. Where we need to perform the contract we are about to enter into or have entered into with you.
4.1.2. 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.
4.1.3. Where we need to comply with a legal or regulatory obligation.
4.2. Generally we do not rely on consent as a legal basis for processing your personal data other than in relation to 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.
4.3. We have set out below, in a table format, a description of all 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.
Type of data
Lawful basis for processing including basis of legitimate interest
To register you as a new customer
Performance of a contract with you
To process and deliver your order including:
(a) Manage payments, fees and charges
(b) Collect and recover money owed to us
(e) Marketing and Communications
(a) Performance of a contract with you
(b) Necessary for our legitimate interests (to recover debts due to us)
To manage our relationship with you which will include:
(b) Asking you to leave a review or take a survey
(d) Marketing and Communications
(a) Performance of a contract with you
(b) Necessary to comply with a legal obligation
(c) Necessary for our legitimate interests (to keep our records updated and to study how customers use our products/services)
To enable you to partake in a prize draw, competition or complete a survey
(e) Marketing and Communications
(a) Performance of a contract with you
(b) Necessary for our legitimate interests (to study how customers use our products/services, to develop them and grow our business and to analyse trends and profiles)
To administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)
(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 deliver relevant website content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you
(e) Marketing and Communications
Necessary for our legitimate interests (to study how customers use our products/services, to develop them, to grow our business and to inform our marketing strategy)
To use data analytics to improve our website, products/services, marketing, customer relationships and experiences
Necessary for our 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 and to analyse trends and profiles and to carry out customer satisfaction and quality assessment checks)
To make suggestions and recommendations to you about goods or services that may be of interest to you
Necessary for our legitimate interests (to develop our products/services and grow our business and to carry out customer satisfaction and quality assessment checks)
4.4. You can ask us or third parties to stop sending you marketing messages at any time by Contacting us at any time.
4.5. 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.
4.6. 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.
4.7. 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
5. DISCLOSURE OF YOUR INFORMATION
We may need to share your personal data with the parties set out below for the purposes set out in the table in paragraph 4 above, including:
5.1. Where we are required to share personal data by law;
5.2. To relevant third parties, public bodies, industry organisations and regulators in our legitimate interest as reasonably required for the operation of our business;
5.3. With government departments and government bodies that provide funding to us and have an interest in our activities in accordance with our legitimate interests. Information is only passed to government departments and government bodies for analysis purposes.
5.4. To specific partners in our delivery of information and services to you in accordance with our legitimate interests.
5.5. In the event that we sell or buy any business or assets, in which case we may disclose your personal data to the prospective seller or buyer of such business or assets.
5.6. Where we, or substantially all of our assets, are acquired by a third party, in which case personal data held by us about our customers will be one of the transferred assets.
5.7. Where we, in accordance with our legitimate interests or pursuant to a duty of disclosure, in order to enforce or apply our Website Terms and Conditions of Use and other agreements; or to protect our rights, property or safety, those of our customers, or others.
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.
6. DATA SECURITY
6.1. We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed, and all personal data held in secure computer storage facilities and paper-based files.
6.2. We limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.
7. DATA RETENTION
7.1. We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.
7.2. 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.
8. COOKIES – WHAT ARE THEY AND HOW DO WE USE THEM?
8.2.1. simplify the logon process for registered users;
8.2.2. help ensure the security and authenticity of registered users;
8.2.3. help us recognise you as a unique visitor when you return to the Website and to allow us to tailor content to match your preferred interests; and,
8.2.4. enable traffic monitoring.
8.3. When you visit the Website you will be sent anonymous cookies to enable us to keep track of browsing patterns and to build up a demographic profile.
8.4. Whilst you do not need to allow your browser to accept cookies in order to browse much of the Website or to access many of our services, you must have cookies enabled if you wish to access any areas reserved for registered users.
10. CHANGES TO THIS NOTICE
We reserve the right to make changes to this Privacy Notice without prior notice. We will only use information in accordance with the Privacy Notice under which the information was collected. If you regularly use the Website you should continue to check this Privacy Notice for updates and amendments, as you will be deemed to have accepted the changes if you continue to use the Website after any changes have been posted.
11. YOUR LEGAL RIGHTS
You have the right to:
11.1. Request access to your personal data (commonly known as a "data subject access request"). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
11.2. Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
11.3. 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.
11.4. 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.
11.5. 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.
11.6. 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.
11.7. 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.
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 can contact us with regard to any of your legal rights via the contact information at paragraph 1,6 of this Privacy Notice.
You also have the right to make a complaint to the Information Commissioner’s Office. If you wish to know more about your rights, you can visit the Information Commissioner's Website at www.ico.org.uk
This Privacy Notice shall be governed by and construed in accordance with the laws of England and Wales whose Courts will have exclusive jurisdiction in relation to any claim or matter arising under or in connection with this Privacy Notice.