PRIVACY POLICY - C4 CARBIDES LIMITED

Introduction

Welcome to the privacy policy of C4 Carbides Limited ('C4 Carbides').

C4 Carbides respects your privacy and is committed to protecting your personal data. This privacy policy will inform you as to how we look after your personal data whether you are: (a) a customer of C4 Carbides, (b) a supplier of C4 Carbides, or (c) visitor to C4 Carbides' website at https://www.c4carbides.com ('website') (regardless of where you visit it from). This policy tells you about your privacy rights and how the law protects you.

This privacy policy is provided in a layered format so you can click through to the specific areas set out below.

Sections 1-9 of this privacy policy apply to all of our data processing activities.

Sections 10-12 provide further information about our data processing activities depending on the nature of your relationship with us, so please also read the section that applies to you.

  1. IMPORTANT INFORMATION AND WHO WE ARE
  2. THE DATA WE COLLECT ABOUT YOU
  3. HOW IS YOUR PERSONAL DATA COLLECTED?
  4. HOW WE USE YOUR PERSONAL DATA
  5. DISCLOSURES OF YOUR PERSONAL DATA
  6. INTERNATIONAL TRANSFERS
  7. DATA SECURITY
  8. DATA RETENTION
  9. YOUR LEGAL RIGHTS
  10. OUR CUSTOMERS
  11. OUR SUPPLIERS
  12. VISITORS TO OUR WEBSITE

1. IMPORTANT INFORMATION AND WHO WE ARE

Purpose of this privacy policy

This privacy policy aims to give you information on how C4 Carbides collects and processes your personal data through your interactions with us as a customer or supplier or through your use of our website.

This website is not intended for children and we do not knowingly collect data relating to children.

It is important that you read this privacy policy together with any other privacy policy or fair processing policy we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. This privacy policy supplements other notices and privacy policies and is not intended to override them. If you are an employee of C4 Carbides or a job applicant, please see our applicable privacy notice related to employees and job applicants.

Controller

C4 Carbides Limited is the controller and responsible for your personal data (collectively referred to as 'C4 Carbides', 'we', 'us' or 'our' in this privacy policy). If you have any questions about this privacy policy, including any requests to exercise your legal rights, please contact us using the details set out below.

We have appointed a data protection officer (DPO) who is responsible for overseeing questions in relation to this privacy policy. If you have any questions about this privacy policy, including any requests to exercise your legal rights, please contact the DPO using the details set out below.

Contact details

If you have any questions about this privacy policy or our privacy practices, please contact us in the following ways:

Full name of legal entity: C4 Carbides Limited

Email address: C4@c4carbides.com

Postal address: International House, Willie Snaith Road, Newmarket, England, CB8 7GG

Telephone number: +44 (0) 1223 225 400

Please contact our DPO in the following way:

Email address: data.protection@c4carbides.com

Telephone number: +44 (0) 1223 225 445

You have the right to make a complaint at any time to the Information Commissioner's Office (ICO), the UK regulator 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.

Changes to the privacy policy and your duty to inform us of changes

We keep our privacy policy under regular review. This version was last updated on 4 November 2021.

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.

Third-party links

This website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow 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, we encourage you to read the privacy policy of every website you visit.

2. THE DATA WE COLLECT ABOUT YOU

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 includes first name and last name, and company name.
  • Contact Data includes billing address, delivery address, company address, email address and telephone numbers.
  • Financial Data includes bank account details.
  • Transaction Data includes details about payments to and from you and other details of products and/or services you have purchased from us.
  • 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, and other technology on the devices you use to access this website.
  • Profile Data includes your feedback and survey responses.
  • Usage Data includes information about how you and other visitors use our website including performing analytics such as trends, sales intelligence, marketing effectiveness (such as click and open rates), uptake and progress.
  • Marketing and Communications Data includes your preferences in receiving marketing from us and your communication preferences (for example if you requested during a trade show to receive marketing from us).

Please read the relevant section under Sections 10-12 that describes your relationship with us as it will set out which categories of personal data are relevant for that particular relationship.

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.

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, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with our products and/or services).

3. 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 Data, Contact Data, Profile Data, and Financial Data and any other information you may choose to supply us by filling in our 'Contact Us' form or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:
    • purchase our products and/or services;
    • request marketing to be sent to you;
    • complete a 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 and other similar technologies. Please see our cookie policy for further details.
  • Third parties. We will receive personal data about you from various third parties as set out below:
    • Technical Data and Usage Data from analytics providers such as Google; and
    • Contact, Financial and Transaction Data from providers of technical, payment and delivery services.

Please see the relevant section under Sections 10-12 below which applies to your relationship with us in order to learn about other methods we may use to collect your personal data.

4. HOW WE USE YOUR PERSONAL DATA

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 under these lawful bases:

  • Where we need to perform the contract we are about to enter into or have entered into with you.
  • 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.
  • Where we need to comply with a legal obligation.

Generally, we do not rely on consent as a legal basis for processing your personal data although we will get your consent before sending marketing communications to you via email if you are a private individual, sole trade, or a partnership. You have the right to withdraw consent to marketing at any time by contacting us.

We describe the lawful basis/bases relied on for specific processing activities and the purposes for which we will use your personal data in the relevant section below under Sections 10-12 that applies to our relationship with you. We have also identified what our legitimate interests are where appropriate.

Marketing and Opting Out

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 and/or services and offers may be relevant for you (we call this marketing).

You will receive marketing communications (which includes communications regarding new or improved products and product demonstration videos) from us if you have requested information from us or bought our products or engaged our services and you have not opted out of receiving that marketing.

You can specify your contact preferences [when registering online to receive communications from us or] by [subsequently] advising us of your contact preferences.

You can ask us to stop sending you marketing messages at any time by responding to the relevant email and requesting to opt out of receiving such messages.

Where you opt out of receiving these marketing messages, such marketing messages will no longer be sent but this will not apply to personal data provided to us as a result of your product/service purchase.

Cookies

You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of this website may become inaccessible or not function properly. For more information about the cookies we use, please see our cookie policy.

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.

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.

5. DISCLOSURES OF YOUR PERSONAL DATA

We may share your personal data with the third parties as set below for the purposes set out in the relevant section that applies to our relationship with you.

We may also share your personal data specific to a particular processing activity with additional parties, in which case such information will be set out in the relevant section under Sections 10-12 that applies to our relationship with you.

EXTERNAL THIRD PARTIES

  • Service providers who provide services in: IT and system administration.
  • Professional advisers including lawyers, bankers, accountants, auditors and insurers who provide legal, banking, accounting and insurance services.
  • HM Revenue & Customs, regulators and government and other public authorities who require reporting of processing activities in certain circumstances under applicable law or regulation.
  • Third parties to whom we may choose to sell, transfer or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy policy.

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.

6. INTERNATIONAL TRANSFERS

We do not transfer your personal data outside the UK.

7. DATA SECURITY

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. In addition, 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.

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.

8. DATA RETENTION

How long will you use my personal data for?

We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.

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, regulatory, tax, accounting or other requirements.

In some circumstances we will anonymise your personal data (so that it can no longer be associated with you), in which case we may use this information indefinitely without further notice to you.

9. YOUR LEGAL RIGHTS

Under certain circumstances, you have rights under data protection laws in relation to your personal data.

You have the right to:

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.

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.

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:

  • If you want us to establish the data’s accuracy.
  • Where our use of the data is unlawful but you do not want us to erase it.
  • 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.
  • 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.

If you wish to exercise any of your legal rights, please contact us using the contact details referred to 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 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.

10. OUR CUSTOMERS

Purposes for which we will use your personal data

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. 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.

Purpose/Activity Type of data Lawful basis for processing including basis of legitimate interest
To register you as a new customer (a) Identity
(b) Contact
Performance of a contract with you
To process and deliver your order including:
(a) Raise invoices, manage payments, fees and charges
(b) Respond to queries
(c) Collect and recover money owed to us
(a) Identity
(b) Contact
(c) Financial
(d) Transaction
(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:
(a) General communication
(b) Account reviews
(c) Notifying you about changes to our terms or privacy policy
(a) Identity
(b) Contact
(c) Profile
(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 respond to queries, resolve complaints from customers, keep our records updated and to study how customers use our products and/or services)
To enable you to complete a customer satisfaction survey (a) Identity
(b) Contact
(c) Profile
(d) Marketing and Communications
(a) Performance of a contract with you (b) Necessary for our legitimate interests (to study how customers use our products and/or services, to develop / improve them, to comply with ISO9001, and grow our business)
To make suggestions and recommendations to you about products and/or services that may be of interest to you (a) Identity
(b) Contact
(c) Profile
(d) Marketing and Communications
Necessary for our legitimate interests (to develop our products and/or services and grow our business)

11. OUR SUPPLIERS

Purposes for which we will use your personal data

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. 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.

Purpose/Activity Type of data Lawful basis for processing including basis of legitimate interest
To register you as a new supplier (a) Identity
(b) Contact
Necessary for our legitimate interests (outsourcing work or to receive third party goods and/or services and manage our suppliers)
To receive goods and/or services from you including:
(a) Agree payment arrangements and manage payments, fees and charges
(b) Recover money owed to us
(a) Identity
(b) Contact
(c) Financial
(d) Transaction
(e) Marketing and Communications
Necessary for our legitimate interests (outsourcing work or to receive third party goods and/or services and manage our suppliers)
To manage our relationship with you which will include:
(a) Making queries
(b) Receiving and reviewing the provision of goods and/or services from you
(c) General communication
(d) Notifying you about changes to our terms or privacy policy
(a) Identity
(b) Contact
(c) Profile
(d) Marketing and Communications
(a) Necessary to comply with a legal obligation
(b) Necessary for our legitimate interests (to resolve a non-conformance with a supplier, to outsource work or to receive third party goods and/or services and to manage our suppliers)

12. VISITORS TO OUR WEBSITE

Purposes for which we will use your personal data

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. 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.

Purpose/Activity Type of data Lawful basis for processing including basis of legitimate interest
Responding to your queries about our products and services via our 'Contact Us' form (a) Identity
(b) Contact
(c) Profile
(d) Marketing and Communications
Necessary for our legitimate interests (to develop our website and our products and services and grow our business)
To administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data) (a) 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
To use data analytics to improve our website, products, services, marketing, contact relationships and experiences by recognising and counting the number of visitors and seeing how visitors move around our website when they are using it, sales intelligence, marketing effectiveness (such as click and open rates) uptake and progress (a) Technical
(a) Technical(b) Usage
Necessary for our legitimate interests (to study how website visitors use our products and services, to develop our website and our products and services, to grow our business and to inform our marketing strategy, to define types of customers for our products and services, to keep our website updated and relevant)