1. Important information and who we are
Purpose of this privacy notice
Lomox Limited (collectively referred to as “we”, “us” or “our” in this privacy notice) collects, uses and is responsible for the personal information about you that we receive. When we do so we are regulated under applicable data protection laws including the General Data Protection Regulation and we are responsible as ‘controller’ of that personal information for the purposes of those laws.
This privacy notice gives you information on how we collect and process your personal data, however you provide it to us.
It is important that you read this privacy notice together with any other privacy notice or fair processing notice we may provide on specific occasions when we are collecting or processing personal data about you. This privacy notice supplements the other notices and is not intended to override them.
If you have any questions about this privacy notice, including any requests to exercise your legal rights, please contact our Chief Executive Officer using the details set out below.
Email address: email@example.com
Postal address: Lomox Limited, Bank House, Market Square, Congleton, Cheshire, CW12 1ET
We also operate the website at https://www.lomox.co.uk/
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 may include (i) your first name, last name and title; (ii) your email address and telephone numbers (iii) details of products you have purchased or otherwise received from us.
We may collect, use and store bank account and payment card details in respect of our suppliers to whom we may make payments (which may constitute personal data).
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. Please also note that we do not knowingly collect data relating to children.
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 or to provide you with products you have requested, and you fail to provide that data when requested, we may not be able to perform the contract we have or to provide you with the products you have requested from us. In this case, we may have to cancel the contract in question that you have with us but we will notify you if this is the case at the time.
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 data by corresponding with us in person, or by post, phone, email or otherwise. This includes for example personal data you provide when you contract with us, or complete an enquiry form on our website.
- Third parties or publicly available sources: We may receive personal data about you from various third parties and public sources.
4. Our legal basis for processing your personal information
When we use your personal information we are required to have a legal basis for doing so. There are various different legal bases upon which we may rely, depending on what personal information we process and why.
The legal bases we may rely on include:
- consent: where you have given us clear consent for us to process your personal information for a specific purpose.
- contract: where our use of your personal information is necessary for a contract we have with you, or because you have asked us to take specific steps before entering into a contract.
- legal obligation: where our use of your personal information is necessary for us to comply with the law (not including contractual obligations).
- legitimate interests: where our use of your personal information is necessary for our legitimate interests or the legitimate interests of a third party (unless there is a good reason to protect your personal information which overrides our legitimate interests).
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.
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||Lawful basis for processing|
|To register you as a new supplier or contractor||(a) Performance of a contract with you (or as a precursor to performance of a contract)|
|To register you as a new customer (or potential new customer)||(a) Performance of a contract with you (or as a precursor to performance of a contract)|
(b) Necessary for our legitimate interests
|To process and deliver any contract you have with us||(a) Performance of a contract with you|
|To manage our relationship with you (including recovery of costs due to us)||(a) Necessary for our legitimate interests|
(b) Performance of a contract with you
|To provide you with information you have requested from us (e.g. through our website enquiry form), respond to enquiries or requests from you, and communicate with you in relation to those enquiries or requests||(a) Necessary for our legitimate interests|
|To administer and protect our business and our website||(a) Necessary for our legitimate interests|
(b) Necessary to comply with a legal obligation
|To send you marketing communications, and to make suggestions and recommendations about services/products that may be of interest to you.||(a) Necessary for our legitimate interests.|
You can ask us to stop sending you marketing messages at any time by following the opt-out links on any marketing message sent to you or by contacting us at any time.
Where you opt out of receiving these marketing messages, this will not apply to personal data that we process and use on a different lawful basis, or in respect of which you continue to consent to us processing.
We will not share your personal data with any third party for marketing purposes.
If you are a supplier to us, you will be asked to supply certain personal data to us and we will process that personal data for the purposes of the contract that you and we enter into for the supply of your products/services.
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 have to share your personal data with the parties set out below for the purposes set out in the table in paragraph 4 above.
- Service providers who provide services to us, including employment services providers.
- Professional advisers including patent agents, lawyers, auditors, accountants and insurers who provide legal, insurance, audit, accounting, IP and other professional services.
- HM Revenue & Customs, regulators and other authorities who may require reporting of processing activities in certain circumstances.
- 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 notice.
We require all third parties to respect the security of your personal data and to treat it in accordance with the law.
6. International transfers
We do not generally transfer your data outside the European Economic Area (EEA).
However if, on occasion, the requirements of our business are such that we do need to transfer your data outside the EEA, we will ensure that suitable safeguards are in place to provide an adequate level of protection for your data. Such safeguards may include the use of appropriate transfer agreements such as the EU-approved “standard contractual clauses”. For more information in this regard, please contact us.
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, 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
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.
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.
Please note that by law we have to keep certain basic information about our customers for up to 7 years after they cease being customers, for tax purposes.
We keep personal data relating to our suppliers for longer, as it is in both our interests and theirs that they remain on our system and potentially available for work from us.
In some circumstances you can ask us to delete your data: see below for further information.
9. Your legal rights
Under certain circumstances, you have rights under data protection laws in relation to your personal data. If you wish to exercise any of these rights, please contact us.
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: (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.
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.
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.
10. Changes to the privacy notice and your duty to inform us of changes
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.
We reserve the right to make changes to this privacy notice at any time.
Legitimate Interest means the interest of our business in conducting and managing our business. 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).
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 or regulatory obligation means processing your personal data where it is necessary for compliance with a legal or regulatory obligation that we are subject to.