KLL Privacy Notice Version 1 May 2018

PRIVACY NOTICE
We are committed to processing personal information about our customers in ways that comply
with our legal obligations as well as being clear with our customers about what we do with their
personal information. Some of the key points of Keighley Laboratories’ Privacy Notice are:

  • We don’t sell your data to third parties
  • We do make it easy for you to manage your information, you can change your
    communication preferences at any time by using the unsubscribe links at the bottom of any
    email we send you
  • We do use data to give you the best customer experience, for example to ensure the
    information we share is relevant, useful and timely.

We are Keighley Laboratories Limited (KLL), Croft House, South Street, Keighley, West Yorkshire,
BD21 1EG, England. We share your concern about the protection of your personal information and
are committed to safeguarding your privacy.

This document covers information we collect about you, whether via our website
(www.keighleylabs.co.uk), via phone calls, through written communication or otherwise. Please
read it carefully to understand how your personal information will be treated.
We will be the “controller” of the personal information which you provide to us or which we collect
from you.

What personal information do we collect?
We collect a range of personal information relating to you, including your

  • name
  • email address
  • telephone number
  • payment information
  • delivery and billing address
  • IP address
  • any other personal information that you may choose to provide to us when you complete
    our online contact forms or otherwise make contact with us.

How do we use your personal information?
We use your personal information:

  • to maintain our relationship with you whilst you are a customer
  • to process orders and provide quotations and agreed services to you
  • for invoicing, processing payments, account set up and maintenance, to communicate with
    you, including to respond to information requests/enquiries submitted and/or to obtain
    your feedback on our services
  • for record keeping, statistical analysis and internal reporting
  • to ensure data security and to provide you with access to secure areas of our website
  • to notify you about changes to our services
  • to decide on and notify you about price changes
  • to monitor the quality of our services
  • for logistical purposes, including to plan and log delivery routes
  • to investigate any complaint you make
  • to provide evidence in any dispute or anticipated dispute
  • as we may otherwise consider necessary to support the operation of our website
  • to obtain credit references, credit checks and for debt collection, fraud detection and
    prevention and risk management purposes
  • and to protect the rights, property, and/or safety of KLL, its personnel and others.

Marketing
We may send you direct marketing in relation to our services by phone, email and post, as long as
this is in line with any marketing preferences that you may have provided to us.

We will only send you direct marketing in relation to our services by email

  • where you have consented to this or
  • where you have not objected to this, and we are marketing similar services to those which
    were the subject of a previous purchase or negotiations of a purchase by you.

Your agreement to the use of your personal information for direct marketing purposes is optional
and if you choose not to consent, your visits to and use of our website will not be affected.

You can choose to opt out of receiving direct marketing information from us at any time, through
the ‘Unsubscribe’ link at the bottom of any KLL marketing email you receive, or by contacting us

  • by post – Keighley Laboratories Limited, Croft House, South St, Keighley, BD21 1EG
  • by email – gdpr@keighleylabs.co.uk
  • by following the email link on our website.

Recruitment
For further information regarding our Job Applicant Privacy Notice, please see the relevant
document within the ‘Job Opportunities‘ section of our website.

Automated decision making/profiling
Credit Checks

We use technology provided by the credit reference agencies such as Experian (“CRAs”) to process
information that you provide to us, in order to analyse and monitor your creditworthiness, which
helps us to decide if we are able to offer you an account. We will also continue to review
information about you with the CRAs on an ongoing basis.

If you pass our credit checks, and our other account opening criteria (details of which will be made
available to you during the account opening process) you will be entitled to open an account with us
and order any of our services in accordance with our Terms and Conditions of Sale. If you do not
pass our credit checks you will not be able to set up an account but you may still be entitled to order
our products or services (in accordance with our Terms and Conditions of Sale) at our discretion, by
making payment on a pro-forma basis.

What is our legal basis for processing?
In terms of the legal basis we rely on to process your personal information, these are

  • where you have provided your consent: for direct marketing communications in respect of
    our services, including in respect of marketing communications sent by electronic means
    (e.g. email and SMS)
  • for the performance of a contract with you (such as a contract for the provision of services)
    or to
  • take steps at your request prior to entering into this contract
  • to comply with legal obligations, including in relation to health and safety and environmental
    legislation, performing anti-money laundering, terrorism prevention and sanctions screening
    checks, complaints and investigations or litigation
  • to protect your vital interests or the vital interests of another person, e.g. where you or they
    are seriously injured or ill, or for our legitimate interests in:
  • management of your account (including processing payments) and our relationship with you
    and communicating with you
  • operating our website
  • sending direct marketing in respect of our services where you have not provided your
    consent and the marketing communication is sent by non-electronic means (e.g. post or
    telephone)
  • processing orders and supplying our services
  • our internal business purposes which may include processing for the purposes of: record
    keeping, research, reporting and statistics, data security, to ensure the quality of our
    services, investigating and responding to queries and complaints, obtaining credit references
    and credit checks, providing payment performance data to credit reference agencies,
    changing our pricing, debt collection, fraud detection and prevention, risk management,
    recruitment and training of our personnel, and protecting our rights, property and safety
    (and that of others). You can object to processing carried out on the basis of our legitimate
    interests at any time by emailing gdpr@keighleylabs.co.uk See also “What are your rights?
    – The right to object”.

How do we share your personal information?

We may share your personal information with

  • third party providers in order for us to process payments that are due to us, in doing so we
    provide bank card details to such providers
  • licensed credit reference agencies, debt collection agencies and lawyers when we carry out
    credit checks, to report on your payment performance and/or or seek to recover debts due
    to us
  • our accountants, auditors, lawyers or similar advisers when we ask them to provide us with
    professional advice
  • emergency services in the event that we need to report accidents or incidents or request
    emergency assistance
  • any Government Department, public body or other third party where we believe in good
    faith that the law requires this, in the interests of public health and safety, or in order to
    protect the rights, property, or safety of KLL, its employees or others
  • investors and other relevant third parties in the event of an actual or potential sale or other
    corporate transaction related to KLL
  • any other third parties, if authorised by you to do so.

We do not transfer your personal information outside the European Economic Area. Should this be
required, we would ensure that, where your personal information is transferred to any country
outside the European Economic Area this is done using “model clauses” (standard contractual
clauses which have been approved by the European Commission as providing adequate safeguards
to enable personal data to be transferred outside the European Economic Area) or other specific
legally-approved safeguards.

The performance of services by our third party service provider(s) may be subject to a separate
privacy statement provided to you by the relevant third party. You should read any such statement
carefully.

How long do we keep your personal information?

We retain your personal information for no longer than is necessary for the purposes for which
the personal information is collected. When determining the relevant retention periods, we will
take into account factors including:

  • legal obligation(s) under applicable law to retain data for a certain period of time
  • statute of limitations under applicable law(s)
  • (potential) disputes
  • Regulatory obligation(s) relating to relevant industry requirements
  • guidelines issued by relevant data protection authorities.

Otherwise, we securely erase your information once this is no longer needed.

How do we use Cookies?
Where you use our website, we will process your personal information collected by using cookies in
accordance with our following Cookie Policy.

Cookie Policy
Cookies are small text files that are placed on your computer by websites that you visit. They are
widely used in order to make websites work, or work more efficiently, as well as to provide
information to the owners of the site.

KLL website uses the following cookies:

Item Cookies Purpose More information
Google Analytics _utma
_utbm
_utmc
_utmz*
Collect information about how
visitors use our site. We use the
information to compile reports
and to help us improve the site.
The cookies collect information in
an anonymous form, including the
number of visitors to the site,
where visitors have come to the
site from the pages they visited.
Google Analytics Privacy Policy
You can choose to opt out of
Google Anayltics

These cookies are provided by a third party who could change their cookies in future outside of our
control. We will review this policy regularly for any such changes.

Most web browsers allow some control of most cookies through the browser settings. To find out
more about cookies, including how to see what cookies have been set and how to manage and
delete them, visit www.allaboutcookies.org

Links to third party websites

Our website contains links to other internet websites. Unless otherwise explicitly stated, we are not
responsible for the privacy practices or the content of such websites, including such sites‘ use of any
personal information. Nevertheless, in the event you encounter any third party associated with our
website (or who claims association with our website) who you feel is improperly collecting or using
information about you, please contact gdpr@keighleylabs.co.uk we will be happy to forward your
message to the third party.

Security
We use reasonable security methods to protect the personal information that we process.

Please note that whilst we take appropriate technical and organisational measures to safeguard the
personal information that you provide to us, no transmission over the internet can be guaranteed to
be secure. Consequently, please note that we cannot guarantee the security of any personal
information that you transfer to us over the internet.

What are your rights?
The following section explains your rights. The various rights are not absolute and each is subject to
certain exceptions or qualifications.

We will grant your request only to the extent that it follows from our assessment of your request
that we are allowed and required to do so under data protection laws. Nothing in this Privacy Notice
is intended to provide you with rights beyond or in addition to your rights as a data subject under
data protection laws.

1. The right to be informed – You have the right to be provided with clear, transparent and
easily understandable information about how we use your personal information and your
rights. This is why we’re providing you with the information in this Privacy Notice.

2. The right of access – You have the right to obtain a copy of your personal information (if
we’re processing it), and other certain information (similar to that provided in this Privacy
Notice) about how it is used. This is so you’re aware and can check that we’re using your
personal information in accordance with data protection law. We can refuse to provide
information where to do so may reveal personal information about another person or would
otherwise negatively impact another person‘s rights.

3. The right to rectification – You can ask us to take reasonable measures to correct your
personal information if it’s inaccurate or incomplete, e.g. if we have the wrong email or
name for you.

4. The right to erasure – This is also known as ‘the right to be forgotten’ and, in simple terms,
enables you to request the deletion or removal of your personal information where there’s
no compelling reason for us to keep using it or its use is unlawful. This is not a general right
to erasure; there are exceptions, e.g. where we need to use the information in defence of a
legal claim.

5. The right to restrict processing – You have rights to ‘block’ or suppress further use of your
personal information when we are assessing a request for rectification or as an alternative
to erasure. When processing is restricted, we can still store your personal information, but
may not use it further. We keep lists of people who have asked for further use of their
personal information to be ‘blocked’ to make sure the restriction is respected in future.

6. The right to data portability – You have rights to obtain and reuse certain personal
information for your own purposes across different organisations. This enables you to move,
copy or transfer your personal information easily between our IT systems and theirs (or
directly to yourself) safely and securely, without affecting its usability. This only applies to
your personal information that you have provided to us that we are processing with your
consent or to perform a contract which you are a party to (such as pay and compensation
services), which is being processed by automated means.

7. The right to object – You have the right to object to certain types of processing, on grounds
relating to your particular situation, at any time in so far as that processing takes place for
the purposes of legitimate interests pursued by KLL or by a third party. We will be allowed to
continue to process the personal information if we can demonstrate “compelling legitimate
grounds for the processing which override [your] interests, rights and freedoms” or we need
this for the establishment, exercise or defence of legal claims.

8. Rights in relation to automated decision making and profiling – You have the right not to be
subject to a decision based solely on automated processing (including profiling), which
significantly affects you, subject to some exceptions. Where this is the case, you have the
right to obtain human intervention, voice your concerns and to have the decision reviewed.

Updating this statement
We review our privacy practices from time to time. We ask that you bookmark and periodically
review this page for updates to our Privacy Notice. We reserve the right to modify this policy
effective seven days after the posting of the revised Privacy Notice.

Want to contact us?
For further information regarding these rights, about this Privacy Notice generally or to make a
complaint please contact us at gdpr@keighleylabs.co.uk or call us on 01535 664211.

Please provide as much information as possible to help us identify the information you are
requesting, the action you want us to take and why you believe this action should be taken.

Before assessing your request, we may request additional information in order to identify you. If you
do not provide the requested information and, as a result we are not in a position to identify you, we
may refuse to action your request.

We will generally respond to your request within one month of receipt of your request. We can
extend this period by an additional two months if this is necessary taking into account the
complexity and number of requests that you have submitted.

We will not charge you for such communications or actions we take, unless:

  • you request additional copies of your personal data undergoing processing, in which case we
    may charge for our reasonable administrative costs, or
  • you submit manifestly unfounded or excessive requests, in particular because of their
    repetitive character, in which case we may either: (a) charge for our reasonable
    administrative costs; or (b) refuse to act on the request.

If after contacting KLL you are still unhappy you may also complain to the Information
Commissioner, all contact details are available on the Information Commissioner‘s
website: https://ico.org.uk.

 

Keighley Laboratories Ltd
Registered Office:
Croft House
South Street
Keighley
West Yorkshire
BD21 1EG
Registered in England 164811
UK Tel: +44 (0)1535 664211
Email: info@keighleylabs.co.uk

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