DATA PROTECTION POLICY

1. Introduction

This Privacy Notice explains the types of personal data we may collect about you when you interact with us. It also explains how we’ll store and handle that data, and keep it safe. We know that there’s a lot of information here but we want you to be fully informed about your rights, and how UZIN UTZ UK Ltd  uses your data. For example, we will explain things such as our credit checking procedure and how we combine data across the UZIN UTZ Group to build your profile. We hope the following sections will answer any questions you have but if not, please do get in touch with us. It’s likely that we’ll need to update this Privacy Notice from time to time. We’ll notify you of any significant changes, but you’re welcome to come back and check it whenever you wish.


2. Who is UZIN UTZ UK Ltd?

UZIN UTZ UK Ltd – which we’ll refer to as ‘the company’ in this document – is a subsidiary of UZIN UTZ Group, we distribute  a number of brands which we refer as business units into the UK and Ireland

  • Uzin
  • Codex
  • Arturo
  • Wolff
  • UZIN UTZ UK Ltd only trades within the UK and Ireland, if you place an order for delivery to a different country,  we may ask you to deal with another company of the UZIN UTZ Group, then we also ask you to look at their privacy policy

For simplicity throughout this notice, ‘we’ and ‘us’ means UZIN UTZ UK and all its brands.


3. Explaining the legal bases we rely on

The law on data protection sets out a number of different reasons for which a company may collect and process your personal data, including:

Consent

UZIN UTZ UK Ltd is responsible for handling personal data provided under your consent For example, when you tick a box to receive newsletters, information and promotions about UZIN UTZ UK Ltd products and services by e-mail, text, phone or post.

When collecting your personal data, we’ll always make clear to you which data is necessary in connection with a particular service. Data will be kept and stored while there will be a mutual interest in maintaining a commercial relationship.

Contractual obligations

In certain circumstances, we need your personal data to comply with our contractual obligations with the company you are connected with. For example, if you order from us and provide a home address, we’ll collect the address details to deliver your purchase, and pass them to our courier.

Legal compliance

If the law requires us to, we may need to collect and process your data. For example, we can pass on details of people involved in fraud or other criminal activity affecting the company to law enforcement.

Legitimate interest

In specific situations, we require your data to pursue our legitimate interests in a way which might reasonably be expected as part of running our business and which does not materially impact your rights, freedom or interests. For example, we may use your purchase history to send you or make available personalised offers. We will also use your address details to send you direct marketing information by post, telling you about products and services that we think might interest you.


4. When do we collect your personal data?

  • When you visit any of our websites, or redeem vouchers from the company on the phone, in a distributor’s shop or online.
  • When you create an account with us.
  • We collect data from a business card you handed over to us.
  • When you purchase a product or service in a distributor’s store or by phone but don’t have (or don’t use) an account.
  • When you engage with us on social media.
  • When you download or install one of our apps.
  • When you join a company loyalty programme (e.g. Stick with Uzin).
  • When you contact us by any means with queries, complaints etc.
  • When you ask one of our Staff to email you information about a product or service.
  • When you enter prize draws or competitions.
  • When you book any kind of appointment with us or book to attend an event, for example a training day at our Technical School.
  • When you choose to complete any surveys we send you.
  • When you comment on or review our products and services. Any individual may access personal data related to them, including opinions. So if your comment or review includes information about any other partner who provided that service, then it may be passed on to them if requested.
  • When you fill in any forms. For example, a claim for damaged goods, a Partner may collect your personal data. (I.e. currier)
  • When you’ve given a third party permission to share with us the information they hold about you.
  • We collect data from publicly available sources (such as Contract Flooring Association) when you have given your consent to share information or where the information is made public as a matter of law.


5. What sort of personal data do we collect?

  • We may request: your name, gender, date of birth, billing/delivery address, orders and receipts, your email account, and telephone number
  • Details of your interactions with us through sales managers, calls into the office or by using one of our apps.
    For example, we collect notes from our conversations with you, details of any complaints or comments you make, details of purchases you made, items viewed or added to your basket, gift list and wish list choices, voucher redemptions, brands you show interest in and how and when you contact us.
    For example, where you redeem your vouchers.
  • Details of your visits to our websites or apps, and which site you came from to ours.
  • Information gathered by the use of cookies in your web browser.
  • Payment card information.
  • Your comments and product reviews.
  • Your car number plate may be recorded at some of our car parks to manage parking restrictions.
  • Your social media username, if you interact with us through those channels, to help us respond to your comments, questions or feedback.


6. How and why do we use your personal data?

We want to give your company the best possible customer experience. One way to achieve that is to get the richest picture we can of who it’s workers are by combining the data we have about you and the company you work for. We then use this to offer you promotions, products and services that are most likely to interest you. In the case of loyalty scheme members, we’ll also offer you relevant rewards. The data privacy law allows this as part of our legitimate interest in understanding our customers and providing the highest levels of service. Of course, if you wish to change how we use your data, you’ll find details in the ‘What are my rights?’ section below. Remember, if you choose not to share your personal data with us, or refuse certain contact permissions, we might not be able to provide some services you’ve asked for. For example, if you’ve asked us to let you know when an item comes back into stock, we can’t do that if you’ve withdrawn your general consent to hear from us.

Here’s how we’ll use your personal data and why:

  • To process any orders that you make by phone, email, apps or in our offices. If we don’t collect your personal data, we won’t be able to process your order and comply with our legal obligations.
    For example, your details may need to be passed to a third party to supply or deliver the product or service that you ordered and we may keep your details for a reasonable period afterwards in order to fulfil any contractual obligations such as refunds, guarantees and so on.
  • To respond to your queries, refund requests and complaints. Handling the information you sent enables us to respond. We may also keep a record of these to inform any future communication with us and to demonstrate how we communicated with you throughout. We do this on the basis of our contractual obligations to you, our legal obligations and our legitimate interests in providing you with the best service and understanding how we can improve our service based on your experience.
  • To protect our business and your account from fraud and other illegal activities. This includes using your personal data to maintain, update and safeguard an account. We’ll also monitor your browsing activity with us to quickly identify and resolve any problems and protect the integrity of our websites. We’ll do all of this as part of our legitimate interest.
  • With your consent, we will use your personal data, preferences and details of your transactions to keep you informed by email, web, text, telephone and through our contact centres about relevant products and services including tailored special offers, discounts, promotions, events, competitions and so on. Of course, you are free to opt out of hearing from us by any of these channels at any time.
  • To send you relevant, personalised communications by post in relation to updates, offers, services and products. We’ll do this on the basis of our legitimate business interest.  You are free to opt out of hearing from us by post at any time.
  • To send you communications required by law or which are necessary to inform you about our changes to the services we provide you. For example, updates to this Privacy Notice, product recall notices, and legally required information relating to your orders. These service messages will not include any promotional content and do not require prior consent when sent by email or text message. If we do not use your personal data for these purposes, we would be unable to comply with our legal obligations.
  • To display the most interesting content to you on our websites or apps, we’ll use data we hold about your favourite brands or products and so on. We do so on the basis of your consent to receive app notifications and / or for our website to place cookies or similar technology on your device.
    For example, we might display a list of items you’ve recently looked at, or offer you recommendations based on your purchase history and any other data you’ve shared with us.
  • To administer any of our prize draws or competitions which you enter, based on your consent given at the time of entering.
  • To develop, test and improve the systems, services and products we provide to you. We’ll do this on the basis of our legitimate business interests.
  • To comply with our contractual or legal obligations to share data with law enforcement.
    For example, when a court order is submitted to share data with law enforcement agencies or a court of law.
  • To send you survey and feedback requests to help improve our services. These messages will not include any promotional content and do not require prior consent when sent by email or text message. We have a legitimate interest to do so as this helps make our products or services more relevant to you. Of course, you are free to opt out of receiving these requests from us at any time by contacting us.


7. Combining your data for personalised direct marketing

We want to bring you offers and promotions that are most relevant to your interests at particular times. To help us form a better, overall understanding of you as a customer, we combine your personal data gathered across our different brands i.e. UZIN & Wolff as described above. For this purpose we also combine the data that we collect directly from you with data that we obtain from third parties to whom you have given your consent to pass that data onto us.


8. How we protect your personal data

We know how much data security matters to all our customers. With this in mind we will treat your data with the utmost care and take all appropriate steps to protect it. We regularly monitor our system for possible vulnerabilities and attacks, and identify ways to further strengthen security.


9. How long will we keep your personal data?

Whenever we collect or process your personal data, we’ll only keep it for as long as is necessary for the purpose for which it was collected. At the end of that retention period, your data will either be deleted completely or anonymised, for example by aggregation with other data so that it can be used in a non-identifiable way for statistical analysis and business planning.

Some examples of customer data retention periods:

Orders

When you place an order, we’ll keep the personal data you give us for five years so we can comply with our legal and contractual obligations.

Inactive accounts

If you’ve not used your account for more than five years, it will be flagged as inactive

Warranties

If your order included a warranty, the associated personal data will be kept until the end of the warranty period.


10. Who do we share your personal data with?

We sometimes share your personal data with trusted third parties. For example, delivery couriers, technicians visiting your home, for fraud management, to handle complaints, to help us personalise our offers to you and so on.

Here’s the policy we apply to those organisations to keep your data safe and protect your privacy:

  • We provide only the information they need to perform their specific services.
  • They may only use your data for the exact purposes we specify in our contract with them.
  • We work closely with them to ensure that your privacy is respected and protected at all times.
  • I f we stop using their services, any of your data held by them will either be deleted or rendered anonymous.

Examples of the kind of third parties we work with are:

  • IT companies who support our website and other business systems.
  • Operational companies such as delivery couriers.
  • Direct marketing companies who help us manage our electronic communications with you.
  • Data insight companies to ensure your details are up to date and accurate.
  • Google/Facebook to show you products that might interest you while you’re browsing the internet. This is based on either your marketing consent or your acceptance of cookies on our websites.

See our Cookies Notice in point 11 (see below).

  • For fraud management, we may share information about fraudulent or potentially fraudulent activity in our premises or systems. This may include sharing data about individuals with law enforcement bodies.
  • We may also be required to disclose your personal data to the police or other enforcement, regulatory or Government body, in your country of origin or elsewhere, upon a valid request to do so. These requests are assessed on a case-by-case basis and take the privacy of our customers into consideration.

For further information please contact our Data Protection Officer

Data Protection Officer

UZIN UTZ UK Ltd,
Unit 2 Mitchell Court,
Rugby,
CV23 0UY


11. What data is collected when you visit our website?

Every time a user accesses an internet page for one of our offers, and every time a file is retrieved, data will be stored in a log file about this process. These files are not personal, so we can’t track which user requested which data. More specifically, the following data record will be stored for each retrieval:

  • Name of file retrieved
  • Date and time of retrieval
  • Amount of data transferred
  • Report of whether retrieval was successful

No personal user profile will be built. The data stored for only be evaluated for statistical purposes. It will not be forwarded to any third parties.

Cookies

Our websites use cookies. A cookie is a small text file that saves the web browser at the command of a web server to a user’s hard drive and contains information about their web requests. Cookies are mainly used as electronic memos for the server to retain user-specific browser requests, such as which websites a user visits, how often, and for how long, or whether the requested website should be sent in a certain version determined by the user. Cookies cannot delete files from the hard drive, nor read their content or transmit viruses, and in this sense are harmless.

Google Analytics

Our websites uses Google Analytics, a web analysis service of Google Inc. (“Google”). Google Analytics uses “cookies,” text files that are saved to your computer and allow your use of the website to be analysed. The information generated by the cookie through your use of this website will generally be transmitted to a Google server in the United States and stored there. In the event that IP anonymisation is activated on this website, however, your IP address will be truncated by Google within member states of the European Union or in other contracting states that are party to the Agreement on the European Economic Area. Only in exceptional cases will the full IP address be transmitted for a Google server in the US and truncated there. Google is commissioned by the operator of this website to use this information for the purpose of evaluating your use of the website, compile reports about website activities, and render additional services related to website and internet usage with respect to the website operator. The IP address transmitted from your browser in the context of Google Analytics will not be combined with other data from Google. You can prevent the storing of cookies by setting your browser software accordingly; however, we would like to inform you that in this event, not all functions of this website may be able to be used to its full extent. In addition, you can prevent the collection of the data generated by the cookie that is related to your use of the website (including your IP address) at Google, as well as the processing of this data by Google, by downloading and installing the browser plug-in available at the following link [Add link here. The current link is tools.google.com/dlpage/gaoptout.

Web beacons

E-mail newsletters may contain “web beacons.” A web beacon is a mostly transparent graphic element that is hosted in the newsletter e-mail to get more information about the online behaviour of the user. Web beacons are used by third-party provider technologies to observe the newsletter usage, as well as the activity of the user on our website, and evaluate it for the purpose of adjusting the content of the newsletter and the websites retrieved to the user’s needs. You allow us to track which computer accessed a specific website, when, and from where. This data may be forwarded to a service provider for analysis and evaluation of user data. All service providers are required by us to adhere to the Federal Data Protection Act.

Personal data

Personal data that the user discloses when visiting our homepage will be treated according to the current legal provisions concerning data privacy. If the user send us an electronic message (e-mail) and/or fills out the online form on our website and submits it to us electronically, we will store and process the data and information provided there and in accordance with the respective purpose intended by the user or assumed by us, such as sending the requested documents or information, or checking application documents that were sent. However, we caution that when your data is transmitted via the internet, it may be noticed or changed by unauthorised persons. The user consents to the storage and usage of data as described above and to the use of cookies.

General conditions of website usage

Access to the sites on the company’s homepage and its pages (webpages), as well as their use, is based on the following regulations. You are only entitled to view and use the website if you state your agreement with the following rules. Our general conditions for delivery and payment remain unaffected by the content of these general conditions of use, unless express reference is made to a change.

Subject to alterations

We retain the right to change the website, as well as these terms and conditions of use, at any time and without notice at their own discretion. The website can also be discontinued by us at any time and without notice. We are not obligated to update the content on the website.

Rights on the website and contents

Any rights to or rights conferred by the website are appertained to UZIN UTZ Group or its allied companies unless otherwise explicitly arranged. The texts, documents, images, and illustrations published on this website are - unless otherwise stated - the sole property of UZIN UTZ Group and its allied companies. Any commercial use or utilisation of the website and its contents is prohibited. The brands listed on this website are the property of UZIN UTZ Group and its allied companies. The use or utilisation of these brands is expressly prohibited and constitutes a violation of trademark law. The existence of other copyright or property rights remains unaffected.

Liability

We do not accept any responsibility for the completeness, correctness, and/or currency of the information contained on the website. The user has access to the site in its “as is” state at the time. The user of our website agrees that they accept the risk associated with accessing the website and its contents. We are not responsible for damage resulting from use of this website, from the fact that the website cannot be used in whole or in part, or from loss of data or change of data on the transmission paths.

We make no guarantee that the products or goods described are always or still available. Please note further that the processing or utilisation of products or goods may only be done by competent contractors. The scope, as well as the manner, of usability or applicability of goods is the result of corresponding respective product data sheets, which are connected to the usage instructions provided on the packaging. It is the responsibility of the customer to inquire with us about the usability of individual goods. Mandatory legal regulations remain unaffected.

Internet links to third-party pages

Our websites contains shortcuts to third-party pages, using them is at the risk of the user. We neither guarantee the availability of these, nor accepts ownership of these sites or the views and other contents expressed on them.
 

12. DOCUSIGN

We use the transaction management platform DocuSign. The service provider is the American company DocuSign, inc., 221 Main Street Suite 1000 San Francisco, CA 94105. USA.

When you submit documents to DocuSign, we collect and process personal data from you. In order to ensure and document a legally compliant signature as well as a valid conclusion of a contract, the following data is generally processed - depending on the respective signature form:

  • Name, user name, email address, telephone number as well as postal address of the acting persons.
  • Documentation of activities and status changes incl. date and time (e.g. dispatch, signature, rejection, forwarding, cancellation)
  • Type of signature and authentication method used
  • Metadata about the transaction, document history, and subject
  • System information, such as IP addresses as well as other online identifiers and location data, if applicable.

When providing the DocuSign service, personal data may be processed by processors based in the USA (e.g. in the context of support services or the transfer of transaction data).

We would like to point out that the USA is not a safe third country in the sense of EU data protection law. US companies may be obliged to hand over personal data to security authorities without you as the data subject being able to take legal action against this. It can therefore not be ruled out that US authorities (e.g. intelligence services) may process, evaluate and permanently store your data located on the servers for monitoring purposes. We have no influence on these processing activities.

DocuSign ensures the appropriate guarantees for the transfer required under Art. 46 (1) DSGVO by means of officially approved binding internal data protection regulations (so-called Binding Corporate Rules - BCR) in accordance with Art. 46 II b) in conjunction with Art. 47 DSGVO. The currently valid Binding Corporate Rules of DocuSign can be found at: https://www.docusign.com/trust/privacy/binding-corporate-rules.

Further information on data protection at DocuSign can be found at: https://www.docusign.com/privacy

Your data will be deleted from our systems as soon as it is no longer required to fulfill the purpose for which it was collected.

The use of DocuSign serves the legitimate interest of formally simplifying and accelerating the process of legally signing documents by using an electronic signature. The legal basis for the initial processing of personal data is therefore Art. 6 para. 1 lit. f) DSGVO.

If you as a contracting party sign electronically yourself via DocuSign, you consent to the electronic signature via DocuSign. The legal basis for this processing is your consent according to Art. 6 para. 1 lit. a) DSGVO. The use of DocuSign is not mandatory and a conventional signature is still possible.

The document signed via DocuSign is regularly the basis for the delivery of goods or the provision of any other service or consideration; the further necessary processing is then based on Art. 6 para. 1 lit. b) DSGVO.


13. Where your personal data may be processed

Sometimes we will need to share your personal data with third parties and suppliers outside the European Economic Area (EEA).

International orders

If you are based outside the UK and inquire with us, we will transfer the personal data that we collect from you to the relevant company of the UZIN UTZ Group

Protecting your data outside the EEA

The EEA includes all EU Member countries as well as Iceland, Liechtenstein and Norway.

We may transfer personal data that we collect from you to third-party data processors in countries that are outside the EEA such as Australia or the USA. For example, this might be required in order to fulfil your order, process your payment details or provide support services. If we do this, we have procedures in place to ensure your data receives the same protection as if it were being processed inside the EEA. For example, our contracts with third parties stipulate the standards they must follow at all times. If you wish for more information about these contracts please contact our Data Protection Officer. Any transfer of your personal data will follow applicable laws and we will treat the information under the guiding principles of this Privacy Notice.


14. What are your rights over your personal data?

An overview of your different rights

You have the right to request:

  • Access to the personal data we hold about you, free of charge in most cases.
  • The correction of your personal data when incorrect, out of date or incomplete.
  • That we stop using your personal data for direct marketing (either through specific channels, or all channels).
  • That we stop any consent-based processing of your personal data after you withdraw that consent.
  • Review by a Partner of any decision made based solely on automatic processing of your data (i.e. where no human has yet reviewed the outcome and criteria for the decision).

You can contact us to request to exercise these rights at any time as follows:

To ask for your information or to ask for your information to be amended contact our customer services team:

UZIN UTZ UK Ltd
Unit 2 Mitchell Court,
Rugby,
CV23 0UY

uksales@uzin-utz.com

If we choose not to action your request we will explain to you the reasons for our refusal.

Your right to withdraw consent

Whenever you have given us your consent to use your personal data, you have the right to change your mind at any time and withdraw that consent.

Where we rely on our legitimate interest

In cases where we are processing your personal data on the basis of our legitimate interest, you can ask us to stop for reasons connected to your individual situation. We must then do so unless we believe we have a legitimate overriding reason to continue processing your personal data.

Direct marketing

You have the right to stop the use of your personal data for direct marketing activity through all channels, or selected channels. We must always comply with your request.

Checking your identity

To protect the confidentiality of your information, we will ask you to verify your identity before proceeding with any request you make under this Privacy Notice.


15. How can you stop the use of your personal data for direct marketing?

There are several ways you can stop direct marketing communications from us:

  • Click the ‘unsubscribe’ link in e-mail communication that we send you. We will then stop any further emails from that particular division.
  • In our apps, you can manage your preferences and opt out from one or all of the different push notifications by selecting or deselecting the relevant options in the ‘Settings’ section.

Write to:

UZIN UTZ UK Ltd
Unit 2 Mitchell Court,
Rugby,
CV23 0UY

uksales@uzin-utz.com

Please note that you may continue to receive communications for a short period after changing your preferences while our systems are fully updated.


16. Contacting the Regulator

If you feel that your data has not been handled correctly, or you are unhappy with our response to any requests you have made to us regarding the use of your personal data, you have the right to lodge a complaint with the Information Commissioner’s Office.

You can contact them by calling 0303 123 1113.

Or go online to www.ico.org.uk/concerns (opens in a new window; please note we can't be responsible for the content of external websites)

If you have any questions that haven’t been covered, please contact our Data Protection Officer who will be pleased to help you:

Email us on uk@uzin-utz.com

Or write to us at

Data Protection Officer

UZIN UTZ UK Ltd
Unit 2 Mitchell Court,
Rugby,

CV23 0UY

This notice was last updated on 16.05.2018

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