Privacy Policy

1 PURPOSE

At UNELEM, we value our customers and take pride in providing you our products and services in the paper converting industry. Our firm obtains certain personally identifiable information about you, to facilitate our relationship and offer you the best possible service. The purpose of this Privacy Policy is to explain our practices and policies for collecting, using and sharing information and Cookies collected from or about you. We have adopted additional policies and procedures that are part of our ongoing product and service support. This Privacy Policy applies regardless of whether you are accessing the website via a personal computer, a mobile device or any other technology or devices, or on records we maintain as part of our ongoing business.

2 TYPES AND USAGE OF INFORMATION WE COLLECT

A/APurposes of processing your dataPersonal data involvedPossible consequences of failure to provide the personal dataLegal basis for processing your data
1Your CustomerPersonal Identifiers, Contact Details, Tax Identifiers, Social Security Identifiers, Financial Information, Connection Information, LocationFailed registration/ContractContract Performance
Registration/ContractInformation, Medical/health information,
Financial Information
2Identity and Contact DetailsPersonal Identifiers, Criminal Activity, Financial Information, Social Security Information, Connection Information,Account suspension/ closure, Unavailability to login, Withdrawal request unavailableRegulatory/ Legal Obligation
VerificationLocalization InformationRefusal to accept
3Transactions ManagementPersonal identifiers, FinancialAccount suspension/ closure, Withdrawal request freezing and/ or cancellationRegulatory/ Legal Obligation
Information
4Monitoring & AssessingPersonal Identifiers, Contact Details,Account suspension/ closure, Unavailability to login, Withdrawal requestRegulatory/ Legal Obligation
Behaviour for Crime PreventionCriminal Activity, Tax Identifiers, Socialunavailable
Security Identifiers, Financial
Information
5Monitoring & Assessing CreditPersonal Identifiers, Criminal Activity, Financial Information, Social SecurityN/ALegitimate Interest (Internal Reporting & Business Development)
Behaviour for BusinessInformation, Connection Information,
DevelopmentLocalisation Information
6Monitoring & Assessing spending Behaviour forPersonal Identifiers, Criminal Activity, Financial Information, Social Security Information, Connection Information,Unavailability of receiving offers and bonuses. Not customized spending experience.Consent
Personalised Offers, Bonuses and User InterfaceLocalisation Information
7Informative Communications, Newsletters and CampaignsPersonal Identifiers, Contact DetailsUnavailability of receiving newsletters and general marketing campaigns.Consent
8Inquiries, Complaints & TroubleshootingPersonal Identifiers, Contact Details,N/ALegitimate Interest (Optimal experience for our customers and troubleshooting of issues)
Occupational Activity, Connection Information, Localisation Information
Financial Information
9Reporting to Regulatory/ Law enforcement AuthoritiesPersonal Identifiers, Criminal Activity, Financial Information, Social Security Information, Connection Information,Account suspension/ closure,Regulatory/ Legal Obligation
Localisation Information, Tax IdentifiersUnavailability to login,
10Professional offersPersonal Identifiers, Contact DetailsUnavailability of the relevant promotion, offer, etc.Consent

Additional Provisions Applicable to Processing of Personal Information of EEA Residents.” This includes detailed information provided pursuant to Regulation (EU) 2016/679 of the European Parliament and of the Council of April 27, 2016, on the protection of natural persons with regard to the processing of Personal Information and on the free movement of such data, commonly referred to as the “General Data Protection Regulation” (GDPR).

Your rights

Exercising your rights. You may exercise any of your rights in relation to your personal data by written notice to us in addition to the other methods specified above subject to:

  1. your request not being found to be unfounded or excessive, in which case a charge may apply;
  2. the supply of appropriate evidence of your identity (for this purpose, we will usually accept a photocopy of your passport certified by a solicitor or bank plus an original copy of a utility bill showing your current address).

We may withhold personal information that you request to the extent permitted by law. You may instruct us at any time not to process your personal information for marketing purposes.

In practice, you will usually either expressly agree in advance to our use of your personal information for marketing purposes, or we will provide you with an opportunity to opt out of the use of your personal information for marketing purposes.

The rights you have under data protection law are:

  1. The right to access;
  2. Your right to access your data. You have the right to ask us to confirm whether or not we process your personal data and, to have access to the personal data, and any additional information. That additional information includes the purposes for which we process your data, the categories of personal data we hold and the recipients of that personal data. You may request a copy of your personal data. The first copy will be provided free of charge, but we may charge a reasonable fee for additional copies

  3. The right to rectification;
  4. Your right to rectification. If we hold any inaccurate personal data about you, you have the right to have these inaccuracies rectified. Where necessary for the purposes of the processing, you also have the right to have any incomplete personal data about you completed.

  5. The right to erasure;
  6. Your right to erasure. In certain circumstances you have the right to have personal data that we hold about you erased. This will be done without undue delay. These circumstances include the following: it is no longer necessary for us to hold those personal data in relation to the purposes for which they were originally collected or otherwise processed; you withdraw your consent to any processing which requires consent; the processing is for direct marketing purposes; and the personal data have been unlawfully processed.
    However, we will only process it for other reasons: with your consent; in relation to a legal claim; for the protection of the rights of another natural or legal person; or for reasons of important public interest.

  7. The right to restrict processing;
  8. Your right to restrict processing. In certain circumstances you have the right for the processing of your personal data to be restricted. This is the case where: you do not think that the personal data we hold about you is accurate; your data is being processed unlawfully, but you do not want your data to be erased; it is no longer necessary for us to hold your personal data for the purposes of our processing, but you still require that personal data in relation to a legal claim; and you have objected to processing, and are waiting for that objection to be verified. Where processing has been restricted for one of these reasons, we may continue to store your personal data.
    However, we will only process it for other reasons: with your consent; in relation to a legal claim; for the protection of the rights of another natural or legal person; or for reasons of important public interest.

  9. The right to object to processing;
  10. Your right to object to processing. You can object to us processing your personal data on grounds relating to your particular situation, but only as far as our legal basis for the processing is that it is necessary for: the performance of a task carried out in the public interest, or in the exercise of any official authority vested in us; or the purposes of our legitimate interests or those of a third party. If you make an objection, we will stop processing your personal information unless we are able to: demonstrate compelling legitimate grounds for the processing, and that these legitimate grounds override your interests, rights and freedoms; or the processing is in relation to a legal claim.

  11. The right to data portability;
  12. Your right to object to direct marketing. You can object to us processing your personal data for direct marketing purposes. If you make an objection, we will stop processing your personal data for this purpose
    Automated data processing. To the extent that the legal basis we are relying on for processing your personal data is consent, and where the processing is automated, you are entitled to receive your personal data from us in a structured, commonly used and machine-readable format. However, you may not have this right if it would adversely affect the rights and freedoms of others.

  13. The right to complain to a supervisory authority;
  14. Complaining to a supervisory authority. If you think that our processing of your personal data infringes data protection laws, you can lodge a complaint with a supervisory authority responsible for data protection. You may do this in the EU member state of your habitual residence, your place of work or the place of the alleged infringement.

  15. The right to withdraw consent;
  16. Right to withdraw consent. To the extent that the legal basis we are relying on for processing your personal data is consent, you are entitled to withdraw that consent at any time. Withdrawal will not affect the lawfulness of processing before the withdrawal.

Our lawful basis for using this Staff data
We only collect and use personal information about you when the law allows us to. Most commonly, we use it where we need to:

  1. Fulfil a contract we have entered into with you
  2. Comply with a legal obligation
  3. Carry out a task in the public interest

Less commonly, we may also use personal information about you where:

  1. You have given us consent to use it in a certain way
  2. We need to protect your vital interests (or someone else’s interests)
  3. We have legitimate interests in processing the data – for example, where:
  4. You have applied for another position and references are required as part of safer recruitment o Your marital status has changed and we are obliged to inform government office about this

Where you have provided us with consent to use your data, you may withdraw this consent at any time. We will make this clear when requesting your consent, and explain how you go about withdrawing consent if you wish to do so. Some of the reasons listed above for collecting and using personal information about you overlap, and there may be several grounds which justify the business’s use of your data.
Collecting this Staff information
While the majority of information we collect from you is mandatory, there is some information that you can choose whether or not to provide to us.
Whenever we seek to collect information from you, we make it clear whether you must provide this information (and if so, what the possible consequences are of not complying), or whether you have a choice.

How we store this Staff data
We create and maintain an employment file for each staff member. The information contained in this file is kept secure and is only used for purposes directly relevant to your employment. The staff files are kept within a locked cupboard in the Director’s office. You are able to have access to your file at any time to ensure that all information about you is up to date.
Once your employment with us has ended, we will retain this file and delete the information in it in accordance with our retention policy which currently states that we will keep it for two years for reasons such as: fulfilling a reference request.

3 DISCLOSURE OF PERSONAL INFORMATION

We will not sell, disclose, or rent your personal information to any third party/entities in ways different from what is disclosed in this privacy notice. However, we may disclose your personal information to third parties:

  1. In the event that we sell or buy any business, assets or shares, we may disclose your personal data to the prospective seller or buyer of such business, assets or shares.
  2. If we are under a duty to disclose or share your personal data in order to comply with any legal or regulatory obligation, in order to enforce or apply our terms and conditions, or to protect our rights, property, or safety, or those of our customers or others.
  3. In order to cooperate with law enforcement agencies to enforce laws, as well as investigate and prosecute unlawful activities such as frauds and scams. We maintain the right to disclose any information about you to law enforcement and other government officials as we, in our sole discretion, believe necessary or appropriate, in connection with any investigation of fraud, scam or other activity that is illegal.
  4. Finally, we may disclose certain personal information to unaffiliated third-party service providers, agents or independent contractors who help us maintain our website and provide other administrative services to us (including, but not limited to, order processing and fulfillment, providing customer service, maintaining and analyzing data, sending customer communications on our behalf, and entry collection, winner selection and prize fulfillment for contests, and other promotions). We seek to ensure that these unaffiliated third parties will not use the personal information for any other purpose than to provide the administrative services for which they are responsible. We also enter into contracts with these third parties that compel them to meet the privacy standards required by law in handling your personal information, and use the information only for the purposes for which it was conveyed to them.
  5. We will not disclose your personal information with any third parties outside of the European Union in countries where there is no adequate data protection regime. However, in the event that such a data transfer occurs, we will take all reasonable steps possible to ensure that your data is treated as securely as it is within the EU/EEA and in accordance with this Privacy Policy and the applicable legislation. Additionally, we will update the current Privacy Policy in order to reflect the cross-border data transfer and the relevant safeguards for your privacy.

4 HOW LONG WE KEEP YOUR DATA

It is our policy to only retain client information for as long as is necessary for the purpose for which it was originally obtained, in alignment with the Data Minimization and Storage Limitation principles. For all purposes below, your data will be retained for a seven years period, after the termination of the customer relationship. Additionally, we align the retention of your information with potential differentiations arising from the exercising of your data privacy rights (please refer to section 6). However, in some cases some personal information may be retained beyond that time period due to potential legal obligations, legitimate interest purposes, etc.

5 YOUR DATA PRIVACY RIGHTS

  1. At any point while we are maintaining or processing your data, you have the following rights and can submit a relevant request via your personal account:
    1. Right of access – you have the right to access the personal data that we hold about you;
    2. Right of rectification – you have the right to correct data that we hold about you that is inaccurate or incomplete. Further analysed in section 7 of the current policy;
    3. Right to erasure – you can ask for the data we hold about you to be erased from our records and we are obliged to satisfy such request in certain circumstances;
    4. Right to restriction on processing – you have the right to request to restrict the processing of your personal information and we are obliged to satisfy such request when certain conditions apply;
    5. Right to data portability – you have the right to have the data we hold about you transferred to another organisation;
    6. Right to object – you have the right to object to particular processing activities, under certain conditions;
  2. We will assess your request and reply to you regarding the progress and outcome of the request (granting of request, partial granting of request, rejection of request), as soon as possible and in any case in no longer than one month of the request’s submission.
    In the event that A. Eracleous Electrical Installation Ltd refuses your request regarding the aforementioned Data Privacy Rights, we will provide you with a reason as to why. You have the right to lodge a complaint directly with the Regulatory authority and the DPO (via the means described in paragraph 13 of the current policy).
  3. We reserve the right to reject requests that are unreasonably repetitive, require disproportionate technical efforts or have disproportionate technical consequences, risk the privacy of others, or would be extremely impractical.