MODUTHERM PRIVACY STATEMENT

Introduction
‍Modutherm Limited (“Modutherm”, “we”, “us”, or “our”) is committed to protecting personal data and this privacy statement describes why and how we collect and use personal data and provides information about individuals’ rights.  It applies to personal data provided to us, both by individuals themselves or by others.  We may use personal data provided to us for any of the purposes described in this privacy statement or as otherwise stated at the point of collection.
Personal data is any information relating to an identified or identifiable living person.  
Modutherm processes personal data for numerous purposes, and the means of collection, lawful basis of processing, use, disclosure, and retention periods for each purpose may differ.When collecting and using personal data, our policy is to be transparent about why and how we process personal data. To find out more about our specific processing activities, please go to the appropriate sections of this statement.

‍When and how we share personal data and locations of processing
‍We will only share personal data with others when we are legally permitted to do so.  When we share data with others, we put contractual arrangements and security mechanisms in place to protect the data and to comply with our data protection, confidentiality and security standards.Personal data held by us may be transferred to:
‍Third party organisations that provide applications/functionality, data processing or IT services to us
We use third parties to support us in providing our services and to help provide, run and manage our internal IT systems.  
For example, providers of information technology, cloud based software as a service providers, data back-up, security and storage services.  The servers powering and facilitating that cloud infrastructure are located in a secure data centre in the UK, and personal data may be stored here.
‍Third party organisations that otherwise assist us in providing goods, services or information e.g. logistics
Auditors and other professional advisers
Law enforcement or other government and regulatory agencies or to other third parties as required by, and in accordance with, applicable law or regulation

Changes to this privacy statement
‍We acknowledge that transparency is a continual responsibility so we will keep this privacy statement under review at regular intervals.  This privacy statement was last updated on 17 May 2018.

‍Data controller and contact information
‍The data controller is Modutherm Limited (registered in England under registration no. 1845418 and with its registered address at Modutherm Limited, Unit 4 Genesis, Endeavour Drive, Basildon, Essex, SS14 3WF).
If you have any questions about this privacy statement or how and why we process personal data, please contact us at:
Data Protection Officer
Modutherm Limited,
Unit 4 Genesis,
Endeavour Drive,
Basildon, Essex
SS14 3WF
Email: modutherm@modularhg.co.uk
Phone: 0345 521 5666
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‍Individuals’ rights and how to exercise them
‍Individuals have certain rights over their personal data and data controllers are responsible for fulfilling these rights.  Where we decide how and why personal data is processed, we are a data controller and include further information about the rights that individuals have and how to exercise them below.

‍Access to personal data
‍You have a right of access to personal data held by us as a data controller. This right may be exercised by emailing us at modutherm@modularhg.co.uk
We will aim to respond to any requests for information promptly, and in any event within the legally required time limits (under GDPR 30 days).
‍Amendment of personal data
‍To update personal data submitted to us, you may email us at modutherm@modularhg.co.uk. Wherever possible, once we’re informed that any personal data processed by us is no longer accurate, we’ll make corrections where appropriate based on your updated information.

‍Withdrawal of consent
‍Where we process personal data based on consent, individuals have a right to withdraw consent at any time.  We do not generally process personal data based on consent (as we can usually rely on another legal basis).  To withdraw consent to our processing of your personal data please email us at modutherm@modularhg.co.uk or, to stop receiving an email from an Modutherm marketing list, please click on the unsubscribe link in the relevant email received from us.

‍Other data subject rights
‍This privacy statement is intended to provide information about what personal data we collect about you and how it is used.  As well as rights of access and amendment referred to above, individuals may have other rights in relation to the personal data we hold, such as a right to erasure/deletion, to restrict or object to our processing of personal data and the right to data portability.If you wish to exercise any of these rights, please send an email to modutherm@modularhg.co.uk

Complaints
‍We hope that it won’t ever be necessary, but if you do want to complain about our use of personal data, please send an email with the details of your complaint to modutherm@modularhg.co.uk. We will look into and respond to any complaints we receive.You also have the right to lodge a complaint with the Information Commissioner’s Office (“ICO”) (the UK data protection regulator).  For further information on your rights and how to complain to the ICO, please refer to the ICO website.
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‍Collection of personal data – BUSINESS CONTACTS
‍Modutherm processes personal data about contacts (existing and potential Modutherm clients and/or individuals associated with them) using a customer relationship management system (the “Modutherm CRM”).The collection of personal data about contacts and the addition of that personal data to the Modutherm CRM is initiated by a Modutherm user and will include name, employer name, contact title, phone, email and other business contact details. In addition, the Modutherm CRM may collect data from the Modutherm email system (sender name, recipient name, date and time) concerning interactions between Modutherm users and contacts or third parties.

‍Use of personal data
‍Personal data relating to business contacts may be visible to and used by Modutherm users to learn more about an account, client, prospect or sales lead they have an interest in, and may be used for the following purposes:Administering, managing and developing our businesses and servicesProviding information about us and our range of services. Making contact information available to Modutherm usersIdentifying clients/contacts with similar needsDescribing the nature of a contact’s relationship with Modutherm. Performing analytics, including producing metrics for Modutherm management team, such as on trends, sales intelligence and progress against sales targets.MHS does not sell or otherwise release personal data contained in the Modutherm CRM to third parties for the purpose of allowing them to market their products and services at any time.

‍Data retention
‍Personal data will be retained on the Modutherm CRM for as long as it is necessary for the purposes set out above (e.g. for as long as we have, or need to keep a record of, a relationship with a business contact). In the absence of specific legal, regulatory or contractual requirements, our baseline retention period for records and other documentary evidence created in the provision of contracts is 10 years.

‍Collection of personal data – Individuals whose personal data we obtain in connection with providing services to our clients
‍Our policy is to collect only the personal data necessary for agreed purposes and we ask our customers only to share personal data where it is strictly needed for those purposes.Where we need to process personal data to provide our services, we ask our clients to provide the necessary information to the data subjects concerned regarding its use.We collect and use contact details for our clients in order to manage and maintain our relationship with those individuals. Please see the Business contacts section of this privacy statement for more information about our processing of this type of data.  Generally, we collect personal data from our clients or from a third party acting on the instructions of the relevant client.  For some of our services, for example, when we are delivering products to a third party on behalf of a client, we may obtain personal data from that third party to facilitate the provision of that service.

‍Data retention
‍We retain the personal data processed by us for as long as is considered necessary for the purpose for which it was collected (including as required by applicable law or regulation).In the absence of specific legal, regulatory or contractual requirements, our baseline retention period for records and other documentary evidence created in the provision of contracts is 10 years.

‍Others who get in touch with us
‍We collect personal data when an individual gets in touch with us with a question, complaint, comment or feedback (such as name, contact details and contents of the communication).  In these cases, the individual is in control of the personal data shared with us and we will only use the data for the purpose of responding to the communication, unless otherwise instructed. In this instance, and where there is no contractual agreement, our retention period for personal data is 2 years.

‍Staff
‍We collect personal data concerning our own personnel as part of the administration, management and promotion of our business activities.

‍Suppliers (including subcontractors and individuals associated with our suppliers and subcontractors)

Collection of personal data
‍We collect and process personal data about our suppliers (including subcontractors and individuals associated with our suppliers and subcontractors) in order to manage the relationship, contract, to receive services from our suppliers and, where relevant, to provide services to our clients.

‍Use of personal data
‍We use personal data for the following purposes:

‍Receiving services
‍We process personal data in relation to our suppliers and their staff as necessary to receive the services. For example, where a supplier is providing us with product or outsourced services, we will process personal data about those individuals that are providing services to us.

‍Administering, managing and developing our businesses and services
‍We process personal data in order to run our business, including:– managing our relationship with suppliers;
– developing our businesses and services (such as identifying client needs and improvements in service delivery);
– maintaining and using IT systems;
– administering and managing our website and systems and applications.

‍Security, quality and risk management activities
‍We have security measures in place to protect our and our clients’ information (including personal data), which involve detecting, investigating and resolving security threats.  Personal data may be processed as part of the security monitoring that we undertake; for example, automated scans to identify harmful emails.  We have policies and procedures in place to monitor the quality of our services and manage risks in relation to our suppliers.  We collect and hold personal data as part of our supplier contracting procedures.  We monitor the services provided for quality purposes, which may involve processing personal data.

‍Data retention
‍We retain the personal data processed by us for as long as is considered necessary for the purpose for which it was collected (including as required by applicable law or regulation).Personal data may be held for longer periods where extended retention periods are required by law or regulation and in order to establish, exercise or defend our legal rights.

‍VISITORS TO OUR OFFICESWe have security measures in place at our offices, including building access controls.We require visitors to our offices to sign in at reception and keep a record of visitors for a short period of time.  Our visitor records are securely stored and only accessible on a need to know basis (e.g. to look into an incident).

‍VISITORS TO OUR WEBSITE
Collection of personal data
‍Visitors to our websites are generally in control of the personal data shared with us.  We may capture limited personal data automatically via the use of cookies on our website. Please see the section on Cookies below for more information.We receive personal data, such as name, title, company address, email address, and telephone and fax numbers, from website visitors; for example when an individual subscribes to updates from us.Visitors are also able to send an email to us through the website. Their messages will contain the users name, email address and business details, as well as any additional information the user may wish to include in the message.We ask that you do not provide sensitive information (such as race or ethnic origin; political opinions; religious or philosophical beliefs; trade union membership; physical or mental health; genetic data; biometric data; sexual life or sexual orientation; and, criminal records) to us when using our website; if you choose to provide sensitive information to us for any reason, the act of doing so constitutes your explicit consent for us to collect and use that information in the ways described in this privacy statement or as described at the point where you choose to disclose this information.

‍Cookies
‍We use small text files called ‘cookies’ which are placed on your hard drives to assist in personalising and enriching your browsing experience by displaying content that is more likely to be relevant and of interest to you. The use of cookies is now standard operating procedure for most websites.  However if you are uncomfortable with the use of cookies, most browsers now permit users to opt-out of receiving them.  You need to accept cookies in order register on our website (where required).  You may find other functionality in the website impaired if you disable cookies. After termination of the visit to our site, you can always delete the cookie from your system if you wish.

‍Use of personal data
‍When a visitor provides personal data to us, we will use it for the purposes for which it was provided to us as stated at point of collection (or as obvious from the context of the collection).  Typically, personal data is collected to: register for certain areas of the site; subscribe to updates; enquire for further information; monitor and enforce compliance with our terms and conditions for use of our website; administer and manage our website, aggregate data for website analytics and improvements.Unless we are asked not to, we may also use your data to contact you with information about Modutherm’s business, services and events, and other information which may be of interest to you.  Should visitors subsequently choose to unsubscribe from mailing lists or any registrations, we will provide instructions on the appropriate webpage, in our communication to the individual, or the individual may contact us by email to modutherm@modularhg.co.uk. Our website does not collect or compile personal data for the dissemination or sale to outside parties for consumer marketing purposes or host mailings on behalf of third parties.

‍Data retention
‍Personal data collected via our websites will be retained by us for as long as it is necessary (e.g. for as long as we have a relationship with the relevant individual).