This policy aims to give you information on how Instanta Ltd (referred to as “we”, “us”, “the Company” in this policy) collects and processes your personal data when you purchase, or make a request for information about, our products or services and through your use of our website, including any data you may provide through our website when you sign up to receive our brochures, newsletters, quotes or purchase a product or service.
2. Important Information and Who We Are
Our website is not intended for children and we do not knowingly collect data relating to children.
It is important that you read this Privacy Statement 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 so that you are fully aware of how and why we are using your data. This Privacy Statement supplements the other notices and is not intended to override them.
Instanta Ltd is the data controller and responsible for your personal data (collectively referred to as “we”, “us” or “our” in this Privacy Statement).
Our Contact Details
Full name of legal entity: Instanta Ltd – company number: 00592540
Email address for enquiries around your data and rights: email@example.com
Telephone number: 0345 6 005 005
You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.
Changes to the Privacy Statement 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.
Our website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy notice of every website you visit.
3. The types of personal data we collect:
- Contact information - such as name, address (billing and home), phone number (landline and/or mobile), email address, and login information;
- Information about your purchase or rental of products or services – such as product registration information, warranty information.
- Your payment details, bank account, payment card details
- Consumer satisfaction and feedback data - such as the results of customer satisfaction and feedback surveys.
- Data collected when you are visiting our website - such as data collected through cookies and other automatically collected data to provide you with our websites, or information that you provide us with when visiting our websites (such as through contact forms etc.)
- Your correspondence and communication with us.
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.
Also our website, and services, is not intended for children and we do not knowingly collect data relating to children.
4. How we collect personal data:
- from you or your representative when purchasing your product, registering your product, visiting our website, activating your account, ordering a service, participating in our campaigns, creating a product review or when downloading and using an application;
- from our retailers or distributors;
- from our third-party service providers, suppliers and partners;
- from publicly available sources;
- from social media, e.g. Facebook if you choose to use Facebook to facilitate logging into our websites/ apps.
You may choose not to provide certain types of personal data to us. If you choose to do so, this may affect our ability to provide you with, and your ability to make use of, certain appliances and/or services or their functionalities and features. In this case, we may have to cancel our contract with you, but we will notify you if this is the case at the time. However, unless otherwise specified, your choice not to provide such information will not result in legal consequences for you.
We may also combine the personal data you provide to us with other information collected online or offline to the extent permitted by applicable laws, including information provided by third parties, and use or share it for the purposes described in this Privacy Statement. We may anonymise the information we collect (meaning that it can no longer be associated to you and hence no longer constitutes personal data).
5. Legal basis for the processing of personal data
We collect and process your personal data because it is required for.
- Complying with our rights under a contract of sale of goods and service
- Our legitimate business interest as listed, but not limited to.
- fulfilling a contract of sale
- sending promotional communication to our clients which are relevant to their needs
- product safety notification
- Warrantee and customer product service aftercare process
- Handling customer requests, complaints, or queries
- Complying with our legal and regulatory obligations
- Promoting and marketing our products
6. Your consent
Where the processing activity is based on your consent, you have the right to withdraw your consent at any time. The revocation of your consent will however not affect the lawfulness of any processing based on your consent before its withdrawal.
7. Information that we share
For the Processing purposes set out above, we may share or disclose your personal data:
- As required by law, to comply with legal process and/or to respond to requests from public and government authorities;
- With companies within the Culligan Group
- With service providers and suppliers trusted to provide services and appliances on our behalf as well as with our partners;
- With a third party in the event of a contemplated or actual reorganisation, merger, acquisition, sale, joint venture, assignment or other disposition of all or any portion of our business, assets and stock;
- To enforce our terms and conditions; or
- To protect our rights.
When sharing personal data with a third party, we require that such third party agrees to protect and handle your personal data in accordance with all legal, regulatory and contractual obligations, or other instructions we provide to them.
8. Your choices regarding marketing and information
You have certain choices regarding how we use and share your personal data for marketing and similar purposes to send you information about appliances, services, events and promotions. The communication may be sent to you via different channels: email, phone, post, social networks. We would like to provide you with the best experience, therefore the communication might be tailored based on the data collected and your preferences.
Where required by law, we will obtain your prior consent. You may withdraw your consent to marketing, or request that we stop using your personal information for this purpose, at any time, for example, you can unsubscribe from messages by following the unsubscribe instructions within the message.
If you choose not to receive marketing communications, your personal data may still be used for the other purposes described in this Privacy Statement, such as communicating with you for administrative or transaction purposes as part of the contractual relationship we have with you or where required by law.
9. Your rights under GDPR
If you are located in the EU/EEA, or if your personal data is otherwise being processed by our entity within the EU/EEA, you have the following rights:
- Request access to your personal data;
- Rectification of your personal data;
- Request the erasure of your personal data;
- Restrict the processing of your personal data;
- Request that your personal data be provided in a format that can be transferred to you or another organisation (portability);
- Object to the processing of your personal data;
- Withdraw consent at any time where we are relying on consent to process your personal information; and
- Lodge a complaint with the relevant supervisory authority.
For further information on each of those rights, including the circumstances in which they apply, see the Guidance from the UK Information Commissioner’s Office (ICO) on individuals’ rights under the General Data Protection Regulation.
If you have any questions regarding these rights, or if you would like to exercise any of these rights, you may do so in writing, by phone or via email (firstname.lastname@example.org).
Please note that exercising some of these rights may impact our ability to provide you with certain appliances or services.
You will not be charged 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.
We will aim to respond to all legitimate requests within one month. This may take longer depending on the complexity of the request, in this case we will inform you and keep to updated.
10. Security of your personal data
We will take appropriate technical and organizational measures in line with applicable data protection laws, including requiring our service providers, business partners or professional advisors to use appropriate measures to protect your personal data.
In addition, we limit access to your personal data to those employees, agents, 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.
11. Storage of your personal data
We will store your personal data for as long as may be required by law, or as required under any contract. If there is no legal requirement, we will retain information about you only for so long as is necessary for the purpose/s for which it was collected.
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.
By law we have to keep basic information about our customers for six years after they cease being customers for tax purposes.
12. International Transfers
As a global company, we may transfer and store your personal data in the European Union (EU) or in the European Economic Area (EEA) or other locations where we our have servers.
We may transfer your information between Culligan group companies or transfer information to our international third-party service providers and suppliers acting on our behalf, for the purposes described in this Privacy Statement.
Whenever we transfer your personal data out of the EEA, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:
- We may transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data by the European Commission. For further details, see European Commission: Adequacy of the protection of personal data in non-EU countries.
- Where we use certain service providers, we may use specific contracts approved by the European Commission which give personal data the same protection it has in Europe. For further details, see European Commission: Model contracts for the transfer of personal data to third countries.
- Where we transfer your personal data to the US, we may do so as part of the Privacy Shield which requires companies in the US to provide similar protection to personal data shared between the Europe and the US. For further details, see European Commission: EU-US Privacy Shield.
Please contact us if you require further information on how we transfer your personal data out of the EEA.