1.1 Nature of this policy
This policy describes how we collect and use personal data in accordance with the General Data Protection Regulation (GDPR), the Data Protection Act 2018 and any other national implementing laws, regulations and secondary legislation, as amended or updated from time to time, in the UK (‘Data Protection Legislation’).
Please read the following carefully to understand our practices regarding personal data and how we will treat it.
1.2 About us
Vita Modular Ltd, whose registered office address is 204 Winsford Avenue, Allesley Park, Coventry, West Midlands, CV5 9NB; Company number 13339855 ("we", “us”, “our” and “ours”)is a company designing and assembling modular rooms for installation in domestic and commercial premises.
1.3 Purpose of the policy
As a provider of both goods and services to private customers and businesses, we only collect personal data in limited circumstances. The policy is intended to inform all of those persons whose data we receive during the normal course of our business.
For the purpose of the Data Protection Legislation and this policy, we will be a ‘controller’ of the personal data that we gather or are provided with in order to do business.
2. THE POLICY
2.1 How we may collect your personal data
We obtain personal data about you either from you or, in the case of a business customer, from a person within the business. For example, when:
• your request an estimate from us when considering whether to commission us to provide a modular building;
• you engage us to provide a modular building and also during the provision of the works leading up to and including the completion of the installation;
• you contact us through the website at www.vita-modular.co.uk or by email, telephone, post or social media (for example when you have a query about our products or services); or
• from third parties and / or publicly available resources (for example, from your employer).
2.2 The kind of information held about you
The information we hold about you may include the following:
• for private customers we will need your name and address and the contact details that you would like us to use together with the name and address (if different) of the occupier of the land where we are to install a modular room;
• if you represent a business customer, we will need your name, the trading address of the customer for delivery and installation and your point of contact details or the details of another person having authority to commission us to provide a modular room;
• the details of contact we have had with you in relation to the provision, or the proposed provision, of our services including our correspondence and communications with you;
• information about any complaints and enquiries you or the customer make to us;
• information we receive from other sources, such as publicly available information or information provided by a third party, for example, the local authority in the area in which the installation address is located.
We will not usually be dealing with third parties unless there is an agreement for us to provide services in relation to planning consent or building regulations. Where that is within the contract that we go on to make or have made, you will be aware of our contact, the records provided by the third party and the extent of the personal data that is provided.
Our policy is to collect and process the minimum amount of personal data necessary for us to deliver the goods and services in the normal course of our business.
2.3 Basis for processing data
The legal basis for collecting and using the information described above will depend on the type of personal data collected and the specific context for which we have collected it.
We will normally collect personal data from you only:
• where we need the personal data to negotiate or enter into a contract with you, the customer, or a business customer that you are representing;
• where the data processing is in our legitimate interests and not overridden by your rights; or
• where we have your consent to do so.
We have a legitimate interest in providing our services. In some cases, we may also have a legal obligation to collect personal data from you.
Occasionally, the nature of the modular room that we are commissioned to install may lead to us having more sensitive data concerning the health of the customer or another member of the family, a co-worker or some other person that accesses the installation address.
In some instances, our contract with a customer may mean that we process more sensitive information (such as health information) which is called ‘special category data’. We do not intend to collect such sensitive personal data from any other personas it will be sufficient for us to know any particular instructions applicable for use to which the modular room will be put. Any other person whose data you may share must first provide us with their consent for us to be made aware of their details.
Sensitive personal data, should it be necessary for us to process it, will always be processed and stored securely.
Any person whose data we process or control may withdraw their consent to us processing their data at any time but this may mean that we can no longer deliver our obligations or some of them under a contract with the customer.
2.4 How we use the personal data that we hold
We may use your personal data in order to:
• carry out our obligations arising from any contracts entered into between a customer and ourselves;
• provide you with information related to our goods and services that you request from us or which we feel may interest you, provided you have consented to be contacted for such purposes;
• seek your thoughts and opinions on the goods and services we provide; and
• notify you about any changes to your order or circumstances relating to your order.
In some circumstances we may anonymise or pseudonymise the personal data so that it can no longer be associated with you, in which case we may use it without further notice to you.
If you do not give us your authority to receive information about you or if you decline to provide it when requested, we may not be able to make or perform a contract with you. Further we may be unable to comply with our legal or regulatory obligations.
We may also process your personal data without your knowledge or consent, in accordance with this policy, where we are legally required or permitted to do so.
2.5 Data retention
We will only retain personal data for as long as is necessary to fulfil the purposes for which it is collected.
When assessing what retention period is appropriate for your personal data, we take into consideration:
• the requirements of our business and the services provided;
• any statutory or legal obligations;
• the purposes for which we originally collected the personal data;
• the lawful grounds on which we based our processing;
• the types of personal data we have collected;
• the amount and categories of your personal data; and
• whether the purpose of the processing could reasonably be fulfilled by other means.
We will keep the names and addresses of customers where we have installed a modular room for the duration of any applicable warranty period which may be applicable under consumer protection law or other wise implied by law in any contract for sale.
Where a stand-alone warranty has been issued after installation of a modular room we must keep a record of the person entitled to claim under the warranty for the duration of the warranty period.
2.6 Change of purpose
Where we need to use your personal data for another reason, other than for the purpose for which we collected it, we will only use your personal data where that reason is compatible with the original purpose.
Should it be necessary to use your personal data for a new purpose, we will notify you and communicate the legal basis which allows us to do so before starting any new processing.
2.7 Data sharing
We may share your personal data with third parties where we are required to do so by law, where it is necessary to administer the relationship between a customer and ourselves or where we have another legitimate interest in doing so. The expression “third parties” means third-parties that provide services to us in running our business. The following activities may be carried out by third-party service providers and you may ask us to identify them at any time whilst we retain your data:
• the provision of business record back up services
• the company accountants
• legal advisers to the company
• sub-contracted persons who are providing services under any contract between us
Our third-party service providers are required to take commercially reasonable and appropriate security measures to protect your personal data. We only permit our third-party service providers to process your personal data for specified purposes and in accordance with our instructions.
2.8 Transferring personal data outside of the EU
We will not transfer the personal data that we collect about you outside of the EEA.
2.9 Data security
We have put in place commercially reasonable and appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. 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 data security breach and will notify you and any applicable regulator of a suspected breach where we are legally required to do so.
2.10 Rights of access, correction, erasure and restriction
It is important that the personal data we hold about you is accurate and current. Should your personal data change, please notify us of any changes of which we need to be made aware by contacting us, using the contact details below.
By law you have the right to:
• request access to your personal data. This enables you to receive details of the personal data we hold about you and to check that we are processing it lawfully.
• request correction of the personal data that we hold about you.
• request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have exercised your right to object to processing (see below).
• object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this basis. You also have the right to object where we are processing your personal data for direct marketing purposes.
• request the restriction of processing of your personal data. This enables you to ask us to suspend the processing of personal data about you, for example if you want us to establish its accuracy or the reason for processing it.
• request the transfer of your personal data to you or another data controller if the processing is based on consent, carried out by automated means and this is technically feasible.
If you want to exercise any of the above rights, please email our DPM at firstname.lastname@example.org.
You will not have to pay 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 for access is clearly unfounded or excessive. Alternatively, we may refuse to comply with the request in such circumstances.
We may need to request specific information from you to help us confirm your identity and ensure your right to access the information (or to exercise any of your other rights). This is another appropriate security measure to ensure that personal data is not disclosed to any person who has no right to receive it.
2.11 Right to withdraw consent
In the limited circumstances where you may have provided your consent to the collection, processing and transfer of your personal data for a specific purpose (for example, in relation to direct marketing that you have indicated you would like to receive from us), you have the right to withdraw your consent for that specific processing at any time.
To withdraw your consent, please email our DPM, email@example.com.
Once we have received notification that you have withdrawn your consent, we will no longer process your personal data (“personal data”) for the purpose or purposes you originally agreed to, unless we have another legitimate basis for doing so in law.
2.12 Changes to this policy
We also collect information about you from other sources. For example, our website automatically collects information from your computer using “cookies” which provides us with limited personal data. 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 website owners. For further information visit www.aboutcookies.org or www.allaboutcookies.org.
You can set your browser not to accept cookies and the above websites tell you how to remove cookies from your browser. However, in a few cases some of our website features may not function as a result.
2.14 Contact us
If you have any questions regarding this policy or if you would like to speak to us about the manner in which we process your personal data, please email our DPM, firstname.lastname@example.org or telephone our DPM on the contact number available on the website.
You also have the right to make a complaint to the Information Commissioner's Office (ICO), the UK supervisory authority for data protection issues, at any time. The ICO’s contact details are as follows:
Information Commissioner's Office
Telephone -0303 123 1113 (local rate) or 01625 545 745