Privacy Policy

Rhodium Engineering services Limited (“Company”, “we”, “us” or “our”) is committed to protecting the privacy and security of your personal data. This Privacy Notice describes how we collect, use and look after your personal data when you visit our website (regardless of where you visit it from) including when you submit a query through our ‘Contact Us’ page or use any other interactive services on our website which involve you submitting any of your personal data to us. It also tells you about your rights and how the law protects you.

This Privacy Notice is provided in a layered format so you can click through to the specific areas set out below. The Glossary sets out the meaning of terms used in this Privacy Notice.

Important information

The data we collect about you

How personal data is collected

How we use your personal data

Disclosure of personal data

International transfers

Data security

Data retention

Your legal rights

Schedule

1. Important      information

This policy is effective from 06/04/2023

This Privacy Notice supplements the other notices on our website (including our terms of use (Terms)) and is not intended to override them.

Rhodium Engineering Services Limited is the controller and responsible for your personal data.

To assist your understanding of this Privacy Notice, Schedule 1 contains a glossary of terms used in this Privacy Notice, examples of types of personal data we collect, how we use it, the lawful basis for processing such data and further details of your rights.

If you have any questions about this Privacy Notice, including any requests to exercise your legal rights, please contact us.

You have the right to make a complaint at any time to the ICO (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.

Our website is not intended for children and we do not knowingly collect data relating to children.

Your duty to inform us of changes

It is important that the data we hold about you is accurate and current, therefore please keep us informed of any changes to your personal data.

Third-party links

Our website may include links to third-party websites, plug-ins and applications. By clicking on these links or enabling connections you may be allowing third parties to collect or share your personal data. We have no control these third-party websites, plug-ins or applications and are not responsible for their privacy notices, therefore you should also read their privacy notices to understand what personal data they collect about you and how they use it.

1. The      data we collect about you

Part 1 of Schedule 1 lists the types of personal data we may process.

We also collect, use and share aggregated data. However, if we combine aggregated data with your personal data so that it can directly or indirectly identify you, we treat this as your personal data.

We do not collect any special categories of personal data or any information about criminal convictions and offences.

Failure to provide personal data

If we are required by law, or under the terms of a contract we have with you, to collect your personal data and you fail to provide it, we may not be able to enter into perform the contract with you and, we may have to cancel a product or service. We will notify you of this at the relevant time.

1. How      personal data is collected

We collect personal data in the following ways:

Direct interactions

You may provide personal data   when you complete online forms, request products/services, join our mailing   list or otherwise use any interactive services on our website which involve   the submission of your personal data or where you correspond with us (by   post, phone or email).

Automated technology

We automatically collect   personal data (technical and usage) when you browse or interact with our   website, by using cookies, server logs and other similar technologies. We may   also receive technical data about you if you visit other websites which use   our cookies.

Publicly available sources

We may collect personal data   from publicly available sources such as Companies House, the Electoral   Register and credit reference agencies based inside the EU, and LinkedIn   which is based outside the EU.

Third parties

We may receive personal data   from: (a) analytics providers; (b) advertising networks; and (c) search   information providers; (d) our suppliers such as website support and   maintenance providers (and in each case, these third parties may be based   outside or inside the EEA).

1. How      we use your personal data

We will only use your personal data when the law allows us to. Most commonly, we will use your personal data:

• to      perform the contract we are to enter into or have entered into with you;
• to      comply with a legal obligation; and
• where      it is necessary to carry out our legitimate interests (or those of a third      party) and your interests and fundamental rights do not override those      interests.

Part 2 of Schedule 1 sets out the lawful basis we will rely on to process your personal data.

We do generally only rely on consent as a legal basis for processing your personal data to send email marketing communications and you have the right to withdraw your consent at any time by contacting us.

We may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your information.

Marketing

Generally, you will only receive marketing communications from us if you have requested information from us, purchased products/services from us or if you consent to marketing at the time we collect your personal data and you have not subsequently opted out or withdrawn your consent or if we have another basis to send you the marketing communications (which includes “soft opt-in” where we have provided products to you in the past and you have not opted-out).

We may also market directly to you where we have legitimate interests to do so and we are not prevented by any other applicable data protection or marketing laws.

How to opt out

You can opt out of email marketing by clicking the unsubscribe button within the particular marketing email. You can also withdraw your consent to marketing at any time by contacting our DPM.

Even if you opt out of receiving marketing, we may still use your personal data for other purposes provided we have a lawful basis to do so.

Change of purpose

We will only use your personal data for the purpose that we originally collected it for, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose.

If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to use your personal data in this manner.

We may process your personal data (without your knowledge or consent) where this is required or permitted by law.

1. Disclosure      of your personal data

We may have to share your personal data with third parties further details of which are set out in Part 4 of Schedule 1. We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes. They can only process your personal data for specified purposes and in accordance with our instructions.

1. International      transfers

Some of our external third parties are based outside the European Economic Area (EEA) so their processing of your personal data will involve a transfer of data outside the EEA.

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      will only transfer your personal data to countries that have been deemed      to provide an adequate level of protection for personal data by the      European Commission.
• we      use specific contracts approved by the European Commission which give      personal data the same protection it has in Europe with our services      providers;
• we      may transfer data to US based service providers under the Privacy Shield      which requires them to provide similar protection to personal data shared      between the Europe and the US.

Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the EEA.

1. Data      security

We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. We also limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know and they can only process your personal data on our instructions and will be subject to a duty of confidentiality.

We have procedures in place 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.

1. Data      retention

We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.

Details of retention periods for different aspects of your personal data are available in our retention policy which you can request from us. However, we are legally required to keep basic information about our customers (including contact, identity, financial and transaction data) for six years after they cease being customers, for tax purposes.

We may also anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes. We can use anonymised information indefinitely without further notice to you.

1. Your      legal rights

Your legal rights in relation to your personal data are set out in Part 3 of Schedule 1. If you wish to exercise any of your rights, please contact our DPM.

You will not have to pay a fee to exercise any of your rights. However, if your request is clearly unfounded, repetitive or excessive, we may charge a reasonable fee for this information or refuse to comply with your request.

We may ask you to provide further information to help us confirm your identity. This is a security measure to ensure that personal data is not disclosed to any person who does not have the right to receive it.

We aim to respond to requests within one month. If your request is particularly complex or you have made a number of requests it may take us longer to respond. In this case, we will notify you and keep you updated.

1. Types      of personal data

contact data

postal address, email address   and telephone number

identity data

first name, last name, job   title

marketing and communication   data

your preferences in receiving   marketing from us and our group members and your communication preferences

profile data

your interests, preferences,   feedback and details of any downloads

technical data

internet protocol (IP) address,   your login data, browser type and version, time zone setting and location,   browser plug-in types and versions, operating system and platform and other   technology on the devices you use to access our website

1. Lawful      basis for processing and processing activities

The lawful basis upon which we may rely on to process your personal data are:

consent

you have given your express   consent for us to process your personal data for a specific purpose.

contract

the processing is necessary for   us to perform our contractual obligations with you under our contract, or   because you have asked us to take specific steps before entering into a   contract with you.

legal obligation

the processing is necessary for   us to comply with legal or regulatory obligation.

legitimate interests

the processing is necessary for   our or a third party’s legitimate interest e.g. in order for us to provide   the best service to you via our website. Before we process your personal data   on this basis we make sure we consider and balance any potential impact on   you, and we will not use your personal data on this basis where such impact   outweighs our interest.

Set out below are specific details of the processing activities we undertake with your personal data and the lawful basis for doing this.

Purpose/Activity

Type of data

Lawful basis for processing

to register your interest in   our services

identity & contact

legitimate interests and   consents

to manage our relationship with   you, notifying you about changes to our Terms or Privacy Notice and ask you   to leave a review or take a survey

identity, contact, profile   & marketing & communications

(i) to perform our contract   with you

(ii) as necessary to comply   with a legal obligation

(iii) as necessary for our   legitimate interests in keeping our records updated and analysing how   customers use our products/services.

to administer and protect our   business and this website (including troubleshooting, data analysis, testing,   system maintenance, support, reporting and hosting of data)

identity, contact &   technical

(i) as necessary for our   legitimate interests in running our business, provision of administration and   IT services, network security, to prevent fraud and in the context of a   business reorganisation or group restructuring exercise

(ii) as necessary to comply   with any legal obligations

to deliver relevant website   content/advertisements to you and measure or understand the effectiveness of   our advertising

identity, contact, profile,   usage, marketing & communications & technical

as necessary for our legitimate   interests in studying how customers use our products/services, to develop   them, to grow our business and to inform our marketing strategy

to use data analytics to   improve our website, products/services, marketing, customer relationships and   experiences

technical & usage

as necessary for our legitimate   interests to define types of customers for our products and services, to keep   our website updated and relevant, to develop our business and to inform our   marketing strategy

to make suggestions and   recommendations to you about goods or services that may be of interest to   you, including promotional offers

identity, contact, technical,   usage & profile

as necessary for our legitimate   interests to develop our products/services and grow our business

1. Your      legal rights

You have the following legal rights in relation to your personal data:

access your data

you can ask for access to and a   copy of your personal data and can check we are lawfully processing it

correction

you can ask us to correct any   incomplete or inaccurate personal data we hold about you

erasure

you can ask us to delete or   remove your personal data where:

1. there is no good reason        for us continuing to process it;
2. you have successfully        exercised your right to object (see below);
3. we may have processed your        information unlawfully; or
4. we are required to erase        your personal data to comply with local law.

We may not always be able to   comply with your request for specific legal reasons, which will be notified   to you at the time of your request.

object

you can object to the   processing of your personal data where:

1. where we are relying on        our legitimate interest (or those of a third party) as the basis for        processing your personal data, if you feel it impacts on your        fundamental rights and freedoms;
2. where we are processing        your personal data for direct marketing purposes.

In some cases, we may   demonstrate that we have compelling legitimate grounds to process your   information which override your rights and freedoms and in such   circumstances, we can continue to process your persona data for such   purposes.

restrict processing

you can ask us to us to suspend   or restrict the processing of your personal data, if:

1. you want us to establish        the accuracy of your personal data;
2. our use of your personal        data is unlawful, but you do not want us to erase it;
3. you need us to hold your        personal data (where we no longer require it) as you need it to        establish, exercise or defend legal claims; or
4. you have objected to our        use of your personal data, but we need to verify whether we have        overriding legitimate grounds to use it.

request a transfer

you can request a transfer of   your personal data which is held in an automated manner and which you   provided your consent for us to process such personal data or which we need   to process to perform our contact with you, to you or a third party. We will   provide your personal data in a structured, commonly used, machine-readable   format.

withdraw your consent

you can withdraw your consent   at any time (where we are relying on consent to process your   personal data). This does not affect the lawfulness of any processing carried   out before you withdraw your consent.

1. Third      Parties

service providers

acting as processors who   provide IT and system administration services

professional advisors

acting as processors or joint   controllers including lawyers, bankers, auditors and insurers who provide   consultancy, banking, legal, insurance and accounting services

HM Revenue & Customs,   regulators and other authorities

acting as processors or joint   controllers based in the United Kingdom who require reporting of processing   activities in certain circumstances

third parties

third parties whom we may   choose to sell, transfer, or merge parts of our business or our assets.   Alternatively, we may seek to acquire other businesses or merge with them. If   a change happens to our business, then the new owners may use your personal   data in the same way as set out in this Privacy Notice

analytics and tracking   companies

acting as processors who   provide analytics and tracking software

1. Glossary

aggregated data

information such as statistical   or demographic data which may be derived from personal data but which cannot   by itself identify a data subject

controller

a body that determines the   purposes and means of processing personal data

data subject

an individual living person   identified by personal data (which will generally be you)

personal data

information identifying a data   subject from that data alone or with other data we may hold but it does not   include anonymised or aggregated data

processor

a body that is responsible for   processing personal data on behalf of a controller.

special categories of personal   data

information about race,   ethnicity political opinions, religious or philosophical beliefs, trade union   membership, health, genetic, biometric data, sex life, sexual orientation.

ICO

Information Commissioner’s   Office, the UK supervisory authority for data protection issues.