BACKGROUND:
Thom Micro Systems (TMS)
understands that your privacy is important to you and that you care about how
your personal data is used and shared online. We respect and value the privacy
of everyone who visits this website, www.tms-scotland.co.uk
(“our site”) and will only collect and use personal data in ways that are
described here, and in a manner that is consistent with our obligations and
your rights under the law.
Please read this Privacy
Policy carefully and ensure that you understand it. Your acceptance of our
Privacy Policy is deemed to occur upon your first use of our site. If you do not accept and agree with
this Privacy Policy, you must stop using our site immediately.
1.
Definitions and
Interpretation
In this Policy the following
terms shall have the following meanings:
“Account” |
means an account required to access and/or use certain areas and
features of our site; |
“Cookie” |
means a small text file placed on your computer or device by our site
when you visit certain parts of our site and/or when you use certain features
of our site. Details of the Cookies used by our site are set out in section
13, below; |
“Cookie Law” |
means the relevant parts of the Privacy and Electronic Communications
(EC Directive) Regulations 2003; |
“personal data” |
means any and all data that relates to an identifiable person who can
be directly or indirectly identified from that data. In this case, it means
personal data that you give to us via our site. This
definition shall, where applicable, incorporate the definitions provided in
the EU Regulation 2016/679 – the General Data Protection Regulation (“GDPR”);
and |
“we/us/our” |
means Thom Micro Systems (TMS) , a limited company registered in
Scotland under company number SC075023, whose registered address and main
trading address is 7 Central Park Avenue, Central Park, Larbert FK5 4RX. |
2.
Information About us
2.1
Our site is owned
and operated by Thom Micro Systems
Ltd, a limited company registered in Scotland under company number SC075023,
whose registered address and whose main trading address is 7 Central Park
Avenue, Central Park, Larbert FK5 4RX.
2.2
Our VAT number is 353669330
2.3
Our Data
Protection Officer is Rebecca Thom and can be contacted by email at privacy@tms-scotland.com
or by telephone on 01324 550760, or by post at 7 Central Park Avenue, Central
Park, Larbert, FK5 4RX.
3.
What Does This
Policy Cover?
This Privacy Policy applies only
to your use of our site. Our site may contain links to other websites. Please
note that we have no control over how your data is collected, stored, or used
by other websites and we advise you to check the privacy policies of any such
websites before providing any data to them.
4.
Your Rights
4.1
As a data subject,
you have the following rights under the GDPR, which this Policy and our use of
personal data have been designed to uphold:
4.1.1
The right to be
informed about our collection and use of personal data;
4.1.2
The right of
access to the personal data we hold about you (see section 12);
4.1.3
The right to rectification
if any personal data we hold about you is inaccurate or incomplete (please
contact us using the details in section 14);
4.1.4
The right to be
forgotten – i.e. the right to ask us to delete any personal data we hold about
you (we only hold your personal data for a limited time, as explained in section
6 but if you would like us to delete it sooner, please contact us using the
details in section 14);
4.1.5
The right to
restrict (i.e. prevent) the processing of your personal data;
4.1.6
The right to data
portability (obtaining a copy of your personal data to re-use with another
service or organisation);
4.1.7
The right to
object to us using your personal data for particular purposes; and
4.1.8
Rights with
respect to automated decision making and profiling.
4.2
If you have any
cause for complaint about our use of your personal data, please contact us
using the details provided in section 14 and we will do our best to solve the
problem for you. If we are unable to help, you also have the right to lodge a
complaint with the UK’s supervisory authority, the Information Commissioner’s
Office.
4.3
For further
information about your rights, please contact the Information Commissioner’s
Office or your local Citizens Advice Bureau.
5.
What Data Do we
Collect?
Depending upon your use of our
site, we may collect some or all of the following personal data (please also
see section 13 on our use of Cookies and similar technologies):
5.1
name;
5.2
business/company name
5.3
contact
information such as email addresses and telephone numbers;
5.4
demographic information
such as post code;
6.
How do we use Your
Data?
6.1
All personal data
is processed and stored securely, for no longer than is necessary in light of
the reason(s) for which it was first collected. We will comply with our
obligations and safeguard your rights under the GDPR at all times. For more details on security see section 7, below.
6.2
Our use of your
personal data will always have a lawful basis, either because it is necessary
for our performance of a contract with you, because you have consented to our
use of your personal data (e.g. by subscribing to emails), or because it is in our
legitimate interests. Specifically, we may use your data for the following
purposes:
6.2.1
Providing and
managing your Account;
6.2.2
Providing and
managing your access to our site;
6.2.3
Supplying our
products and services to you (please note that we require your personal
data in order to enter into a contract with you);
6.2.4
Personalising and
tailoring our products and services for you;
6.2.5
Replying to emails
from you;
6.2.6
Supplying you with
emails that you have opted into (you may unsubscribe or opt-out at any time by
emailing privacy@tms-scotland.com);
6.3
With your
permission and/or where permitted by law, we may also use your data for
marketing purposes which may include contacting you by email, telephone, text message or post with information, news and offers on our
products and services. We will not, however, send you any unsolicited marketing
or spam and will take all reasonable steps to ensure that we fully protect your
rights and comply with our obligations under the GDPR and the Privacy and Electronic Communications (EC Directive)
Regulations 2003.
6.4
You have the right
to withdraw your consent to us using your personal data at any time, and to
request that we delete it.
6.5
We do not keep
your personal data for any longer than is necessary in light of the reason(s)
for which it was first collected. Data will therefore be retained for the
following periods (or its retention will be determined on the following bases):
6.5.1
Personal data
obtained for the purposes of buying one of our products or services will be
retained for no longer than one year after you cease to become a customer of TMS.
6.5.2
Personal data will
be retained for marketing purposes for as long as we have your consent to hold
such data. You can remove permission for this at any time.
7.
How and Where Do we
Store Your Data?
7.1
We only keep your
personal data for as long as we need to in order to use it as described above
in section 6, and/or for as long as we have your permission to keep it.
7.2
Your data will
only be stored by TMS in the UK.
7.3
Data security is
very important to us, and to protect your data we have taken suitable measures
to safeguard and secure data collected through our site.
8.1
We may sometimes
contract with third parties to supply products and services to you on our
behalf. These may include payment processing, delivery of goods or services,
search engine facilities, advertising, and marketing. In some cases, the third
parties may require access to some or all of your data. Where any of your data
is required for such a purpose, we will take all reasonable steps to ensure
that your data will be handled safely, securely, and in accordance with your
rights, our obligations, and the obligations of the third party under the law.
8.2
We may sometimes
use third party data processors that are located outside of the European Economic Area (“the EEA”) The EEA consists
of all EU member states, plus Norway, Iceland, and Liechtenstein. Where we
transfer any personal data outside the EEA, we will take all reasonable steps
to ensure that your data is treated as safely and securely as it would be
within the UK and under the GDPR.
8.3
In certain
circumstances, we may be legally required to share certain data held by us,
which may include your personal data, for example, where we are involved in
legal proceedings, where we are complying with legal requirements, a court
order, or a governmental authority.
9.
What Happens If our
Business Changes Hands?
9.1
We may, from time
to time, expand or reduce our business and this may involve the sale and/or the
transfer of control of all or part of our business. Any personal data that you
have provided will, where it is relevant to any part of our business that is
being transferred, be transferred along with that part and the new owner or
newly controlling party will, under the terms of this Privacy Policy, be
permitted to use that data only for the same purposes for which it was
originally collected by us.
9.2
In the event that
any of your data is to be transferred in such a manner, you will be contacted
in advance and informed of the changes.
10.
How Can You
Control Your Data?
10.1
In addition to
your rights under the GDPR, set out in section 4, when you submit personal data via our site, you may be given options to
restrict our use of your data. In particular, we aim to give you strong
controls on our use of your data for direct marketing purposes (including the
ability to opt-out of receiving emails from us which you may do by
unsubscribing using the links provided in our emails and at the point of
providing your details).
10.2
You may also wish
to sign up to one or more of the preference services operating in the UK: The
Telephone Preference Service (“the TPS”), the Corporate Telephone Preference
Service (“the CTPS”), and the Mailing Preference Service (“the MPS”). These may
help to prevent you receiving unsolicited marketing. Please note, however, that
these services will not prevent you from receiving marketing communications
that you have consented to receiving.
11.
Your Right to
Withhold Information
11.1
You may access
certain areas of our site without providing any data at all.
11.2
You may restrict our
use of Cookies.
12.
How Can You Access
Your Data?
You have the right to ask for a
copy of any of your personal data held by us (where such data is held). Under
the GDPR, no fee is payable and we will provide any and all information in
response to your request free of charge.
Please contact us for more details at rebecca.thom@tms-scotland.com, or
using the contact details below in section 14.
13.
Our use of Cookies
13.1
Our site does not
currently use Cookies. Our policy will updated immediately if this changes in
the future.
14.
Contacting us
If you have any questions about our
site or this Privacy Policy, please contact us by email at privacy@tms-scotland.com,
by telephone on 01324 550760, or by post at 7 Central Park Avenue, Central
Park, Larbert FK5 4GW. Please ensure that your query is clear, particularly if
it is a request for information about the data we hold about you (as under
section 12, above).
15.
Changes to our
Privacy Policy
We may change this Privacy
Policy from time to time (for example, if the law changes). Any changes will be
immediately posted on our site and you will be deemed to have accepted the
terms of the Privacy Policy on your first use of our site following the
alterations. We recommend that you check this page regularly to keep
up-to-date.
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