PRIVACY AND SECURITY POLICY
Last updated: [September 2021]
1. INTRODUCTION
1.1 Dear User, Rawlplug Limited (“Rawlplug”, “we”, “us” or “our”) is a company incorporated in England and Wales with company number 5497750, having its resitered address at 21 Holborn viaduct, Lonodn, EC1A 2DY.
1.2 Rawlplug is committed to protecting your online privacy and secure all personal information you provide. Rawlplug respects and values the privacy of all its customers, employees and suppliers and will only collect and use personal data in ways which are described in these Terms, and in a way consistent with our obligations and your rights under the law.
1.3 Any personal data Rawlplug collects will be used in accordance with applicable laws, including the Data Protection Act 2018 (the “Act”) and where relevant, the General Data Protection Regulations (EU) 2016/679 (“GDPR”) or such other applicable legislation.
2. The term ‘personal data and/or information’ as used herein comprises any information relating to an identified or identifiable natural person; an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.
2.1 WHO IS THE CONTROLLER
2.2 Any personal data collected via the Website or purchase of our goods is controlled by Rawlplug. Rawlplug is the “controller” under the Act and under the Act, Rawlplug must always have a lawful basis for using and collecting your personal data.
2.3 You may contact us at any time in relation to personal data of yours processed by us.
2.4 Rawlplug is a part of a Rawlplug Group which is a holding of companies for which RAWLPLUG S.A. with its registered office in Wroclaw, Poland (VAT EU: 895-168-78-80) is the dominant company on the grounds of Statute on Accounts dated on 29 September 1994 (unified text Dz.U.2019.351 as amended from time to time), comprising of following companies:
- Rawlplug S.A., ul. Kwidzyńska 6, 51-416 Wrocław, Poland;
- Koelner Rawlplug IP sp. z o.o., ul. Kwidzyńska 6, 51-416 Wrocław, Poland;
- Rawlplug Ltd, Skibo Drive, Thornliebank Industrial Estate, Glasgow G46 8JR, Wlk. Brytnia;
- Koelner Deutschland GmbH, Lutherstr. 54, 73614 Schorndorf, Germany;
- RAWLPLUG France SAS, Bâtiment DC6, ZAC de la Feuchère 16, rue Jean Mermoz, 77290 COMPANS, France;
- Rawlplug Middle East FZE, P.O. Box 261024, Jebel Ali Free Zone, Dubai, ZEA;
- Rawlplug Building & Construction Material Trading (L.L.C.), Al Qouz Industrial Area 3, 22 ND Street, Compound 81, P. O. Box 261024 Dubai, ZEA;
- Rawl Scandinavia AB, Baumansgatan 4, 593 32 Västervik, Sweden;
- Rawlplug Ireland Ltd, Unit 10 Donore Business Park, Donore Road Drogheda, Co Louth, Ireland;
- Koelner CZ s.r.o, Komerční Park Tulipan, Palackého 1154/76A (hala T3), 702 00 Ostrava-Přívoz, Czech Republic;
- KOELNER Slovakia s.r.o., Dlhá 95, 010 09 Žilina, Slovakia;
- Koelner Hungária Kft., Jedlik Ányos u. 34, 2330 Dunaharaszti, Hungary;
- UAB Koelner Vilnius, Žarijų g. 2, LT-02300, Vilnius, Lithuania;
- Rawlplug Italia s.r.l., Via Savonarola 217 Padova cap 35137, Italy,
- Koelner Ukraine LLC, vul. Naukova 3a, 79060 Lviv, Ukraine;
- Koelner Trading KLD LLC, ul. Dzerzhinskogo 219, 236034 Kaliningrad, Russia;
- Rawlplug Singapore Pte. Ltd., 25B, Loyang Crescent, Block 302, #04-11, Loyang Offshore Supply Base, Sinagpore 506817 #05-34, Singapore;
- Rawlplug Shanghai Trading Co. Ltd., 1/F, Building 1 No.251 Yaohua Rd, Shanghai Free Trade Zone, China;
- Rawlplug Inc., Corp. Trust Center 1209 Orange St. New Castle, Delaware DE 19801, USA.
3. INFORMATION RAWLPLUG COLLECTS
3.1 Rawlplug will not collect personal data about you, except where it is specifically and knowingly provided by you, including through the use of the website or when purchasing goods. Rawlplug may collect other information it learns about you from your use of the Website. As such Rawlplug may collect and process the following personal data about you:
- contact and identification information: name, surname, address, telephone number, email address, tax number and any identification number (such as number of ID document),
- payment information: name and surname of a card holder, payment card number and expiration date, bank account number.
- data provided through any forms available on the Website, such as data required to create an user-account, purchase the products and/or services offered by Rawlplug, newsletter subscription, publishing of an information. Rawlplug may ask you to provide additional information if you are willing to participate in promotional actions or communicated problems with the Website.
- login and access credentials: username and password for your account on the Website, or social media identifications.
- data Rawlplug receives from the computer, mobile phone or other device you use to access the Website: IP address, location and time.
- data Rawlplug receives when you interact with the Website: posted content, photographs.
3.2 Rawlplug may also collect other information, other than personal data, such as the contact and business details of organization entity you represent, browser you use, your operating system or the pages you visit, information received when you view another person's profile or post content etc.
3.3 Rawlplug collects this information, including personal data:
- directly from you when you provide it to Rawlplug.
- automatically as you navigate through the Website. Information collected automatically may include usage details, IP addresses, location and information collected through cookies, web beacons, and other tracking technologies.
3.4 Personal data collected for purposes other than compliance with legal obligation may be subject of profiling, which is an automated processing of personal data to analyse or predict aspects concerning your personal preferences or behaviour (for example, to personalize the Website or marketing content sent to you).
3.5 The information Rawlplug collects will also be used to help us review, develop and improve the products and services Rawlplug offers.
3.6 You also may provide information to be published or displayed (hereinafter, “posted”) on public areas of the Website, or transmitted to other users of the Website or third parties (collectively, “User Contributions”). Your User Contributions are posted on and transmitted to others at your own risk. Although, please be aware that no security measures are perfect or impenetrable. Additionally, Rawlplug cannot control the actions of other users of the Website with whom you may choose to share your User Contributions. Therefore, Rawlplug cannot and do not guarantee that your User Contributions will not be viewed by unauthorized persons.
3.7 Any publication of a photograph on the Website containing your image, constitutes a consent to use such image by Rawlplug on the Website (for example, avatar).
3.8 Rawlplug may request additional personal information to provide certain services available on the Website. If such personal data are not provided by you, Rawlplug will not be able to provide you requested services.
3.9 Rawlplug collects your personal data for operating Rawlplug ID – (i) which is a system of coherent and joint signing-on, so called “single sign-on” or SSO, to Rawlplug’s services and functionalities available online allowing Rawlplug ID’s registered users (as a result of registering an account on any Rawlplug’s website or Rawlplug ID’s dedicated website) to secure signing-on to other Rawlplug’s services or websites online which require registered user account, or (ii) a data base of your personal data if you use our online services without registering an user account.
3.10 Rawlplug ID records personal data which are necessary for Rawlplug to provide online services through the Website, as well as to perform other contracts, which have been concluded by you through the Website when placing an order.Rawlplug ID also allows you to manage your personal data and contracts you have concluded with Rawlplug as well as enforcing your rights under GDPR.
4. USE OF INFORMATION
4.1 Under the Act, we must always have a lawful basis for using personal data. This may be because the data is necessary for our performance of a contract with you, because you have consented to our use of your personal data, or because it is in our legitimate business interests to use it.
4.2 Personal data provided by you are collected by Rawlplug for following purposes:
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4.3 We collect and process personal data for other purpose than above only with your expressed consent and only within the scope of such consent. You are entitled to withdraw the consent at any time, however the withdrawal of the consent will not affect the lawfulness of processing based on consent before its withdrawal.
5. SHARING OF THE INFORMATION RAWLPLUG RECEIVES
5.1 Rawlplug may share your information including personal data with Rawlplug Group companies for marketing purposes if you have given an expressed consent.
5.2 Rawlplug uses third parties service providers to carry out certain activities on its behalf. Examples include, agency activities, fulfilling orders, subcontracting, carrying out surveys and installations, delivering packages, sending postal mail, operating IT systems, including e-mail, providing IT resources, analyzing data, providing marketing assistance, processing credit card payments, and providing customer service, legal services, accounting services etc. These third parties are processors of your personal data needed to perform their functions, but may not use it for other purposes. Rawlplug will ensure that any processing of personal data by processors complies with provisions of GDPR, especially that any such processor is aware of and abides by obligations set for the therein. We will also ensure that any processor treats your personal data no less protective as required by applicable data protection laws and that they adopt adequate technical and organizational security measures.
5.2.1 Third party services providers include (but are not limited to):
5.2.1.1 Sana Commerce Ltd, Adyen Ltd & Mailchimp
And may change overtime. We endeavor to keep this list up to date.
5.3 Rawlplug may share your personal data with other controllers, when we believe it necessary to comply with the law, to protect the rights or safety of the Website, other users, or third parties (e.g., for fraud protection purposes, settlements purposes). Without limitation, this may include cases in which we share your personal data with government authorities, local authorities or court authorities, persons running offices of business information and assignees. Rawlplug will carefully determine the permissibility of providing personal data in each such context, paying particular attention to the type of request, types of data affected and any impact that a disclosure of personal data would have on the user affected. Should we decide to disclose personal data in such context we will also consider ways of reducing the scope of the disclosure, for instance by redacting the information provided.
5.4 Rawlplug may disclose personal data as described in this Privacy and Security Policy to a buyer or other successor in the event of a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of Rawlplug’s assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal data held by Rawlplug about the Website users is among the assets transferred.
5.5 Rawlplug may share your personal data with carefully selected third parties so they may contact you with offers and information about their goods and services or for other purposes, unless you expressed your consent.
5.6 Recipients of your personal data, including Rawlplug Group companies, may be located in any country. This may include countries where applicable data protection laws provide a lesser degree of protection than EU laws, especially countries outside the territory of European Union (“third countries”). In such case, Rawlplug may transfer your personal data to a third country only where:
- the Commission has decided that the third country, a territory or one or more specified sectors within that third country, ensures an adequate level of protection. Such a transfer shall not require any specific authorization, or
- adequate level of protection is applied for your personal data, for instance by ensuring that the recipient abides by so-called EC Model Clauses, which are sets of contractual clauses adopted by the European Commission for the purpose of adducing adequate safeguards to personal data in connection with cross-border transfers, or
- the transfer meets other requirements set forth in the Act.
6. LINKS TO THIRD PARTY WEBSITES
6.1 Rawlplug may from time to time establish relationships with other third party companies and the Website may contain links to and from such third party websites. Rawlplug will try to provide you with links to high quality, reputable sites which it believes will be of interest and relevant to you, but please note that such third party sites are not under its control and Rawlplug does not contribute to the content of such sites.
6.2 If you follow a link to any third party website, please note that they will have their own policies. When you click through to these sites you leave the area controlled by Rawlplug. Rawlplug cannot accept responsibility for any issues arising in connection with either the third party's use of your data, the site content or the services offered to you by these sites. Rawlplug therefore encourages you to check any third party website's policies before you submit any personal data to these sites.
7. SECURITY
7.1 Rawlplug maintains administrative, technical, and physical safeguards designed and intended to protect personal data against accidental, unlawful, or unauthorized destruction, loss, alteration, access, disclosure or use. Despite these safeguards, due to inherent uncertainty in the use of the Internet and information systems and the potential for unlawful attacks by third parties, Rawlplug cannot guarantee that the use of systems, websites (including the Website) or applications will be completely safe or secure.
7.2 Rawlplug retains information for as long as it is needed or useful to provide and improve Rawlplug’s products and services, comply with its legal obligations, resolve disputes, and enforce its agreements.
7.3 The safety and security of your personal data also depends on you. Where Rawlplug has given you (or where you have chosen) a password for access to certain parts of the Website, you are responsible for keeping this password confidential. Rawlplug asks you not to share your password with anyone. Rawlplug also urges you to be careful about giving out information in public areas of the Website like message boards. The information and personal data you share in public areas may be viewed by any user of the Website.
7.4 Unfortunately, the transmission of information via the internet is not completely secure. Although Rawlplug does its very best to protect your personal data, Rawlplug cannot guarantee the security of your personal data transmitted to the Website. Any transmission of personal data is at your own risk. Rawlplug is not responsible for circumvention of any privacy settings or security measures contained on the Website.
8. Cookies
You can set your browser to refuse all or some browser cookies, or to alert you when our website request access cookies. If you disable or refuse cookies, please note that some parts of the website may become inaccessible or not function properly. For further details please see our Cookie Policy.
9. YOUR RIGHTS
9.1 You have following rights under the Act in relation to your personal data:
- accessing your personal data (including receiving copies thereof);
- correcting your personal data;
- deleting your personal data ;
- to demand restriction of processing; and
- to demand transmission of personal data.
9.2 You may enforce the above rights by contacting our representative for data protection or sending a respective email to our address: marketing@rawlplug.co.uk
9.3 We may require additional information enabling us to verify your identity and your right to enforce the above rights.
9.4 You can review and change your personal data by logging into the Website and visiting your account profile page.
10. RIGHT TO OBJECT
10.1 Apart from rights referred to in preceding paragraphs, you have the right to object, at any time, to processing of your personal data by us (including profiling) for direct marketing purpose. After filing the objection, we will restrain from processing your data for this purpose.
10.2 You have also right to object, on grounds relating to your particular situation, at any time to processing of your personal data which is based on legitimate interest or public interest (including profiling). The controller shall no longer process the personal data unless the controller demonstrates compelling legitimate grounds for the processing which override the interests, rights and freedoms of the data subject or for the establishment, exercise or defense of legal claims.
11. COMPLAINT
If you have any questions or concerns about this notice, please contact Niall Thompson at:
● Email: marketing@rawlplug.co.uk ;
● Telephone: 0141 638 7961;
● Write to: Rawlplug Ltd, Skibo Drive, Thornliebank Industrial Estate, Glasgow G46 8JR
If the matter cannot be resolved then you have the right to lodge a complaint to:
The Information Commissioner’s Office at Water Lane, Wycliffe House, Wilmslow, Cheshire SK9 5AF, tel. +44 1625 545 700, email: casework@ico.org.uk, website: https://ico.org.uk - if you are of the opinion that we process your personal data illegally.
11.2 We are regulated by the ICO. You can also contact them for advice and support and details
about this are on their website at www.ico.org.uk
12. CHANGES TO OUR PRIVACY POLICY
Rawlplug may revise, update and change this privacy policy at any time and without notice to you at Rawlplug’s sole discretion. Where appropriate, Rawlplug may notify its customers and/or users of the change by email.