The information described below is in addition to any personal data we are required by law to process in any given situation.
Client Data: The data we collect about Clients is actually very limited. We generally only need to have your contact details or the details of individual contacts at your organisation (such as their names, telephone numbers and email addresses) to enable us to ensure that our relationship runs smoothly. We also hold purchase history and other material published by Orangetek, which we use to ensure that our marketing communications to you are relevant and timely. We may also hold extra information that someone in your organisation has chosen to tell us. We record bank details to reconcile payments. In certain circumstances, such as when you engage with our Finance and Debt Recovery teams, our calls with you may be recorded, depending on the applicable local laws and requirements. If we need any additional personal data for any reason, we will let you know.
To the extent that you access our website we will also collect certain data from you. If you would like more information about this, please see our “Cookies Policy” below.
Supplier Data: We need to make sure that our relationship runs smoothly. We'll collect the details for our contacts within your organisation, such as names, telephone numbers and email addresses. We'll also collect bank details, so that we can pay you. We may ask for proof of accreditations, for example ISO certification, and to confirm compliance with supply chain related policies, for example anti-slavery and human trafficking policy.
We may also hold extra information that someone in your organisation has chosen to tell us. In certain circumstances, such as when you engage with our Finance and Debt Recovery teams, our calls with you may be recorded, depending on the applicable local laws and requirements.
To the extent that you access our website we will also collect certain data from you. If you would like more information about this, please see our “Cookies Policy” below.
Referees: To ask for a reference, we need the referee's contact details. We use the following:
Emergency contacts: Emergency contact details give us somebody to call on in the event of an accident or an emergency. We use the following:
Website Users: We collect a limited amount of data from our Website Users which we use to help us to improve your experience when using our website and to help us manage the services we provide. This includes information such as how our website is used, the frequency with which you access our website, your browser type, the location you view our website from, and the times that our website is most popular. If you contact us via the website, we will collect any information that you provide to us, for example your name and contact details.
If you would like to find out more information about what data we collect about you when you visit our website, please see our “Cookies Policy” below.
Client Data: We collect Client personal data in three ways:
Personal data that we receive directly from you: We will receive data directly from you in two ways:
Personal data we receive from other sources: Where appropriate, and in accordance with any local laws and requirements, we may seek more information about you or your colleagues from other sources generally by way of due diligence or other market intelligence including:
Personal data we collect via our website: To the extent that you access our website or read or click on an email from us, where appropriate and in accordance with any local laws and requirements, we may also collect your data automatically or through you providing it to us. For more information please see our “Cookies Policy” below.
Website Users: When you visit our website there is certain information that we may automatically collect, whether or not you decide to use our services. This includes your IP address, the date and the times and frequency with which you access the website and the way you browse its content. We will also collect data from you when you contact us via the website, for example by using the model generator facilities.
We collect your data automatically via cookies, in line with cookie settings in your browser. If you would like to find out more about cookies, including how we use them and what choices are available to you, please see the “Cookies” section.
Having obtained data about you, we then use it as follows:
Client Data: We use Client information/data for:
Here are some more details about each:
We may use your personal data for these purposes if we deem this to be necessary for our legitimate interests. If you would like to know more about what this means, please see “Our Legal basis for processing your data” section.
If you are not happy about this, in certain circumstances you have the right to object and can find out more about how and when to do this in the “How can you access, amend or take back the personal data that you have given to us?” section below.
If you are not happy about this, you have the right to opt out of receiving marketing materials from us and can find out more about how to do so in the “How can you access, amend or take back the personal data that you have given to us?” section below.
Please note that in certain of the jurisdictions in which we operate, we comply with additional local law requirements regarding marketing activities.
Supplier Data: We realise that you're probably busy, and don't want us to be contacting you about all sorts of things. To find the right balance, we will only use your information:
To store (and update when necessary) your details on our database, so that we can contact you in relation to our agreements;
We may use your personal data for these purposes if we deem this to be necessary for our legitimate interests. If you want to know more about what this means, please see “Our Legal basis for processing your data” section. We will not, as a matter of course, seek your consent when sending marketing messages to a corporate postal or email address.
If you are not happy about this, in certain circumstances you have the right to object and can find out more about how to do so in the “How can you access, amend or take back the personal data that you have given to us?” section below.
Please note that in certain jurisdictions in which we operate, we comply with additional local law requirements.
People whose data we receive from candidates and staff, such as referees and emergency contacts: We will only use the information that our Candidate gives us about you for the following purposes:
We may use your personal data for these purposes if we deem this to be necessary for our legitimate interests. If you would like to find out more about what this means, please see “Our Legal basis for processing your data” section.
If you are not happy about this, you have the right to object and can find out more about how to do so in the “How can you access, amend or take back the personal data that you have given to us?” section below.
Website Users: We use your data in the form of “Cookies” to help us to improve your experience of using our website. If you would like to find out more about cookies, including how we use them and what choices are available to you, please see “Cookies” section.
Where appropriate and in accordance with local laws and requirements, we may share your personal data, in various ways and for various reasons, with the following categories of people:
We are committed to taking all reasonable and appropriate steps to protect the personal information that we hold from misuse, loss, or unauthorised access. We do this by having in place a range of appropriate technical and organisational measures. These include measures to deal with any suspected data breach.
If you suspect any misuse or loss of or unauthorised access to your personal information please let us know immediately. Details of how to contact us can be found in the “Contact Us” section below.
We will Delete your personal data from our systems if we have not had any meaningful contact with you (or, where appropriate, the company you are working for or with) for three years (or for such longer period as we believe in good faith that the law or relevant regulators require us to preserve your data). After this period, it is likely your data will no longer be relevant for the purposes for which it was collected.
For staff whose services are provided via a third party company or other entity, "meaningful contact" with you means meaningful contact with the company or entity which supplies your services. Where we are notified by such company or entity that it no longer has that relationship with you, we will retain your data for no longer than three years from that point or, if later, for the period of three years from the point we subsequently have meaningful contact directly with you.
When we refer to "meaningful contact", we mean, for example, communication between us (either verbal or written), or where you are actively engaging with our online services. If you are a client or prospective client, we will consider there to be meaningful contact with you if you submit a quote request on our website. We will also consider it meaningful contact if you communicate with us about potential sales, either by verbal or written communication or click through from any of our marketing communications. Your receipt, opening or reading of an email or other digital message from us will not count as meaningful contact – this will only occur in cases where you click-through or reply directly.
One of the GDPR's main objectives is to protect and clarify the rights of EU citizens and individuals in the EU with regards to data privacy. This means that you retain various rights in respect of your data, even once you have given it to us. These are described in more detail below.
To get in touch about these rights, please contact us. We will seek to deal with your request without undue delay, and in any event within one month (subject to any extensions to which we are lawfully entitled). Please note that we may keep a record of your communications to help us resolve any issues which you raise.
Right to object: This right enables you to object to us processing your personal data where we do so for one of the following four reasons: (i) our legitimate interests; (ii) to enable us to perform a task in the public interest or exercise official authority; (iii) to send you direct marketing materials; and (iv) for scientific, historical, research, or statistical purposes.
The "legitimate interests" and "direct marketing" categories above are the ones most likely to apply to our Clients and Suppliers. If your objection relates to us processing your personal data because we deem it necessary for your legitimate interests, we must act on your objection by ceasing the activity in question unless:
If your objection relates to direct marketing, we must act on your objection by ceasing this activity.
Right to withdraw consent: Where we have obtained your consent to process your personal data for certain activities (for example, for our marketing arrangements), you may withdraw this consent at any time and we will cease to carry out the particular activity that you previously consented to unless we consider that there is an alternative reason to justify our continued processing of your data for this purpose - in which case we will inform you of this condition.
Data Subject Access Requests (DSAR): You may ask us to confirm what information we hold about you at any time, and request us to modify, update or delete such information. We may ask you to verify your identity and for more information about your request. If we provide you with access to the information we hold about you, we will not charge you for this unless your request is "manifestly unfounded or excessive". If you request further copies of this information from us, we may charge you a reasonable administrative cost where legally permissible. Where we are legally permitted to do so, we may refuse your request. If we refuse your request we will always tell you the reasons for doing so.
[Please note: In some circumstances we comply with additional local law requirements regarding data subject access requests. Your personal data is processed in accordance with the fair processing condition relating to our rights and obligations under local law, this relates to our processing of your personal data which is necessary for compliance with local legal obligations. In such circumstances we may refuse your request in accordance with local laws.
We would only be entitled to refuse to comply with your request for one of the following reasons:
When complying with a valid request for the erasure of data we will take all reasonably practicable steps to Delete the relevant data].
Right to erasure: You have the right to request that we erase your personal data in certain circumstances. Normally, the information must meet one of the following criteria:
[Please note: In some circumstances we comply with additional local law requirements regarding data subject right to erasure. Your personal data is processed in accordance with the fair processing condition relating to our rights and obligations under local law, this relates to our processing of your personal data which is necessary for compliance with local legal obligations. In such circumstances we may refuse your request in accordance with local laws.
We would only be entitled to refuse to comply with your request for one of the following reasons:
When complying with a valid request for the erasure of data we will take all reasonably practicable steps to Delete the relevant data.]
Right to restrict processing: You have the right to request that we restrict our processing of your personal data in certain circumstances. This means that we can only continue to store your data and will not be able to carry out any further processing activities with it until either: (i) one of the circumstances listed below is resolved; (ii) you consent; or (iii) further processing is necessary for either the establishment, exercise or defence of legal claims, the protection of the rights of another individual, or reasons of important EU or Member State public interest. The circumstances in which you are entitled to request that we restrict the processing of your personal data are:
If we have shared your personal data with third parties, we will notify them about the restricted processing unless this is impossible or involves disproportionate effort. We will, of course, notify you before lifting any restriction on processing your personal data.
Right to rectification: You also have the right to request that we rectify any inaccurate or incomplete personal data that we hold about you. If we have shared this personal data with third parties, we will notify them about the rectification unless this is impossible or involves disproportionate effort. Where appropriate, we will also tell you which third parties we have disclosed the inaccurate or incomplete personal data to. Where we think that it is reasonable for us not to comply with your request, we will explain our reasons for this decision.
Right of data portability: If you wish, you have the right to transfer your personal data between data controllers. In effect, this means that you are able to transfer your account details to another online platform. To allow you to do so, we will provide you with your data in a commonly used machine-readable format that is password-protected so that you can transfer the data to another online platform. Alternatively, we may directly transfer the data for you. This right of data portability applies to: (i) personal data processed automatically (i.e. without any human intervention); (ii) personal data provided by you; and (iii) personal data that we process based on your consent or in order to fulfil a contract.
Right to lodge a complaint with a supervisory authority: You also have the right to lodge a complaint with your local supervisory authority. Details of how to contact them can be found here.
If you would like to exercise any of these rights or withdraw your consent to the processing of your personal data (where consent is our legal basis for processing your personal data), please refer to the “How to contact us” section below.
[Please note that we may keep a record of your communications to help us resolve any issues which you raise.]
It is important that the personal information we hold about you is accurate and current. Please keep us informed if your personal information changes during the period for which we hold your data.
[1 Delete: While we will endeavour to permanently erase your personal data once it reaches the end of its retention period or where we receive a valid request from you to do so, some of your data may still exist within our systems, for example if it is waiting to be overwritten. For our purposes, this data has been put beyond use, meaning that, while it still exists on an archive system, this cannot be readily accessed by any of our operational systems, processes or Staff.]
Our website is managed and hosted by Stamp Design and we use “cookies” to record various pieces of data – for a full list of cookies used please see the “Cookies Policy” below.
If you have any comments or suggestions concerning this Privacy Policy please get in touch with us using the contact details in the “Contact Us” section below. We take privacy seriously, so we will endeavour to get back to you as soon as possible.
In order to provide you with the best service and to carry out the purposes described in this Privacy Policy, your data may be transferred:
We want to make sure that your data is stored and transferred in a way which is secure. We will therefore only transfer data outside of the European Economic Area or EEA (i.e. the Member States of the European Union, together with Norway, Iceland and Liechtenstein) where it is compliant with data protection legislation and the means of transfer provides adequate safeguards in relation to your data, for example:
Personal data issued by Orangetek Ltd. will take place where recipients have agreed to treat the data in accordance with all current Orangtek Ltd. data protection and privacy policies.
What's a cookie?
A "cookie" is a piece of information that is stored on your computer's hard drive and which records your navigation of a website so that, when you revisit that website, it can present tailored options based on the information stored about your last visit. Cookies can also be used to analyse traffic and for advertising and marketing purposes.
Cookies are used by nearly all websites and do not harm your system. If you want to check or change what types of cookies you accept, this can usually be altered within your browser settings.
How do we use cookies?
We use cookies to track your use of our website. This enables us to understand how you use the site and track any patterns that emerge individually or from larger groups. This helps us to develop and improve our website and services in response to what our visitors want and need.
Cookies are either:
Cookies can also be categorised as follows:
Cookie Name |
Cookie Provider |
Purpose of Cookie |
Expiry (type) |
__RequestVerificationToken |
Orangetek.co.uk |
Helps prevent Cross-Site Request Forgery (CSRF) Attacks |
Session (Necessary) |
ASP.NET_SessionId |
Orangetek.co.uk |
Preserves the visitor's session state across page requests. |
Session (Necessary) |
_ga |
Orangetek.co.uk |
Registers a unique ID that is used to generate statistical data on how the visitor uses the website |
2 years (Statistics) |
_gat |
Orangetek.co.uk |
Used by Google Analytics to throttle request rate |
Session (Statistics) |
_gid |
Orangetek.co.uk |
Registers a unique ID that is used to generate statistical data on how the visitor uses the website. |
Session (Statistics) |
Collect |
Google-analytics.com |
Used to send data to Google Analytics about the visitor’s device and behaviour. Tracks the visitor across devices and marketing channel |
Session (Marketing) |
r/collect |
Doubleclick.net |
Unclassified |
Session |
Our basis for processing legal data falls into three categories:
Please see below for how this information relates to you:
1. Legitimate Interests
Article 6(1)(f) of the GDPR allows data to be processed where it is “necessary for the purposes of the legitimate interests pursued by [us] or by a third party, except where such interests are overridden by the interests or fundamental rights or freedoms of [you] which require protection of personal data.”
Please note that in certain jurisdictions in which we operate, a different legal basis for data processing might apply in certain cases.
Client Data: To ensure that we provide you with the best service possible, we store your personal data and/or the personal data of individual contacts at your organisation as well as keeping records of our conversations, meetings and correspondence. We also hold financial records in order to reconcile payments for goods and/or services.
From time to time we may ask you to undertake a customer satisfaction survey. We feel this is reasonable and deem these uses of your data to be necessary to our legitimate interests as an organisation providing various lighting products and services to you.
Supplier Data: We use and store the personal data of individuals within your organisation in order to facilitate the receipt of services from you as one of our Suppliers. We also hold your financial details, so that we can pay you for your products and/or services. We deem all such activities to be necessary within the range of our legitimate interests as a recipient of your services.
Emergency Contact Data (Supplier and Client): We keep personal data for any member of staff given to us as an emergency contact. As an employer and provider of services and products, we feel that maintaining records of emergency contacts is vital to minimise impact of an emergency situation – the act of provision of an emergency contact reinforcing the necessity to retain this information.
2. Consent
In certain circumstances, we are required to obtain your consent to the processing of your personal data in relation to certain activities. Depending on exactly what we are doing with your information, this consent will be opt-in consent or soft opt-in consent.
Article 4(11) of the GDPR states that (opt-in) consent is "any freely given, specific, informed and unambiguous indication of the data subject's wishes by which he or she, by a statement or by a clear affirmative action, signifies agreement to the processing of personal data relating to him or her." In plain language, this means that:
We will keep records of the consents that you have given in this way.
In some cases, we will be able to rely on soft opt-in consent. We are allowed to market products or services to you which are related to the products and services we provide as long as you do not actively opt-out from these communications.
Please note that in certain jurisdictions in which we operate, we comply with additional local law requirements regarding consenting to receive marketing materials.
As we have mentioned, you have the right to withdraw your consent to these activities. You can do so at any time, and details of how to do so can be found above in the “How can you access, amend or take back the personal data that you have given to us?” section above.
3. Establishing Exercising or Defending Legal Claims
Sometimes it may be necessary for us to process personal data and, where appropriate and in accordance with local laws and requirements, sensitive personal data in connection with exercising or defending legal claims. Article 9(2)(f) of the GDPR allows this where the processing "is necessary for the establishment, exercise or defence of legal claims or whenever courts are acting in their judicial capacity". This may arise, for example, where we need to take legal advice in relation to legal proceedings or are required by law to preserve or disclose certain information as part of the legal process.
4. Contract
A large proportion of our working relationships are subject to contractual agreements. Where data would otherwise not be processed, will process data in order to maintain our obligations. Article 6(1)(b) of the GDPR allows processing of data where “processing is necessary for the performance of a contract to which the data subject is party or in order to take steps at the request of the data subject prior to entering into a contract”. This may arise, for example, in producing management returns or calculating and substantiating rebate invoices.
Please contact us if you have any questions about our privacy policy or information we hold about you.
Email: info@orangetek.co.uk
Phone: 01283 716 690
Post:
Orangetek Ltd. (FAO Data Protection Manager),
The Coachhouse,
Blakenhall Park,
Bar Lane,
Barton-Under-Needwood,
DE13 8AJ
Country in which you use Orangetek services or products, or supply Orangetek with services or products: UK.
Name of authority: The Information Commissioner’s Office.
Authority Phone Number: 0303 123 1113
Authority Email: casework@ico.org.uk
Authority Postal Address:
Information Commissioner's Office,
Wycliffe House,
Water Lane,
Wilmslow,
Cheshire,
SK9 5AF.
We keep our privacy notice under regular review. This privacy notice was last updated on 23 May 2018.
Clients - while it speaks for itself, this category covers our customers, clients, and others to whom Orangetek provides services in the course of its business.
Suppliers – refers to partnerships and companies (including sole traders), and atypical workers such as independent contractors and freelance workers, who provide services to Orangetek. In certain circumstances Orangetek will sub-contract the services it provides to Clients to third party suppliers who perform services on Orangetek's behalf. In this context, suppliers that are individual contractors, freelance workers, or employees of suppliers will be treated as Candidates for data protection purposes. Please note that in this context, Orangetek requires Suppliers to communicate the relevant parts of this Privacy Policy (namely the sections directed at Candidates) to their employees.
Website Users - any individual who accesses any of the Orangetek websites (Including aforementioned categories of ‘person’).
Delete – while we will endeavour to permanently erase your personal data once it reaches the end of its retention period or where we receive a valid request from you to do so, some of your data may still exist within our systems, for example if it is waiting to be overwritten. For our purposes, this data has been put beyond use, meaning that, while it still exists on an archive system, this cannot be readily accessed by any of our operational systems, processes or Staff.
General Data Protection Regulation (GDPR) – a European Union statutory instrument which aims to harmonise European data protection laws. It has an effective date of 25 May 2018, and any references to it should be construed accordingly to include any national legislation implementing it.