Business Privacy Policy

Last updated: 18 May 2018

Please read this privacy notice (“Privacy policy”) carefully as it describes our collection, use, disclosure, retention and protection of your personal information. This Privacy Notice applies to any website, application or service which references this Privacy Notice. Where you provide us with your personal information in any of the ways described in section 2 below, you agree that we may collect, store and use it: (a) in order to perform our contractual obligations to you; (b) based on our legitimate interests for processing (i.e. for internal administrative purposes, data analytics and benchmarking (see section 3 below for more information), direct marketing, maintaining automated back-up systems or for the detection or prevention of crime); or (c) based on your consent, which you may withdraw at any time, as described in this Privacy Notice.

 

1. Who we are

Our Privacy Notice applies to all products, applications and services offered by STM Power Transmission Limited (“STM”).

 

2. How we collect information

To the extent permissible under applicable law, we collect information about you and any other party whose details you provide to us when you:

  • Register to use our website, applications or services (including free trials); this may include your name (including business name), address, email address and telephone number. We may also ask you to provide additional information about your business and your preferences;
  • Place an order using our websites, applications or services; this may include your name (including business name), address, contact (including telephone number and email address) and payment details;
  • Interact with us using social media;
  • Provide your contact details to us when registering to use or accessing any websites, applications or services we make available or when you update those details; and
  • Contact us offline, for example by telephone, fax, SMS, email or post.

We may enhance personal information we collect from you with information we obtain from third parties that are entitled to share that information; for example, information from credit agencies, search information providers or public sources (e.g. for customer due diligence purposes), but in each case as permitted by applicable laws.

If you intend giving us personal information about someone else, you are responsible for ensuring that you comply with any obligation and consent obligations under applicable data protections laws. In so far as required by applicable data protection laws, you must ensure that beforehand you have their explicit consent to do so and that you explain to them how we collect, use, disclose and retain their personal information or direct them to read our Privacy Notice.

 

3. How we use your information

To the extent permissible under applicable law, we use your information to:

  • Provide any information and services that you have requested or any applications or services that you have ordered;
  • Compare information for accuracy and to verify it with third parties;
  • Provide, maintain, protect and improve any applications, products, services and information that you have requested from us;
  • Manage and administer your use of applications, products and services you have asked us to provide;
  • Manage our relationship with you (for example, customer services and support activities);
  • Monitor, measure, improve and protect our content, website, applications and services and provide an enhanced, personal, user experience for you;
  • Provide you with any information that we are required to send you to comply with our regulatory or legal obligations;
  • Detect, prevent, investigate or remediate, crime, illegal or prohibited activities or to otherwise protect our legal rights (including liaison with regulators and law enforcement agencies for these purposes);
  • To monitor, carry out statistical analysis and benchmarking, provided that in such circumstances it is on an aggregated basis which will not be linked back to you or any living individual;
  • Deliver targeted advertising, marketing (including in-product messaging) or information to you which may be useful to you, based on your use of our applications and services;
  • Provide you with location-based services (for example, advertising and other personalised content), where we collect geo-location data.

To the extent permitted by applicable law, we retain information about you after the closure of your account, if your application for an account is declined or if you decide not to proceed. This information will be held and used for as long as permitted for legal, regulatory, fraud prevention and legitimate business purposes.

 

4. Sharing your information

We may share your information with:

  • Our service providers and agents (including their sub-contractors) or third parties which process information on our behalf (e.g. internet service and platform providers, payment processing providers and those organisations we engage to help us send communications to you) so that they may help us to provide you with the applications, products, services and information you have requested or which we believe is of interest to you;
  • Partners and developers that may help us to provide you with the applications, products, services and information you have requested or which we believe is of interest to you;
  • Third parties used to facilitate payment transactions, for example clearing houses, clearing systems, financial institutions and transaction beneficiaries;
  • Third parties where you have a relationship with that third party and you have consented to us sending information (for example social media sites or other third-party application providers);
  • Credit reference and fraud prevention agencies;
  • Regulators to meet STM’s legal and regulatory obligations;
  • Law enforcement agencies so that they may detect or prevent crime or prosecute offenders;
  • Any third party in the context of actual or threatened legal proceedings, provided we can do so lawfully (for example in response to a court order);
  • Any third party in order to meet our legal and regulatory obligations, including statutory or regulatory reporting or the detection or prevention of unlawful acts;
  • Our own and STM’s professional advisors and auditors for the purpose of seeking professional advice or to meet our audit responsibilities;

 

5. Your information and your rights

If you are based within the EEA or within another jurisdiction having similar data protection laws, in certain circumstances you have the following rights:

  • The right to be told how we use your information and obtain access to your information;
  • The right to have your information rectified or erased or place restrictions on processing your information;
  • The right to object to the processing of your information e.g. for direct marketing purposes;
  • The right to have any information you provided to us on an automated basis returned to you in a structured, commonly used and machine-readable format, or sent directly to another company, where technically feasible (“data portability”);
  • Where the processing of your information is based on your consent, the right to withdraw that consent subject to legal or contractual restrictions;
  • The right to object to any decisions based on the automated processing of your personal data, including profiling; and
  • The right to lodge a complaint with the supervisory authority responsible for data protection matters (e.g. in the UK, the Information Commissioner’s Office).

If you request a copy of your information you may be required to pay a statutory fee.

If we hold any information about you which is incorrect or if there are any changes to your details, please let us know by so that we can keep our records accurate and up to date.

If you withdraw your consent to the use of your personal information for purposes set out in our Privacy Notice, we may not be able to provide you with access to all or parts of our website, applications, and services.

 

6. Data retention

We will retain your personal information for the duration of our business relationship and afterwards for as long as is necessary and relevant for our legitimate business purposes, in accordance with the STM Data Retention, Marking and Destruction Policy or as otherwise permitted applicable laws and regulation. Where we no longer need your personal information, we will dispose of it in a secure manner (without further notice to you).

 

7. Changes to our privacy notice

We may change our Privacy Notice from time to time. However we will not reduce your rights under this Privacy Notice. We will always update this Privacy Notice on our website, so please try to read it when you visit the website (the ‘last updated’ reference tells you when we last updated our Privacy Notice).

 

8. Security and storage of information

We will keep your information secure by taking appropriate technical and organisational measures against its unauthorised or unlawful processing and against its accidental loss, destruction or damage. We will do our best to protect your personal information, but we cannot guarantee the security of your information which is transmitted to our website, applications or services or to other website, applications and services via an internet or similar connection.

 

9. Transfers outside of the European Economic Area

Personal information in the European Union is protected by data protection laws but other countries do not necessarily protect your personal information in the same way.

Our website and some of our applications or services or parts of them may also be hosted in the United States or otherwise outside of the EEA (which means all the EU countries plus Norway, Iceland and Liechtenstein) (“EEA”) and this means that we may transfer any information which is submitted by you through the website or the application or service outside the EEA to the United States or to other territories outside of the EEA. When you send an email to us, this will also be stored on our email servers which are hosted in the United States.

We may use service providers based outside of the EEA to help us provide our website, applications and services to you (for example, platform and payment providers who help us deliver our applications and services, or advertising or execute your payments) and this means that we may transfer your information to service providers outside the EEA for the purpose of providing our applications, advertising and services to you.

We take steps to ensure that where your information is transferred outside of the EEA by our service providers and hosting providers, appropriate measures and controls in place to protect that information in accordance with applicable data protection laws and regulations.

By using our website, products or services or by interacting with us in the ways described in this Privacy Notice, you consent to the transfer of your information outside the EEA in the circumstances set out in this Privacy Notice. If you do not want your information to be transferred outside the EEA you should not use our website, applications or services.

 

10. Other sites and social media

If you follow a link from our website, application or service to another site or service, this notice will no longer apply. We are not responsible for the information handling practices of third party sites or services and we encourage you to read the privacy notices appearing on those sites or services.

Our websites, applications or services may enable you to share information with social media sites or to connect your social media account. Those social media sites may automatically provide us with access to certain personal information retained by them about you (for example any content you have viewed). You should be able to manage your privacy settings from within your own third party social media account(s) to manage what personal information you enable us to access from that account.

 

11. Cookies, Analytics and Traffic Data

Cookies are small text files which are transferred from our websites, applications or services and stored on your device. We use cookies to help us provide you with a personalised service, and to help make our websites, applications and services better for you.

How to disable cookies

You may be able to configure your browser or our website, application or service to restrict cookies or block all cookies if you wish, however if you disable cookies you may find this affects your ability to use certain parts of our website, applications or services.

 

12.  Further information

If you have any queries about how we treat your information, the contents of this notice, your rights under local law, how to update your records or how to obtain a copy of the information that we hold about you, please write to our Data Protection Officer at STM Power Transmission Limited, Unit 1, Oasis Business Park, Road 1, Winsford Industrial Estate, Winsford, Cheshire. CW7 3RY.