We may collect, use and be responsible for certain personal data about you. When we do so we are subject to the data protection laws (as defined below) and we are responsible as data controller of that personal data for the purposes of those laws. We may also act in some instances as a data processor of personal data in which case we comply with the data protection laws and the terms of any data processing arrangements we enter into with applicable data controllers.
Key terms used in this Policy:
|Alchemy, we, us, our||Alchemy Telco Solutions UK Limited (incorporated in England and Wales under company number 09689100) with a registered office at Unit 16 & 17 Evolution Hooters Hall Road, Newcastle Under Lyme, Staffordshire, ST5 9QF, United Kingdom and Alchemy Telco Solution Limited (incorporated in Ireland under company number 595997) with a registered address at First Floor, Connaught House, 1 Burlington Road Dublin 4, Dublin 4, Dublin, D04 C5y6, Ireland.|
|Data Protection Officer (DPO)||Mr Bela Lainck|
|data protection laws||Applicable data privacy and related laws and regulations including the General Data Protection Regulation (GDPR) which applies across the European Union, and the United Kingdom Data Protection Act 2018|
|personal data||Any information relating to an identified or identifiable individual (as defined more fully in the data protection laws)|
|special category personal data||Personal data revealing racial or ethnic origin, political opinions, religious beliefs, philosophical beliefs or trade union membership
Genetic and biometric data
Data concerning health, sex life or sexual orientation
Alchemy is a global services company, specialising in Trade-In and Recycling Services, Problem Solving / Consultancy, Product Sourcing, Accessories and Onsite Managed Services.
Alchemy operates conscientiously within the requirements of the data protection laws. We work within the principles of fair data processing, namely:
- Using information in a way that people would reasonably expect.
- Thinking about the impact of our processing.
- Being transparent and ensuring that people know how we will use their information.
This statement which will be updated at regular intervals, sets out the basis on which any personal data we collect from you, or that you provide to us, will be processed by us, as data controller and a data processor.
Please read the following carefully to understand our views and practices regarding your personal data and how we will treat it.
1. What this Privacy Statement covers
This statement covers how we treat any personal data that we collect and receive either from our website or as part of our broader operating processes within our UK business, and our Ireland businesses supporting clients across the EEA.
We do not sell any personal data about our clients or prospects and we only use any information shared with us for running and improving our services and in that capacity operate as a data controller and, to the extent that we process the data, as a data processor. This statement tells you what information we collect, the steps we take to protect and secure it, how we use and share information, and finally, how you can contact us with questions or concerns.
2. Personal data we may collect about you
We may collect and use the following personal information about you (and any other information you decide to share with us):
- your name and contact information, including email address and telephone number
- Information to enable us to check and verify your identity
- your billing information, transaction and payment card information
- your professional online presence, e.g. LinkedIn profile
- your contact history, purchase history and saved items
- information from accounts you link to us / our systems, e.g. Google accounts
- information to enable us to undertake credit or other financial checks on you
- Information about how you use our website, IT, communication and other systems
3. How your personal information is collected
We collect most of this personal data directly from you — by telephone, text or email and/or via our website and apps, and otherwise while supplying services to you. However, we may also collect information:
- from publicly accessible sources, e.g. Companies House;
- directly from a third party, e.g. credit reference agencies;
- from a third party with your consent, e.g. your bank;
- via our IT systems, e.g.:
- automated monitoring of our websites and other technical systems, such as our computer networks and connections, CCTV and access control systems, communications systems, email and instant messaging systems.
When you access and use our services, we may collect additional contextual information about your company as well as your design and aesthetics preferences. We do not link this additional data to any other information we collect about you and do not undertake any profiling activity.
4. How and why we use your personal information
We only use your personal information if we have a lawful reason for doing so, e.g.:
- to comply with our legal and regulatory obligations;
- for delivering services to you and generally for the performance of any contract with you, and to take steps at your request before entering into a contract such as developing and issuing sales proposals.
- for our legitimate interests or those of a third party; or
- where you have given consent.
A legitimate interest is when we have a business or commercial reason to use your information, so long as this is not overridden by your own rights and interests.
The table below explains what we use (process) your personal information for and our reasons for doing so:
|What we use your personal information for||Our reasons|
|To provide services to you||For the performance of our contract with you or to take steps at your request before entering into a contract|
|To prevent and detect fraud against you or Alchemy and preventing unauthorised access to systems||For our legitimate interests or those of a third party, i.e. to minimise fraud that could be damaging for us and for you|
|Conducting checks to identify our customers and verify their identity
Screening for financial and other sanctions or embargoes
Other processing necessary to comply with professional, legal and regulatory obligations that apply to our business, e.g. under health and safety regulation or rules issued by our professional regulator
|To comply with our legal and regulatory obligations|
|Ensuring business policies are adhered to, e.g. policies covering security and internet use||For our legitimate interests or those of a third party, i.e. to make sure we are following our own internal procedures so we can deliver the best service to you|
|Operational reasons, such as improving efficiency, training and quality control and Keeping up to date customer and other records||For our legitimate interests or those of a third party, i.e. to be as efficient as we can so we can deliver the best service for you at the best price|
|Ensuring the confidentiality of commercially sensitive information||For our legitimate interests or those of a third party, i.e. to protect trade secrets and other commercially valuable information|
|Ensuring safe working practices, staff administration and assessments||To comply with our legal and regulatory obligations|
|Marketing our services to:
—existing and former customers;
—third parties who have previously expressed an interest in our services;
—third parties with whom we have had no previous dealings.
|Consent and/or for our legitimate interests, i.e. to promote our business and services to customers.
We offer opt-out functionality for those no longer wishing to hear from us in this way.
|External audits and quality checks||For our legitimate interest, i.e. to maintain our accreditations so we can demonstrate we operate at the highest standards
To comply with our legal and regulatory obligations
5. Promotional communications
We may use your personal information to send you updates (by email, text message, telephone or post) about our services, including exclusive offers, promotions or new services.
We have a legitimate interest in processing your personal information for promotional purposes (see above ‘How and why we use your personal information’). This means we do not usually need your consent to send you promotional communications. However, where consent is needed, we will ask for this consent separately and clearly.
You have the right to opt out of receiving promotional communications at any time by:
- contacting us at email@example.com
- using the ‘unsubscribe’ link in emails
We may ask you to confirm or update your marketing preferences if you instruct us to provide further services in the future, or if there are changes in the law, regulation, or the structure of our business.
6. Who we share your personal information with
We may share your personal information with:
- companies within the Alchemy group
- third parties we use to help deliver our services to you, e.g. payment service providers, partners and delivery companies;
- other third parties we use to help us run our business, e.g. marketing agencies or website hosts;
- third parties approved by you, e.g. social media sites you choose to link your account to or third party payment providers;
We may allow our service providers to handle your personal information only if we are satisfied they take appropriate measures to protect your personal information. We also impose contractual obligations on service providers to ensure they can only use your personal information to provide services to us and to you.
We may disclose and exchange information with law enforcement agencies and regulatory bodies to comply with our legal and regulatory obligations.
We may also need to share some personal information with other parties, such as potential buyers of some or all of our business or during a re-structuring. Usually, information will be anonymised but this may not always be possible. The recipient of the information will be bound by confidentiality obligations.
Alchemy does not sell, rent or trade personal data with third parties for marketing or promotional purposes.
7. Where your personal information is held
Information may be held at our offices and those of our group companies, third party service providers, representatives and agents as described above (see above: ‘Who we share your personal information with’).
Some of these third parties may be based outside the European Economic Area. For more information, including on how we safeguard your personal information when this occurs, see below: International Transfer of your personal data’.
8. How long your personal information will be kept
We will keep your personal information while you have an account with us or we are providing services to you. Thereafter, we will keep your personal information for as long as is necessary:
- to respond to any questions, complaints or claims made by you or on your behalf;
- to show that we treated you fairly;
- to keep records required by law.
We will not retain your personal information for longer than necessary for the purposes set out in this policy or otherwise for carrying out the originally envisaged processing activities. Different retention periods apply for different types of personal information. When it is no longer necessary to retain your personal information, we will delete or anonymise it.
9. International transfer of your personal data
To deliver services to you, it is sometimes necessary for us to share your personal data outside the UK and/or European Economic Area (EEA), for example:
- with our group entities located outside the UK/EEA;
- with your and our service providers located outside the UK/EEA;
- if you are based outside the UK/EEA;
- where there is an international dimension to the services we are providing to you.
These transfers are subject to special rules under European and UK data protection law. This means we can only transfer your personal data to a country or international organisation outside the UK/EEA where:
- the European Commission has issued an ‘adequacy decision’ in relation to that country or international organisation; or
- there are appropriate safeguards in place, together with enforceable rights and effective legal remedies for data subjects; or
- a specific exception applies under data protection law,
These are explained below.
European Commission adequacy decision
The European Commission has the power to determine whether a country or international organisation provides an adequate level of protection for personal data and, if it does, to issue an ‘adequacy decision’. The effect of such a decision is that personal data can flow from the UK/EEA to that country without any further safeguards being necessary.
We may transfer personal data to countries that have the benefit of a European Commission adequacy decision. Some countries or international organisations we may transfer personal data to may not have the benefit of an adequacy decision. In such cases we look at alternative grounds for transferring the personal data, such as implementing safeguards or relying on an exception, as explained below.
Transfers with appropriate safeguards
We may transfer your data to a third country or international organisation on this ground where we are satisfied the transfer complies with data protection law, appropriate safeguards are in place, and enforceable rights and effective legal remedies are available for data subjects.
The safeguards will usually include using standard data protection contract clauses approved by the European Commission.
Transfers under an exception
In the absence of an adequacy decision or appropriate safeguards, we may transfer personal data to a third country or international organisation where an exception applies under Data Protection Law, e.g.:
- you have explicitly consented to the proposed transfer after having been informed of the possible risks;
- the transfer is necessary for the performance of a contract between us or to take pre-contract measures at your request;
- the transfer is necessary for a contract in your interests, between us and another person; or
- the transfer is necessary to establish, exercise or defend legal claims
We may also transfer information for the purpose of our compelling legitimate interests, so long as those interests are not overridden by your interests, rights and freedoms. Specific conditions apply to such transfers and we will provide relevant information if and when we seek to transfer your personal data on this ground.
10. Confidentiality and Security
We use physical, electronic, and procedural safeguards to protect personal data. We have appropriate security measures to prevent personal data from being accidentally lost, or used or accessed unlawfully. We limit access to your personal data to those who have a genuine business need to access it. Those processing your information will do so only in an authorised manner and are subject to a duty of confidentiality. We continually test our systems and we follow top industry standards for information security.
We have procedures in place to deal with any suspected data security breach. We will notify you and any applicable regulator of a suspected data security breach where we are legally required to do so.
Data transmissions over the Internet are not 100% secure. Consequently, we cannot guarantee or warrant the security of any information you transmit to us and you do so at your own risk. Once we receive your transmission, we use reasonable efforts to ensure security on our systems.
If you want detailed information from Get Safe Online on how to protect your information and your computers and devices against fraud, identity theft, viruses and many other online problems, please visit www.getsafeonline.org. Get Safe Online is supported by HM Government and leading businesses.
11. Your rights
You have the following rights, which you can exercise (in most cases free of charge):
|Access||The right to be provided with a copy of your personal data|
|Rectification||The right to require us to correct any mistakes in your personal data|
|Right to be forgotten / right to erasure||The right to require us to erase your personal data (in certain situations)|
|Restriction of processing||The right to require us to restrict processing of your personal data (in certain circumstances, e.g. if you contest the accuracy of the data)|
|Data portability||The right to receive the personal data you provided to us, in a structured, commonly used and machine-readable format and/or transmit that data to a third party (in certain situations)|
|To object||The right to object:
—at any time to your personal data being processed for direct marketing (including profiling)
—in certain other situations to our continued processing of your personal data, e.g. processing carried out for the purpose of our legitimate interests
|Not to be subject to automated individual decision making||The right not to be subject to a decision based solely on automated processing (including profiling) that produces legal effects concerning you or similarly significantly affects you|
For further information on each of those rights, including the circumstances in which they apply, please contact us or see the Guidance from the UK Information Commissioner’s Office (ICO) on individuals’ rights under the Data Protection Act 2018.
If you would like to exercise any of those rights, please:
- Contact our DPO — see below: ‘How to contact us’; and
- provide us with enough information to identify you (e.g. your full name, address and customer or matter reference number);
- provide us with proof of your identity (e.g. depending on the circumstances a copy of your driving licence or passport and a recent utility or credit card bill may be required); and
- let us know which right(s) you want to exercise and the specific information to which your request relates. Please note that the more specific you can be regarding the information you wish to receive the quicker it will be for us to locate and share with you the information that is of most interest and relevance to you.
12. Changes to this Privacy Notice
This privacy notice was last updated on 17th January 2021.
Alchemy reserves the right to change this notice at any time. We will notify you via email about material changes in the way we treat personal data or by placing a prominent notice on this website.
13. How to contact us about data protection issues
If you have a privacy concerns regarding Alchemy or this statement, you may contact us via firstname.lastname@example.org
14. How to complain
We hope that Data Protection Officer can resolve any query or concern you may raise about our use of your personal data.
Data protection law also gives you right to lodge a complaint with a supervisory authority, in particular in the country where you work, reside or where any alleged infringement of data protection laws occurred.
The supervisory authority in the UK is the Information Commissioner who may be contacted at https://ico.org.uk/concerns or telephone: 0303 123 1113.
The supervisory authority in Ireland is the Data Protection Commission who may be contacted at https://www.dataprotection.ie/en/contact/how-contact-us.