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Orbro Pools Limited Privacy Notice
Our contact details
Orbro Pools Limited
Unit 5 Cottons Yard
Water Lane
Storrington
West Sussex
RH20 3EA
01903 944594
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Contact Data Protection Officer: Maxine Pringle
info@orbro.co.uk
01903 944594
1. What Does This Notice Cover? 

This Privacy Notice explains how we use your personal data: how it is collected, how it is held, and how it is processed. It also explains your rights under the law relating to your personal data. 

2. What Is Personal Data? 

Personal data is defined by the General Data Protection Regulation (EU Regulation 2016/679) (the “GDPR”) and the Data Protection Act 2018 (collectively, “the Data Protection Legislation”) as ‘any information relating to an identifiable person who can be directly or indirectly identified in particular by reference to an identifier’.
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Personal data is, in simpler terms, any information about you that enables you to be identified. Personal data covers obvious information such as your name and contact details, but it also covers less obvious information such as identification numbers, electronic location data, and other online identifiers. 
The personal data that we use is set out in Part 4, below. 

3. What Are My Rights?
Under the Data Protection Legislation, you have the following rights, which we will always work to uphold:
a) The right to be informed about our collection and use of your personal data. This Privacy Notice should tell you everything you need to know, but you can always contact us to find out more or to ask any questions using the details in Part 10. 

b) The right to access the personal data we hold about you. Part 9 will tell you how to do this. 

c) The right to have your personal data rectified if any of your personal data held by us is inaccurate or incomplete. Please contact us using the details in Part 10 to find out more. 

d) The right to be forgotten, i.e. the right to ask us to delete or otherwise dispose of any of your personal data that we hold. Please contact us using the details in Part 10 to find out more. 

e) The right to restrict (i.e. prevent) the processing of your personal data. 

f) The right to object to us using your personal data for a particular purpose or purposes. 

g) The right to withdraw consent. This means that, if we are relying on your consent as the legal basis for using your personal data, you are free to withdraw that consent at any time. 

h) The right to data portability. This means that, if you have provided personal data to us directly, we are using it with your consent or for the performance of a contract, and that data is processed using automated means, you can ask us for a copy of that personal data to re-use with another service or business in many cases. 

i) Rights relating to automated decision-making and profiling. We do not use your personal data in this way 

j) For more information about our use of your personal data or exercising your rights as outlined above, please contact us using the details provided in Part 10. 

It is important that your personal data is kept accurate and up-to-date. If any of the personal data we hold about you changes, please keep us informed as long as we have that data.
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Further information about your rights can also be obtained from the Information Commissioner’s Office or your local Citizens Advice Bureau.
If you have any cause for complaint about our use of your personal data, you have the right to lodge a complaint with the Information Commissioner’s Office. We would welcome the opportunity to resolve your concerns ourselves, however, so please contact us first, using the details in Part 11.
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4. What Personal Data Do You Collect and How?
Depending upon your use, we may collect and hold some or all of the personal and non-personal data set out below, using the methods also set out in the table. We do not collect any ‘special category’ or ‘sensitive’ personal data or any personal data relating to children.
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Identity Information including: Name, title, date of birth and gender.
Provided direct to us by you via e- mail, post or telephone
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Contact information including: address, email address, telephone numbers
Provided direct to us by you via e- mail, post or telephone.
Business information including: business name, job title and profession.
Provided direct to us by you via e-mail, post or telephone.
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Payment information including: card details and bank account information.
Provided direct to us by you via e- mail, post or telephone.
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Cookies
When you conduct a transaction on our website, as part of the process, we collect personal information you give us such as your name, address and email address. Your personal information will be used for the specific reasons stated below only.
Google receive, collect and store any information you enter on our website or provide us in any other way. In addition, they collect the Internet protocol (IP) address used to connect your computer to the Internet; login; e-mail address; password; computer and connection information and purchase history. We may use software tools to measure and collect session information, including page response times, length of visits to certain pages, page interaction information, and methods used to browse away from the page. We also collect personally identifiable information (including name, email, password, communications); payment details (including credit card information), comments, feedback, product reviews, recommendations, and personal profile.
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5. How Do You Use My Personal Data?
Under the Data Protection Legislation, we must always have a lawful basis for using personal data. The following table describes how we may use your personal data, and our lawful bases for doing so:
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Administering our business.
Identity Information,Contact information, Business information , Payment information
Contract – Processing is necessary for a contract we have with you 

Consent – We have received your consent to process your personal data 

Legitimate Interests – in managing and running our business
Supplying our services to you.
Identity Information, Contact information, Business information, Payment Information
Contract – Processing is necessary for a contract we have with you 

Consent – We have received your consent to process your personal data
Legitimate Interests – in managing and running our business 

Managing payments for our services.
Contact information, Payment information
Contract – Processing is necessary for a contract we have with you 

Consent – We have received your consent to process your personal data. 

Legitimate Interests – in managing and running our business 

Communicating with you.
Contact information
Consent – We have received your consent to process your personal data.
Legitimate Interests – in managing and running our business 

Supplying you with information by email, post, telephone or text that you have opted-in-to (you may opt-out at any time by contacting us )
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With your permission and/or where permitted by law, we may also use your personal data for marketing purposes, which may include contacting you by email, telephone, text message or post with information, news, and offers on our products or services. You will not be sent any unlawful marketing or spam. We will always work to fully protect your rights and comply with our obligations under the Data Protection Legislation and the Privacy and Electronic Communications (EC Directive) Regulations 2003, and you will always have the opportunity to opt-out. We will always obtain your express opt-in consent before sharing your personal data with third parties for marketing purposes and you will be able to opt-out at any time.
We will only use your personal data for the purpose(s) for which it was originally collected unless we reasonably believe that another purpose is compatible with that or those original purpose(s) and need to use your personal data for that purpose. If we do use your personal data in this way and you wish us to explain how the new purpose is compatible with the original, please contact us using the details in Part 10.
If we need to use your personal data for a purpose that is unrelated to, or incompatible with, the purpose(s) for which it was originally collected, we will inform you and explain the legal basis which allows us to do so.
In some circumstances, where permitted or required by law, we may process your personal data without your knowledge or consent. This will only be done within the bounds of the Data Protection Legislation and your legal rights.
6. How Long Will You Keep My Personal Data?

We will not keep your personal data for any longer than is necessary in light of the reason(s) for which it was first collected. Your personal data will therefore be kept for the following periods (or, where there is no fixed period, the following factors will be used to determine how long it is kept):
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Identity Information including:
Name, title, date of birth and gender.
Customer Projects
- For 5 Years after the completion of Live project(s) Projects which did not proceed, New Leads & Enquiries - For 2 Years if no project commenced

Employee information
- For 5 Years after period of employment ends
Contact information including: address, email address, telephone numbers
Customer Projects
- For 5 Years after the completion of Live project(s) Projects which did not proceed, New Leads & Enquiries - For 2 Years if no project commenced

Employee information
- For 5 Years after period of employment ends
Business information including:
Business name, job title and profession.
Customer Projects - For 5 Years after the completion of Live project(s) project commenced
Projects which did not proceed, New Leads & Enquiries - For 2 Years if no project commenced

Payment information including:
card details and bank account information.
Customer Projects
- For 5 Years after the completion of Live project(s) Projects which did not proceed, New Leads & Enquiries - For 2 Years if no project commenced

Employee information
- For 5 Years after period of employment ends
Data from third parties including: contact information, business information and payment information.
Customer Projects
- For 5 Years after the completion of Live project(s) Projects which did not proceed, New Leads & Enquiries - For 2 Years if no project commenced

Employee information
- For 5 Years after period of employment ends
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7. How and Where Do You Store or Transfer My Personal Data?

We will only store or transfer your personal data within the UK. This means that it will be fully protected under the Data Protection Legislation.
The security of your personal data is essential to us, and to protect your data, we take a number of important measures, including the following:
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limiting access to your personal data to those employees, agents, contractors, and other third parties with a legitimate need to know and ensuring that they are subject to duties of confidentiality; 

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procedures for dealing with data breaches (the accidental or unlawful destruction, loss, alteration, unauthorised disclosure of, or access to, your personal data) including notifying you and/or the Information Commissioner’s Office where we are legally required to do so;
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8. Do You Share My Personal Data?

We will not disclose Personal Data to any third parties other than employees, directors, agents, subcontractors or advisors on a strict "need-to-know" basis and only under the same (or more extensive) conditions as set out in these terms and conditions or to the extent required by applicable legislation and/or regulations, subject to the following exceptions.
If we sell, transfer, or merge parts of our business or assets, your personal data may be transferred to a third party. Any new owner of our business may continue to use your personal data in the same way(s) that we have used it, as specified in this Privacy Policy.
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In some limited circumstances, we may be legally required to share certain personal data, which might include yours, if we are involved in legal proceedings or complying with legal obligations, a court order, or the instructions of a government authority.
If any of your personal data is shared with a third party, as described above, we will take steps to ensure that your personal data is handled safely,securely, and in accordance with your rights, our obligations, and the third party’s obligations under the law, as described above in Part 7
If we sell, transfer, or merge parts of our business or assets, your personal data may be transferred to a third party. Any new owner of our business may continue to use your personal data in the same way(s) that we have used it, as specified in this Privacy Policy.
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9. How Can I Access My Personal Data? 

If you want to know what personal data we have about you, you can ask us for details of that personal data and for a copy of it (where any such personal data is held). This is known as a “subject access request”. 

All subject access requests should be made in writing and sent to the email or postal addresses shown in Part 10. 
There is not normally any charge for a subject access request. If your request is ‘manifestly unfounded or excessive’ (for example, if you make repetitive requests) a fee may be charged to cover our administrative costs in responding. 

We will respond to your subject access request within Two weeks and, in any case, not more than one month of receiving it. Normally, we aim to provide a complete response, including a copy of your personal data within that time.
In some cases, however, particularly if your request is more complex, more time may be required up to a maximum of three months from the date we receive your request. You will be kept fully informed of our progress. 

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10. How Do I Contact You?
To contact us about anything to do with your personal data and data protection, including to make a subject access request, please use the following details:
For the attention of Maxine Pringle: 

Email address: info@orbro.co.uk

Telephone number: 01903 944594

Postal Address: Unit 5 Cottons Yard, Water Lane, Storrington, West Sussex, RH20 3EA
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11. Changes to this Privacy Notice
We may change this Privacy Notice from time to time. This may be necessary, for example, if the law changes, or if we change our business in a way that affects personal data protection. 
Any changes will be made available via our Website. This Privacy Notice was last updated on 03/08/2020 

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How to complain
You can also complain to the ICO if you are unhappy with how we have used your data.
The ICO’s address:
Information Commissioner’s Office Wycliffe House
Water Lane
Wilmslow
Cheshire
SK9 5AF
Helpline number: 0303 123 1113
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