Privacy Policy

This privacy policy was last updated on 21 June 2018.

This privacy policy states how “Space-Ray” will respect your privacy when processing your personal data. It sets out how “Space-Ray” utilises and protects any information collected about you.  “Space-Ray” is the trading name of Gas Fired Products (UK) Limited, a company registered in England and Wales with company number 00812608 whose registered office is at Space Ray House, Claydon, Ipswich, Suffolk  IP6 0JL.

We are committed to ensuring that your privacy is protected. Should we ask you to provide certain information by which you can be identified, then you can be assured that it will only be used in accordance with this privacy statement.

We may change this policy from time to time by updating this page. You should check this page from time to time to ensure that you are happy with any changes. This policy is effective from the “Last Updated” date above.

You can contact our data privacy manager using the following e-mail address: info@spaceray.co.uk.  You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK Supervisory authority for data protection issues (www.ico.org.uk).  We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.

Some areas of our website will request or collect information from you, this may include the following:

• Your name.
• Demographic information (like your postal address).
• Contact information (like your email address and telephone number).
• Other information relevant to our customer surveys or offers like preferences and interests.

We do not collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data).  Nor do we collect any information about criminal convictions and offences.

Where we need to collect personal data by law, or under the terms of a contract we have with you and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example to provide you with goods or services).  In this case, we may have to cancel a product or service you have with us but we will notify you if this is the case at the time.

How is your personal data collected?

We use different methods to collect data from and about you including through:

• Direct interactions.  You may give us your identity, contact and financial data by filling in forms or by corresponding with us by post, phone, e-mail or otherwise.  This includes personal data you provide when you:

• • apply for our products or services;
  • create an account on our website;
  • subscribe to our service or publications;
  • request marketing to be sent to you;
  • enter a competition, promotion or survey; or
  • give us some feedback.

• Automated technologies or interactions.  When and if you interact with our website, we may automatically collect Technical Data about your equipment, browsing actions and patterns and your usage data in respect of your use of our website.  We collect this personal data by using cookies and other similar technologies.  Please see our Cookie Policy below for further details.

What “Space-Ray” do with the information we gather

“Space-Ray” require information to better understand our clients’ needs and to provide the best services possible. We may use any information collected for:

• Internal record keeping.
• Delivery of goods ordered by you.
• Improving our products and services.
• Contacting you with regards to any solicitations you have made to us.
• Periodically sending you emails, with your permission, about new products, special offers or other information which we think you may find interesting.
• Complying with legal or regulatory obligations.
• We will not pass on your personal information to any 3rd parties without your express permission or where it is necessary for the purpose of performing a contract with you, or where we are required by law to do so.

How we use your personal data

We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:

• Where we need to perform the contract we are about to enter into or have entered into with you.
• Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
• Where we need to comply with a legal or regulatory obligation.

See the glossary at the end of this policy to find out more about the types of lawful basis that we will rely on to process your personal data.

Generally we do not rely on consent as a legal basis for processing your personal data other than in relation to sending third party direct marketing communications to you via email or text message. You have the right to withdraw consent to marketing at any time by contacting us (please see the details at the beginning of this policy for details of for how to contact us).

Purposes for which we will use your personal data

We use your personal data in the following ways:

• personal data that you provide to us is used to:

• • provide you with the information, products and services that you request from us;
  • provide you with marketing information in accordance with your marketing preferences (see below for issue details);
  • manage and administer our business; and
  • review and improve our goods and service.

Personal data that we receive from third parties is combined with the personal data that you provide to us and used for the purposes described above.

Personal data about your use of our website is used to:

• administer our website and for internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes;
• to improve our website to ensure that content is presented in the most effective manner for you and for your computer or mobile device;
• to allow you to participate in interactive features of our website, when you choose to do so;
• to provide support services; and
• as part of our efforts to keep our site safe and secure.

How we use your personal data for marketing

We will add your details to our marketing database if:

• you make an enquiry about our goods or services;
• you buy our goods or services;
• you have told a third party that you would like them to pass us your contact details so that we can send you updates about our goods and services; and
• you have registered an account on our website and have indicated during the sign up process that you are happy to receive marketing communications.

We may send you marketing communications by e-mail, telephone, automated calls, text message or post.

You can ask us to only send you marketing communications by particular methods (for example, you may be happy to receive emails from us but not telephone calls), or you may ask us not to send you any marketing communications at all.

We may ask you to indicate your marketing preferences when you first register an account on our website.  You can check and update your current marketing preferences at any time by contacting us (see the beginning of this policy for how to contact us).

We never share your personal data with third parties for marketing purposes.

Change of purpose

We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us (see the beginning of this policy for how to contact us).

If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.  If this requires your consent, you are not required to give your consent just because we ask for it.  If you do give your consent, you can change your mind and withdraw it at a later date by contacting us (see the beginning of this policy for how to contact us).

Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

Security

“Space-Ray” are committed to ensuring that your information is as secure as practically possible. In order to prevent unauthorised access or disclosure we have put in place suitable physical, electronic and managerial procedures to safeguard and secure the information we collect online.

Links to Other Websites

Our website may contain links to other websites of interest. However, once you have used these links to leave our site, you should note that we do not have any control over that other website. Therefore, we cannot be responsible for the protection and privacy of any information which you provide whilst visiting such sites and such sites are not governed by this privacy statement. You should exercise caution and look at the privacy statement applicable to the website in question.

Data retention

How long will you use my personal data for?

We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.

To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.

By law we have to keep basic information about our customers (including Contact, Identity, Financial and Transaction Data) for six years after they cease being customers for tax purposes.

In some circumstances you can ask us to delete your data: see request for erasure in the next section  below for further information.

In some circumstances we may anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes in which case we may use this information indefinitely without further notice to you.

Your legal rights

Under certain circumstances, you have rights under data protection laws in relation to your personal data, these are as follows:

• Request access to your personal data (commonly known as a “data subject access request”):

• This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.

• Request correction of your personal data:

• This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.

• Request erasure of your personal data:

• This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.

• Object to processing of your personal data:

• You can object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.

• Request restriction of processing your personal data:

• This enables you to ask us to suspend the processing of your personal data in the following scenarios: (a) if you want us to establish the data’s accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.

• Request transfer of your personal data:

• If requested, we will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.

• Right to withdraw consent:

• You can withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.

If you wish to exercise any of the rights set out above, please contact us (please see the beginning of this policy for how to contact us).

No fee usually required

You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.

What we may need from you

We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

Time limit to respond

We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.

Glossary

Controller means, unless otherwise provided by law, the natural or legal person, public authority, agency or other body which, alone or jointly with others, determines the purposes and means of the processing of personal data.

Lawful Basis

Legitimate Interest means conducting and managing our business in our interests, or the interests of a third party.  Our interests could include, for example, our internal administrative purposes, ensuring network and information security or for direct marketing. Whether a particular legitimate interest may exist can also depend on the relationship we have with you (for example, where you are a customer of ours).

We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests or the interests of a third party. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us (please see the beginning of this policy for how to contact us).

Performance of Contract means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.

Comply with a legal or regulatory obligation means processing your personal data where it is necessary for compliance with a legal or regulatory obligation that we are subject to.

Personal data means any information relating to an identified or identifiable natural person (data subject); 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.

Processing means any operation or set of operations which is performed on personal data or on sets of personal data, whether or not by automated means, such as collection, recording, organisation, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction.

Processor means a natural or legal person, public authority, agency or other body which processes personal data on behalf of the controller.