GDPR: DATA PRIVACY NOTICE FOR CLIENTS AND SUPPLIERS

Introduction

Vessel Technology Ltd ("We") are committed to protecting and respecting your privacy.

This policy (together with our terms of use and any other documents referred to on it) sets out the basis on which any personal data we collect from you, or that you provide to us, will be processed by us.  Please read the following carefully to understand our views and practices regarding your personal data and how we will treat it.

The rules on processing of personal data are set out in the General Data Protection Regulation (the “GDPR”).

 

1. Definitions

Data controller - A controller determines the purposes and means of processing personal data.

Data processor - A processor is responsible for processing personal data on behalf of a controller.

Data subject – Natural person

Categories of data: Personal data and special categories of personal data

Personal data - The GDPR applies to ‘personal data’ meaning any information relating to an identifiable person who can be directly or indirectly identified in particular by reference to an identifier (as explained in Article 6 of GDPR). For example name, passport number, home address or private email address. Online identifiers include IP addresses and cookies.

Special categories personal data - The GDPR refers to sensitive personal data as ‘special categories of personal data’ (as explained in Article 9 of GDPR). The special categories specifically include genetic data, and biometric data where processed to uniquely identify an individual. Other examples include racial and ethnic origin, sexual orientation, health data, trade union membership, political opinions, religious or philosophical beliefs.

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.

Third party - means a natural or legal person, public authority, agency or body other than the data subject, controller, processor and persons who, under the direct authority of the controller or processor, are authorised to process personal data.

 

2. Who are we?

Vessel Technology Ltd is the data controller. This means we decide how your personal data is processed and for what purposes. Our contact details are: Company No SC528971 Registered in Scotland; Registered Office: Vessel Technology Ltd, Banchory business centre, Burn O’Bennie Road, Banchory, AB31 5ZU, UK. For all data matters contact the data protection officer at sales@vessel.technology.

 

3. The purpose(s) of processing your personal data

We use your personal data for the following purposes:

  • To maintain our own accounts and records

  • To correspond with you

  • To offer our services

  • To enter into contract negotiations

  • For the performance of any contract with you

  • To send out invoices to clients and follow up on payment of these

  • To make payments to suppliers

  • To maintain our own accounts and records

  • To adhere to legal requirements

  • To inform individuals of news, events or activities

  • You may give us information about you by filling in forms on our site www.vessel.technology (“our site”) or by corresponding with us by phone, email or otherwise.

 

4. The categories of personal data concerned

With reference to the categories of personal data described in the definitions section, we process the following categories of your data:

Personal data:

  • Contact information, which may include, for example, some or all of your name, business address, email address, Skype address, phone number, social media links

  • Invoices sent by suppliers or generated by Vessel Technology Ltd for clients

  • Photographs, drawings and data supplied by clients for the purposes of fulfilling a contract

  • Contractual information agreed between both parties

  • Bank details supplied by yourself

 

We have obtained your personal data in one or more of the following ways: directly from you when doing business with you (including previous business); through completing a webform on our website; from publicly available sources such as those published on company websites; collected from correspondence with others (e.g. other individuals in your organization and you are cc’d); referrals from other clients or individuals; business cards from networking.

5. What is our legal basis for processing your personal data?

    a) Personal data (article 6 of GDPR)

Our lawful basis for processing your general personal data:

  • Processing necessary for the performance of a contract with the data subject or to take steps to enter into a contract

Contact details, Contractual information with clients or suppliers, Bank details for suppliers for remuneration as per terms of contract, or occasionally for clients if a refund is required.

  • Processing necessary for compliance with a legal obligation

Invoices– preparation and storage of invoices in accordance with HMRC requirements.

 

  • Processing necessary for the purposes of the legitimate interests of the data controller or a third party, except where such interests are overridden by the interests or fundamental rights or freedoms of the data subject

Contact details of existing or potential customers or potential suppliers. We have conducted a Legitimate Interest Assessment (LIA) to verify that this is the correct lawful basis for the processing of these data.

More information on lawful processing can be found on the ICO website.

 

6. Sharing your personal data

Your personal data will be treated as strictly confidential, and may be shared only with our distributors in order to supply products and or services.

 

7. How long do we keep your personal data?

We keep your personal data for no longer than reasonably necessary and we only retain your data for the following purposes and use the following criteria to determine how long to retain your personal data.

 

Personal Data

Retention

Purpose

Personal Data = Contact details – clients and suppliers

Unlimited

Fulfilling our contract with you.
Offering you relevant opportunities to engage us to work with you.

Contractual information

Unlimited

Creating quotes and establishing working practices for current contracts.
Taking steps to enter into contracts with you.

Bank details – clients

Deleted after use

Only on occasion that a refund is required.

Bank details – suppliers

Unlimited

For remuneration of current and future contracts.

Invoices – clients

7 years

For fulfilling our legal obligation to HMRC for accounting records.

Invoices – suppliers

7 years

For fulfilling our legal obligation to HMRC for accounting records.

Photographs – suppliers

Unlimited

Marketing.

Photographs – clients

Unlimited

In project archives for relevant projects.

 

 

8. Providing us with your personal data

a) You are under no statutory or contractual requirement or obligation to provide us with your personal data below.

  • Potential customer: contact details.

  • Supplier: contact details and bank details.

But failure to provide data will have the following consequences.

  • Potential customer: we will not be able to offer relevant opportunities for you to use our services.

  • Supplier bank details: we will not be able to pay you for your services.

b) We require your personal data below as it is a statutory or contractual requirement, or a requirement necessary to enter into a contract.

  • Existing customers: contact details, contractual information (including information necessary for invoicing).

  • Suppliers: invoices in order to be paid; contractual information.

 

9. Your rights and your personal data

Unless subject to an exemption under the GDPR, you have the following rights with respect to your personal data:

  • The right to request a copy of the personal data which we hold about you;

  • The right to request that we correct any personal data if it is found to be inaccurate or out of date;

  • The right to request your personal data is erased where it is no longer necessary to retain such data;

  • The right to withdraw your consent to the processing at any time, where consent was your lawful basis for processing the data;

  • The right to request that we provide you with your personal data and where possible, to transmit that data directly to another data controller, (known as the right to data portability), (where applicable i.e. where the processing is based on consent or is necessary for the performance of a contract with the data subject and where the data controller processes the data by automated means);

  • The right, where there is a dispute in relation to the accuracy or processing of your personal data, to request a restriction is placed on further processing;

  • The right to object to the processing of personal data, (where applicable i.e. where processing is based on legitimate interests (or the performance of a task in the public interest/exercise of official authority); direct marketing and processing for the purposes of scientific/historical research and statistics).

 

10. Transfer of Data Abroad

Some personal data may be transferred outside the European Economic Area when information is sent to distributors.

 

11. Automated Decision Making

We do not use any form of automated decision making in our business.

 

12. Further processing

If we wish to use your personal data for a new purpose, not covered by this Data Privacy Notice, then we will provide you with a new notice explaining this new use prior to commencing the processing and setting out the relevant purposes and processing conditions.

 

13. Changes to our privacy policy

Any changes we may make to our privacy policy in the future will be posted on this page and, where appropriate, notified to you by e-mail. Please check back frequently to see any updates or changes to our privacy policy.

 

14. How to make a complaint

To exercise all relevant rights, queries or complaints please in the first instance contact our data protection officer at sales@vessel.technology.

If this does not resolve your complaint to your satisfaction, you have the right to lodge a complaint with the Information Commissioners Office on 03031231113 or via email https://ico.org.uk/global/contact-us/email/ or at the Information Commissioner's Office, Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF, England.