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  The purpose of this statement is to provide information regarding how and why Vincent Timber Limited collect, process and store data, as well as providing the appropriate contact information should you wish to request the information we hold about you or request deletion of any data we hold about you.
 
Under the EU General Data Protection Regulation (GDPR) there are six lawful basis for processing personal data. These are detailed as follows:
  • Consent - the individual has given clear consent for you to process their personal data for a specific purpose
  • Contract - the processing is necessary for a contract you have with the individual, or because they have asked you to take specific steps before entering into a contract
  • Legal Obligation - the processing is necessary for you to comply with the law (not including contractual obligations)
  • Vital Interests - the processing is necessary to protect someone's life
  • Public Task - the processing is necessary for you to perform a task in the public interest or for your official functions, and the task or function has a clear basis in law
  • Legitimate Interests - the processing is necessary for your legitimate interests or the legitimate interests of a third party unless there is a good reason to protect the individual's personal data which overrides those legitimate interests. (This cannot apply if you are a public authority processing data to perform your official tasks.)
Further information regarding the lawful basis for processing personal data can be found at ico.org.uk
 
  Vincent Timber Limited Marketing and Sales Data
 
As an organisation that processes business related data, Vincent Timber Limited has assessed all six grounds for lawful processing of personal data and has selected 'Legitimate Interests' as the most suitable lawful ground for the processing of data for the purposes of Vincent Timber Limited marketing and sales.
 
Vincent Timber Limited collects, processes and stores data relating to businesses and decision makers. We believe that the individuals that we process the data of, are likely to have an interest in the Vincent Timber Limited product. Deemed as 'Legitimate Interest' this is based upon specific criteria including the business industry sector, size of organisation as well as the individual's job function within the organisation. Our typical segmentation includes those within marketing, sales, business development, MD and owner related job functions, although this list is not exhaustive and other variables may apply.
 
We will only ever collect, process and store the essential information required for making contact with the data subjects within a business environment. The personal data we collect is limited to first name, last name, email address, contact telephone numbers and social profiles. Other business related data may also be processed including business name, job function, turnover and business address, however we will never collect further personal data such as those classed under 'Sensitive Personal Data'.
 
The data collected will be used to communicate marketing and sales messages relating to Vincent Timber Limited products, based upon the job function held by the data subject. Vincent Timber Limited specifically only sends messages to those we believe are likely to be interested in Vincent Timber Limited products based upon the organisation they are employed by and based upon their job function within that organisation. Messages from Vincent Timber Limited could be delivered via email, social media, via telephone or any other business to business (B2B) marketing methods that may be relevant.
 
When you send Vincent Timber Limited an enquiry form via our website or one of our micro sites you will be asked to provide your contact details. We will use the data you provide to process your request and may use it to inform you by email, telephone or mail about other Vincent Timber Limited products and services that we feel may be of interest to you, it is deemed that as you have visited the Vincent Timber Limited website and provided us with your contact information that you are legitimately interested in our products and services. You have the right to object from any method of correspondence at any time, by informing the telephone operator or by contacting us via any of the methods below.
 
  How we Procure Data
 
At Vincent Timber Limited we procure data in a variety of ways, collected in line with the lawful basis of 'Legitimate Interests'. If you have received correspondence from us, we will have procured your data in one of the following ways:
  • You have requested information from Vincent Timber Limited on a previous occasion
  • Someone has sent us your e-mail address requesting information about our products and/or services be sent to you
  • You or someone else has expressly shared your contact details with us for the purpose of receiving information now and/or in the future
  • We have previously met at an event and your business card or contact details were handed to us willingly
  • You or a business colleague has visited our website and we believe that there is a genuine legitimate interest in our services
  • You have previously connected with a member of our team via social media and discussed our services
  • A member of our team has found your business and your contact details online, believing that your business would genuinely be interested in Vincent Timber Limited products, based upon your job function aligning with our typical customer profiles they have made contact to introduce you to our products
  • Your data has been purchased by a registered third party data supplier, which will have been segmented by industry, organisation size and job function based upon our typical customer profiles. (Due diligence checks around GDPR compliance will have been conducted accordingly).
  Legitimate Interest Assessment (LIA)
 
Vincent Timber Limited has carried out a Legitimate Interest Assessment (LIA) as advised by the ICO. Based upon that assessment it is deemed that the rights and freedoms of the data subjects would not be overridden in our correspondence regarding Vincent Timber Limited and that in no way would a data subject be caused harm by our correspondence. Based upon our segmentation by organisation and by specific job function, coupled with our processing of personal data within the context of a business environment, we believe that any individual that receives correspondence from Vincent Timber Limited in a direct marketing or sales capacity, could be legitimately interested in Vincent Timber Limited products. Per the ICO guidance, Vincent Timber Limited can confirm:
  • We have checked that legitimate interests is the most appropriate basis
  • We understand our responsibility to protect the individual's interests
  • We have conducted a legitimate interests assessment (LIA) and kept a record of it, to ensure that we can justify our decision
  • We have identified the relevant legitimate interests
  • We have checked that the processing is necessary and there is no less intrusive way to achieve the same result
  • We have done a balancing test, and are confident that the individual's interests do not override those legitimate interests
  • We only use individuals' data in ways they would reasonably expect
  • We are not using people's data in ways they would find intrusive or which could cause them harm
  • We do not process the data of children
  • We have considered safeguards to reduce the impact where possible
  • We will always ensure there is an opt-out / ability to object
  • Our LIA did not identify a significant privacy impact, and therefore we do not require a DPIA
  • We keep our LIA under review every six months, and will repeat it if circumstances change
  • We include information about our legitimate interests in our privacy notice
  Data Storage and Retention
 
The data held within the Vincent Timber Limited system is processed and stored in the UK within a secure environment.
 
  Request for Deletion
 
If you make a request for deletion, we will remove any data we hold about you from the Vincent Timber Limited system.
 
Please make your request in writing by emailing:
data-compliance@vincenttimber.co.uk
 
Or by writing to:
Data Compliance, Vincent Timber Limited, 8 Montgomary Street, Sparkbrook, Birmingham, B11 1DU.
 
  Request for Data Held
 
You may request that we send you all of the data we hold that relates to you.
 
Please make your request in writing by emailing:
data-compliance@vincenttimber.co.uk
 
Or by writing to:
Data Compliance, Vincent Timber Limited, 8 Montgomary Street, Sparkbrook, Birmingham, B11 1DU.
 
  This policy was last reviewed and updated on the 21st May 2018. Policies are periodically reviewed to ensure compliance with the current compliance environment.
 
For questions relating to this policy, please contact
data-compliance@vincenttimber.co.uk

 
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Vincent Timber Privacy Policy