We are John Hogg Technical Solutions Ltd of Mellors Road, Trafford Park, Manchester M17 1PB, England, (“John Hogg”). We are part of the John Hogg Group of companies. We share your concern about the protection of your personal data and are committed to safeguarding your privacy.
This policy covers data we collect about you, whether via our website: www.johnhogg.co.uk (our “Website”), through our sales and customer service departments, our agents or otherwise. Please read it carefully to understand how your personal data will be treated. We will be the “controller” of the personal data which you provide to us or which we collect from you.
personal data that we collect
We collect a range of personal data relating to you, including your:
- email address;
- telephone number;
- payment information;
- delivery and billing address;
- IP address; and
- any other personal data that you choose to provide to us when you complete our online contact forms or otherwise make contact with us.
how we use your personal data
We use your personal data as follows:
- to maintain our relationship with you whilst you are a customer;
- to process orders and provide agreed goods and services to you;
- for invoicing, processing payments, account set up and maintenance,
- to communicate with you, including to respond to information requests/enquiries submitted and/or to obtain your feedback on our products and services;
- for record keeping, statistical analysis and internal reporting and research purposes;
- to ensure data security and to provide you with access to secure areas of our Website;
- to notify you about changes to our products and services;
- to decide on and notify you about price changes;
- to monitor the quality of our products and services;
- for logistical purposes, including to plan and log delivery routes;
- to investigate any complaint you make;
- to provide evidence in any dispute or anticipated dispute between you and us;
- to customise various aspects of our Website to improve your experience;
as we may otherwise consider necessary to support the operation of our Website;
- to obtain credit references, credit checks and for debt collection, fraud detection and prevention and risk management purposes;
- to monitor and/or record telephone conversations to or from you in order to offer you additional security, resolve complaints, improve our service standards and for staff training purposes; and
- to protect the rights, property, and/or safety of John Hogg, its personnel and others.
automated decision making/profiling
We use technology provided by the credit reference agency Coface (“CRA”) that processes data that you provide to us, in order to analyse customer creditworthiness, which helps us to decide if we are able to offer you an account, through which you can purchase products and services from John Hogg. We will also continue to exchange information about you with the CRA on an ongoing basis, including about your settled accounts and any debts not fully repaid on time. CRAs will share this data with other organisations, which may use it to make decisions on future applications for credit.
If you pass our credit checks, and we provide you with credit terms (details of which will be made available to you) you will be entitled to open an account with us and order any of our products and services in accordance with our Terms of Trading (https://www.johnhogg.co.uk/wp-content/uploads/2015/09/0828271-John-Hogg-Ts_Cs_LR.pdf). If you do not pass our credit checks you will not be able to set up an account but you may still be entitled to order our products or services (in accordance with our Terms of Trading) at our discretion, by making payment upfront.
legal basis for processing
In terms of the legal bases we rely on to process your personal data, these are as follows:
- where you have provided your consent: for direct marketing communications in respect of our own products and services, including in respect of marketing communications sent by electronic means (e.g. email and SMS);
- for the performance of a contract with you (such as a contract for the provision of good and services) or to take steps at your request prior to entering into this contract;
- to comply with legal obligations, including in relation to health and safety and environmental legislation, performing anti-money laundering, terrorism prevention and sanctions screening checks, complaints and investigations or litigation;
- for our legitimate interests in:
– management of your account (including processing payments) and our relationship with you, and communicating with you;
– operating our Website;
– processing orders and supplying our products and services; and
– our internal business purposes which may include processing for the purposes of: record keeping, research, reporting and statistics, data security, to ensure the quality of our products and services, investigating and responding to queries and complaints, obtaining credit references and credit checks, providing payment performance data to credit reference agencies, changing our pricing, debt collection, fraud detection and prevention, risk management, recruitment and training of our personnel, and protecting our rights, property and safety (and that of others). You can object to processing carried out on the basis of our legitimate interests at any time by emailing GDPR@johnhogg.co.uk. See also “Your Rights – The right to object”.
how we share your personal data
When we use your personal data for the purposes specified above, we may also share it with other companies in the John Hogg Group for reporting purposes. In addition, we may share your personal data with:
- third party provider(s) who provide the following types of services to us: marketing, market research, warehousing and logistics, software, recruitment and customer relationship management;
- third party providers in order for us to process payments that are due to us;
- third party service providers and agents we appoint as our sales agents or to perform services on our behalf, who are provided with access to certain John Hogg customer account details in order to process sales or provide services on our behalf:
- third party advertising partners in order for them to assist us in providing us with marketing materials;
- licensed credit reference agencies, debt collection agencies and lawyers when we carry out credit checks, to report on your payment performance and/or seek to recover debts due to us;
- our accountants, auditors, lawyers or similar advisers when we ask them to provide us with professional advice;
- emergency services in the event that we need to report accidents or incidents or request emergency assistance;
- any Government Department, public body or other third parties where we believe in good faith that the law requires this; in the interests of public health and safety; or in order to protect the rights, property, or safety of John Hogg, its employees or others;
- investors and other relevant third parties in the event of an actual or potential sale or other corporate transaction related to John Hogg;
- any other third parties, if authorised by you to do so.
We ensure that where your personal data is transferred to any country outside the European Economic Area this is done using “model clauses” (standard contractual clauses which have been approved by the European Commission as providing adequate safeguards to enable personal data to be transferred outside the European Economic Area) or other specific legally-approved safeguards.
The performance of services by our third party service provider(s) may be subject to a separate privacy statement provided to you by the relevant third party. You should read any such statement carefully.
IP addresses and cookies
We collect data about your computer, including where available your IP address, operating system and browser type, for system administration and to report aggregate data to our advertisers. This is statistical data about our users’ browsing actions and patterns, and does not identify any individual.
For the same reason, we may obtain data about your general internet usage by using a cookie file which is stored on the hard drive of your computer. Cookies contain data that is transferred to your computer’s hard drive. They help us to improve our site and to deliver a better and more personalised service. They enable us:
- To estimate our audience size and usage pattern.
- To store data about your preferences, and so allow us to customise our site according to your individual interests.
- To speed up your searches.
- To recognise you when you return to our site.
We use reasonable security methods to protect the personal data that we process, including Internet standard encryption technology (“SSL“ or “Secure Socket Layer“ technology) to encode personal data that you send to us through our Website. SSL works by using a private key to encrypt data that‘s transferred over the SSL connection. To check that you are in a secure area of the Website before sending personal data to us, please look at the bottom right of your website browser and check that it displays an image of a closed padlock or an unbroken key.
However, please note that whilst we take appropriate technical and organisational measures to safeguard the personal data that you provide to us, no transmission over the Internet can be guaranteed to be secure.
Consequently, please note that we cannot guarantee the security of any personal data that you transfer to us over the Internet.
The following section explains your rights. The various rights are not absolute and each is subject to certain exceptions or qualifications. We will grant your request only to the extent that it follows from our assessment of your request that we are allowed and required to do so under data protection laws. Nothing in this Privacy Statement is intended to provide you with rights beyond or in addition to your rights as a data subject under data protection laws.
A. The right to be informed
You have the right to be provided with clear, transparent and easily understandable information about how we use your personal data and your rights. This is why we’re providing you with the information in this Privacy Statement.
B. The right of access
You have the right to obtain a copy of your personal data (if we’re processing it), and other certain data (similar to that provided in this Privacy Statement) about how it is used. This is so you’re aware and can check that we’re using your personal data in accordance with data protection law. We can refuse to provide information where to do so may reveal personal information about another person or would otherwise negatively impact another person‘s rights.
C. The right to rectification
You can ask us to take reasonable measures to correct your personal information if it’s inaccurate or incomplete e.g. if we have the wrong date of birth or name for you.
D. The right to erasure
This is also known as ‘the right to be forgotten’ and, in simple terms, enables you to request the deletion or removal of your personal data where there’s no compelling reason for us to keep using it or its use is unlawful. This is not a general right to erasure; there are exceptions, e.g. where we need to use the data in defence of a legal claim.
E. The right to restrict processing
You have rights to ‘block’ or suppress the further use of your personal data when we are assessing a request for rectification or as an alternative to erasure.
When processing is restricted, we can still store your personal data, but may not use it further. We keep lists of people who have asked for further use of their personal data to be ‘blocked’ to make sure the restriction is respected in future.
F. The right to data portability
You have rights to obtain and reuse certain personal data for your own purposes across different organisations. This enables you to move, copy or transfer your personal data easily between our IT systems and theirs (or directly to yourself) safely and securely, without affecting its usability. This only applies to your personal data that you have provided to us that we are processing with your consent or to perform a contract which you are a party to (such as pay and compensation services), which is being processed by automated means.
G. The right to object
You have the right to object to certain types of processing, on grounds relating to your particular situation, at any time insofar as that processing takes place for the purposes of legitimate interests pursued by John Hogg or by a third party. We will be allowed to continue to process the personal data if we can demonstrate “compelling legitimate grounds for the processing which override [your] interests, rights and freedoms” or we need this for the establishment, exercise or defence of legal claims.
H. Rights in relation to automated decision making and profiling
You have the right not to be subject to a decision based solely on automated processing (including profiling), which significantly affects you, subject to some exceptions. Where this is the case, you have the right to obtain human intervention, voice your concerns and to have the decision reviewed.
UPDATING THIS STATEMENT
We review our privacy practices from time to time. We ask that you bookmark and periodically review this page for updates to our Privacy Statement. We reserve the right to modify this policy effective seven (7) days after the posting of the revised Privacy Statement.
For further information regarding these rights, about this Privacy Statement generally or to make a complaint please contact our Data Protection Officer at GDPR@johnhogg.co.uk or call us on +44 (0) 161 872 5611. Please provide as much information as possible to help us identify the data you are requesting, the action you are wanting us to take and why you believe this action should be taken. Before assessing your request, we may request additional information in order to identify you. If you do not provide the requested information and, as a result, we are not in a position to identify you, we may refuse to action your request. We will generally respond to your request within one month of receipt of your request. We can extend this period by an additional two months if this is necessary taking into account the complexity and number of requests that you have submitted. We will not charge you for such communications or actions we take, unless:
- you request additional copies of your personal data undergoing processing, in which case we may charge for our reasonable administrative costs, or
- you submit manifestly unfounded or excessive requests, in particular, because of their repetitive character, in which case we may either: (a) charge for our reasonable administrative costs; or (b) refuse to act on the request.
If after contacting John Hogg you are still unhappy you may also complain to the Information Commissioner, all contact details are available on the Information Commissioner‘s Website: https://ico.org.uk.
John Hogg Technical Solutions Ltd
Tel +44 (0) 161 872 5611