What is a Privacy Statement and Why is It Important
We know your personal information is important to you and it is also important to ProPhotonix Europe (which means the European wholly and partially owned subsidiaries and affiliates of ProPhotonix Limited hereinafter referred to as “ProPhotonix”, “we”, “us”).
This Privacy Statement applies to your use of www.prophotonix.com (“Our Site”) and tells you what we use your personal information for and explains your rights around how we use it. Please read this Privacy Statement to understand how and why we use your personal information when you use Our Site. If you do not agree with the personal data practices described in this Privacy Statement, please do not use Our Site.
The terms “you” and “your” refers to visitors to Our Site.
Who Controls Your Information
For the purposes of applicable data protection legislation, ProPhotonix Europe is the data controller. You will find our contact details in the “Contact us” section below.
Information We May Collect and Process
We may collect and process the following categories of data:
Information you give us
We receive and store information you enter on Our Site or you give us in any other way when you fill in an online form, check product availability or download a brochure. This includes but may not be limited to:
- Email address
- Phone numbers;
- Company name;
Information we collect about you
Even if you do not explicitly provide us with information, we may collect certain personal information when you interact with Our Site. For example, our servers may keep an activity log that tracks all visitors to Our Site. The information in the activity log may be anonymous and therefore may not identify you individually, however such information, in conjunction with other information that we hold, may also be capable of identifying you and so may constitute personal data within the meaning of personal data legislation. The information our server collects may include among other data:
- Registered domain or home server;
- Email opens and number of clicks (in case you have agreed to receive marketing communications from us);
- The time and date of your visit;
- Your IP address;
- Content, features, and activities that you access and participate in on Our Site;
- Session identification number;
- Your browser type and;
- Your referring URL
We may collect this information passively using technologies such as standard server logs and cookies (see below). We use passively-collected information to administer, operate, and improve Our Site and our other services and systems, and to provide advertisements and other content that is tailored to you.
If, by virtue of applicable laws in your country, any of the information gathered through these passive means constitutes or includes personal data, or if, through linking or associating any information gathered through passive means with any other personal information, we treat the combined information as personal data, the terms of this Privacy Statement will apply. Otherwise, we use and disclose information collected by passive means in aggregate form or otherwise in a non-personally identifiable form.
Information we receive from other sources
We work closely with third parties (including, for example, business partners, sub-contractors in technical, payment and delivery services, advertising networks, analytics providers, search information providers) and may receive information about you from them. This includes but may not be limited to:
- details of your name;
- e-mail address;
- phone number;
- contact information;
We may also process other information, which is not personal data within the meaning of data protection law.
Why We Collect and Process Your Information
Without collecting and using the information you provide to us or we obtain about you, it would not be possible for us to provide you with adequate responses about our products and/or services.
We use information held about you in the following ways:
Information you give to us.
We will use this information:
- to respond to your inquiry;
- to carry out our obligations arising from any contracts entered into between you and us and to provide you with the information, products, and services that you request from us;
- to provide you with information about new products or services we offer that are similar to those that you have already purchased or enquired about, special offers;
- in order to carry out and administer the operation of ProPhotonix’s business;
- to contact you from time to time for market research purposes. We may contact you by email or phone;
- to notify you about important functionality changes to Our Site;
- to tailor advertisements, content, and other aspects of your experience on and in connection with Our Site,
Information we collect about you.
We will use this information:
- to help us determine how people use Our Site and to improve the Site’s performance and usefulness;
- to administer our products and services and for internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes;
- to improve our products and services to ensure that content is presented in the most effective manner for you and for your computer;
- as part of our efforts to keep our products and services safe and secure;
- to measure or understand the effectiveness of advertising we serve to you and others, and to deliver relevant advertising to you;
Information we receive from other sources.
We may combine this information with information you give to us and information we collect about you. We may use this information and the combined information for the purposes set out above (depending on the types of information we receive).
We must have lawful bases to collect and use your personal information, the below sets these out:
Needed for your contract.
Personal information about you is held and used to:
- provide you with a quote;
- provide you with information about the product/ service;
- receive payment;
Required by law:
We use your personal information to comply with law and regulations. For example:
- keeping proper books and records;
- audit purposes;
- to comply with any other legal obligations to which we are subject;
Our legitimate interest.
We use your personal information for our legitimate interests as shown below. We have taken account of any privacy risks and ensured that your data protection rights are not affected. We believe these uses benefit our website visitors and customers. You can contact us if you have any questions using the contact details below.
- Statistical Analysis: we combine and group personal information for analysis to help us understand our website visitors and customers and develop better products and services;
- Prevention of fraud;
- Provision of customer care and service;
With your consent:
From time to time we would like to contact you to:
- invite you to events we are organizing;
- provide you with information on products or services which we feel may interest you;
- gauge satisfaction with the products and/ or services you received from us
Who We Share Your Personal Information With
We may disclose your personal information to our group companies for the administration and management of our business and compliance with applicable laws rules and regulations, and internal policies and procedures across the ProPhotonix Group (including statutory reporting and disclosures to regulatory authorities).
Governmental, regulatory, etc.
We may disclose your personal information to a governmental or regulatory body (including tax authorities, law enforcement agencies, and financial regulators) in order to comply with a legal obligation or to any person pursuant to an order of a court or tribunal.
Professional Advisors and Experts
We may also disclose your information to our solicitors, auditors, insurance advisors and financial services advisors.
We may share your information with selected third parties including:
- Business partners, suppliers, and sub-contractors for the performance of any contract we enter into with them or you (for example, professional advisors, IT systems providers and communications providers, marketing services providers).
- Advertisers and advertising networks that require the data to select and serve relevant adverts to you and others.
- Analytics and search engine providers that assist us in the improvement and optimization of our products or services.
We may disclose your personal information to third parties:
- In the event that we sell or buy any business or assets, in which case we may disclose your personal data to the prospective seller or buyer of such business or assets.
- If ProPhotonix or substantially all of its assets are acquired by a third party, in which case personal data held by it about its customers will be one of the transferred assets.
- If we are under a duty to disclose or share your personal data in order to comply with any legal obligation and agreements; or to protect the rights, property, or safety of ProPhotonix, its customers, or others.
Data Retention Periods
It is our aim to only hold your data for as long as this is necessary.
How long ProPhotonix will hold your personal data for will vary and will be determined by the following criteria:
- the purpose for which ProPhotonix is using it – ProPhotonix will need to keep the data for as long as is necessary for that purpose; and
- legal obligations – laws or regulation may set a minimum period for which ProPhotonix has to keep your personal data.
We are committed to protecting the security of your personal data. We use a variety of security technologies and procedures to help protect your personal data from unauthorized access and use. Any area of our site that is used to capture your personal information or payment details will always be in a secure session using 128-bit Secure Socket Layer (SSL) encryption, which is the industry standard.
As effective as modern security practices are, no physical or electronic security system is entirely secure. The transmission of information via the internet is also not completely secure. We cannot guarantee the complete security of our databases, nor can we guarantee that information you supply will not be intercepted while being transmitted to us over the internet. We will continue to revise policies and implement additional security features as new technologies become available.
Although we will do our best to protect your personal data, we cannot guarantee the security of your personal data transmitted to us. Any transmission of data is at your own risk. Once we receive your personal data, we use appropriate security measures to seek to prevent unauthorized access.
Transfers of Your Information Outside of the European Economic Area
We store your information in different locations. Electronic files are stored on our secure servers in the United Kingdom, Ireland, and the United States of America or in the cloud.
We use cloud solutions for web hosting or proprietary software solutions delivered through the Cloud. Our use of servers and cloud solutions may involve transferring your information outside of the European Economic Area (“EEA”).
We may in some circumstances need to transfer your information to our other offices or agents and contractors located outside the European Economic Area.
Where we transfer your personal data outside the EEA, we will ensure that it is protected in a manner that is consistent with how your personal data will be protected by ProPhotonix in the EEA. Under applicable data protection legislation, this can be done in a number of ways, for instance:
- the country that ProPhotonix sends the data to might be approved by the European Commission as offering an adequate level of protection for personal data;
- the recipient might have signed up to a contract based on “model contractual clauses” approved by the European Commission, obliging them to protect your personal data; or
- where the recipient is located in the US, it might be a certified member of the EU-US Privacy Shield scheme.
In other circumstances, the law may permit ProPhotonix to otherwise transfer your personal data outside the EEA. In all cases, ProPhotonix will ensure that any transfer of your personal data is done in accordance with data protection law.
You can obtain more details of the protection given to your personal data if it is transferred outside the EEA (including a copy of the standard data protection clauses which ProPhotonix has entered into with recipients of your personal data) by contacting us as described below.
As an individual, under EU law you have the right to request that we:
- provide you with information as to whether we process your data and details relating to our processing, and that we provide you with a copy of your data (‘access right’).
- rectify and/ or update any inaccurate data we might have about you without undue delay (‘right to rectification’).;
- the right to object to the processing of data relating to you (‘right to object’).
- under certain circumstances, be restricted from processing your data (‘right to restriction’).
- under certain circumstances, erase your personal data without undue delay (i.e. the “right to erasure”). and
- under certain circumstances, furnish you with the personal data which you provided us within a structured, commonly used and machine-readable format (‘right to data portability’).
You also have the right to lodge a complaint with the competent supervisory authority at any time.
- UK ICO – helpline: 0303 123 1113 or via the contact form on https://ico.org.uk/global/contact-us/email/
- Irish Data Protection Commission – telephone: +353 57 8684800, +353 (0)761 104 800 or via e-mail on firstname.lastname@example.org
Where we process your data solely on the basis of your consent, you are entitled to withdraw your consent at any time. This will not affect the lawfulness of our processing before the withdrawal.
The exercise of your rights might be subject to certain conditions and we might require further information from you before we can respond to your request.
You may exercise your rights by contacting our Data Protection Champion at the address or e-mail address provided below.
Changes to This Statement
We reserve the right to change this Statement from time to time at our sole discretion. If we make any changes, we will publish those changes on our website. At the bottom of this document, you will find the date on which this Statement was last updated.
Questions, comments, requests, and complaints regarding this Statement and the information we hold should be addressed to us at:
Data Protection Champion, dataprotection@prophotonix.
We endeavor to deal with all requests promptly and efficiently.
Last updated: 14th September 2018