(“” “ ” or “ ”) handle personal information. This Policy applies to personal information which we process in the course of doing business including information processed through the Company’s website and in the course of the sale of our products and services to you (collectively, our “ ”).
Please read this Policy carefully and contact us if you have any questions about our privacy practices or your personal information choices.
It is important that you check back often for updates to this Policy. If we make changes we consider to be important, we will let you know by placing a notice on our website and/or contacting you using other methods such as e-mail.
This Policy was last updated on [date and time].
Who are we?
Complete Pool Controls Ltd is a leading independent company supplying recreational water treatment chemicals and dosing equipment for swimming pool & hot tub users via our comprehensive dealer network throughout the UK.
Our brands of Blue Horizons for pools, AquaSPArkle & Gold Horizons SPA for hot tubs and Blue Horizons Commercial for commercial pool operators offer both traditional water treatment products and innovative speciality solutions for swimming pool and hot tub users.
Purpose, legal basis and duration of the processing
We may process personal information about you in different ways depending on our relationship with you. Please click on the link below which most closely identifies your relationship with us:
1. You are or were a customer of our products and/or services.
2. You are a prospective customer or supplier.
3. You are or were a supplier to us.
4. You are a third party with whom we are in contact during the delivery of services to our customers or the possible delivery of services to prospective customers.
5. You are an employee, former employee or a relative of either.
6. You are a prospective employee.
7. We have received your information from a third party.
8. Your relationship with us is not covered by any of the above.
1.You are or were a customer of our products and/or services
We will collect and store personal information such as contact details (including name, address, e-mail address and contact number) of our customers in accordance with our contract with you. Processing your personal data is necessary for the performance of a contract to which you have entered into, or in order to take steps at your request prior to entering into a contract.
We will retain that information and any information relating to the contract between us following completion of the contract(s) between us so that we can respond to any complaints or enquiries relating to the purchase of our products and comply with our obligations to retain information for tax purposes. We keep customer information for up to seven years following the date of our last sale to you.
The Company may also contact you about similar products, because it is in our legitimate interests to direct market to you. However, we will not send you direct marketing e-mail unless you were given the option to opt out of receiving direct marketing e-mail when you purchased products or services from us and did not opt out or you have otherwise given your consent to receiving direct marketing e-mails.
2.You are a prospective client or a prospective supplier
We will collect and store personal information including contact details of people who have expressed an interest in our products or services or signed up to receive our newsletters or people who we reasonably consider we might do business with as a supplier or a client or enter into competitions.
We may collect this information from you, when you contact us (including through this website) at an event or from a mutual contact. We will only collect contact information from your website or another third party website if we have identified you specifically as someone who may be interested in purchasing products from us or delivering goods or services to us.
We may contact you about our products, services, events and new business opportunities for us to work together with you and to keep you informed of our activities and competitions. We believe that it is in our legitimate interests to develop our business and that you would reasonably expect us to process your personal information in this way and that such processing does not have an impact on you in a way that would make this processing unfair. Where your information is stored in our contacts database but is not kept in a customer or supplier file, we carry out a review of our contacts database every 2 years when we consider whether or not we still have a legitimate interest to keep your contact information. Where we consider that we no longer have a legitimate interest to keep your contact information we will delete it.
We will not send you general marketing information as part of a group mailing, e-mailing or telephone campaign unless you have consented to be contacted in this way.
3.You are or were a supplier to us
We will collect and store personal information including contact details of our contractors, sub-contractors, other suppliers and their employees who are involved in the delivery of the contract so that we can receive your goods or services in accordance with our contract with you. We will also retain that information and any information relating to the contract between us for a period of up to seven years following completion of the contract(s) between us so that we can review your performance if any complaints or issues arise after completion of the contract.
We may also contact you about new business opportunities for us to work together with you and to keep you informed of our activities. We will do this where it is in our legitimate interests to develop our business and we will only do this if we believe that you would reasonably expect us to contact you in this way and that such processing does not have an impact on you in a way that would make this processing unfair.
We will not send you general marketing information as part of a group e-mailing campaign unless you have consented to be contacted in this way.
4.You are a third party with whom we are in contact during the delivery of services to our customers or the possible delivery of services to prospective customers
We will collect and store personal information including contact details of third parties with whom we are in contact during the delivery of Services to our customers or discussions relating to Services to prospective customers. We process that information because it is in our legitimate interests to do so in order for us to be able to perform our contracts for our customers or pitch for work from prospective customers. We believe that you would reasonably expect us to process your personal information in this way and that such processing does not impact on you in a way that would make this processing unfair.
Where your personal information is kept as part of a file relating to the performance of a contract with one of our customers, we will also retain that information and any information relating to that contract following completion of that contract(s) so that we can review the file if any complaints or issues arise after completion of the contract. We keep customer information for up to seven years.
Where your information is stored in our contacts database but is not kept in a customer or supplier file, we carry out a review of our contacts database every 2 years when we consider whether or not we still have a legitimate interest to keep your contact information. Where we consider that we no longer have a legitimate interest to keep your contact information we will delete it.
We may also contact you about new business opportunities for us to work together with you and to keep you informed of our activities. We will do this where it is in our legitimate interest to develop our business and we will only do this if we believe that you would reasonably expect us to contact you in this way and that such processing does not have an impact on you in a way that would make this processing unfair.
We will not send you general marketing information as part of a group mailing, e-mailing or telephone campaign unless you have consented to be contacted in this way.
5.You are an employee or relative of any employee
6.You are a prospective employee
If we have received your details in response to a recruitment initiative, we will store the personal information that either you, your recruitment agent or another third party has provided us with. We process that information because it is in our legitimate interests to do so in order for us to be able to assess the suitability of your application for the advertised role and make an informed decision about whether to interview you and, ultimately, recruit you. We may ask for details about your previous experience, education, referees and for answers to questions relevant to the role you have applied for. We believe that you would reasonably expect us to process your personal information in this way and that such processing does not have an impact on you in a way that would make this processing unfair. Therefore, processing your personal data is necessary to take steps at your request prior to potentially entering into an employment contract.
You may be shortlisted to attend an informal introductory meeting or a more structured interview. Information will be generated by both yourself and us. If you have applied for a role online, then we may use a third-party recruitment agency to support us by providing elements of our recruitment service. This service may include short listing applicants for interview.
However, any third party we work with cannot do anything with your personal information which we have provided them unless we have instructed them to do so. This means they cannot share your information with any other organisation other than us and they cannot hold your information any longer than for the retention period detailed below.
Unless you request us not to do so, we may also contact those individuals who are referred to in any information you provide us with, for example referees, this contact may be made by telephone, e-mail or post. We will only do this if we have your express permission to contact them in this way.
If you are unsuccessful then the information you have provided up to that point will be retained for six months following the date from which the role was filled.
If you are successful, the information you have provided throughout the recruitment process will be retained by us as part of your employee file.
7. We have received your information from a third party
8. Your relationship with us is not covered by any of the above
We may hold your contact details and personal information as a result of an interaction between you and one of our employees. We are processing your personal information in this way because it is in our legitimate interests to retain a record of our employee’s engagement with third parties. We believe that you would reasonably expect us to process your personal information in this way and that such processing does not have an impact on you in a way that would make this processing unfair. We carry out a review of our contacts database every 2 years when we consider whether or not we still have a legitimate interest to keep your contact information. Where we consider that we no longer have a legitimate interest to keep your contact information we will delete it.
Where you provide us with personal information about another person
If you give us personal information about another person, you must ensure that:
a) you are legally entitled to give us that information;
b) the disclosure is in accordance with any applicable data protection or privacy laws; and
Personal information we hold
We will store contact information, delivery information and the contents of any correspondence between us. We may also record or take notes during telephone calls and meetings which we will store on any applicable file.
If you purchase a product from us your card information is not held by us, it is collected by our third-party payment processors, who specialise in the secure online capture and processing of credit/debit card transactions.
We may analyse your personal information to create a profile of your interests and preferences so that we can contact you with information relevant to you. By using our website and providing your personal information to us, you are consenting to us analysing your personal data and creating a profile of your interests and preferences. We may make use of additional information about you when it is available from external sources to help us do this effectively. We may also use your personal information to detect and reduce fraud and credit risk.
When we share personal information
The third-party entities we pass your information onto are as follows:
· In the case of customers, our suppliers, sub-contractors and other associated organisations engaged to deliver products and provide services to you.
· Service providers acting as processors who provide, platform, cloud hosting and IT and system administration services.
· HM Revenue & Customs, regulators and other authorities who require reporting of processing activities in certain circumstances.
· Professional advisers acting as processors or joint controllers including lawyers, debt recovery providers, bankers and accountants who provide consultancy, banking, legal, debt recovery, insurance and accounting services.
· Document Transmission Providers (Electronic Signing and Up loading).
We may also share personal information when we believe it is required, such as:
· to comply with legal obligations and respond to requests from government agencies, including law enforcement and other public authorities;
· in the event of a merger, sale, restructure, acquisition, joint venture, assignment, transfer, or other disposition of all or any portion of our business, assets, or stock (including in connection with any bankruptcy or similar proceedings); and
· to protect our rights, users, systems, and Services.
Security precautions in place to protect your information
When you give us personal information, we take steps to ensure that it’s treated securely. Any sensitive information (such as credit or debit card details) is encrypted and protected with the following software 128 Bit encryption on SSL. When you are on a secure page, a lock icon will appear on the bottom of web browsers such as Microsoft Internet Explorer.
Non-sensitive details (your e-mail address etc.) are transmitted normally over the Internet, and this can never be guaranteed to be 100% secure. As a result, while we strive to protect your personal information, we cannot guarantee the security of any information you transmit to us, and you do so at your own risk. Once we receive your information, we make our best effort to ensure its security on our systems. Where we have given (or where you have chosen) a password which enables you to access certain parts of our websites, you are responsible for keeping this password confidential. We ask you not to share your password with anyone.
Under what circumstances will Complete Pool Controls Limited contact me?
Unless you have consented to us marketing to you, we will not share any of the information you have provided with any third parties for marketing purposes or store any of your information outside of the European Economic Area. Regardless of any marketing preferences you have or may consent to, we will continue to communicate with you in respect of the supply and installation of goods.
How long we keep personal information
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.
Details of retention periods for different aspects of your personal data set out in the above Section:.
Your legal rights
We respect your right to access and control your information, and we will respond to requests for information and, where applicable, will correct, amend, or delete your personal information.
· Access to personal information: You have the right to request access to your personal data ( 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. If you request access to your personal information, we will gladly comply, subject to any relevant legal requirements and exemptions, including identity verification procedures. Before providing data to you, we will ask for proof of identity and sufficient information about your interaction with us so that we can locate any relevant data.
· 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 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 above), 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.
· Request restriction of processing of 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 accuracy of the data; (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 the transfer of your personal data to you or to a third party. We will provide to you, or a third party chosen by you, 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.
· Correction of your data: You have the right to request that we correct your personal information if it is inaccurate or requires updating or complete your personal information if the information we hold is incomplete.
· Withdrawal of consent If we are processing your personal information on the basis that you have given your consent to us processing that personal information, you have a right to withdraw your consent at any time by contacting us by e-mail at firstname.lastname@example.org or by telephone on 01242 662700.
· Marketing preferences: to opt out of e-mail marketing, you can use the unsubscribe link found in the e-mail communication you receive from us or you can contact us by e-mail at email@example.com or by telephone on 01242 662700.
If you fail to provide personal data
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 our products 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.
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 let us know by contacting us by e-mail at firstname.lastname@example.org or by telephone on 01242 662700.
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.
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.
This website has links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy notice of every website you visit.
16 or under
We are concerned to protect the privacy of children aged 16 or under. If you are aged 16 or under‚ please get your parent/guardian's permission beforehand whenever you provide us with personal information.
How to contact us
Please contact us with any requests related to your personal information.
We understand that you may have questions or concerns about this Policy or our privacy practices or may wish to file a complaint. Please feel free to contact us in one of the following ways:
Data Protection contact details
Unit 2 The Park
Telephone: 01242 662700