Highgate Building Services Ltd - Company Registration 09924538
Registered address: Sterling House, 97 Lichfield Street, Tamworth, Staffordshire B79 7QF
The protection of your Personal Data matters to us, therefore we aim to collect, store and process customers and supplier’s data in a lawful, appropriate and transparent manner, in accordance with the European General Data Protection Regulation (EU) 679/2016 (GDPR).
· We ensure transparency in the nature of the Personal Data we collect online and offline through forms and applications.
· We ensure transparency in the use of Personal Data collected.
· We facilitate Data Subjects in the exercise of their rights.
This is our Data Protection Policy which applies to enquiring customers, customers and suppliers, it is important to read this policy in order to understand how we collect and use your information.
1. DATA CONTROLLERS
Any Personal Data you submit online or offline through Forms or through the Website and/or Applications is used for the purposes described below by Highgate Building Services Ltd, in its capacity of Data Controller.
2. DATA PROCESSORS
Highgate Building Services Ltd can also act as Data Processor for online or offline processing or Personal Data .
3. PERSONAL DATA WE COLLECT AND PURPOSES
Highgate Building Services Ltd, to the extent necessary, collects, processes, registers, stores and transfers Data Subjects’ Personal Data provided offline through Forms or online through the Website and/or Applications while, for example, but not limited to:
visiting the Website;
filling in offline or online registration Forms;
submitting job applications;
clicking on social media buttons;
providing feedback (e.g. on Forms, products, Applications, Website, customer service); answering to surveys and other activities.
Personal Data is collected either on a facultative basis or on a compulsory basis. If it is compulsory to provide the Personal Data, this will be marked accordingly. In case a Data Subject fails or denies providing the Personal Data that Highgate Building Services Ltd has marked as compulsory, as a consequence Highgate Building Services Ltd will not be able to carry on the process or the activity requested by that Data Subject.
An example of Personal Data that is marked as compulsory is the situation in which a Data Subject wants to submit an invoice or purchase order. In this case HIGHGATE BUILDING SERVICES LTD needs some personal details in order to process the related request of registration. If the Data Subject wishes to register but does not provide the personal details marked as compulsory, HIGHGATE BUILDING SERVICES LTD will not be able to accept and process the request.
HIGHGATE BUILDING SERVICES LTD can collect Personal Data on a consent basis or without the consent of the involved Data Subject if: 1) a legal obligation must be fulfilled; or 2) a contract in which the Data Subject is party has to be performed or will be performed; or 3) there are Legitimate Interests, public interests or Vital Interests to protect; or 4) an authority has requested HIGHGATE BUILDING SERVICES LTD to process Personal Data.
HIGHGATE BUILDING SERVICES LTD can further process your Personal Data only:
Please find below, the Personal Data we collect and the purposes for which we collect them.
4. PERSONAL DATA WE COLLECT FROM YOU OR FROM THIRD PARTIES.
You can be asked to provide us, depending on the purpose of each Processing and to the extent necessary, different kind of Personal Data including, but not limited to, name, surname, date and place of birth, title, address, telephone, mobile, email address, language, country, nationality, identity card, driver’s license number, national registration number, passport number, curriculum information, employer, occupation, client number, personal social media URL, credit card, preferences, interests, feedbacks.
You can also be asked to provide us, depending on the purpose of each Processing and to the extent necessary, some Special Categories of Personal Data (e.g. trade union membership, Personal Data concerning health).
HIGHGATE BUILDING SERVICES LTD will process Special categories of Personal Data in accordance with GDPR on the basis of :
1) explicit consent of the Data Subject; or
2) fulfilment of legal obligations and/or exercise of the rights of the Controller or of the Data Subject in the field of employment and social security law; or
3) Vital Interests of the Data Subject; or
4) establishment, exercise or defence of legal claims; or
5) substantial Public Interest.
We also use Personal Data you provided to third parties, for example to service providers, or Personal Data that fall within the public domain such as commonly acknowledged Personal Data, Personal Data visible on your own website or blog or posted on your publicly accessible social media profile.
HIGHGATE BUILDING SERVICES LTD may also receive Personal Data via third parties after mergers, acquisitions and any other transforming operation.
5. Purposes of the collection of Personal Data.
Once collected, we use such Personal Data mentioned above for a variety of purposes. Please find them listed below:
Business Administration and customer management.
HIGHGATE BUILDING SERVICES LTD has to be able to perform contracts duly and properly and to carry out all the necessary statutory and accounting processes. Accordingly, HIGHGATE BUILDING SERVICES LTD will need some Personal Data provided by Data Subjects offline through Forms or online through Website and Applications. In accordance with Regulation (EU) 679/2016, for the purpose of performing contracts, the consent of the Data Subject that is or is going to be a party to a contract is not required. The consent of the Data Subject is not required in case of duty to fulfil a legal obligation.
With regard to the management of relationship with customers and the provision of consumer services, HIGHGATE BUILDING SERVICES LTD uses Personal Data (e.g. name, country, nationality, email address, client number, bank account information) in order to:
HIGHGATE BUILDING SERVICES LTD uses Personal Data for product distribution, on the basis of performing a contract/ fulfilling a legal obligation, and particularly in order to:
HIGHGATE BUILDING SERVICES LTD uses Personal Data to keep records of suppliers and service providers, to register and manage purchase orders, business expenses and invoices provided by suppliers or service providers, acting on the basis of performing a contract/ fulfilling legal obligation.
As leading contractor, HIGHGATE BUILDING SERVICES LTD is in the position to provide you with information that is tailored to you and your needs (for example, by using your transaction details, HIGHGATE BUILDING SERVICES LTD is able to inform you about services, offers and suggestions related to your purchase. This is the so called “direct marketing”).
HIGHGATE BUILDING SERVICES LTD uses collected Personal Data, Personal Data that is publicly available (e.g. information available on Internet, through results of the searches, social media results) or Personal Data received from third parties (e.g. Internet Service Providers) for direct marketing purposes and to attract new customers.
HIGHGATE BUILDING SERVICES LTD performs direct marketing also with the aim of organizing internal events, travels, presentations, meetings for employees, customers and Business Partners.
HIGHGATE BUILDING SERVICES LTD does direct marketing through a variety of media including, without limitation, mobile’s text messaging, surveys, email, the Website, online adverts, database marketing, applications and events.
HIGHGATE BUILDING SERVICES LTD performs direct marketing on the basis of its Legitimate Interest of pursuing business objectives.
HIGHGATE BUILDING SERVICES LTD can carry out direct marketing in response to explicit consent of the Data Subject. If you do not want to receive a highly personalised offer, you should not consent to receiving direct marketing when asked to.
HIGHGATE BUILDING SERVICES LTD commits itself to ensure that direct marketing information are provided in a way that is clear and adequate and this by using the channel designated by the recipient in order to keep the inconvenience of being disturbed to a minimum.
Quality improvement of products and services.
HIGHGATE BUILDING SERVICES LTD, based upon its Legitimate Interest to do business or the consent of Data Subjects, uses Personal Data collected through Forms, job applications, surveys, inquiries, comments, feedback submitted to HIGHGATE BUILDING SERVICES LTD, in order to: improve its products and services; carry out further surveys; develop analytical, risk, marketing and other models and to produce statistics. HIGHGATE BUILDING SERVICES LTD also uses your transaction details to develop global models and to perform analyses.
Example: HIGHGATE BUILDING SERVICES LTD may need to process the number of people that have bought a specific Highgate Building Services Ltd product or have applied for a specific service.
In this regard, HIGHGATE BUILDING SERVICES LTD commits as much as possible to aggregate Personal Data in anonymous or Pseudo Anonymous form to make sure that these Personal Data are not easily or are no longer identifiable as yours.
The practice of Processing Personal Data for statistical purposes is particularly justified by Highgate Building Services Ltd desire to put in place strategic choices in order to better perform in the market and to provide you with better products and services.
Personal Data can also be used to assess, simplify and improve Highgate Building Services Ltd processes, for example in order to optimize campaigns, procedures and sales, both offline or online, through the Website and/or through Applications. Example: if you have not completed a procedure or the sales process, we may contact you to find out what went wrong and whether we can help you. In this case we limit our contact to providing technical and administrative support for that specific procedure or process.
Recruitment and Selection.
For the purpose of recruiting talents, HIGHGATE BUILDING SERVICES LTD collects Personal Data such as, but not limited to, name, email, phone number, curriculum information, URL to social media profile from open applicants and targeted applicants applying for example for job vacancies, international traineeship, student internship.
This processing is allowed by the fact that applicants are voluntarily taking steps in order to enter into a contract with HIGHGATE BUILDING SERVICES LTD.
The Personal Data provided by applicants (through filling in Forms or registering and creating a personal account on the Website or when entering Applications) will be used for Processing applications, contacting applicants for human resources management related activities, managing hiring processes (e.g. inviting applicants for interviews and for conducting written tests) and drafting employment contracts.
HIGHGATE BUILDING SERVICES LTD commits itself to erase from its archives Personal Data belonging to applicants, who were not hired at the end of the selection process, when there is no legitimate reason to keep them.
Personnel Administration and Salary Benefits.
HIGHGATE BUILDING SERVICES LTD uses Personal Data, on the basis of performing an (employment) contract, for the purpose of managing personnel and particularly:
Bookkeeping and Accounting.
HIGHGATE BUILDING SERVICES LTD uses Personal Data, on the basis of performing a contract, for the purpose of bookkeeping and accounting and with the aim of:
Legal Claims and Disputes.
We can use Personal Data as evidence and for ascertaining, exercising and safeguarding the rights of HIGHGATE BUILDING SERVICES LTD or of those it represents (e.g. in disputes) before any jurisdiction of any country (for example, among others, the right of HIGHGATE BUILDING SERVICES LTD to defend itself from acts of unfair competition or the right of HIGHGATE BUILDING SERVICES LTD to solicit the fulfilment of an unpaid invoice).
Fraud or Crime prevention.
We can also use Personal Data to prevent, detect and investigate crimes and cyber risks for Legitimate Interest or when a public authority requests to do so.
Corporate Business and Housekeeping.
HIGHGATE BUILDING SERVICES LTD transmits and/or jointly uses the Personal Data collected only when needed and in view of elaborating periodic reports on the outcome and business-related aspects, business plans and corporate strategies. The processing is based on HIGHGATE BUILDING SERVICES LTD Legitimate Interest of doing business.
HIGHGATE BUILDING SERVICES LTD processes Personal Data of Citizens that were lawfully collected unless there is no legal impediment (e.g. a duty of confidentiality or a provision in the data protection legislation).
HIGHGATE BUILDING SERVICES LTD is committed to put in place all the appropriate measures for the protection of Personal Data in line with Regulation (EU) 679/2016.
6. PERSONAL DATA WE GET FROM YOUR USE OF THE WEBSITE AND/OR APPLICATIONS.
Purposes of the collection of Personal Data
When you are visiting the Website and/or Applications, HIGHGATE BUILDING SERVICES LTD collects some of your Personal Data for the following purposes:
Easing the use of the Website and/or Applications.
By collecting some Personal Data (e.g., IP address, log-in data) on the basis of consent of the Data Subject or Legitimate Interest HIGHGATE BUILDING SERVICES LTD is able to adapt the Website and/or applications more according to your needs.
7. WILL PERSONAL DATA COLLECTED BE DISCLOSED TO THIRD PARTIES?
For the above purposes, HIGHGATE BUILDING SERVICES LTD may need services, advice and/or assistance from third parties, including, but not limited to, maintenance of Applications and bug fixing, purchase of Applications, data hosting, advice on compliance with laws and regulations, development of Applications, human resources services, supply services, Internet providers’ services, production of statistics and others.
In this regard, to the extent necessary, we can transmit or disclose Personal Data we collected to any natural person or legal entity, to subcontractors and Business partners that are third parties with respect to HIGHGATE BUILDING SERVICES LTD.
Every time we need to transmit or disclose some Personal Data we collected to third parties, except in case of Legitimate Interest of the third party, HIGHGATE BUILDING SERVICES LTD will make sure to have in place a data processing agreement with this third party under the provisions of Regulation (EU) 679/2016, asking the third party to comply with the principles and the provisions of the same Regulation and to align on appropriate security standards.
8. STORAGE AND CRITERIA
HIGHGATE BUILDING SERVICES LTD does not keep your Personal Data forever. We use your Personal Data to the extent necessary and only with the aim of pursuing the purposes described above. Once the aim no longer exists, we commit to delete the Personal Data, unless archiving them is required by law, at international, European or national level.
The starting point for storing your Personal Data is the statutory retention period (which is often ten years and lasts until the expiry of a contract or the end of a business relationship). The period can be longer where needed for the exercise of our rights.
If no retention period is stipulated by law, the retention period can be shorter in accordance to, but not limited to, one of the following criteria: contract length and legal obligations; business and organizational needs; long-term business relationship; pursuit of direct marketing; statistics.
Some insights only get clearer once they are viewed over a longer time span. For this reason, for some types of Personal Data a more extended time horizon may be necessary (e.g. for those needed in order to design marketing and risk models).
As has been stated, HIGHGATE BUILDING SERVICES LTD commits as much as possible to work with aggregated, anonymized or Pseudo-Anonymized Personal Data and in all cases, it will cease the connections to individuals as quickly as possible.
9. YOUR RIGHTS AS DATA SUBJECT AND HOW TO EXERCISE THEM.
If you have any questions about the protection of your Personal Data or the exercise of your rights, you can contact us at any time by writing to Highgate Building Services Ltd, or by sending via postal mail or by submitting the Form available online under the “contact us” section of the Website and/or the Applications.
Once your Personal Data are subject to Processing, you have several rights as Data Subject that can be exercised, as listed below.
Be as specific as possible any time you wish to exercise your rights. HIGHGATE BUILDING SERVICES LTD can only properly answer queries asked in sufficient detail.
HIGHGATE BUILDING SERVICES LTD will need to verify your identity in as much detail as possible, in order to avoid that someone else tries to exercise your rights. You will therefore be asked to provide a valid identification document when making such a request.
You can have access to your Personal Data
If you would like to access the Personal Data that HIGHGATE BUILDING SERVICES LTD processes about you or you want to know more about:
Please send us your questions in writing (email, contact us form or post).
We will use the Personal Data you provide us through the contact us form/email/posted letter only for the purpose of verifying and Processing your request.
If you exercise your right to access, HIGHGATE BUILDING SERVICES LTD will give you as complete as possible a list or a copy of your Personal Data.
You can complete/rectify/erase/restrict the processing of your Personal Data
It can happen that certain Personal Data held on you by HIGHGATE BUILDING SERVICES LTD is not (or has ceased to be) correct.
It can also happen that you want to add something to the Personal Data you provided us. You can ask for your Personal Data to be rectified or completed at any time, through the contact us form/email/posted letter.
If you want HIGHGATE BUILDING SERVICES LTD to erase your Personal Data, your request will be processed unless no impediment or incompatibility would arise according to law or Legitimate Interests towards the deletion.
If you want to ask for the erasure of your Personal Data, please contact us via the contact us form/email/posted letter.
You can ask for the portability of your Personal Data to yourself or to third parties
If your Personal Data were collected through electronic means, you can ask for the portability of the Personal Data you provided us to yourself or to third parties, via the contact us form/email/posted letter.
You can withdraw your consent to Processing of your Personal Data
Please remember that every time you provide HIGHGATE BUILDING SERVICES LTD with your consent to process your Personal Data, you can subsequently withdraw that consent at any time by following the suggested procedure and as easily as you gave it.
If you want to withdraw your consent, you can do it at any time via the contact us form/email/posted letter.
You can object to Processing or object to Processing by automatized decision-making systems
If you disagree with how HIGHGATE BUILDING SERVICES LTD processes certain Personal Data, you can object it at any time via the contact us form/email/posted letter.
We shall process objections unless there are valid reasons not to do so or reasons provided by law (for example, an objection will be declined if the Processing of Personal Data has been conducted in view of combating fraud).
If you disagree with Processing of your Personal Data based solely on Automated Decision-Making (including Profiling) which produces legal effects or affects similarly a Data Subject, you can object at any time by clicking via the contact us form/email/posted letter.
If you do not agree with the way HIGHGATE BUILDING SERVICES LTD is Processing your Personal Data or you have other questions in this regard, you can always contact the relevant Data Protection Authority.
10. DATA PROTECTION OFFICER
Here follow the contact details of Highgate Building Services Ltd Data Protection Officer:
Through its Website or Applications HIGHGATE BUILDING SERVICES LTD does not knowingly process any Personal Data of persons aged under 16, neither does it make commercial offers to or tries to contact them, unless their legal representative has consented.
12. SECURITY MEASURES TO PROTECT PERSONAL DATA
HIGHGATE BUILDING SERVICES LTD has implemented adequate security measures in order to maintain integrity and security and prevent accidental or unlawful destruction, loss, alteration, unauthorized disclosure of, or access to, Personal Data transmitted, stored or otherwise processed, in line with Regulation (EU) 679/2016.
13. PRIVACY BY DESIGN
HIGHGATE BUILDING SERVICES LTD commits before starting Processing activities using new technologies to carry out data protection impact assessments in accordance with GDPR and by undertaking appropriate actions accordingly.
14. FURTHER CHANGES TO THIS DATA PROTECTION POLICY
HIGHGATE BUILDING SERVICES LTD regularly seeks to improve efforts in protecting Personal Data. This Data Protection Policy can be changed or updated in light of upcoming legislations, at national level.
HIGHGATE BUILDING SERVICES LTD will inform you of all substantive changes of this Data Protection Policy via offline or online means (for example, via the Website).
If you have any questions or remarks, please do not hesitate to contact us.