GDPR POLICY

1. Introduction


1.1 We are committed to safeguarding the privacy of our website visitors
and also existing and new customers originating through telephone and
email enquiries.
1.2 This policy applies where we are acting as a data controller with
respect to the personal data of all our customers; in other words, where we
determine the purposes and means of the processing of that personal data.
1.3 We will ask you to consent to our use of cookies in accordance with the
terms of this policy when you first visit our website.
1.4 In this policy, “we”, “us” and “our” refer to EASY OPEN LIMITED. For
more information about us, see Section 15.

2. How we use your personal data


2.1 In this Section 2 we have set out:
(a) the general categories of personal data that we may process;
(b) in the case of personal data that we did not obtain directly from you, the
source and specific categories of that data;
Easy Open Ltd
(c) the purposes for which we may process personal data; and
(d) the legal bases of the processing.
2.2 We may process data about your use of our website (“usage data”).
The usage data may include your IP address, geographical location,
browser type and version, operating system, referral source, length of visit,
page views and website navigation paths, as well as information about the
timing, frequency and pattern of your service use. The source of the usage
data is our analytics tracking system. This usage data may be processed
for the purposes of analysing the use of the website and services. The
legal basis for this processing is consent and our legitimate interests,
namely monitoring and improving our website.
2.3 We may process your personal data that are provided in the course of
the use of our services (“service data”). The service data may include your
contact and company details. The source of the service data is you or your
employer. The service data may be processed for the purposes of
providing our services and communicating with you. The legal basis for this
processing is consent.
2.4 We may process information contained in any enquiry you submit to us
regarding goods and/or services (“enquiry data”). The enquiry data may be
processed for the purposes of offering, marketing and selling relevant
goods and/or services to you. The legal basis for this processing is
consent.
2.5 We may process information that you provide to us for the purpose of
subscribing to our email notifications and/or newsletters (“notification
data”). The notification data may be processed for the purposes of sending
you the relevant notifications and/or newsletters. The legal basis for this
processing is consent.
2.6 We may process information contained in or relating to any
communication that you send to us (“correspondence data”). The
correspondence data may include the communication content and
metadata associated with the communication. Our website will generate the
metadata associated with communications made using the website contact
forms. The correspondence data may be processed for the purposes of
communicating with you and record-keeping. The legal basis for this
processing is our legitimate interests, namely the proper administration of
our website and business and communications with users.
2.7 We may process any of your personal data identified in this policy
where necessary for the establishment, exercise or defence of legal claims,
whether in court proceedings or in an administrative or out-of-court
procedure. The legal basis for this processing is our legitimate interests,
namely the protection and assertion of our legal rights, your legal rights and
the legal rights of others.
2.8 We may process any of your personal data identified in this policy
where necessary for the purposes of obtaining or maintaining insurance
coverage, managing risks, or obtaining professional advice. The legal basis
for this processing is our legitimate interests, namely the proper protection
of our business against risks.
2.9 In addition to the specific purposes for which we may process your
personal data set out in this Section 2, we may also process any of your
personal data where such processing is necessary for compliance with a
legal obligation to which we are subject, or in order to protect your vital
interests or the vital interests of another natural person.
2.10 Please do not supply any other person’s personal data to us, unless
we prompt you to do so.

3. Providing your personal data to others


3.1 We may disclose your personal data to any member of our group of
companies (this means our subsidiaries, our ultimate holding company and
all its subsidiaries) insofar as reasonably necessary for the purposes, and
on the legal bases, set out in this policy.
3.2 We may disclose your personal data to our insurers and/or professional
advisers insofar as reasonably necessary for the purposes of obtaining or
maintaining insurance coverage, managing risks, obtaining professional
advice, or the establishment, exercise or defence of legal claims, whether
in court proceedings or in an administrative or out-of-court procedure.
3.3 We may disclose your personal data to our suppliers or subcontractors
insofar as reasonably necessary for the fulfilment of our services.
3.4 In addition to the specific disclosures of personal data set out in this
Section 3, we may disclose your personal data where such disclosure is
necessary for compliance with a legal obligation to which we are subject, or
in order to protect your vital interests or the vital interests of another natural
person.
We may also disclose your personal data where such disclosure is
necessary for the establishment, exercise or defence of legal claims,
whether in court proceedings or in an administrative or out-of-court
procedure.

4. Retaining and deleting personal data


4.1 This Section 4 sets out our data retention policies and procedure, which
are designed to help ensure that we comply with our legal obligations in
relation to the retention and deletion of personal data.
4.2 Personal data that we process for any purpose or purposes shall not be
kept for longer than is necessary for that purpose or those purposes.
4.3 It is not possible for us to specify in advance the periods for which your
personal data will be retained.
(a) usage data
(b) service data
(c) enquiry data
(d) notification data
(e) correspondence data
We will determine the period of retention based on the independent
circumstances of each case.
4.4 Notwithstanding the other provisions of this Section 4, we may retain
your personal data where such retention is necessary for compliance with a
legal obligation to which we are subject, or in order to protect your vital
interests or the vital interests of another natural person.

5. Security of personal data


5.1 We will take appropriate technical and organisational precautions to
secure your personal data and to prevent the loss, misuse or alteration of
your personal data.
5.2 We will store all your personal data on secure servers, personal
computers and mobile devices, and in secure manual record-keeping
systems.
5.3 Data relating to your enquiries and financial transactions that is sent
from your web browser to our web server, or from our web server to your
web browser, will be protected using encryption technology.
5.4 You acknowledge that the transmission of unencrypted (or
inadequately encrypted) data over the internet is inherently insecure, and
we cannot guarantee the security of data sent over the internet.
5.5 You should ensure that your password is not susceptible to being
guessed, whether by a person or a computer program.

6. Amendments


6.1 We may update this policy from time to time by publishing a new
version on our website.
6.2 You should check this page occasionally to ensure you are happy with
any changes to this policy.
6.3 We may notify you of changes to this policy by email or phone.

7. Your rights


7.1 You may instruct us to provide you with any personal information we
hold about you; provision of such information will be subject to:
(a) the payment of a fee (currently fixed at GBP 10); and
(b) the supply of appropriate evidence of your identity (for this purpose, we
will usually accept a photocopy of your passport certified by a solicitor or
bank plus an original copy of a utility bill showing your current address).
7.2 We may withhold personal information that you request to the extent
permitted by law.
7.3 You may instruct us at any time not to process your personal
information for marketing purposes.
7.4 In practice, you will usually either expressly agree in advance to our
use of your personal information for marketing purposes, or we will provide
you with an opportunity to opt out of the use of your personal information
for marketing purposes.

8. Third party websites


8.1 Our website includes hyperlinks to, and details of, third party websites.
8.2 We have no control over, and are not responsible for, the privacy
policies and practices of third parties.

9. Personal data of children


9.1 Our website and services are targeted at persons over the age of 18.
9.2 If we have reason to believe that we hold personal data of a person
under that age in our databases, we will delete that personal data.

10. Updating information


10.1 Please let us know if the personal information that we hold about you
needs to be corrected or updated.

11. About cookies


11.1 A cookie is a file containing an identifier (a string of letters and
numbers) that is sent by a web server to a web browser and is stored by
the browser. The identifier is then sent back to the server each time the
browser requests a page from the server.
11.2 Cookies may be either “persistent” cookies or “session” cookies: a
persistent cookie will be stored by a web browser and will remain valid until
its set expiry date, unless deleted by the user before the expiry date; a
session cookie, on the other hand, will expire at the end of the user
session, when the web browser is closed.
11.3 Cookies do not typically contain any information that personally
identifies a user, but personal information that we store about you may be
linked to the information stored in and obtained from cookies.

12. Cookies that we use


12.1 We use cookies for the following purposes:
(a) authentication – we use cookies to identify you when you visit our
website and as you navigate our website;
(b) personalisation – we use cookies to store information about your
preferences and to personalise our website for you;
(c) security – we use cookies as an element of the security measures used
to protect user accounts, including preventing fraudulent use of login
credentials, and to protect our website and services generally;
(d) analysis – we use cookies to help us to analyse the use and
performance of our website and services; and
(e) cookie consent – we use cookies to store your preferences in relation to
the use of cookies more generally.

13. Cookies used by our service providers


13.1 Our service providers use cookies and those cookies may be stored
on your computer when you visit our website.
13.2 We use Google Analytics to analyse the use of our website. Google
Analytics gathers information about website use by means of cookies. The
information gathered relating to our website is used to create reports about
the use of our website. Google’s privacy policy is available at:
https://www.google.com/policies/privacy/

14. Managing cookies


14.1 Most browsers allow you to refuse to accept cookies and to delete
cookies. The methods for doing so vary from browser to browser, and from
version to version. You can however obtain up-to-date information about
blocking and deleting cookies via these links:
(a) https://support.google.com/chrome/answer/95647?hl=en (Chrome);
(b) https://support.mozilla.org/en-US/kb/enable-and-disable-cookieswebsite-preferences (Firefox);
(c) http://www.opera.com/help/tutorials/security/cookies/ (Opera);
(d) https://support.microsoft.com/en-gb/help/17442/windows-internetexplorer-delete-manage-cookies (Internet Explorer);
(e) https://support.apple.com/kb/PH21411 (Safari); and
(f) https://privacy.microsoft.com/en-us/windows-10-microsoft-edge-andprivacy (Edge).
14.2 Blocking all cookies will have a negative impact upon the usability of
many websites.
14.3 If you block cookies, you will not be able to use all the features on our
website.

15. Our details


15.1 This website is owned and operated by EASY OPEN LIMITED.
15.2 We are registered in England and Wales under registration number
4806881, and our registered office is at 65-67 HIGH STREET, IBSTOCK,
LEICESTERSHIRE, LE67 6LH.
15.3 Our principal place of business is at 65-67 High Street, Ibstock,
Leicestershire, LE67 6LH. You can contact us:
(a) by post, to the postal address given above;
(b) using our website contact form;
(c) by telephone, on the contact number published on our website or by
email, using the email address published on our website


Signed:
L Bradley, Director
Date: August 2020
Review date: August 2022