Privacy Policy and GDPR

Protecting our people, customers, the environment and the future

DATA PROTECTION STATEMENT

From the Complete Connect Directors

Complete Connect Ltd are fully committed to complying with the Data Protection Act 2018 which came into force on 25 May 2018 ensuring Complete Connect complies with all UK and EU law in relation to the collection, management, use, security, access and destruction of personal data. This includes compliance with the EU General Data Protection Regulation (GDPR).

Complete Connect needs to collect personal information in order to carry out our business and provide our wide range of products and services. Personal information may come from existing customers, prospective customers, suppliers, regulatory authorities, our current employees, past employees, prospective employees or other key stakeholders. This personal information may be held in hard copy or electronic format and is controlled and handled according to the above legislation.

Complete Connect maintains compliance through a data management process which includes conducting an annual data assessment, maintaining an up to date privacy policy, maintaining an up-to date data security policy and conducting an annual data management process audit.

Complete Connect have a data controller who is responsible for the management of personal data within Complete Connect and 3rd party services used by Complete Connect.

Our data controller can be contacted by emailing datacontroller@completeconnect.co.uk

or calling our head office on 020-8286-6529

Complete Connect manages data security through:

  1. Our commitment to our data statement
  2. Our data management process
  3. Ensuring we maintain a legal basis for the data we collect
  4. Ensuring how and where data is collected is understood across the company
  5. Ensuring how data is protected is understood across our company
  6. Ensuring adherence with all employees to our internal data security policy

As part of our data management process, Complete Connect have a mechanism to notify the authorities and your data subjects in the event of a data breach.

To ensure Complete Connect have accountability and corporate governance, we have a designated person (data controller) responsible for ensuring GDPR compliance.

The data controller is empowered to evaluate data protection policies, amend policies with the approval of the board and is responsible for the implementation of those policies by working with the senior management team.

The data controller is also responsible for ensuring all third parties that process personal data on our behalf are compliant with our policies, the DPA 2018 and GDPR.

The 5 Core Principles of our Privacy Policy

We will ensure it’s easy for people to request and receive all the information we have about them.

  1. People have the right to see what personal data we have about them and how we are using it.
  2. People also have a right to know how long we plan to store their information and the reason for keeping it that length of time.
  3. We will send them the first copy of this information for free but we will charge a fee for subsequent copies.
  4. We will make sure we can verify the identity of the person requesting the data.
  5. We will comply with such requests within a month.

We will ensure it’s easy for people to correct or update inaccurate or incomplete information in accordance with GDPR Art 15 and 16

  1. We will endeavour to keep data up to date by putting a data quality process in place.
  2. People can view (Article 15) and update their personal information for accuracy and completeness.
  3. We will ensure we can verify the identity of the person requesting the data.
  4. We will comply with requests under Article 16 within a month.

People have the right to ask us to delete all the personal data we have about them

  1. We will honour their request within a month except where we have grounds to deny.
  2. We may deny the request if this is means we cannot comply with a legal obligation.
  3. We will verify the identity of the person making the request.
  4. We will stop processing a person’s data if there’s a dispute about the lawfulness of the processing or the accuracy of the data.
  5. We will honor their request within a month.
  6. We will notify the data subject before we begin processing their data again.

We will send a person’s personal data if requested and we are allowed to do so

  1. We will send in a commonly readable format (e.g. a spreadsheet) either to them or to a third party they designate all information we hold
  2. We will verify the identity of the person making the request.

We will ensure it is easy for people to object to us processing their data

  1. We will stop processing people’s data immediately for the purposes of direct marketing if requested.

Below are a list of definitions that Complete Connect use within their Data Protection and Privacy Policy. These have been aligned to the definitions set out in Article 4 of the GDPR

‘personal data’ means any information relating to an identified or identifiable natural person

‘data subject’ means the identifiable person for who we hold personal data

‘processing’ means any operation or set of operations which is performed on personal data

‘restriction of processing’ means the marking of stored personal data with the aim of limiting their processing in the future

‘profiling’ means any form of automated processing of personal data consisting of the use of personal data to evaluate certain personal aspects relating to a natural person

‘pseudonymisation’ means the processing of personal data in such a manner that the personal data can no longer be attributed to a specific data subject

‘filing system’ means any structured set of personal data which are accessible according to specific criteria, whether centralised, decentralised or dispersed on a functional or geographical basis;

‘controller’ means the legal person alone or jointly with others, determines the purposes and means of the processing of personal data

‘processor’ means a person which processes personal data

1‘recipient’ means a person to which the personal data are disclosed, whether a third party or not

‘third party’ means a natural or legal person body other than the data subject, controller, processor and persons who, under the direct authority of the controller or processor, are authorised to process personal data;

‘consent’ of the data subject means any freely given, specific, informed and unambiguous indication of the data subject’s signifies agreement to the processing of personal data

‘personal data breach’ means a breach of security leading to the accidental or unlawful destruction, loss, alteration, unauthorised disclosure of, or access to, personal data transmitted, stored or otherwise processed;

‘genetic data’ means personal data relating to the inherited or acquired genetic characteristics

‘biometric data’ means personal data resulting from specific technical processing relating to the physical, physiological or behavioural characteristics of a natural person

‘data concerning health’ means personal data related to the physical or mental health of a natural person, including the provision of health care services, which reveal information about his or her health status

‘main establishment’ means:
• as regards a controller with establishments in more than one Member State, the place of its central administration in the Union, unless the decisions on the purposes and means of the processing of personal data are taken in another establishment of the controller in the Union and the latter establishment has the power to have such decisions implemented, in which case the establishment having taken such decisions is to be considered to be the main establishment;

• as regards a processor with establishments in more than one Member State, the place of its central administration in the Union, or, if the processor has no central administration in the Union, the establishment of the processor in the Union where the main processing activities in the context of the activities of an establishment of the processor take place to the extent that the processor is subject to specific obligations under this Regulation;
‘representative’ means a natural or legal person established in the Union who, designated by the controller or processor in writing pursuant to Article 27, represents the controller or processor with regard to their respective obligations under this Regulation;

‘enterprise’ means a natural or legal person engaged in an economic activity, irrespective of its legal form, including partnerships or associations regularly engaged in an economic activity;

‘group of undertakings’ means a controlling undertaking and its controlled undertakings;

‘binding corporate rules’ means personal data protection policies which are adhered to by a controller or processor established on the territory of a Member State for transfers or a set of transfers of personal data to a controller or processor in one or more third
countries within a group of undertakings, or group of enterprises engaged in a joint economic activity;

‘supervisory authority’ means an independent public authority which is established by a Member State pursuant to Article 51;

‘supervisory authority concerned’ means a supervisory authority which is concerned by the processing of personal data because:
• the controller or processor is established on the territory of the Member State of that supervisory authority;
• data subjects residing in the Member State of that supervisory authority are substantially affected or likely to be substantially affected by the processing;
• a complaint has been lodged with that supervisory authority;
‘cross-border processing’ means either:
• processing of personal data which takes place in the context of the activities of establishments in more than one Member State of a controller or processor in the Union where the controller or processor is established in more than one Member State; or

• processing of personal data which takes place in the context of the activities of a single establishment of a controller or processor in the Union but which substantially affects or is likely to substantially affect data subjects in more than one Member State.

‘relevant and reasoned objection’ means an objection to a draft decision as to whether there is an infringement of this Regulation, or whether envisaged action in relation to the controller or processor complies with this Regulation, which clearly demonstrates the significance of the risks posed by the draft decision as regards the fundamental rights and freedoms of data subjects and, where applicable, the free flow of personal data within the Union;

‘information society service’ means a service as defined in point (b) of Article 1(1) of Directive (EU) 2015/1535of the European Parliament and of the Council (_);

‘international organisation’ means an organisation and its subordinate bodies governed by public international law, or any other body which is set up by, or on the basis of, an agreement between two or more countries.

DATA PROTECTION

Some key points for our customers and other stakeholders

The legal basis for Complete Connect to collect personal data is through the performance of a contract to which the data subject is party or in order to take steps at the request of the data subject prior to entering into a contract (In accordance with Article 6 and Article 7 GDPR).

For example, for customers this is likely to be through providing a quote of information about our products and services that will lead to making a quote.

Complete Connect will ensure that people have timely and easy access to any personal data we hold on them. We will also ensure people can have their personal data removed or amended as long as this doesn’t conflict with any of our legal obligations. We are in full compliance with Articles 12 through to 21 GDPR in relation to the rights of the person.

Complete Connect do not make decisions based on any form of automated profiling.

Complete Connect review and amend our data management process annually to ensure we maintain correct handling of personal data.

Complete Connect do not pass on any personal data to other organisations except where we are using 3rd party services for our own internal use. All 3rd party services have been audited to ensure full compliance to the data protection act and GDPR.

DATA PROTECTION AND OUR WEBSITE

Complete Connect Ltd (“us”, “we”, or “our”) operates the completeconnect.co.uk website (the “Service”, the “Website”). Our registered address is: Unit 16 Southdown Drive, London, SW20 8EZ.

The information below informs you of our policies regarding the collection, use, and disclosure of personal data when you use our website and the choices you have associated with that data.

We use your data to provide and improve our service. By using our service, you agree to the collection and use of information in accordance with this policy.

Usage Data

Complete Connect use Google analytics to collect usage data. This data is collected automatically, either generated by the use of our website or from the website infrastructure itself (for example, the duration of a page visit).

We may also collect information on how the website is accessed and used (“Usage Data”). This usage data may include information such as your computer’s internet protocol address (e.g. IP address), browser type, browser version, the pages of our Website that you visit, the time and date of your visit, the time spent on those pages, unique device identifiers and other diagnostic data.

Cookies

Cookies are small pieces of data stored on a user’s device (For example: laptop, mobile phone, tablet).

Re-marketing

Re-marketing (sometimes known as “re-targeting”) is the tactic of serving targeted ads to people who have already visited or taken action on a website. In terms of technical execution, re-marketing is the process of using a javascript tag (known as a pixel) to place a cookie in the user’s browser. The cookie then informs a re-marketing platform to serve specific display ads to an internet user, based on the pages or products the user has engaged with or searched for on a website or app.

Complete Connect’s Data Controller

Our data controller determines the purposes of the data we collect from our website and the manner in which data is processed. You can contact our data controller through the email address on this page.

Complete Connect data processors and our external service providers

Complete Connect ensure our data processors work in accordance with our data management process.

External service providers (any person other than an employee of the data controller who processes the data on behalf of the data controller) are used so that we can process your data more effectively. All external service providers fully comply with the DPA and GDPR.

Information Collection And Use

We collect several different types of information for various purposes to provide and improve our Service to you.

Tracking Cookies Data

We use cookies and similar tracking technologies to track the activity on our Website and hold certain information. Cookies are files with small amount of data which may include an anonymous unique identifier.

Cookies are sent to your browser from a website and stored on your device. Tracking technologies also used are beacons, tags, and scripts to collect and track information and to improve and analyse our Service. You can instruct your browser to refuse all cookies or to indicate when a cookie is being sent. However, if you do not accept cookies, you may not be able to use some portions of our Website.

We recommend that you conduct an internet search for the terms “control cookies via browser” for appropriate results on how to control cookies.

Google Analytics

We use Google Analytics to track the use of our Website, this data allows us understand (for example) the most popular pages of our website, which general geographic location our Website is users come from and how long users spend on our Website.

We cannot use this data to personally identify you and we would not seek to do so.

Heatmaps

We use “Heatmaps” to track where users click on our Website pages. Tthis allows us to understand the most popular features of a given web page.

We are unable to identify which users clicked where, only that a click was registered.

Re-marketing

We use cookies to track website users so that we are able to offer them online behavioural advertising via our advertising partners (Facebook and Google are two examples).

We are unable to identify you personally from this information and we rely on our partners to serve the advertisements to you.

If you reside within the European Union, you may use this tool to help you opt out of these advertising services – www.youronlinechoices.com

Please be aware that we share data with our partners as part of our cookie use.

We select our service providers using our Data Management Process and would never knowingly use any service that would put your data at risk.

Use of Data

Complete Connect Ltd uses the collected data for various purposes:

  1. to provide and maintain our Service
  2. to notify you about changes to our Service
  3. to allow you to participate in interactive features of our Website when you choose to do so
  4. to provide customer support
  5. to gather analysis or valuable information so that we can improve our Service
  6. to monitor the usage of our Website, to detect, prevent and address technical issues.

Retention of Data

Complete Connect Ltd will retain your Personal Data only for as long as is necessary for the purposes set out in this Privacy Policy.

We will retain and use your Personal Data to the extent necessary to comply with our legal obligations (for example, if we are required to retain your data to comply with applicable laws), resolve disputes, and enforce our legal agreements and policies.

We will only use your Personal Data to contact you regarding enquiries submitted via our Website.

Any other use of Personal Data (such as email marketing) will be used only with your consent, which will be obtained at the point of data submission (such as contact forms).

Complete Connect Ltd will also retain Usage Data for internal analysis purposes. Usage Data is generally retained for a shorter period of time, except when this data is used to strengthen the security or to improve the functionality of our Service, or we are legally obligated to retain this data for longer time periods.

Transfer of Data

Your information, including Personal Data, may be transferred to – and maintained on – computers located outside of your state, province, country or other governmental jurisdiction where the data protection laws may differ than those from your jurisdiction. We do this as some of our service providers operate outside of the European Union. If you are located outside United Kingdom and choose to provide information to us, please note that we transfer the data, including Personal Data, to United Kingdom and process it there. Your consent to this Privacy Policy followed by your submission of such information represents your agreement to that transfer.

Complete Connect Ltd will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this Privacy Policy and no transfer of your Personal Data will take place to an organisation or a country unless there are adequate controls in place including the security of your data and other personal information.
Disclosure of Data – Complete Connect Ltd may disclose your Personal Data in the good faith belief that such action is necessary to: to comply with a legal obligation, to protect and defend the rights or property of Complete Connect Ltd, to prevent or investigate possible wrongdoing in connection with the Website, to protect the personal safety of users of the Website or the public, to protect against legal liability.

Your Rights

Complete Connect Ltd aims to take reasonable steps to allow you to correct, amend, delete, or limit the use of your Personal Data. To update or delete any details that we hold about you, or if you wish to be informed what Personal Data we hold about you and if you want it to be removed from our systems, please contact us by phone 020 8286 6529 or by email marketing@completeconnect.co.uk and we will make the required changes to any of our systems.

Also, if you would like to access and receive a copy of the Personal Data we hold about you, to rectify any Personal Data held about you that is inaccurate, to request the deletion of Personal Data held about you please contact us by phone 020 8286 6529 or by email marketing@completeconnect.co.uk

You have the right to data portability for the information you provide to Complete Connect Ltd. You can request to obtain a copy of your Personal Data in a commonly used electronic format so that you can manage and move it. Please note that we may ask you to verify your identity before responding to such requests.

Security of Data

The security of your data is important to us but remember that no method of transmission over the Internet, or method of electronic storage is 100% secure. While we strive to use commercially acceptable means to protect your Personal Data, we cannot guarantee its absolute security.

Your Rights

Complete Connect Ltd aims to take reasonable steps to allow you to correct, amend, delete, or limit the use of your Personal Data. To update or delete any details that we hold about you, or if you wish to be informed what Personal Data we hold about you and if you want it to be removed from our systems, please contact us by phone 020 8286 6529 or by email marketing@completeconnect.co.uk and we will make the required changes to any of our systems.

Also, if you would like to access and receive a copy of the Personal Data we hold about you, to rectify any Personal Data held about you that is inaccurate, to request the deletion of Personal Data held about you please contact us by phone 020 8286 6529 or by email marketing@completeconnect.co.uk

You have the right to data portability for the information you provide to Complete Connect Ltd. You can request to obtain a copy of your Personal Data in a commonly used electronic format so that you can manage and move it. Please note that we may ask you to verify your identity before responding to such requests.

Service Providers

We may employ third party companies and individuals to facilitate the function of our Website (“Service Providers”), to provide the Service on our behalf, to perform Service-related services or to assist us in analysing how our Website is used.

These third parties have access to your Personal Data only to perform these tasks on our behalf and are obligated not to disclose or use it for any other purpose.

Links to Other Sites

Our Service may contain links to other sites that are not operated by us.

If you click on a third party link, you will be directed to that third party’s site.

We strongly advise you to review the Privacy Policy of every site you visit. We have no control over and assume no responsibility for the content, privacy policies or practices of any third party sites or services.

Children’s Privacy

Our Service does not address anyone under the age of 13 (“Children”).
We do not knowingly collect personally identifiable information from anyone under the age of 13. If you are a parent or guardian and you are aware that your Children has provided us with Personal Data, please contact us.

If we become aware that we have collected Personal Data from children without verification of parental consent, we take steps to remove that information from our servers.

Parents or guardians are advised to control the data that could possibly be collected on persons under 13 years of age by changing their browser settings to control cookies.

Changes to This Privacy Policy

We may update our Privacy Policy from time to time.

We will notify you of any changes by posting the new Privacy Policy on this page. If we hold Personal Data about you and our policy change may impact you, we will let you know via email and/or a prominent notice on our Service, prior to the change becoming effective and update the “effective date” at the top of this Privacy Policy.

You are advised to review this Privacy Policy periodically for any changes. Changes to this Privacy Policy are effective when they are posted on this page.

CONTACT US

If you have any questions about this Privacy Policy, please contact us

by phone 020 8286 6529 or
by email datacontroller@completeconnect.co.uk.

The information, images and other material contained in this website are subject to change without notice. Complete Connect Limited shall not be liable to any person or organisation for any special, incidental, indirect or consequential damages, including, without limitation, damages resulting from use of or reliance on this information, loss of profits or revenues or costs of replacement goods, even if informed in advance of the possibility of such damages.

The copyright of images and other material on this website are owned by Complete Connect Limited. You may download and reprint images and other information for non-commercial, private purposes only. You may not manipulate or alter in any way images or information on this website without specific permission from Complete Connect Limited or the copyright owner.


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