Privacy Notice – May 2018

Phoenix Inspection Systems Limited (Phoenix) understands the importance of privacy and protecting your personal data. This privacy notice sets out the data which Phoenix collects about you and how Phoenix uses your personal data.

This privacy notice applies to our website at (the Website) and to any other dealings which we may have with you (including, for example, dealings over the phone or in person).

1. Phoenix is the data controller in respect of your personal data.

2. We collect the following personal data from you:

Information you give us:

• Information that you provide to us by filling in forms or registering with the Website or by dealing with us or our representatives by telephone, e-mail, in person or otherwise.
• Information you provide when you subscribe for our services, search for a product, place an order, whether on the Website or otherwise, or when you report a problem with the Website.

The information may include:

a) your personal details, such as your name, address, email address and telephone number; and
b) if needed or if you purchase a product from us: your financial details, delivery details and information relating to your purchase(s).

It is important that any personal data we retain about you is accurate. Please keep us informed if your personal data changes at any point during your relationship with us.

Information we collect about you:

• We and our service providers may collect various pieces of technical information each time you visit the Website including:

• your internet protocol (IP) address, any login information, your browser type and version, your time zone setting, your browser plug-in types and versions and your device operating system and platform;

• statistical and analytical information, including the full Uniform Resource Locators (URL), clickstream to, through and from the Website (including the date and time of access), products you viewed or searched for, page response times, download requests and errors, length of visits to certain pages, page interaction information (for instance scrolling, clicks and mouse-overs) and methods used to browse away from the page.

3. We and our service providers collect your personal data for the following purposes:

In respect of sales:

• to respond to enquiries you place with us, either via the Website, telephone or through a visit in person;
• to assist with, or complete and deliver any orders you place with us;
• to take payments for any orders and arrange any refunds;
• to identify other items that may be of potential interest to you;
• to let you know about those of our services which we believe may be of interest to you;
• to maintain records of ownership for the purposes such as warranties and servicing; and
• to assist you with any future interactions or with any queries you may have.

In respect of your user experience:

• to allow you to register and create an account with the Website;
• to review and improve your online experience with the Website;
• to verify your identity and ensure your right to access your personal data;
• to improve the Website to ensure that content is presented in the most effective manner for you and your computer;
• to, if you sign up to our newsletter, provide you with our newsletter; and
• to allow you to participate in interactive features of our service.

In respect of technical and administrative matters:

• to notify you about changes to our business practices, services or to the Website;
• to administer the Website and for our internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes;
• to keep the Website safe and secure; and
• to measure or understand the effectiveness of advertising which we serve to you and others, and to deliver relevant advertising to you.

4. We rely on one, or more, of the following legal bases for processing your personal data:

• your consent, in circumstances where this has been given unambiguously: although you may withdraw your consent at any time by notice to us;
• it is necessary for the performance of a contract between you and us (i.e. for us to process and complete any sales transaction which you would like);
• at your request prior to entering into a contract; or
• it is necessary for the purposes of the legitimate interests pursued by us (e.g. operating and making available the Website or providing you with information about our products or services, particularly in connection with pre-sales post-sales and relationship management activities).

5. We will share your personal data with the following third party recipients:

• other companies and staff in the same group of companies as us in locations around the world;
• our third party suppliers who help us to fulfil any order that you place on the Website or otherwise with us, e.g. our delivery companies and third party payment processors;
• our third party suppliers who help us maintain the Website and support our business, e.g. our hosting provider, Website developers, marketing agencies and our IT support team; and
• credit and identity checking service providers, law enforcement, regulatory bodies and fraud prevention agencies, to comply with our legal obligations or to help tackle fraud or investigate any breach of the Website terms and conditions of this privacy notice.

6. Data transfers

If we intend to transfer your personal data outside of the European Economic Area, it is to companies and staff in the same group of companies based in the USA and we are transferring personal data on the basis of standard data protection clauses which have been put in place with these third party recipients.

7. Data retention and storage

• We will keep your personal data for as long as you are a customer of ours.
• After you stop being a customer of ours, we will retain your personal data to comply with our legal obligations and our obligations under any product warranties.
• If we have had a contractual relationship with you we will store your personal data for six years after the contract ends. Note: a contractual relationship includes where we have sold goods to you which are subject to a long-term support program.

After this period, we will delete your personal data in a safe and secure manner.

8. Cookies

The Website uses cookies to distinguish you from other users of the Website. Cookies are small files which your device accepts from websites that you may visit, allowing websites to recognize your device when you move between pages or when you return to a website after having been away.

We use cookies, amongst other things, to review how you use the Website, to facilitate any online transaction or to see how you browse the Website and our catalogue of products. This information allows us to improve and maintain the Website and our service to you.

9. Your rights

You have the right, under certain circumstances, to request from us:
• access to your personal data;
• rectification or erasure of your personal data;
• restriction of processing concerning you or to object to our processing of your personal data where we rely on our legitimate interests to process your data; and
• the right to data portability.

If you wish to stop receiving any marketing emails from us, you may unsubscribe from these emails at any time by contacting the Phoenix directly and making such request or clicking on the “Unsubscribe” link in the emails.

You also have the right to complain about the manner in which we process your personal data to the European Data Protection Authority listed below:

Information Commissioner’s Office
Wycliffe House
Water Lane, Wilmslow
Cheshire, SK9 5AF
United Kingdom

Any questions concerning this Privacy Notice should be directed to the following:

Paul Haughan, General Manager
Dalton House, 40 Hardwick Grange
Warrington, WA1 4RF
United Kingdom

10. Third party links to the Website

This Website may include links to third-party websites, plug-ins and applications. Clicking on these links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites, plug-ins and applications, and are not responsible for their privacy statements or for what happens to you after you leave this Website. When you leave this Website, we encourage you to read the privacy notice of every other website you visit.

11. Updates to this privacy notice

From time to time we may need to update this privacy notice to ensure that it remains up to date. Please refer to the date at the top of this privacy notice to make sure that you are looking at the latest version.