Privacy Policy
Privacy Policy - Subterandt Limited
We take your privacy very seriously. Please read this privacy policy carefully as it contains important information on who we are and how and why we collect, store, use and share your personal data. It also explains your rights in relation to your personal data and how to contact us or supervisory authorities if you have a complaint.
This privacy policy does not apply to any third-party websites that may have links to our own website.
Who are we and what do we do?
Subterandt Limited provides: asset integrity solutions for the detection of corrosion and moisture under insulation.
We collect, use and are responsible for certain personal data about you. When we do so we are subject to the UK General Data Protection Regulation (UK GDPR).
Key terms
It would be helpful to start by explaining some key terms used in this policy:
| We, us, our | Subterandt Limited (CRN 08160793) |
| Personal data | Any information relating to an identified or identifiable individual |
| Special category personal data | Personal data revealing racial or ethnic origin, political opinions, religious beliefs, philosophical beliefs or trade union membership Genetic data Biometric data (where used for identification purposes) Data concerning health, sex life or sexual orientation |
| Data subject | The individual who the personal data relates to |
Personal data we collect about you
The personal data we collect about you depends on the products and services we provide to you. We will collect and use the following personal data about you: –
- your name and contact information, including email address and telephone number and company details
- your address, for delivery purposes
- information to check and verify your identity, e.g. your date of birth
- your gender
- location data
- your billing information, transaction and payment card information
- your personal or professional interests
- your contact history, purchase history and saved items
- information from accounts you link to us
- information to enable us to undertake credit or other financial checks on you
- information about how you use our website, IT, communication and other systems
We collect and use this personal data for the purposes described in the section ‘How and why we use your personal data’ below. If you do not provide personal data we ask for, it may delay or prevent us from providing products and/or services to you.
How your personal data is collected
We collect most of the above information from you. However, we may also collect information:
- from publicly accessible sources, e.g. Companies House or HM Land Registry;
- directly from a third party, e.g. other companies or credit reference agencies;
- from a third party with your consent, e.g. your bank or building society, another financial institution or advisor;
- via our website—we use cookies and similar technologies on our website;
- via our information technology (IT) systems, e.g.:
- from door entry systems and reception logs;
- through automated monitoring of our websites and other technical systems, such as our computer networks and connections, CCTV and access control systems, communications systems, email and instant messaging systems;
How and why, we use personal data
Under data protection law, we can only use your personal data if we have a proper reason, e.g.:
- you have given consent—where we need your consent, we will ask for it separately of this privacy policy and you can withdraw consent at any time;
- to comply with our legal and regulatory obligations;
- to fulfil our contract with you, or take steps at your request, before entering into a contract; or
- for our legitimate interests or those of a third party.
A legitimate interest is when we have a business or commercial reason to use your personal data, so long as this is not overridden by your own rights and interests. You have the right to object to processing based on legitimate interests. We must then stop the processing unless we can demonstrate compelling legitimate grounds which override your interests, rights and freedoms or the processing is required to establish, exercise or defend legal claims.
The table below explains what we use your personal data for and why.
| What we use your personal data for | Our reasons |
| Providing products and services to you or your company | To fulfil our contract with you or your company and to take steps at your request before entering into a contract |
| Conducting checks to identify our customers and verify their identity Screening for financial and other sanctions or embargoes Other activities necessary to comply with legal and regulatory obligations that apply to our business, eg under health and safety law | Depending on the circumstances: —to comply with our legal and regulatory obligations —for our legitimate interests |
| Gathering and providing information required by or relating to audits, enquiries or investigations by regulatory bodies | Depending on the circumstances: —to comply with our legal and regulatory obligations —for our legitimate interests |
| Operational reasons, such as improving efficiency, training and quality control | For our legitimate interests, ie to be as efficient as we can so we can deliver the best service to you at the best price |
| Ensuring the confidentiality of commercially sensitive information | Depending on the circumstances: —for our legitimate interests, ie to protect trade secrets and other commercially valuable information —to comply with our legal and regulatory obligations |
| Statistical analysis to help us manage our business, e.g. in relation to our financial performance, customer base, services range or other efficiency measures | For our legitimate interests, ie to be as efficient as we can so we can deliver the best service to you at the best price |
| Protecting the security of systems and data used to provide services, prevent unauthorised access and changes to our systems | Depending on the circumstances: —for our legitimate interests, ie to prevent and detect criminal activity that could be damaging for you and/or us —to comply with our legal and regulatory obligations |
| Ensuring safe working practices, staff administration and assessments | Depending on the circumstances: —to comply with our legal and regulatory obligations —for our legitimate interests, eg to make sure we are following our own internal procedures and working efficiently so we can deliver the best service to you |
| Marketing our services and those of selected third parties to existing and former customers and third parties | Depending on the circumstances: —for our legitimate interests, ie to promote our business —consent (which we will ask for separately) |
Where we process special category personal data (see above ‘Key terms’), we will also ensure we are permitted to do so under data protection laws, e.g.:
- we have your explicit consent;
- the processing is necessary to protect your (or someone else’s) vital interests where you are physically or legally incapable of giving consent;
- the processing is necessary to establish, exercise or defend legal claims; or
- the processing is necessary for reasons of substantial public interest.
Who we share your personal data with
We routinely share personal data with:
- third parties we use to help deliver our services to you, e.g. providers of our finance system, IT service providers including cloud service providers such as data storage platforms, shared service centres and financial institutions in connection with invoicing and payments;
- We only allow those organisations to handle your personal data if we are satisfied they take appropriate measures to protect your personal data. We ensure all outsourcing providers operate under service agreements that are consistent with our legal obligations.
We or the third parties mentioned above may occasionally also share personal data with:
- our and their external auditors, e.g. in relation to the audit of our or their accounts, in which case the recipient of the information will be bound by confidentiality obligations
- our and their professional advisors (such as lawyers and other advisors), in which case the recipient of the information will be bound by confidentiality obligations
- law enforcement agencies, courts, tribunals and regulatory bodies to comply with our legal and regulatory obligations
Where your personal data is held
Personal data may be held at our premises and those of our service providers, representatives and agents as described above (see ‘Who we share your personal data with’).
How long your personal data will be kept
We will not keep your personal data for longer than we need it for the purpose for which it was collected or as required by law.
Following the end of the of the relevant retention period, we will delete or anonymise your personal data.
Transferring your personal data abroad
It may sometimes be necessary for us to transfer your personal data to countries outside the UK and EEA. This may include countries which do not provide the same level of protection of personal data as the UK or EEA.
We will transfer your personal data outside the UK and EEA only where:
- the UK government has decided the recipient country ensures an adequate level of protection of personal data (known as an adequacy decision); or
- there are appropriate safeguards in place (e.g. standard contractual data protection clauses published or approved by the relevant data protection regulator), together with enforceable rights and effective legal remedies for you; or
- a specific exception applies under data protection law.
Your rights
You have the following rights, which you can exercise free of charge:
| Access | The right to be provided with a copy of your personal data | |
| Rectification | The right to require us to correct any mistakes in your personal data | |
| Erasure (also known as the right to be forgotten) | The right to require us to delete your personal data—in certain situations | |
| Restriction of processing | The right to require us to restrict processing of your personal data—in certain situations, e.g. if you contest the accuracy of the data | |
| Data portability | The right to receive the personal data you provided to us, in a structured, commonly used and machine-readable format and/or transmit that data to a third party—in certain situations | |
| To object | The right to object: —at any time to your personal data being processed for direct marketing (including profiling); —in certain other situations to our continued processing of your personal data, eg processing carried out for our legitimate interests unless we demonstrate compelling legitimate grounds for the processing which override your interests or for establishing, exercising or defending legal claims | |
| Not to be subject to automated individual decision making | The right not to be subject to a decision based solely on automated processing (including profiling) that produces legal effects concerning you or similarly significantly affects you | |
| The right to withdraw consent | If you have provided us with a consent to use your personal data, you have a right to withdraw that consent at any time You may withdraw consents by contacting us through our web contact form to make an initial consent withdrawal request. Withdrawing consent will not affect the lawfulness of our use of your personal data in reliance on that consent before it was withdrawn |
If you would like to exercise any of those rights, please:
- email, call or write to us—see below: ‘How to contact us’; and
- provide enough information to identify yourself (e.g. your full name, address and customer or matter reference number) and any additional identity information we may reasonably request from you;
- let us know what right you want to exercise and the information to which your request relates.
Keeping your personal data secure
We have implemented appropriate technical and organisational measures to keep your personal data confidential and secure from unauthorised access, use and disclosure. We limit access to your personal data to those who have a genuine business need to access it. Those processing your personal data will do so only in an authorised manner and are subject to a duty of confidentiality.
We require our business partners, suppliers and other third parties to implement appropriate security measures to protect personal data from unauthorised access, use and disclosure.
We also have procedures to deal with any suspected data security breach. We will notify you and any applicable regulator of a suspected data security breach where we are required to do so.
How to complain
Please contact us if you have any queries or concerns about our use of your personal data (see below ‘How to contact us’). We hope we will be able to resolve any issues you may have.
You may also have the right to lodge a complaint with the Information Commissioner (the UK data protection regulator.
Changes to this privacy policy
We may change this privacy policy from time to time. When we do, we will publish the updated version on our website and ask for your consent to the changes if legally required.
Updating your personal data
We take reasonable steps to ensure your personal data remains accurate and up to date. To help us with this, please let us know if any of the personal data you have provided to us has changed, eg your surname or address—see below ‘How to contact us’.
How to contact us
You can contact us by post or via our website, if you have any questions about this privacy policy or the information we hold about you, to exercise a right under data protection law or to make a complaint.
Our postal contact details are shown below:
| Subtera R104, Rutherford Appleton Laboratory Harwell Campus, Didcot Oxfordshire OX11 0QX United Kingdom |