WELLVEND LTD T/AS CONTRAC LIGHTING PRIVACY POLICY

IMPORTANT INFORMATION AND WHO WE ARE

Who we are
Wellvend Ltd t/as Contrac Lighting are a privately-owned company registration number 1676200 based in Goole East
Yorkshire. We design, manufacture and supply lighting and whether you are a supplier, customer or potentional
customer, we want you to be able to trust us with your information. This Privacy Policy is meant to help you
understand what data we collect, why we collect it and what we do with it.

Purpose of this privacy policy
This privacy policy aims to give you information on how we collect and process your personal data through your use
on our website, purchase products or services from us, contact us over the phone, by email or post, supply us with
your services, or sign up to any of our mailing lists.

How to contact us
Questions, comments and requests regarding this privacy policy are always welcomed, so if you have any or would
like to exercise any of your legal rights, please don’t hesitate to contact us. You can contact our data protection team
by emailing gdpr@contrac-lighting.co.uk. If you’d prefer, you can write to us at Data Protection Team, Contrac
Lighting, Nielsen Road, Goole, East Yorkshire DN14 6UE.

Changes to Privacy Policy
We may change this privacy policy from time to time, to reflect how we are processing your data. If we make
significant changes, we will make this clear on our website or by such other means of contact such as email, so that
you are able to review the changes before continuing to use our services.

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

THE PERSONAL DATA WE COLLECT ABOUT YOU

Why
We collect, use, store and transfer different kinds of personal data about you to enable us to run our business in an
efficient and effective way and to comply with legal requirements placed on us. The data will enable us to provide
you with our services, to give you information on our pricing, products and company, to help us monitor and
improve our services and, where we are permitted to, tell you about new products or company news.

What is personal data
Personal data, or personal information, means any information about an individual from which that person can be
identified.
We may collect, use, store and transfer different kinds of personal data about you which we have grouped together
as follows:

• Name and contact details – this includes your name, title, business name and address, email address and
  telephone numbers
• Payment information – only in relation to those we pay via bank transfer
• Purchase or supply history – this includes information on past and present purchases and sales.
• Linked account information – this includes any Facebook, Twitter or Linked In information you have
  provided us.
• Marketing preferences – this includes your preferences in receiving marketing from us and your
  communication preferences where specified
• Customer or supplier service history – this includes interactions via phone, email, website, social media or
  post we may have had with you.

We do not collect any Special Categories of Personal Data (this includes details about your race or ethnicity,
religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information
about your health and genetic and biometric data).

If you don’t provide personal data
You don’t have to give us any of your personal data but, if you don’t, you are unlikely to receive our optimal
customer service experience. Where we need to collect personal data by law, or under the terms of a contract we
have or are trying to enter into with you (for example supply you goods or prices).

Keeping your personal data up-to-date
It is important that the personal data we hold about you is accurate and current. Please keep us informed if your
personal data changes during your relationship with us.

HOW WE COLLECT YOUR PERSONAL DATA

How
We use different methods to collect data from and about you including through:

• Direct interactions. You may give us your name and contact details and payment information by filling in forms
  or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when
  you:
  • Purchasing goods from us
  • Set up a credit account with us.
  • Requesting pricing, product information or services from us via phone, email, website or mail.
  • Subscribe to our mailing lists or newsletters
  • Request marketing information to be sent to you
  • Take part in promotion or survey
  • Give us feedback on our services or website
  • Supply goods to us
  • Set up a credit account for us with you or your company
• Automated technologies or interactions. Our website does not use cookies and does not automatically collect
  any personal data on you.

HOW WE USE YOUR PERSONAL DATA

Why
We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in
the following circumstances:

• Where we need to perform the contract, we are about to enter into or have entered into with you.
• Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental
  rights do not override those interests.
• Where we need to comply with a legal or regulatory obligation.
• For certain processing purposes, we may request your consent to authorise the processing. For example, if you
  are not a customer of ours and have not enquired about our product or services, we would need a clear consent
  from you in order to send any communications to you about our products or services

Purposes for which we use your personal data
We have set out in the table below a description of what we do with your personal data and why we do it. We have
also identified what our legitimate interests are where appropriate.
Please contact us if you need details about specific legal grounds we are relying on to process your personal data
where more than one ground has been set out in the table below.

How?	What?	Why?
To register you as a contact within a new or existing customer or supplier account and to assist in the management of that account	Name and contact details	To perform our contract with you or your company. We can’t set up or manage a customer or supplier account without personal details of who we are dealing with within the company
To sell you products and services	Name and contact details Account history	To perform our contract with you. We need to be able to identify who in an organisation has instigated a purchase
To purchase goods from you or your company	Name and contact details Account history	To perform our contract with you. We need to be able to identify who in an organisation we are dealing with
To make payments or give refunds	Payment information	To perform our contract with you. As a company our preferred choice of payment is bank transfer
To deliver your goods and other services to you	Name and contact details	To deliver goods, quotes, lighting designs, product information etc
To provide customer service and support	Purchase history Customer service history	To perform our contract with you. You expect and we want to deliver the best possible customer service
To provide training to our staff	Customer service history	We have a legitimate interest – so that we can make sure you get the best possible customer service
To send you information about our products and services	Name and contact details Marketing preferences	We have a legitimate interest – to develop our products and services to grow our business. If you are not an existing customer we will only send this information with your permission
To administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)	Name and contact details Payment information	We have a legitimate interest – for running our business, provision of administration and IT services, network security, to prevent and protect fraud and in the context of a business reorganisation or company restructuring exercise. We’ve also got legal obligation.

MARKETING MESSAGES AND PROMOTIONAL OFFERS

We strive to provide you with choices regarding certain personal data uses, particularly around marketing and
advertising. You will not receive marketing communications from us unless you have actively opted in to receive
such items from us.
You can tell us that you want to stop receiving marketing communications from us at any time. You can do this by
emailing gdrp@contrac-lighting.co.uk, clicking on the unsubscribe link in the email we have sent to you, or by
contacting us directly by post or phone.

Website Cookies
We do not use cookies on our website, should this change we will alter our privacy policy accordingly.

Mailing Lists
When you sign up to our mailing list, either through the sign-up form on our website or via email, we collect
personal information. We use that information for a couple of reasons: to send you regular newsletters; to contact
you if we need to obtain or provide additional information; to check our records are right and to check every now
and then that you’re happy and satisfied with our service.

Change of Purpose
We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that
we need to use it for another reason and that reason is compatible with the original purpose. Please note we may
process your personal data without your knowledge or consent, in compliance with the above rules, where this is
required by law.

SHARING YOUR PERSONAL DATA

We’re serious when we say we’re committed to protecting your privacy – we want to earn and maintain your trust.
We will not, and do not sell so we do not sell any of your personal data to any third party – including your name and
contact details and your payment information.
We do however share your personal data with the following categories of companies as an essential part of being
able to provide our products and services to you, as set out in this notice:

• Professional service providers, such as IT and system administration providers and website hosts, who help us
  run our business
• Credit reference agencies, law enforcement and fraud prevention agencies, so we can help tackle fraud.
• Professional advisers acting as processors or joint controllers including lawyers, bankers, auditors and insurers
  who provide consultancy, banking, legal, insurance and accounting services.
• HM Revenue & Customs, regulators and other authorities acting as processors or joint controllers based in the
  United Kingdom who require reporting of processing activities in certain circumstances.
• Third parties to whom we may choose to sell, transfer, or merge parts or all of our business or our assets.

SENDING YOUR PERSONAL DATA TO COUNTRIES OUTSIDE EUROPE

We do not transfer data outside of the European Economic Area (EEA)

KEEPING YOUR PERSONAL DATA SECURE

We’re committed to keeping your personal data secure and have put in place appropriate security measures to
prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or
disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third
parties who have a business need to know. They will only process your personal data on our instructions and they
are subject to a duty of confidentiality.
We have put in place procedures to deal with any suspected personal data breach and will notify you and any
applicable regulator of a breach where we are legally required to do so.

HOW LONG WE WILL KEEP YOUR PERSONAL DATA FOR

We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for
the purpose of satisfying any legal, accounting, or reporting requirements.
To determine the appropriate retention period for personal data, we consider the amount, nature and sensitivity of
the personal data, the potential risk of harm from unauthorised use or discloser of your personal data, the purpose
for which we process your personal data and whether we can achieve those purposes through other means, and the
applicable legal requirements.
Details of retention periods for different aspects of your personal data are available in our retention policy which
you can request from us by contacting us.
In some circumstances, you can ask us to delete your data: see the section detailing your legal rights below for
further information.
In some circumstances, we may anonymise your personal data (so that it can no longer be associated with you) for
research or statistical purposes in which case we may use this information indefinitely without further notice to you.

YOUR LEGAL RIGHTS

You have lots of legal rights relating to your personal data, we have summarised these below:

• The right to request access to your personal data
• The right to request correction of your personal data
• The right to request erasure of your personal data
• The right to object to processing of your personal data or to withdraw consent. Remember, you can always stop
  direct marketing messages by clicking on unsubscribe link on any of our emails or getting in touch via email,
  phone or post
• The right to request restriction of processing of your personal data
• The right to request transfer of your personal data.

If you wish to exercise any of the rights set out above or if you have any questions or a complaint. Please contact us
and we will respond within 30 days, you will not have to pay a fee to access your personal data, however, we may
charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to
comply with your request in these circumstances.