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Privacy Policy

Date of last update: [15 December 2021]

1. About Western Global

1.1 Western Global Holdings Limited is a company registered in England and Wales under company number 08809455 whose registered office is at Western House, Broad Lane, Yate, Bristol BS37 7LD.

1.2 We are registered as a data controller in the UK with the Information Commissioner’s Office (the UK Regulator) and our registration number is ZA934163.

1.3 All references in this policy to “Western Global”, “our, “us” or “we” refer to Western Global Group Limited or our group companies, as appropriate.

2. About this privacy policy

2.1 It is important that you read this Privacy Policy in full. It explains who we are, how and why we collect personal data from you, how and why it will be processed by us and our commitment to protecting your data.

2.2 This policy applies to those who access our websites or premises, obtain products or services from us, provide products or services to us, are engaged by us or who we otherwise have dealings with in the course of our business. Depending on our relationship, we will collect and use your information in different ways. We may update our privacy policy from time to time. Any changes we make to our privacy policy in the future will be posted on this page.

3. How we obtain your personal information

3.1 You may provide us with your personal information voluntarily. We may also receive information about you from third parties such as marketing agencies, market research companies, our suppliers, contractors and consultants, group companies, public websites and public agencies, which we refer to as “third party sources” or “suppliers” throughout this policy.

3.2 You may give us personal information about yourself by using the online forms provided on our website, setting up an account with us, using bulletin boards or forums on our website, or by contacting us by phone, email or other means. This includes, for example, where you provide your personal information to us in order to receive products, deliveries, information or services from us. If you are a supplier, you may also give us personal information about you when you are offering or providing services to us.

4. Collection of your personal information

4.1 We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:

  • 4.1.1 Identity data – includes first name, maiden name, last name, marital status, title, date of birth and gender.
  • 4.1.2 Contact data – includes e-mail address, telephone numbers and, if applicable, address.
  • 4.1.3 Financial data – includes bank account and/or payment card details.
  • 4.1.4 Transaction Data – includes details about payments to and from you and other details of products and services you have purchased from us.
  • 4.1.5 Technical data – includes the Internet Protocol (IP) address used to connect your computer to the internet address; the website address and country from which you access information; the files requested; browser type and version; browser plug-in types and versions; operating system; and platform used to access our Website.
  • 4.1.6 Marketing and communications data – includes your preferences in receiving marketing from us and your communication preferences.
  • 4.1.7 Profile Data – includes your username and password, purchases or orders made by you, your interests, preferences, feedback and survey responses.
  • 4.1.8 Usage Data – includes information about how you use our website, products and services.

4.2 We may also collect, use and share aggregated data such as statistical or demographic data. Aggregated data is anonymised and is not considered personal data in law as this data does not directly or indirectly reveal your identity.

5. How we use your personal data

5.1 Our purpose or legal basis for collecting and using personal information depends on the personal information concerned and the context in which we collect it. We will only use personal data when the law allows us to.

5.2 In general, we will use the personal information we collect from you only for the purposes described in this Privacy Notice or for purposes that we explain to you at the time we collect your personal information. However, we may also use your personal information for other purposes that are not incompatible with the purposes we have disclosed to you (such as statistical purposes) if and where this is permitted by applicable data protection laws.

5.3 Some common examples of ow we may use your personal data are described below:

  • 5.3.1 Recruitment – When you apply for a role, we collect and use personal information (such as your contact details, covering letter, CV/résumé, and application form) to reach a hiring decision. This includes assessing your skills and qualifications, verifying your information, carrying out reference checks, (where applicable to your role) carrying out background checks and improving our recruitment processes. We may also keep this information on file to contact you about future opportunities unless you ask us not to do this.
  • 5.3.2 Cookies – We use cookies, web beacons, pixels, and similar tracking technology to collect and use personal information. This may include your IP address, device type, unique device identification numbers, browser-type, broad geographic location and other technical information. We may also collect information about how your device has interacted with our website or portal, including the pages accessed and links clicked. For detailed information on the cookies we use, how we use them, and how to refuse them, please see our Cookies Policy.
  • 5.3.3 Marketing – We may send you marketing information about our products and/or services. Where required by law, we will obtain your consent before contacting you. You can ask us to stop sending you marketing communications at any time by contacting us or clicking on any unsubscribe options in the communications that you receive. We may track whether communications were delivered or undelivered and whether you unsubscribed to keep our mailing lists current and manage your preferences.
  • 5.3.4 Order management – We may use your personal information (including where applicable financial information) to manage customer or supplier orders, including for the purposes of order processing, billing, payment processing, financial reporting, trend analysis and product planning. We may also send you operational notices and correspondence about your account (such as product update notices and delivery status updates).
  • 5.3.5 Network monitoring – If you correspond with us, we may log personal information while monitoring our company systems, data and equipment for the purposes of threat detection and prevention, investigating and remedying security incidents, and ensuring lawful use of such systems, data and equipment.
  • 5.3.6 Customer support – If you contact us to report problems or ask questions about our products and services, we may record your contact information and details of our interaction with you. We may use this information to respond to your request, improve our existing products and services, research and develop new products and services, troubleshoot and remedy issues with our products and services and monitor support.
  • 5.3.7 Compliance – We may use your personal information to enforce our terms and conditions and to carry out checks aimed at preventing illegal activities such as export and trade sanction violations, bribery, fraud, corruption, and modern slavery.
  • 5.3.8 Feedback – If you participate in customer satisfaction surveys, we may use your personal information for our internal business analysis and training purposes in order to improve our understanding of our users’ requirements, to measure and increase customer satisfaction, and to improve our products and services.
  • 5.3.9 Forums – Some of our webpages or social media pages may allow you to like, post or comment on information. You are reminded that any information that you share on publicly available pages may be read and used by any member of the public for any purpose and you should carefully consider the sensitivity of any information before you share it. Your interactions with social media sites are governed by the privacy notices of the relevant third-party provider.
  • 5.3.10 Events – If you attend an event at which we are exhibiting, you may consent to share your contact details with us for marketing purposes by allowing us to scan your attendee badge or giving us your business card. You can subsequently opt out as described under the heading ‘Marketing’ above.
  • 5.3.11 Visitors – If you visit our offices or events that we organise, you may be required to register as a visitor/attendee and to provide your name, title, company name, contact details and time/date of arrival for security, confidentiality, health, safety, and event planning purposes. At our premises we may also collect ID and CCTV information for security and safety purposes.

6. Legal basis for use of your personal information

6.1 We consider that the legal bases for using your personal information as set out in this privacy policy are as follows:

  • 6.1.1 our use of your personal information is necessary to perform our obligations under any contract with you (for example, to fulfil an order which you place with us, to comply with the terms of use of our website which you accept by browsing our website and/or to comply with our contract to provide services to or receive services from you or your employer); or
  • 6.1.2 our use of your personal information is necessary for complying with our legal obligations (for example, for health and safety purposes); or
  • 6.1.3 our use of your personal information is necessary for our legitimate interests or the legitimate interests of others (for example, to ensure the security of our website). Our legitimate interests are to:
          • a) run, grow and develop our business;
          • b) operate our website;
          • c) select appropriately skilled and qualified suppliers;
          • d) ensure a safe environment for our staff, customers and suppliers;
          • e) place, track and ensure fulfilment of orders with our suppliers and/or customers; and
          • f) for internal group administrative purposes.

6.2 We may process your personal information in some cases for marketing purposes on the basis of your consent (which you may withdraw at any time after giving it, as described below).

6.3 If we rely on your consent for us to use your personal information in a particular way, but you later change your mind, you may withdraw your consent by contacting us.

7. How and why we share your personal information with others

7.1 We may share your personal information with our group companies where it is in our legitimate interests to do so for internal administrative purposes (for example, for corporate strategy, compliance, auditing and monitoring, research and development and quality assurance).

7.2 In certain circumstances we also share your information with the following third parties: partners, suppliers, sub-contractors including but not limited to payment service providers, advertising networks, our professional advisors such as lawyers, auditors, insurers and information, service and software providers.

8. How long we store your personal information

We keep your personal information for no longer than necessary for the purposes for which the personal information is processed.  The length of time for which we retain personal information depends on the purposes for which we collect and use it and/or as required to comply with applicable laws and to establish, exercise or defend our legal rights.

9. Your rights

9.1 You have the following rights:

  • 9.1.1 Right of access – You have a right of access to any personal information we hold about you. You can ask us for a copy of your personal information; confirmation as to whether your personal information is being used by us; details about how and why it is being used; and details of the safeguards which are in place on transfers of data internationally.
  • 9.1.2 Right to update your information – You have a right to request an update to any of your personal information which is out of date or incorrect.

9.2 In certain specific circumstances you also have the following rights:

  • 9.2.1 Right of deletion – You have a right to ask us to delete any personal information which we are holding about you.
  • 9.2.2 Right to restrict use of your information – You have a right to ask us to restrict the way that we process your personal information.
  • 9.2.3 Right to stop marketing – You have a right to ask us to stop using your personal information for direct marketing purposes.  If you exercise this right, we will stop using your personal information for this purpose.
  • 9.2.4 Right to data portability – You have a right to ask us to provide your personal information to a third party provider of services.
  • 9.2.5 Right to object – You have a right to ask us to consider any valid objections which you have to our use of your personal information where we process your personal information on the basis of our or another person’s legitimate interest.

10. Children

We do not intentionally collect any information about visitors to this website who are under eighteen years of age. If we become aware that a child has provided any information, this will immediately be deleted from our records.

11. Marketing

11.1 We may collect and use your personal information for undertaking marketing by email telephone and post.

11.2 We may send you certain marketing communications (including electronic marketing communications) if it is in our legitimate interests to do so for marketing and business development purposes or, if you are a sole trader or a non-limited liability partnership if you have consented to receive such electronic marketing information.

11.3 However, we will always obtain your consent to direct marketing communications where we are required to do so by law and if we intend to disclose your personal information to any third party for such marketing.

11.4 If you wish to stop receiving marketing communications, please contact us.

12. Where we may transfer your personal information

We have offices across the world, inside and outside of the UK and EEA and we sometimes share personal information between offices in order to deliver our products and services effectively. We may also transfer your information to suppliers based in different countries across the world. When transferring data across borders we ensure appropriate safeguards are in place.

13. Links to other websites

Our website may contain hyperlinks to websites that are not operated by us. These hyperlinks are provided for your reference and convenience only and do not imply any endorsement of the activities of such third-party websites or any association with their operators. This privacy policy only applies to the personal information that we collect or which we receive from third party sources, and we cannot be responsible for personal information about you that is collected and stored by third parties. Third party websites have their own terms and conditions and privacy policies, and you should read these carefully before you submit any personal information to these websites. We do not endorse or otherwise accept any responsibility or liability for the content of such third party websites or third party terms and conditions or policies.

14. Further questions

If you have any questions or queries about your privacy with us of this Policy, please contact us.

The practices described in this privacy policy statement are current as of the ‘date of last update’ noted at the top of this privacy policy.

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