Privacy Policy

Updated February 2023

INTRODUCTION
At Huws Gray, we respect your privacy and are committed to protecting your personal data. We take data protection very seriously and will ensure that we uphold the trust that our customers and clients place in us when they provide us with their personal information.

This Privacy Policy will inform you as to how we collect, use, handle and disclose your personal data, as well as telling you about your privacy rights and how the law protects you.

Huws Gray is made up of a number of related businesses encompassing; Huws Gray, Buildbase, Hirebase, @Home, Electricbase, Tool Centre, Huws Gray Supply Chain Solutions, PDM, Civils & Lintels, NDI, Timber Engineering, Qualplas, The Timber Group, Smiths Briten, Frontline Bathrooms and Lloyd Worrall.Our Privacy and Cookie Policy is used to explain how personal data is collected and used by Huws Gray (company number: 2506633) – referred to as “Huws Gray”, “we”, “us”, “our” throughout this policy.

DATA CONTROLLER
Huws Gray is the “controller” for the purposes of data protection legislation and is therefore responsible for your personal data.

As part of our commitment to you, we have appointed a data protection officer who is responsible for overseeing questions in relation to this Privacy Policy and Huws Gray’s data protection compliance in general. If you have any questions about this Privacy Policy, including any requests to exercise your legal rights, please contact the data protection officer using the following details:

CONTACT DETAILS
Name: Data Protection Officer
Address: Huws Gray Ltd, Llangefni Ind Estate, Llangefni, LL777JA
Email: dataprotection@huwsgray.co.uk
Tel: 01248 719210

You have the right to make a complaint at any time to the Information Commissioner’s Office (“ICO”), the UK supervisory authority for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.

We keep this Privacy Policy under regular review and may amend it from time to time. Please check back regularly to view the latest version.

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.

This Privacy Policy contains the following sections:

1. Data Protection Principles
2. Why Does Huws Gray Collect This Personal Information?
3. What Personal Information Does Huws Gray Collect?
4. Does Huws Gray Share Your Personal Information?
5. Data Security
6. Data Retention
7. Your Legal Rights
8. Glossary

1. DATA PROTECTION PRINCIPLES
Huws Gray adheres to the principles set out in data protection legislation when handling personal data. These principles require personal data to be:

• Processed lawfully, fairly and in a transparent manner.
• Collected only for specified, explicit and legitimate purposes.
• Adequate, relevant and limited to what is necessary in relation to the purposes for which it is processed.
• Accurate and where necessary kept up to date.
• We will only retain your data for “no longer than is necessary” for the purposes for which it was created or obtained.

Not kept in a form which permits identification of data subjects for longer than is necessary for the purposes for which the data is processed.

Processed in a manner that ensures its security using appropriate technical and organisational measures to protect against unauthorised or unlawful processing and against accidental loss, destruction or damage.

Not transferred to another country without appropriate safeguards being in place.Made available to data subjects and allow data subjects to exercise certain rights in relation to their personal data.

We are also responsible and accountable for ensuring that we can demonstrate compliance with the data protection principles listed above.

2. WHY DOES HUWS GRAY COLLECT THIS PERSONAL INFORMATION?
We collect personal data to assist us in providing continual improvements to our products and services. This includes personal data you provide when you or your business:

• Purchase and / or accept delivery of our products and services. We use your personal information to process orders and payments, deliver our products and services and communicate with you about your order, our products and offers.
• Apply for, or operate, a credit or cash account with us.
• Use data analytics to improve this website, marketing, client relationships, user experience and our organisation in general; and
• Administer and protect the website and our organisation (including troubleshooting, data analysis, testing and system maintenance and network security).
• Recommendations and personalisation. We may use your personal information to recommend products and personalise your customer journey based on your preferences and previous purchases.
• Process financial transactions (including collection of payments for products or services which have been provided, management of any additional charges and fees and administration of any refunds).
• Respond to any enquiries that you submit to us
• Contact you by post, e-mail, telephone and via social media regarding the products or services that you have requested from us
• Comply with our legal and regulatory obligations
• Prevent and detect fraud
• Provide customer service and support (including investigating complaints)

In some cases, we will only use your personal information where we have your consent or because we need to use it in order to fulfil a contract with you (for example, because you have requested that we provide our services to you).

However, there are other lawful reasons that allow us to process your personal information, including where we have a “legitimate interest”. This means that the reason that we are processing information is because there is a legitimate interest for Huws Gray to process your information.

Whenever we process your personal data on the basis of a “legitimate interest”, we make sure that we take into account your rights and interests and will not process your personal information if we feel that there is a disproportionate privacy impact on you.

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. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.

If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

3. WHAT PERSONAL INFORMATION DOES HUWS GRAY COLLECT?
The personal data that we collect, use and store may include:

• Contact details including your name, address, telephone number, date of birth and email address
• Payment information, including credit/debit card details and bank account details
• Contact history, such as any communications with us by telephone, e-mail, post, through our website or via social media
• Transaction history, including information about the services we have provided to you
• Technical data such as internet protocol (IP) address, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, session replay data and other technology on the devices you use to access the website.
• Information from third parties and publicly available sources including:
  1. Credit reference agencies, Insurers/Brokers and fraud prevention organisations including by not limited to; Dun & Bradstreet(D&B), Graydon, QBE, Zurich, Nexus, & TopService. When you or your business in which you are a partner or a director makes an application for a credit account with us, we will or may make searches about you with credit reference agencies and fraud prevention organisations. [Searches are made against addresses provided, and so may also return information relating to other household members.] The relevant agencies/organisations will keep a record of that search and will share information from their records with us and with other business assessing applications for credit and to prevent fraud. We will record information as to your/your business’ trading history with us and may share this information with credit reference agencies and fraud prevention organisations. Should it become necessary to review a credit account, a further check with credit reference agencies [fraud prevention organisations] and Insurers may be made, and a record kept by them of the search.
  2. Debt collection, Solicitors and debtor tracing organisations. Where you/your business’ debts are unpaid, we may share your personal information with relevant debt collection and/or debtor tracing agencies or Solicitors such as Top Service/TS Legal, Silverback Law, Irwin Mitchell/Ascent Performance Group, Shoosmiths & R Gordon Roberts Laurie & Co Ltd.
  3. Other businesses in the same or related sectors. As part of our credit referencing [and anti-fraud] procedures we may make enquiries of other businesses in the same or related sectors as to your/your business’ trading history with them and may share information as to your/your business’ trading history with us.
  4. Technical Data from analytics providers such as Google & Google Maps based outside the EU.
  5. Contact, Financial and Transaction Data from providers of technical, payment and delivery services such as SagePay, Worldpay, Global Payment, Prommt, based inside the EU.
  6. Identity and Contact Data from publicly availably sources such as Companies House and the Electoral Register based inside the EU and TransUnion based outside the EU. A link to TransUnions relevant privacy notice which explains more information about their activities is available at: https://www.transunion.co.uk/legal-information/bureau-privacy-notice.
  7. Contract and Planning Applications data from publicly available sources including local authorities, ABI , Bravo Solutions, In-Tend, CCS, Housing Net, Contract.Net, Forsee, based inside the EU.

We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data may be derived from your personal data but is not considered personal data under data protection law, as this data does not directly or indirectly reveal your identity. For example, we may aggregate data about your use of the website to calculate the percentage of users accessing a specific feature.

We will not collect or process Sensitive Personal Data (as defined in the Glossary) about you at any time. Criminal offences may, however, appear on credit references or anti-fraud checks we may make.

4. DOES HUWS GRAY SHARE YOUR PERSONAL INFORMATION?
Huws Gray will only share your essential personal information with suppliers and sub-contractors we work with to provide you with the products or services that you have requested.

• Updated delivery and address information from our carriers or other third parties, which we use to correct our records and deliver orders.
• Service providers who provide IT, security, software, marketing, advertising and system administration services.
• Third party agencies, such as credit reference agencies, for identification verification purposes which enables us to offer certain credit or financial services and reduce fraud.

Professional advisers acting as processors or joint controllers including lawyers, bankers, experts, accountants, insurers and other third parties who provide legal, banking, consultancy, accounting, insurance and other related 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 of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this Privacy Policy.

We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.

We do not and will not sell your personal data to any third party.

5. DATA SECURITY
We 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.

6. DATA RETENTION
How long will you use my 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 purposes 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 disclosure of your personal data, the purposes 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 on request by contacting us using the details above.

7. YOUR LEGAL RIGHTS
Under certain circumstances, you have rights under data protection laws in relation to your personal data including:

• Your right of access – You have the right to ask us for copies of your personal information.
• Your right to rectification – You have the right to ask us to rectify personal information you think is inaccurate. You also have the right to ask us to complete information you think is incomplete.
• Your right to erasure – You have the right to ask us to erase your personal information in certain circumstances.
• Your right to restriction of processing – You have the right to ask us to restrict the processing of your personal information in certain circumstances.
• Your right to object to processing – You have the right to object to the processing of your personal information in certain circumstances.
• Your right to data portability – You have the right to ask that we transfer the personal information you gave us to another organisation, or to you, in certain circumstances.
• You will not have to pay a fee to access your personal data (or to exercise any of the other rights). 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.

What we may need from you
We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

Time limit to respond
We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.

8. GLOSSARY
“Personal data”, or “personal information”, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).

“Sensitive Personal Data” means information revealing racial or ethnic origin, political opinions, religious or similar beliefs, trade union membership, physical or mental health conditions, sexual life, sexual orientation, biometric or genetic data, and personal data relating to criminal offences and convictions.

Lawful Basis
“Legitimate interest” means the interest of our business in conducting and managing our services to enable us to give you the best and secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the privacy impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us.

“Comply with a legal or regulatory obligation” means processing your personal data where it is necessary for compliance with a legal or regulatory obligation that we are subject to.