We ask that you read this privacy notice carefully as it contains important information on who we are, how and why we collect, store, use and share personal information, your rights in relation to your personal information and on how to contact us in the event you have a complaint.
This policy applies to:
(i) all those who visit our website, mobile applications, such as the William Smith Heating App, or who have had face to face contact with one of our employees;
(ii) business customers); and
(iii) consumers (including homeowners)
to that extent relevant to those individuals and except where the policy indicates otherwise.
Our 'Company' refers to the constituent companies of William Smith Heating Solutions Scotland Ltd.
1. WHO WE ARE
William Smith Heating Solutions Scotland Ltd. ("We") collect, use and are responsible for, certain personal information about you ("personal data"). We are a data controller under data protection law which includes the Data Protection Act 1998 and the General Data Protection Regulation (GDPR) 2016 as appropriate.
2. WILLIAM SMITH HEATING SOLUTIONS SCOTLAND LTD RESPECTS YOUR PRIVACY
The protection of your privacy in the processing of your personal data is an important concern, which we pay special attention to during our business operations. We use ("process") your personal data collected during your visit to our website and when you provide your personal data to us in other ways, in a confidential manner and solely in accordance with the law including the General Data Protection Regulation ("GDPR").
3. THE PERSONAL DATA WE COLLECT AND USE
Information collected by us
If you are a consumer (including homeowners)
We may collect your personal data when you provide it to us through our website, if you write to us or telephone our offices or if you provide your details to us through a third party. Your information may be provided to us in the following ways:
if you contact us to register the guarantee for your boiler (or other product)
if you contact our Customer Services Department, to make a request for a product service appointment, enquire about our products and services, including our service plans, or to provide feedback to us on our products and services;
The personal data which we collect about you may include your name, postal address, your email address, contact telephone number, credit card details and details of any comments or feedback which you provide to us.
If you are a business customer
We may collect your personal data when you provide it to us through our website or 'William Smith Heating' app or when you purchase products or make enquiries about our products and services, enter a competition, register to use our website, or join our installer reward scheme. We may collect this information directly through the website or app or if you provide your details over the telephone, or by post.
We may collect your name, billing address, delivery address details, your email address, date of birth, gender, contact telephone number, Gas Safe or other industry accreditation reference number, and details of any comments or feedback which you or a third party provides to us.
We may also collect and process records of any correspondence and communications with us and a record of transaction history and details of transactions conducted on our site or through our app is kept by us together with details of the fulfilment of any order. Cookies will collect a certain amount of data - we use the information within cookies to display re-marketing advertising on third party websites to consumers that did not complete a purchase
We may receive personal information about you from other sources such as, from consumers who register their products with us and from third parties who work with us in connection with our sites and services. We may also obtain your personal data through third parties such as the Gas Safe Register and OFTEC Third-party service providers may, without limitation, be appointed to provide technical support, process your transactions, and maintain your accounts or to run promotions or marketing campaigns. We may have access to any personal information provided to such vendors, service providers and third-party e-commerce services.
We may monitor, record, store and use any telephone, email, or other communication you provide to check any instructions given to us, for training purposes, for crime prevention and to improve the quality of our customer service.
What other information do we collect?
As you move around our site, subject to appropriate consents being obtained, we will collect information about your visit, such as which pages you visit, how often you visit and what links you click on.
We may also receive information about you if you use any of the other websites we operate or the other services we provide. In this case we will have informed you when we collected that personal data that it may be shared internally and combined with personal data collected on this site for the purposes set out in this policy, including helping us to build a profile of you to get to know you better, and so that we can personalise and enhance your customer experience with us.
4. HOW DO WE USE YOUR PERSONAL INFORMATION?
Information you give to us.
We will use this information:
to carry out our obligations arising from any agreements entered into between you and us and to provide you with the information, products, and services that you request from us;
to carry out appropriate and necessary investigations and discharge our legal and regulatory obligations and duties, including to comply with anti-fraud and anti-money laundering requirements;
to send you a welcome email to verify your account when you register with the site and other emails for the purposes of providing any services, products, competitions, or promotions to you, including in relation to account management or system maintenance;
to provide you with marketing information about other services or products we offer that are similar to those that you have already purchased, or services or products you have consented to receiving on the site or; to notify you about changes to our services and/or products;
build a profile of you, your preferences, and your habits in order to personalise and enhance your customer experience; to provide customer support; and/or
to ensure that content from the site is presented in the most effective manner for you and for your computer.
We may use the personal data we collect about you on an anonymised basis to create statistics and anonymised information which we then share with third parties including ad networks, search engines and analytics providers.
Please note we will not use any financial or credit card information for any purpose other than to discharge our legal / regulatory duties and to process payments paid by you for our products and services or due to you by agreement (e.g. refunds).
Information we collect about you.
We will use this information:
to administer our site and for internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes;
to carry out appropriate and necessary investigations and discharge our legal and regulatory obligations and duties, including to comply with anti-fraud and anti-money laundering requirements, and (where applicable) to safeguard our staff and other customers / users in respect of unlawful, disruptive, or objectionable behaviour on our premises or on our website;
to improve our website to ensure that content is presented in the most effective manner for you and for your computer;
to enhance our website experience to ensure you receive a personalised and continuously improving customer service;
to allow you to participate in interactive features of our website, when you choose to do so;
as part of our efforts to keep our website safe and secure;
to deliver (whether directly or indirectly via third parties) effective and personalised marketing material and content of William Smith Heating Solutions Scotland Ltd and where you have consented, other companies and to assist us in the improvement and optimisation of advertising, marketing material and content, our services, and the sites
to measure, understand or monitor the effectiveness of advertising, promotions, marketing material and content and any joint initiatives with our affiliates, suppliers, partners, subcontractors and other selected third parties;
build a profile of you, your preferences, and your habits;
to measure or understand the effectiveness of advertising we serve to you and others, and to deliver relevant advertising to you where permitted; and/or
to make suggestions and recommendations to you and other users of our site or services about goods or services that may interest you or them
Information we receive from other sources.
We will combine this information with information you give to us and information we collect about you. We will use this information and the combined information for the purposes set out above (depending on the types of information we receive).
5. USING YOUR INFORMATION IN ACCORDANCE WITH DATA PROTECTION LAWS
Compliance with legal obligations: As an entity established under the laws of Scotland, England, and Wales, William Smith Heating Solutions Scotland Ltd is obliged to comply with UK laws and guidance provided by UK regulatory bodies. In particular, we will need to process your personal data to verify your identity, establish your age, verify your source of funds for anti-money laundering and fraud purposes, and to establish whether you have been barred from any stores which stock our products or from using our site due to objectionable behaviour. We are also legally obliged to process your personal data in accordance with gas safety regulations. You will not be able to object to processing or ask for the deletion of your personal information insofar as it falls under this category.
Necessary for the entry into / performance of a contract: When you enter into a transaction with us, a contract between you and us will have been entered into. In order for us to fulfil our obligations under such contract (e.g. to allow you to purchase goods from us), we will need to collect and process your personal data. Failure to provide the requisite personal information on sign-up and financial information on entering into the transaction or objecting to this type of processing / exercising your deletion rights will unfortunately mean we cannot provide our goods / services to you.
Consent: We may send you marketing messages by email, text message or telephone about us and our products and offers where you have not unsubscribed and where you have purchased products or other services from us. We may also send you information by post on the products and services which we provide which we believe may be of interest to you. We provide easy ways to stop our marketing, and you can opt out at any time by updating your preferences on our Opt-in page (link) or selecting the unsubscribe (link) on any email we send you.
If you are not a customer of ours but you have provided us with consent to use your details for marketing purposes, then we may also contact you about our products and services.
If you have confirmed that you would like to hear from us about other the products and services of other companies associated with William Smith Heating Solutions Scotland Ltd then we will use your details to contact, you with marketing information about such products and services.
If you have confirmed that you would like to hear directly from other parties about such partys products and services, then we will share your details with such third party, so they can contact you about their products and services.
In each of the situations above, you have the right to withdraw your consent at any time and can object to processing of this nature. Where you consent to us sending you marketing information, we will treat this as lasting for 12 months unless we tell you otherwise at the time.
6. HOW LONG WE KEEP YOUR INFORMATION FOR
When your data is no longer required for the purposes listed above, we will delete it within the periods set out below:
Marketing consents will be refreshed/deleted after 12 months (60 Months for Commercial & Industrial projects) or can be withdrawn at any time (see Clause 5);
Marketing emails and other communications where possible will typically be deleted after 24 months.
Any other information will typically be deleted within 6 years from the data of our last positive interaction with you. This data is archived where customers are inactive for a period of 12 months. In some circumstances, some of your data will be deleted in much shorter timescales, where possible (e.g. copies of marketing emails and other communications). We keep your personal information for 6 years, to enable us to retain the information we may require for legal and regulatory purposes.
We want to keep you informed about all our products, promotions, and news, and where you have indicated you are happy to receive marketing by email, SMS, or phone we will keep in touch with the latest news. We may also send you relevant information on products and services which we think may be of interest to you - you can easily opt out of this at any time by contacting as indicated below.
If you are an existing customer, we will contact you by e-mail, SMS, post, or phone with information about products and services similar to those which you have already purchased from us.
If you have not made a purchase from us, and where we permit other companies in the William Smith Heating Solutions Scotland Ltd use your data, we (or they) will contact you with marketing if you have consented to this.
We may also send updates and marketing from the other companies in our Group about their products, promotions, and news to you on their behalf where you have consented to this.
If you prefer not to continue to receive promotional or marketing information from us or from the other companies in our Group, please use the unsubscribe function in the information we send you or alternatively write to our Data Security Officer using the contact details in section 15.
We may disclose your personal data to any member of William Smith Heating Solutions Scotland Ltd group (being our subsidiaries, as defined in section 1159 of the UK Companies Act 2006).
We will only share your personal information with other members of William Smith Heating Solutions Scotland Ltd group for marketing purposes where you have expressly opted-in/consented to the disclosure of your personal data for these purposes.
We will only disclose your information to:
analytics and search engine providers that assist us in the improvement and optimisation of our site and other selected third parties such as DRP; and
your employer, educational institution (e.g. school, college, or university), email or internet provider, parents (if you are under the age of 18) or law enforcement agencies, or other appropriate third parties, where we consider your behaviour to be unlawful, offensive, inappropriate, or objectionable in one of our training facilities;
We will disclose your personal information to third parties:
in the event that we sell or buy any business or assets, in which case we may disclose your personal data to the prospective seller or buyer of such business or assets;
in the event of any insolvency situation (e.g. the administration or liquidation) of William Smith Heating Solutions Scotland Ltd, if William Smith Heating Solutions Scotland Ltd or substantially all of its assets are acquired by a third party, in which case personal data held by it about its customers will be one of the transferred assets.
to protect the rights, property or safety of us, our staff, our customers, or others. This includes exchanging information with other companies and organisations (including without limitation, other third parties, your employer, educational institution, email or internet provider, your parents (if you are under the age of 18) and law enforcement agencies) for the purposes of staff and customer safety, crime prevention, fraud protection and credit risk reduction; and
In assessing your request for goods or services, we may use your personal data for the purposes of the prevention and detection of fraud. At all times where we disclose your personal data it will remain secure.
9. WHERE WE STORE YOUR PERSONAL DATA
Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your personal data transmitted to our site; any transmission is at your own risk. Once we have received your personal data, we will use strict procedures and security features to try to prevent unauthorised access.
10. PROTECTING YOUR INFORMATION
Our site uses up-to-date industry procedures to protect your personal information. We also protect the security of your data during transmission using Secure Sockets Layer (SSL) encryption software. We may vary this in the future if we feel you will benefit from greater security whilst using our site.
We have appropriate security measures in place in our physical facilities to protect against the loss, misuse, or alteration of information that we have collected from you via our site. Where we have given you (or where you have chosen) a password which enables you to access certain parts of our site, you are responsible for keeping this password confidential. We ask you not to share a password with anyone.
On occasion, we may gather information about your computer for our services, and to provide statistical information regarding the use of our Website to our advertisers.
Such information will not identify you personally, it is statistical data about our visitors and their use of our site. This statistical data does not identify any personal details whatsoever. It is used by us to analyse how visitors interact with the Website so that we can continue to develop and improve this Website.
We may gather information about your general Internet use by using a cookie file that is downloaded to your computer. Where used, these cookies are downloaded to your computer automatically. This cookie file is stored on the hard drive of your computer as cookies contain information that is transferred to your computers hard drive. They help us to improve our Website and the service that we provide to you.
All computers have the ability to decline cookies. This can be done by activating the setting on your browser which enables you to decline the cookies. Please note that should you choose to decline cookies, you may be unable to access particular areas of our Website.
Any advertising featured on this Website may also incorporate cookies, over which we have no control. Such cookies (if used) would be downloaded once you click on advertisements on our Website.
11. THIRD PARTY SERVICES
William Smith Heating Solutions Scotland Ltd websites may contain links to third-party websites operated by providers that are not associated with us. After you click the link, we no longer have any influence over the collection, storage, or processing of any personal data transmitted by clicking the link (such as IP address or URL of the page that contains the link), as the behaviour of third parties is, by nature, beyond our control.
Please note that these websites have their own privacy policies and that we do not accept any responsibility or liability for these policies. Please check these policies before you submit any personal data to these websites.
12. YOUR RIGHTS
You have a number of rights under data protection law in relation to the way we process your personal data, although these are not absolute, and, in some instances, we may be unable to accept your request, in which case we will respond to you to explain why. These are set out below. You may contact us using the details on our site (or by contacting us directly details below) to exercise any of these rights and we will respond to any request received from you within one month from the date of the request.
|NUMBER||DESCRIPTION OF RIGHT|
|Right 1||A right to access personal data held by us about you.|
|Right 2||A right to require us to rectify any inaccurate personal data held by us about you.|
|Right 3||A right to require us to erase personal data held by us about you. This right will only apply where (for example): we no longer need to use the personal data to achieve the purpose we collected it for; or where you withdraw your consent if we are using your personal data based on your consent; or where you object to the way we process your data (in line with Right 6 below).|
|Right 4||In certain circumstances, a right to restrict our processing of personal data held by us about you. This right will only apply where (for example): you dispute the accuracy of the personal data held by us; or where you would have the right to require us to erase the personal data but would prefer that our processing is restricted instead; or where we no longer need to use the personal data to achieve the purpose we collected it for, but we require the data for the purposes of dealing with legal claims.|
|Right 5||In certain circumstances, a right to receive personal data, which you have provided to us, in a structured, commonly used, and machine-readable format. This right will only apply where the processing is based on consent or a contract (see above) and the processing is carried out by automated means. You also have the right to require us to transfer this personal data to another organisation, at your request.|
|Right 6||A right to object to our processing of personal data held by us about you where the processing of such data is necessary for the purposes of our legitimate interests, unless we are able to demonstrate, on balance, legitimate grounds for continuing to process personal data which override your rights, or which are for the establishment, exercise, or defence of legal claims.|
|Right 7||A right for you not to be subject to a decision based solely on an automated process, including profiling, which produces legal effects concerning you or similarly significantly affect you.|
|Right 8||A right to withdraw your consent, where we are relying on it to use your personal data (for example, to provide you with marketing information about our services or products).|
13. UPDATING YOUR INFORMATION
If you believe your details are incorrect you can amend your details by contacting us at the address provided below.
This policy was last reviewed and updated: May 2018
Data Protection Officer William Smith Heating Solutions Scotland Ltd Unit 33 Anniesland Business Park Netherton Road Anniesland Glasgow G13 1EU
Please address any questions, comments, and requests regarding our data processing practices to us in this way in the first instance.
Please remember to include your name, address, and postcode along with any correspondence reference you may have.
If you have any concerns regarding our processing of your personal data or are not satisfied with our handling of any request by you in relation to your rights, you also have the right to make a complaint to the Information Commissioner's Office. Their address is:
First Contact Team Information Commissioner's Office Wycliffe House Water Lane Wilmslow SK9 5AF
William Smith Heating Solutions Scotland Ltd is registered with the ICO Z3298213