GDPR Customer Privacy Notice

Last updated: 21/01/2019

What is the purpose of this document?

AI London Limited (“AI London”) is a “data controller”. This means that we are responsible for deciding how we hold and use personal information about you.

This privacy notice is relevant to you if you are (1) our direct customer, where we may process and deliver incoming orders, deal with customer service issues and take payment for our services or (2) if we are carrying out warranty work at your property on behalf of a third party, such as a Building Developer. In this document the word ‘customer’ includes both.

This notice makes you aware of how and why your personal data will be used, namely for the purposes of the supply of goods or services, and how long it will usually be retained for. It provides you with certain information that must be provided under the General Data Protection Regulation (GDPR).

The Notice will be reviewed periodically and may be updated at any time.

Data protection principles

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).

There are “special categories” of more sensitive personal data which require a higher level of protection.

We will comply with data protection law and principles, which means that your data will be:

• Used lawfully, fairly and in a transparent way.
• Collected only for valid purposes that we have clearly explained to you and not used in any way that is incompatible with those purposes.
• Relevant to the purposes we have told you about and limited only to those purposes.
• Accurate and kept up to date.
• Kept only as long as necessary for the purposes we have told you about.
• Kept securely.

The kind of information we hold about you

In connection with your request for or acceptance of our goods and services, we may collect, store, and use the following categories of personal information about you:

• Name, address and contact information, such as your email address and telephone number
• Payment information
• Information you provide relevant to the goods or services we may supply, which may relate to the property you occupy
• Details of any complaint or customer service issue you may raise

How is your personal information collected?

We collect personal information about customers from the following sources:

• You, the customer
• Third parties, such as the Building Developer for the property

How we will use information about you

We will use the personal information we collect about you to:

• Process enquiries, quotations and orders
• Deliver and install goods
• Fulfil our customer service and warranty obligations to you and, where relevant, to the Building Developer
• Where relevant, to monitor our compliance with the NHBC warranty and insurance obligations
• Comply with any other legal or regulatory requirements

Where we may be instructed to carry out warranty work on behalf of another party, such as the Building Developer, we act as a “data processor”. In this case we will comply with any Data Protection requirements they place on us which may include deleting or anonymising your personal data.

The legal basis for processing your personal data, as prescribed in the GDPR, is for performance of the contract. The contract would be either between us and you, or between you or us and the Building Developer.

If you fail to provide personal information

If you fail to provide information when requested, we will not be able to handle your enquiry or process your order successfully.

Data sharing

Why might you share my personal information with third parties?

We will not share your data with third parties other than for any legal or regulatory reasons.  The only exception to this would be when we carry our warranty work at your property on behalf of a Building Developer, in which case your personal information will need to be shared between us and the Property Developer.

Data security

We have put in place appropriate security measures to prevent your personal information from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal information to those workers and other third parties who have a business need-to-know. They will only process your personal information on our instructions and they are subject to a duty of confidentiality.

We have put in place procedures to deal with any suspected data security breach and will notify you and any applicable regulator of a suspected breach where we are legally required to do so.

Data retention

How long will you use my information for?

In order to support warranties and guarantees provided by us or by the Building Developer (such as through the NHBC warranty and insurance) we will retain your data for a minimum of two years and up to ten years accordingly.

Your rights regarding your personal information

Under data protection legislation, you have the right to request access to information about you that we hold, also known as a Subject Access Request. You will not have to pay a fee to access your personal information (or to exercise any of the other rights listed below.) However, we may charge a reasonable fee if your request for access is clearly unfounded or excessive. Alternatively, we may refuse to comply with the request in such circumstances.

Under certain circumstances, by law you have the right to:

• Request access to your personal information (commonly known as a “data subject access request”). This enables you to receive a copy of the personal information we hold about you and to check that we are lawfully processing it.
• Request correction of the personal information that we hold about you. This enables you to have any incomplete or inaccurate information we hold about you corrected.
• Request erasure of your personal information. This enables you to ask us to delete or remove personal information where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal information where you have exercised your right to object to processing (see below).
• Object to processing of your personal information where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground.
• Request the restriction of processing of your personal information. This enables you to ask us to suspend the processing of personal information about you, for example if you want us to establish its accuracy or the reason for processing it.
• Request the transfer of your personal information to another party.

If you want to review, verify, correct or request erasure of your personal information, object to the processing of your personal data, or request that we transfer a copy of your personal information to another party, please contact the data privacy manager.

Right to withdraw consent

We are not relying on your consent to process your personal data as described in this policy. Therefore the right to withdraw consent is not relevant.

Data privacy manager

We have appointed a data privacy manager to oversee compliance with this privacy notice. If you have any questions about this privacy notice or how we handle your personal information, please contact the data privacy manager.

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
0303 123 1113