Privacy Policy

Version: V 5.0
Date: 08/11/22
Author: GDPR Local
Stored at: Safe Storage

Privacy Statement Summary:

Who will use my data?	Senko Advanced Co Ltd and other companies in the Senko Group.
What for?	We will collect, store and process your data in order to allow us to provide our products and services to you. If you share your details with us for any reason and where we have your consent or other appropriate lawful basis we may also send you marketing material including offer details that we think you will be interested in. You can opt-out of marketing at any time. If you are a supplier or other third party, we will collect, store, and process your data as required to manage the relationship between us.
What will happen if I contact you?	If you share your details with us for any reason and where we have your consent or other appropriate lawful basis we may also send you marketing material including offer details that we think you will be interested in. You can opt-out of marketing at any time.
What data will be stored?	We will store your personal details in order to respond to your enquiry, provide our services to you, manage our relationship with you, and as required to run and develop our business including our marketing activities.
What data will be shared?	We will not share your data with any third parties outside of the Group other than as required to run our company, meet our contractual commitments to our customers, and meet our obligations to you. If necessary we will share your information with any regulator or legal body that requests it.
How long?	We will only store your data for as long as necessary and always in line with data retention principles. For more details please see our Data Retention policy.
Who can access my data?	We will never sell, share or otherwise distribute your data to any other third party. Access to your data is strictly controlled and monitored to protect your privacy.
How is my data kept secure?	We may store your data on servers which are based in the UK, EU and in third countries as necessary. We use industry standard security protocols/technology to secure data.

About This Privacy Policy

This policy sets out how Senko Advanced Co Ltd and the companies in the Senko Group will collect, store, process, use and share the information that you give us.

The General Data Protection Regulation (GDPR) describes how organisations must collect, handle, process and store personal information. These rules apply regardless of whether data is stored electronically, on paper or on other materials. To comply with the law, personal information must be collected and used fairly, stored safely and not disclosed unlawfully. GDPR is underpinned by eight important principles. These say that personal data must:

• Be processed fairly and lawfully
• Be obtained only for specific, lawful purposes
• Be adequate, relevant and not excessive
• Be accurate and kept up to date
• Not be held for any longer than is necessary
• Processed in accordance with the rights of the data subjects
• Be protected in appropriate ways
• Not be transferred outside the United Kingdom, unless that country or territory also ensures an adequate level of protection

We take these responsibilities seriously, this document describes our approach to data protection. This policy helps to protect us from data security risks, including:

• Breaches of confidentiality. For instance, information being given out inappropriately.
• Failing to offer choice as required by GDPR. For instance, all individuals should be free to choose how the company uses data relating to them.
• Reputational damage. For instance, the company could suffer if hackers successfully gained access to sensitive data.
• Any other risk associated with processing personal data

Our Data Protection Officer and Article 27 Representative

For any GDPR issues please contact our Data Protection Officer:

Name: Adam Brogden
Email: adam@gdprlocal.com
Company: GDPRLocal Ltd
Tel: +441772 217772

We have appointed an EU Representative as required by Article 27 of the GDPR. You can contact our EU Representative at:

Instant EU GDPR Representative Ltd
Adam Brogden
contact@gdprlocal.com
Tel + 353 15 549 700

INSTANT EU GDPR REPRESENTATIVE LTD
Office 2,
12A Lower Main Street, Lucan Co. Dublin
K78 X5P8
Ireland

Who We Are And How To Contact Us

The UK office is Senko Advanced Components Ltd, registered in UK reg: 02999350 and is registered with the Information Commissioner’s Office ref: ZA458350 .

Website: https://www.senko.com/

Post:

Senko Advanced Components Ltd.
2 Rankine Road, Daneshill Industrial Estate,
Basingstoke,Hampshire,
RG24 8PP
United Kingdom

Who this privacy policy applies to

This policy relates to any personal data held relating to any individual considered to be within the scope of the GDPR. This includes data held on all data subjects including website visitors, potential customers, customers, suppliers, and all other third-parties etc.. Processing of personal data is required to respond to requests, run our company, provide our products and services to our clients, and to manage the relationship between us and the individuals involved.

It applies to all data that the company holds relating to identifiable individuals covered by the scope of GDPR. This can include:

• Names of Individuals
• Contact details [email, post, phone etc…]
• Company / employment information
• Any other information relating to individuals

What this policy applies to

This section describes the lawful basis for processing your data and applies to the information about yourself that you choose to provide us with or that you allow us to collect. This includes:

• Information you provide when contacting us about using our specialist component manufacturing services
• When you contact us in order to discuss using these services
• Information we collect about how you use the website
• Information relating to products and services we offer to you and other transactions including financial and other personal information required to complete these transactions
• Information given and stored as part of our ongoing relationship
• Information we collect to facilities marketing and business development
• Any other information as shared during our relationship

We do not routinely collect sensitive personal data, however where this is the case we will take appropriate action to protect the data.

How your information will be used

We will only use your personal data for the purposes for which we collected it and as you would reasonably expect your data to be processed and only where there is a lawful basis for such processing, for example:

Purpose/Activity	Type of data	Lawful basis for processing
To register you as a new customer	(a) Identity, (b) Contact information, (c) financial information for reference and credit vetting etc…	Performance of a contract with you, or potential contract with customers, suppliers, and other third parties
When you visit our website	(a) Identity, (b) Contact, (c) Customer Profile, (d) Marketing and Communications	(a) Performance of a contract with you, (b) Necessary to comply with a legal obligation, (c) Necessary for our legitimate interests to keep our records updated and to study how customers use our products/services, (d) with your consent
To process and deliver the products and services you request including managing payments, fees and charges, and to collect and recover money owed to us	(a) Identity, (b) Contact, (c) Financial, (d) Transaction, (e) Marketing and Communications	(a) Performance of a contract with you, (b) Necessary for our legitimate interests to recover debts owed to us, (c) Necessary to operate our business [CRM and Credit Control]
To manage our ongoing relationship with you which will include notifying you about changes to our terms, products and services, or privacy policy, to maintain our records	(a) Identity, (b) Contact, (c) Customer Profile, (d) Marketing and Communications	(a) Performance of a contract with you, (b) Necessary to comply with a legal obligation, (c) Necessary for our legitimate interests to keep our records updated and to study how customers use our products/services, (d) with your consent
To administer and protect our business and our site (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)	(a) Identity, (b) Contact, (c) Technical information	(a) Necessary for our legitimate interests for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise, (b) Necessary to comply with a legal obligation
To deliver relevant content and advertisements to you and measure and understand the effectiveness of our advertising	(a) Identity, (b) Contact, (c) Profile, (d) Usage, (e) Marketing and Communications, (f) Technical	Necessary for our legitimate interests to study how customers use our products/services, to develop them, to grow our business and to inform our marketing strategy. To help target our social media campaigns.
To use data analytics to improve our website, products/services, marketing, customer relationships and experiences	(a) Technical, (b) Usage	Necessary for our legitimate interests to define types of customers for our products and services, to keep our site updated and relevant, to develop our business and to inform our marketing strategy
To make suggestions and recommendations to you about goods or services that may be of interest to you	(a) Identity, (b) Contact, (c) Technical, (d) Usage, (e) Profile	Necessary for our legitimate interests to develop our products/services and grow our business

In accordance with your preferences, we may also use your personal information to provide you with information about products, services, promotions and offers that may be of interest to you. We may use your personal information in order to ascertain the products and services that are likely to be of particular interest to you. This document explains how you can change whether to receive this information. Please note that, even if you choose not to receive this information, we may still use your personal information to provide you with important services communications, including communications in relation to any purchases you make or services you use.

How to change your preferences

We operate in line with GDPR data protection guidelines. We respect your rights and will respond to any request for access to personal information and requests to delete, rectify, transfer, data and to stop processing. We will also advise you on how to complain to the relevant authorities, in the UK this is the Information Commissioner’s Office [ico.org.uk]. Any requests or objections should be made to the Data Protection Officer, you can write to us, call, or email us to discuss any issues at any time.

Scope of Agreement

By submitting your personal data to us, you are affirming your agreement for such information to be used in accordance with this privacy policy. We may from time to time use your information for marketing, account management or relationship management purposes. The main purpose of this is to provide you with information about goods and services which we think may be of interest to you and/or to maintain any existing relationship we may have with you.

Opting out at a later date

Where you give your consent for us to process your data, for example when you agree to us sending you marketing information or where you agree to us processing financial data, you can contact us to amend or withdraw your consent at any time. You can also choose to object to processing and request deletion of your data. We respect all user rights as defined in GDPR. If you have any comments or wish to complain please contact us.

How we store and process your data

Your data may be collected, stored, or processed by any company in the Group and as such may be stored in various locations. We will always take the utmost care and all reasonable precautions to protect your data.

In order to provide our services to you we use recognised third parties to take payment, conduct credit reports and other checks, manage our company accounts and provide banking services. We will store transactions, payment and order data for up to 7 years or for as long as required by UK financial and company regulations. These third parties may operate outside the UK, if this is the case we will ensure precautions are in place to protect your data.

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 find out more about how the processing for the new purpose is compatible with the original purpose, please email us.

We may be legally obliged to disclose your personal information without your knowledge to the extent that we are required to do so by law; in connection with any ongoing or prospective legal proceedings; in order to establish, exercise or defend our legal rights (including providing information to others for the purposes of fraud prevention and reducing credit risk); to any person who we reasonably believe may apply to a court or other competent authority for disclosure of that personal information where, in our reasonable opinion, such court or authority would be reasonably likely to order disclosure of that personal information.

You will only receive marketing communications from us if you have:

• Requested information from us or purchased goods or services from us
• If you provided us with your details and ticked the box at the point of entry of your details for us to send you marketing communications
• Where we have a legitimate interest to send you marketing information
• You have not opted out of receiving marketing

Third Parties

We may have to share your personal data with the parties set out below for the purposes described in this document:

• Companies within the Senko Group
• Service providers who provide IT and system administration services.
• Service providers, IT companies, Consultancies who provide services required to operate our business. These companies may operate outside of the UK or EU.
• Third parties who provide advertising and marketing services.
• Websites including social media we use to advertise our products and services
• Professional advisers including lawyers, bankers, auditors and insurers who provide consultancy, credit scoring, banking, legal, fraud protection, insurance and accounting services.
• Couriers or other parties necessary to provide our products and services to you.
• Government bodies, Regulators and other authorities and other relevant jurisdictions who require reporting of processing activities in certain circumstances.
• Third parties to whom we sell, transfer, or merge parts of our business or our assets.

We require all third parties to whom we transfer your data to respect the security of your personal data and to treat it in accordance with the law. We only allow such third parties to process your personal data for specified purposes and in accordance with our instructions.

Security

Senko Advanced Components developed a Cyber-Security policy (also called an information security policy or IT security policy) this policy defines the rules, expectations, and overall approach that Senko Advanced Components uses to maintain the confidentiality, integrity, and availability of its data to both internal and external requests.

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 such data. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.

Where we share your data with any third parties we will take reasonable precautions to ensure that your data is protected including ensuring that any third party meets GDPR standards.

We will report any breaches or potential breaches to the appropriate authorities within 24 hours and to anyone affected by a breach within 72 hours. If you have any queries or concerns about your data usage, please contact us.

This website uses cookies and may include third-party websites, plug-ins and applications and 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 statements. When you leave our website, we encourage you to read the privacy notice of every website you visit.

We use Hotjar in order to better understand our users’ needs and to optimise this service and experience. Hotjar uses cookies and other technologies to collect data on our users’ behaviour and their devices. This includes a device’s IP address, device screen size, device type, browser information, geographic location, and the preferred language used to display our website. Hotjar stores this information on our behalf in a pseudonymized user profile. For further details, please see the Hotjar’s support site.

We also use a 3D rendering plug-in Expivi – Expivi uses cookies. These cookies are used to store information including visitors’ preferences, and the pages on the website that the visitor accessed or visited. The information is used to optimise the users’ experience by customising our web page content based on visitors’ browser type and/or other information. For more information take a look at the Expivi privacy information: https://www.expivi.com/en/privacy

Cookies

A cookie is a small file which asks permission to be placed on your computer’s hard drive. Once you agree, the file is added and the cookie helps analyse web traffic or lets you know when you visit a particular site. Cookies allow web applications to respond to you as an individual. The web application can tailor its operations to your needs, likes and dislikes by gathering and remembering information about your preferences. We use traffic log cookies to identify which pages are being used. This helps us analyse data about webpage traffic and improve our website in order to tailor it to customer needs. We only use this information for statistical analysis purposes and then the data is removed from the system.

Overall, cookies help us provide you with a better website by enabling us to monitor which pages you find useful and which you do not. A cookie in no way gives us access to your computer or any information about you, other than the data you choose to share with us.

You can choose to accept or decline cookies. Most web browsers automatically accept cookies, but you can usually modify your browser setting to decline cookies if you prefer. This may prevent you from taking full advantage of the website.

As well as your ability to accept or reject cookies, we also require your permission to store cookies on your machine, which is why when you visit our site, you are presented with the ability to accept our terms of use, including the storage of cookies on your machine. Should you not accept, then you are free to leave our website, at any time

Contacting us, exercising your information rights and Complaints

If you have any questions or comments about this Privacy Policy, wish to exercise your information rights in connection with the personal data you have shared with us or wish to complain, please contact our Data Protection Officer. We will process SARs as required by GDPR. SAR responses are usually free, but we reserve the right to charge for excessive or unfounded requests. We fully comply with Data Protection legislation and will assist in any investigation or request made by the appropriate authorities.

If you remain dissatisfied you have the right to apply directly to your local Data Protection Regulator. You can find their contact details on the following link: https://edpb.europa.eu/about-edpb/about-edpb/members_en