Our approach to privacy
At AJ Products (UK) Ltd (“AJ”), we always strive to build long-term relationships with our customers, companies and organisations as well as their representatives and all consumers who buy directly from us. Our customers are of the utmost importance to us, and we will, therefore, always handle personal data with the greatest caution and security in accordance with the General Data Protection Regulation (“GDPR”) and other applicable data protection laws in the United Kingdom.
For the purposes of this Privacy Notice, a reference to the GDPR, insofar as the applicable data protection law is that of the United Kingdom, will be a reference to the UK GDPR (as incorporated into UK law by section 3 of the European Union (Withdrawal) Act 2018, and as amended by Schedule 1 to the Data Protection, Privacy and Electronic Communications (Amendments etc) (EU Exit) Regulations 2019).
We, AJ Products (UK) Ltd, a limited liability company with registered company no. 3762591, Units 19 & 20 Nimbus, Hercules Way, Farnborough GU14 6UU, UK, are the controller of the personal data. The personal data can be processed by us or, in limited circumstances, by our partners.
We are responsible for the partners who processes personal data on our behalf. Please find more information about our processors and other receivers of the personal data below.
When you as a customer, either as a representative of a company or as a private consumer, purchase products from, or interact with AJ, we may process your personal data such as name, email address and phone number.
The data is used by AJ to enable a good customer experience throughout the entire order and sales process: presentation of our range of products, placement of orders, delivery, potential complaints/warranty matters and development of our IT processes.
We document our communication with you. The communication with you as a customer is carried out via phone, email, chat, written and physical contact as well as digital media. The reason for documenting it is to enable follow ups of customer matters and complaints as well as handling all matters during your time as an AJ customer, such as questions relating to purchases/orders, complaints or technical support.
What data is collected, for what purpose and for how long is the data stored?
We will process some personal data due to legal requirements. Other personal data will be processed as part of the contractual relationship with you so that we can fulfil our commitments within the purchase agreement.
Your personal data is needed so that we can enter into an agreement with you and subsequently fulfil our commitments listed below. The collection of such personal data is done on the legal basis for the fulfilment of the agreement.
We need to process your personal data in connection with orders and delivery (including notifications and contact regarding delivery) to fulfil our commitments within the purchase agreement. In certain cases, we will also collect personal data to handle complaints and warranty matters. Additional personal data may be processed in connection with services such as booking assembly and delivery.
The personal data
Personal data that will be processed in order to fulfil the purchase agreement includes:
If you are a company customer, the categories of personal data above will also be processed regarding the person specified as contact person.
The retention period for company and customer contact data is based on the warranty period our products have. Therefore, depending on which item you have purchased from us, the retention period can vary between three (3) and thirty (30) years.
When the warranty period has expired, your personal data is stored for up to twelve (12) months and is then anonymised. The anonymisation process is undertaken on a monthly basis.
Your data will be deleted or anonymised when the order has been completed, delivered, paid and the warranty period has expired. If the data is anonymised, it is no longer identifiable and therefore not considered personal data under the GDPR.
However, we will process your personal data for as long as it is required to handle any complaint and warranty matters in relation to an order.
Main purpose: Creation of customer account
You must create a customer account to be able to make a purchase from us. This is needed because we must be able to keep our product specific guarantees (please see further information below). The processing of personal data is done on the legal basis for the performance of the agreement.
To enable a purchase and, thus, a contractual relationship, customers need to create a customer profile on AJ Products' website through My Pages. This means AJ can honour guarantees and document customer matters/complaints. You are responsible for updating the data at all times in the event of changes.
The personal data
The personal data that will be processed for customer profiles is:
AJ will process the personal data required to keep your customer profile active as long as you are a customer, have ongoing matters with us (e.g. warranty matter or complaints) or use the digital services. Thereafter, we will process your personal data, for the same purpose as above, for a period of twelve (12) months. The personal data will then be anonymised. The anonymisation process is undertaken on a monthly basis. We keep communication that has been submitted in our digital channels until we no longer need it for our purposes.
Main purpose: Distribution of newsletter
Legal basis and purpose
Personal data that is necessary to enable communication through newsletters is listed below. We will only send marketing communications to you by email where you have consented to receive such content by email, or where we have another lawful right to send marketing to you using email. For example, in certain circumstances we may rely on our legitimate interest to send marketing by email to consumers who have purchased our products. We may also rely on our legitimate interest to send marketing by email to certain business users of our website and our products.
The personal data
Personal data that will be processed in order to communicate such offers includes:
i. name, and
AJ will process the personal data required to distribute newsletters to you until you request to unsubscribe from such. You can always unsubscribe by following the unsubscribe link in the footer of the email or by contacting us.
Main Purpose: Personalised marketing
We and our third party partners will process some of your personal data to individualise offers and make them as relevant as possible for you. We will provide you with, and analyse the effectiveness of, personalised advertisements when you visit other websites (including social media platforms). By personalised advertisements we mean advertisements for products that you have shown an interest in when you have used our website or which you otherwise might be interested in based on your browsing habits. We will also customise newsletters and the distribution of relevant catalogues to you.
The Personal Data
Personal data that will be processed to individualise such offers includes:
The personal data is collected through various digital channels such as your interaction with search engines such as Google and Bing, as well as social media, digital networks for ads, and our own, as well as external, customer surveys.
AJ will process the personal data required to keep your customer profile active as long as you are a customer, have ongoing matters with us (e.g. warranty matter or complaints) or use the digital services. Thereafter, we will process your personal data, for the same purpose as above, for a period of twelve (12) months. Then, the personal data will be anonymised. The anonymisation process is undertaken on a monthly basis. We keep communication that has been submitted in our digital channels until we no longer need it for our purposes.
How does our individualisation process take place (i.e. how do we process your data)?
We perform analysis at an individual level which either sorts the data into a customer group (so called customer segment or industry type), or which results in a unique profile. The insights from the analysis form the basis of your personal profile and relevant offers. This data is then used as a basis for the creation of different marketing activities, such as email distributions and digital advertisements in all media the company uses.
Main Purpose: Campaigns based on your digital interaction
Purpose and legal basis
The personal data
- User generated data (e.g. click and visit history) on our website.
Main Purpose: Evaluation, development and improvement of AJ
Purpose and legal basis
To meet our interest of constant evaluation, development and improvement of AJ’s service, the personal data listed below is processed through our website, communication channels, digital channels and IT systems on the legal basis of legitimate interest. AJ has a legitimate interest in processing purchase history, complaints and other related information to be able to better develop our offers and service to you as a customer. The processing is necessary to meet our legitimate interest of managing the life cycle of our systems, products and services as well as to protect and develop them.
AJ may use data collected through customer surveys, customer contact or purchase history and analyse the data for the purpose of company development, e.g. to develop our website and its functions. This informs our logistical processes and forecasts for warehousing and development of our range, and helps inform our IT system and security practices.
The personal data
Personal data that will be processed to aid the development and improvement of AJ includes:
Your personal data is retained for the same period as specified in relation to the respective stated purpose of the processing of your personal data above. From the time when the personal data was first recorded in logs, the data will be retained for troubleshooting and incident response for a period of thirteen (13) months.
You have several statutory rights when we process your personal data, e.g. you have the right to access all personal data we process about you (extracts), you have the right to demand correction of incorrect data and you can demand deletion (to some extent) of personal data. Your rights are:
i. Right to be informed
Your privacy is of the utmost importance to us. Therefore, it is important for AJ that there is full transparency regarding our processing of your personal data. If you wish to exercise your right of access you can do this easily by sending an email to: firstname.lastname@example.org.
To ensure that we disclose the data to the correct person and that we do not disclose your personal data to anyone else, we must obtain proof that the request is made by you. In order to handle your request, we will provide you with information on how you should identify yourself in connection with the submission of the form via our website.
You can request deletion of your customer contact data (right to deletion), and also have the right to rectification of your personal data. We perform a review and anonymisation of our business customers’ contact data after four (4) years, where no transaction has taken place during the four-year period. Individuals, i.e. data on consumers, follow the same anonymisation process, given that all commitments from us and the customer are completed.
You can easily request deletion by sending an email to us at email@example.com. We will respond with information on how you should identify yourself so that we can handle your request.
If we rely on your consent (or explicit consent) as our legal basis for processing your personal data, you have the right to withdraw that consent at any time. You can exercise your right of withdrawal by contacting us. Please visit My Pages on our website, contact us via the Contact Us page or call our customer service team on 01252 359760 if you wish to exercise this right, change or correct customer contact data, or unsubscribe from marketing communication such as newsletters and catalogues.
You always have the right to submit a complaint regarding our processing of your personal data to the UK Information Commissioner’s Office (“ICO”). Contact details for the ICO can be found on its website https://ico.org.uk. However, we prefer that you contact us directly as a first step so that we can resolve your questions and complaints. You can reach us at: firstname.lastname@example.org.
We are committed to keeping the personal data you provide to us secure and we have implemented information security policies, rules and technical measures to protect the personal data under our control from unauthorised access, improper use or disclosure, unauthorised modification and unlawful destruction or accidental loss. Within our organisation, the access to your personal data is limited to the persons who actually need to process your personal data.
Processors of the personal data
We share personal data with third party processors who assist us in providing our services. A processor of the personal data is a company that processes the data on our behalf in accordance with our instructions.
We have processors helping us with:
i. Transport (logistics companies and freight forwarders),
When your personal data is shared with processors of the personal data, it is solely for purposes that are compatible with the purposes for which we have collected the data. We perform checks on all processors to ensure that they can provide adequate guarantees regarding the security and confidentiality of personal data. We have written agreements in place with all processors in which they guarantee the security of the personal data and undertake to comply with our security requirements as well as restrictions and requirements regarding international transfers of personal data.
Companies that are independent controllers of the personal data
We share your personal data with certain companies that are independently responsible for the personal data (controllers of the personal data).
Independent controllers we share your personal data with are:
i. Authorities (police authority, tax agency or other authorities) if we are obliged to do so by law or in case of suspicion of criminal offence,
We always strive to process your customer contact data within the UK or the EEA and all our IT systems are located within the UK or the EEA. In the event of system support, maintenance and development, we may have to transfer the data to a country outside of the UK or the EEA, e.g. if we share your customer contact data with a processor who, either itself or through a subcontractor, is located in a country outside the UK or the EEA or stores the personal data there. In these cases, the processor will only take the part of the data that is relevant for the given purpose.
Regardless of the country in which your customer contact data is processed, we take all reasonable legal, technical and organisational measures to ensure that the level of protection is equivalent to the level of protection within the UK or the EEA. We require, through our agreements, that our processors comply with applicable privacy laws and regulations, such as GDPR and applicable national data protection legislation. Also, we prohibit personal data from being transferred to a country outside the UK or the EEA unless there is a lawful basis for transferring the personal data and appropriate safeguards in place to ensure an adequate level of protection. Please contact us if you would like further information on the specific mechanisms used by us when transferring your personal data outside the UK or the EEA.
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