CARVER GROUP LIMITED MOBILE APP (Biddle) PRIVACY POLICY
Introduction
This policy applies to your use of the
Carver Climate Systems Mobile Applicatio Biddle (App), once you have downloaded or streamed a copy of the App onto
your mobile telephone or handheld device (Device).
This policy sets out the basis on which any
personal data we collect from you, or that you provide to us via the App, will
be processed by us. This App is not intended for children and we do not
knowingly collect data relating to children. Please read the following
carefully to understand our practices regarding your personal data and how we
will treat it.
Important information and who we are
Carver Group Limited is the controller
and is responsible for your personal data (collectively referred to as "Company",
"we", "us" or "our" in this policy).
Contact
details
If you have any questions about this
privacy policy, please contact us using the details set out below:
·Email address: contact@carver-group.co.uk
·Postal address: Carver Group
Ltd, St. Mary's Road, Nuneaton, CV11 5AU Warwickshire, United Kingdom
You have the right to make a complaint
at any time to the Information Commissioner's Office (ICO), the UK regulator
for data protection issues.
Changes
to the privacy policy and your duty to inform us of changes
We keep our privacy policy under regular
review. It may change and if it does, these changes will be posted on this page
and, where appropriate, notified to you by email or when you next start the App.
The new policy may be displayed on-screen and you may be required to read and
accept the changes to continue your use of the App.
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 our relationship with you.
Third
party links
Our App may, from time to time, contain
links to and from the websites of our partner networks, advertisers and
affiliates. Please note that these websites and any services that may be
accessible through them have their own privacy policies and that we do not accept
any responsibility or liability for these policies or for any personal data
that may be collected through these websites or services. Please check these policies before you submit any personal data
to these websites or use these services.
The data
we collect about you
We may collect, use, store and transfer
different kinds of personal data about you as follows:
·Identity Data: first name, last name,
username or similar identifier.
·Contact Data: postal address, email
address and telephone numbers.
·Device Data: includes the type of mobile
device you use, a unique device identifier (for example, your Device's IMEI
number, IP address, the MAC address of the Device's wireless network interface,
or the mobile phone number used by the Device), mobile network information,
your mobile operating system, App version number, push notification identifier
and log files.
·Profile Data: includes your username and
password, the type of unit that our App interfaces with and the location of the
unit, and any feedback or other information you communicate to us.
·Usage Data: includes details of your use
of any of our Apps including, but not limited to, visits, clicks, downloads,
messages sent/received,traffic data and other communication data.
·Marketing and Communications Data:
includes your preferences in receiving marketing from us and our third parties
and your communication preferences.
We also collect, use and share
Aggregated Data such as statistical or demographic data for any purpose.
Aggregated Data could be derived from your personal data but is not considered
personal data in law as this data will not directly or indirectly reveal your
identity. For example, we may aggregate your Usage Data to calculate the
percentage of users accessing a specific App feature. However, if we combine or
connect Aggregated Data with your personal data so that it can directly or
indirectly identify you, we treat the combined data as personal data which will
be used in accordance with this privacy policy.
We do not collect any special categories
of personal data about you (this includes details about your race or ethnicity,
religious or philosophical beliefs, sex life, sexual orientation, political
opinions, trade union membership, information about your health, and genetic
and biometric data). We do not collect any information about criminal
convictions and offences.
How is
your personal data collected?
We will collect and process the
following data about you:
·Information you give us. This is
information (including Identity, Contact and Marketing and Communications Data)
you give us about you by filling in forms on the App, or by corresponding with
us (for example, by email). It includes information you provide when you
register to use the App or download it, and when you report a problem with an
App. If you contact us, we will keep a record of that correspondence.
Information we collect about you and your device. Each time you visit our App we will automatically collect personal
data including Device, Content and Usage Data.
How we use
your personal data
We will only use your personal data when
the law allows us to do so. Most commonly we will use your personal data in the
following circumstances:
·Where you Consent to the processing of your personal data. Consent will only
be valid if it is a freely given, specific, informed and unambiguous indication
of what you want. You can withdraw your consent at any time by contacting us.
·Performance of Contract means processing
your data where it is necessary for the performance of a contract to which you
are a party or to take steps at your request before entering into such a
contract.
·Where it is Necessary for our Legitimate Interests
(or those of a third party) and your interests and fundamental rights do not
override those interests. 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 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.
·Where we need to comply with a Legal or RegulatoryObligation.
We will only send you direct marketing
communications by email or text if we have your consent. You have the right to
withdraw that consent at any time by contacting us.
Purposes
for which we will use your personal data
Purpose/activity
| Type
of data | Lawful
basis for processing |
|---|
To install the App | Device | Your consent |
To register you as a new App user | Identity Contact Device | Performance of a contract with you
|
To provide services to you via the App | Identity Contact Device Usage Profile
| Performance of a contract with you
|
To manage our relationship with you
including: notifying you of changes to the App; and answering your queries or
complaints | Identity Contact Profile Device Usage [Marketing and Communications] | Your consent Performance of a contract with you Necessary for our legitimate interests
(to keep records updated and to analyse how customers use the App) Necessary to comply with legal
obligations (to inform you of any changes to our terms and conditions) |
To enable you to participate in a prize
draw, competition or complete a survey | Identity Contact Device Profile Marketing and Communications | Your consent Performance of a contract with you Necessary for our legitimate interests
(to analyse how customers use our products/Services and to develop them and
grow our business) |
To administer and protect our business
and this App including troubleshooting, data analysis and system testing
| Identity Contact Device Usage | Necessary for our legitimate interests
(for running our business, provision of administration and IT services,
network security) |
To deliver content and advertisements to
you
| Identity Contact Device Profile Usage Marketing and Communications
| Consent
|
To develop new products and services, or
to improve the App
| Identity Contact Device Profile Usage Marketing and Communications
| Necessary for our legitimate interests
(to develop our products/Services and grow our business) |
For the establishment, exercise or
defence of legal claims | Identity Contact Device Profile Usage Marketing and Communications
| Necessary for our legitimate interests
(to protect our business) |
Disclosures of your personal data
When you provide us with your personal
data, we may also share your personal data with the third parties set out
below:
·Other companies within the same
corporate group.
·Service providers acting as
processors who provide IT and system administration services.
·Professional advisers including
lawyers, bankers, auditors and insurers who provide consultancy, banking,
legal, insurance and accounting services.
·HM Revenue and Customs,
regulators and other authorities 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.
International
transfers
We do use suppliers who are located
outside the UK, including in China, where your information relating to use of
the App may be stored. Other external third parties to whom we might provide
personal data may also be outside the UK. Whenever we transfer your personal
data out of the UK, we ensure a similar degree of protection is afforded to it
by ensuring at least one of the following safeguards is implemented:
·We will only transfer your
personal data to countries that have been deemed to provide an adequate level
of protection for personal data under UK data protection law.
·Where we use certain service
providers, we may use specific contracts approved by the UK regulator which
give personal data the same protection it has in the UK.
Please contact us if you want further
information on the specific mechanism used by us when transferring your
personal data out of the UK.
Data security
All information you provide to us is
stored on our secure servers. Once we have received your information, we will
use strict procedures and security features to try to prevent your personal
data from being accidentally lost, used or accessed in an unauthorised way. We
have put in place procedures to deal with any suspected personal data breach
and will notify you and any applicable regulator when we are legally required
to do so.
Where we have given you (or where you
have chosen) a password that enables you to access the App, you are responsible
for keeping this password confidential. We ask you not to share a password with
anyone.
Data retention
Details of retention periods for
different aspects of your personal data are available in our retention policy
which you can request by contacting us. In some circumstances you can ask us to
delete your data, see Your legal rights
below for further information.
In some circumstances we will anonymise
your personal data (so that it can no longer be associated with you) for
research or statistical purposes, in which case we may use this information
indefinitely without further notice to you.
Your legal
rights
Under certain circumstances you have the
following rights under data protection laws in relation to your personal data:
·Request access to your personal data
(commonly known as a "data subject access request"). This enables you
to receive a copy of the personal data we hold about you and to check that we
are lawfully processing it.
·Request correction of the personal data
that we hold about you. This enables you to have any incomplete or inaccurate
data we hold about you corrected, though we may need to verify the accuracy of
the new data you provide to us.
·Request erasure of your personal data.
This enables you to ask us to delete or remove personal data 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 data where you have successfully exercised
your right to object to processing (see below), where we may have processed
your information unlawfully or where we are required to erase your personal
data to comply with local law. Note, however, that we may not always be able to
comply with your request of erasure for specific legal reasons which will be
notified to you, if applicable, at the time of your request.
·Object to processing of your personal
data 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 as you feel it impacts on your fundamental
rights and freedoms. You also have the right to object where we are processing
your personal data for direct marketing purposes. In some cases, we may demonstrate
that we have compelling legitimate grounds to process your information which
override your rights and freedoms.
·Request restriction of processing of
your personal data. This enables you to ask us to suspend the processing of
your personal data in the following scenarios:
·if you want us to establish the
data's accuracy;
·where our use of the data is
unlawful but you do not want us to erase it;
·where you need us to hold the
data even if we no longer require it as you need it to establish, exercise or
defend legal claims; or
·you have objected to our use of
your data but we need to verify whether we have overriding legitimate grounds
to use it.
·Request the transfer of your personal
data to you or to a third party. We will provide to you, or a third party you
have chosen, your personal data in a structured, commonly used,
machine-readable format. Note that this right only applies to automated
information which you initially provided consent for us to use or where we used
the information to perform a contract with you.
·Withdraw consent at any time where we
are relying on consent to process your personal data. However, this will not
affect the lawfulness of any processing carried out before you withdraw your
consent. If you withdraw your consent, we may not be able to provide certain
products or services to you. We will advise you if this is the case at the time
you withdraw your consent. You also have the right to ask us not to continue to
process your personal data for marketing purposes.
Contact Us
If you have any questions about our practices or this Privacy Policy, please
contact us as follows:
Postal Mailing Address: St Mary’s Road,Nuneaton,Warwickshire,CV11 5AU Email:sales@biddle-air.co.uk