Privacy Policy

Last updated: 9th August 2022

Contents

1. Who is the Data Controller?
2. What kinds of Personal Data does Prime Plc Process?
3. What are the reasons Prime Plc collects Personal Data?
4. Where does Prime Plc obtain Personal Data from?
5. Who will Prime Plc share your Personal Data with?
6. Where will Prime Plc store your Personal Data?
7. How long will Prime Plc keep your Personal Data?
8. Your Rights, Our Responsibility
9. Prime Plc Contact Details
10. Who is the Prime Plc Data Protection Officer?

1.0 Who is the Data Controller?

1. We are Prime Plc.
2. Registered address: 5 The Triangle, Wildwood Drive, Worcester, Worcestershire, WR5 2QX
3. Registration number: 03432065
4. In this document Prime Plc may be referred to as “we”, “us”, or “our”.

2.0 What kinds of Personal Data does Prime Plc Process?

1. Prime Plc collects personal data for various purposes; with that in mind we have created a list of the types of personal data that we may collect, either directly from yourself or from other sources, in order to achieve those purposes.
2. The kinds of personal data we may collect include:
   

   Customer / Client	first name, last name, username or similar identifier, title, Contact Data includes billing address, delivery address, email address and telephone numbers
   Applicant / Temp / Intern	CV
   Professional Contact	first name, last name, title, Contact Data includes email address and telephone numbers
   Supplier / Trader / Consultant / Contractor	first name, last name, title, Contact Data includes billing address, delivery address, email address and telephone numbers
   Sub-Contractor	first name, last name, title, Contact Data includes billing address, delivery address, email address and telephone numbers

3. 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 website 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.
4. 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). Nor do we collect any information about criminal convictions and offences.

3.0 What are the reason Prime Plc collects Personal Data?

Legal Obligations

1. 1. Prime Plc uses personal data firstly to fulfil any contractual obligations that exist between us and yourself. Where we request personal data be provided to enter into, or meet the terms of any such contract, you will be required to provide the relevant personal data or we will not be able to deliver the goods or services you want. In such cases the lawful basis of us processing the personal data is that it is necessary for the performance of a contract.
   2. We are required by law to process personal data for purposes relating to our legal obligations, these include:
      • To provide for our financial commitments, or to relevant financial authorities.
      • To comply with regulatory requirements and any self-regulatory schemes.
      • To carry out required business operations and due diligence.
      • To co-operate with relevant authorities for reporting criminal activity, or to detect and prevent fraud.
      • To investigate any insurance claims, claims of any kind of harassment or of discrimination, or any other claim whereby the organisation may have to defend itself.

Consent

1. 1. Prime Plc may process Personal Data for marketing purposes where it has received your consent.
   2. You may withdraw your consent for us to process your personal data for these purposes at any time; after a withdrawal of consent request is received, we may have to contact you to verify the request.
   3. Withdrawing your consent for us to process your personal data will not affect the lawfulness of the processing beforehand.

Legitimate Interests

1. 1. Prime Plc may process Personal Data for any of the following purposes, which are considered to be within our legitimate business interests:
      • To provide goods and services where it has been requested
      • To inform people of goods and services we provide or offers that may interest them
      • To send notification on subjects to individuals who have asked to be kept informed
      • To invite people to participate in research in fields and disciplines they are interested in
      • To improve the quality of the services we offer, and to better understand customers’ needs by requesting feedback, or reviews of the services provided, or sending survey forms
      • To send notifications of any changes to the goods and/or services provided that may affect people
      • To recognise when people re-engage with our organisation
      • To improve the organisations website so content is delivered more efficiently.

4.0 Where does Prime Plc obtain Personal Data from?

1. We will collect personal data directly from you in various ways. This could include when you complete an online form, or if you provide the data directly to a representative of Prime Plc.
2. We collect some personal data from publicly accessible sources such as web searches.
3. We may also gather personal data by any of the following methods:
   • Automated technologies or interactions. As you interact with our website, we will automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies, server logs and other similar technologies. We may also receive Technical Data about you if you visit other websites employing our cookies. Please see our cookie policy for further details.
   • Third parties or publicly available sources. We will receive personal data about you from various third parties and public sources as set out below.
   • Technical Data from analytics providers such as Google based outside the European Economic Area (EEA). Contact, Financial and Transaction Data from providers of technical, payment and delivery services based inside the European Economic Area (EEA).
   • Identity and Contact Data from data brokers or aggregators based inside the European Economic Area (EEA).
   • Identity and Contact Data from publicly available sources such as Companies House and the Electoral Register based inside the European Economic Area (EEA).

5.0 Who will Prime Plc share your Personal Data with?

1. To achieve the above stated purposes for which we process your personal data, we may have to share your personal data with certain third parties.
2. We shall make all reasonable efforts to ensure that any third-party we share your personal data with is also compliant with data protection law.

6.0 Where will Prime Plc store your Personal Data?

1. We will not transfer your personal data to any country outside the European Economic Area (EEA) other than those that have been granted an adequacy decision under the General Data Protection Regulation (GDPR).
2. We may be required to transfer your personal data to organisations who intend to transfer the data outside the EEA. Where such transfers of data take place, we shall ensure that contracts are in place between the parties involved that ensure the recipient organisation has a suitable standard of data protection in place.

7.0 How long will Prime Plc keep your Personal Data?

1. We will keep your personal data only for as long as required to achieve the purposes for which it was collected, in line with this privacy notice.
2. The following criteria are what determine the period for which we will keep your personal data:
   • Until we are no longer required to do so to comply with regulatory requirements or financial obligations.
   • Until we are no longer required to do so by any law we are subject to.
   • Until all purposes for which the data was originally gathered have become irrelevant or obsolete.
   • Until it has been requested that we no longer process the data and that it is erased; in some cases, where there is a remaining relevant or legal reason why we are required to keep this data, we may opt to restrict the amount of processing being conducted to what is absolute necessary rather than erase it.

8.0 Your Rights, Our Responsibility

1. There are several rights granted to you immediately upon providing us with your personal information; some of these are mentioned above. We’d like you to know that at Prime Plc we take your rights seriously and will always conduct ourselves in a way that is considerate of our responsibility to serve your legal rights.

The Right of Access

1. This grants you the right to confirm whether or not your personal data is being processed, and to be provided with relevant details of what those processing operations are and what personal data of yours is being processed.
2. If you would like access to the personal data we have about you, we ask that you contact us using the details below.

The Right to Rectification

1. This one is fairly straight forward; if you notice that the data we have about you is inaccurate or incomplete, you may request we rectify the mistake. We will make every effort to respond to requests of this type immediately.

The Right to Erasure

1. Otherwise known as the ‘right to be forgotten’, this gives you the right to request your personal data be deleted.
2. This is not an absolute right; if you were to request that we erase your personal data, we would erase as much of that data as we could but may have to retain some information if it is necessary.
3. Were we have received a request for personal data to be erased, if it is necessary for us to retain some of that information we shall ensure that the remaining data is used only when and where it is absolutely necessary.

The Right to Objection

1. The right to object is a basic freedom all democracies enjoy. If you wish to object to the way we use, or have used, your personal data you may do so freely.

The Right to Complain

1. We will always try to maintain the highest standards and encourage the confidence our customers have in us as an organisation. To achieve this, we request that any complaints be first brought to our attention so we can properly investigate matters. If you would like to complain about Prime Plc to a regulatory body, you may do so by contacting your local data protection supervisory authority.

CHANGES TO THE PRIVACY POLICY AND YOUR DUTY TO INFORM US OF CHANGES

This version was last updated on 5th August 2022 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 your relationship with us.

9.0 Prime Plc Contact Details

Prime Plc
5 The Triangle, Wildwood Drive, Worcester, WR5 2QX
01905 362120
enquiries@primeplc.com

10.0 Who is the Prime Plc Data Protection Officer?

Ametros Group Ltd
Lakeside Offices, Thorn Business Park
Rotherwas Industrial Estate
Hereford
Herefordshire
England
HR2 6JT

0330 223 2246
dpo@ametrosgroup.com
www.ametrosgroup.com