Goodfellow Privacy Notice
YOUR PRIVACY IS IMPORTANT TO GOODFELLOW
Notice last updated: 22nd November 2021
This Privacy Notice ("Notice") is adopted by Metals & Materials Limited and all subsidiary companies and other entities which directly or indirectly are controlled by Metals & Materials Limited (each, an Affiliate), with Metals & Materials Limited and its Affiliates being collectively referred to as “Goodfellow”, "we", "us".
Important things to note:
- You can contact us using the information in the “contact us” section of the website: http://www.goodfellow.com/contact-us/ .
- A full list of Goodfellow entities who may process your information is also available there.
- We may send you information about our products and services. To learn more about when and how we do this and how you can change your contact or marketing preferences at any time, click here.
- We may share your personal information with other third parties. To learn more about who we share your information with and how we ensure your personal information is protected, click here.
- Some of your personal information will be transferred outside your country of residence. To learn more about where we transfer your personal information to and the measures we have in place to adequately secure your personal information, click here.
- You might find external links to third party websites, including social media websites, on our Site. We have no control over these websites. To learn more about the precautions you should take, click here.
Unless stated otherwise, Metals & Materials Limited is the data controller in respect of all personal data collected by us on this website or otherwise. This means that we are responsible for ensuring that we do so in full compliance with the General Data Protection Regulation, all other related privacy laws and any codes of practice issued by the Information Commissioner’s Office or any other data protection supervisory authority where we are active.
Goodfellow understands your concerns about the privacy of data you may provide us, or which we obtain through your use of the Goodfellow Website (“Site”) or the services we provide to our prospective customers and customers ("Services").
This Notice provides you with information about:
- Who we collect information from and the information we collect
- How we use the information we collect
- Who we disclose your information to
- International transfers
- How we protect and store your information
- Retention of your personal information
- How this notice applies to links and third-party websites
- Your rights and how to opt out or request changes to your personal information
- How you can contact us
WHO WE COLLECT INFORMATION FROM AND THE INFORMATION WE COLLECT
Who we collect information from
Goodfellow collects information from the following data subjects:
- Site users;
- individual prospective customers & customers;
- representatives of corporate prospective customers & customers;
- Goodfellow suppliers and business partners and their personnel;
- job applicants, collectively referred to as "you" in this Notice.
The Site is not intended for or directed at children under the age of 16 and we will never knowingly collect Personal Information from individuals under this age.
We collect Personal and Aggregate Information
We collect two types of information from you: “Personal Information” (anything which identifies you as an individual, either on its own or by reference to other information) and “Aggregate Information” (non-personally identifiable and anonymous data).
On our Site, Personal Information (such as your name, address, telephone number, or email address) is collected when you voluntarily submit it through a Site form, such as during a request for product information. Other information that may also constitute Personal Information (such as your browser type, operating system, IP address, domain name, number of times you visited the Site, dates you visited the Site, and the amount of time you spent viewing the Site) may be collected via cookies and other tracking technologies. Aggregate Information (such as how many times visitors log onto this Site) may also be collected.
Outside of this Site, Personal Information may also be collected directly by us or by our representatives when you enter into a contract with us, apply for a job with us, provide us with goods or services, contact us to make enquiries or complaints via telephone, email or by post or otherwise interact with us in the course of our business operations. We or a Goodfellow representative may collect your business contact details and information about your profession, as well as information about you if you attend meetings, events or conferences that we organise or are present at, or if you sign up to our newsletters.
We will indicate to you where the provision of certain Personal Information is required in order for us to provide you or the organisation you represent with our services or certain features of the Site. If you choose not to provide such Personal Information, we may not be able to provide you with our services or access to certain aspects of the Site.
Source of your Personal Information
We will collect most of the Personal Information referred to above from you directly. However, there may be circumstances where we collect Personal Information about you indirectly from the following third parties:
- Your employer, colleagues or business partners;
- Our professional advisors;
- Recruiters, referees and governmental agencies (if you apply for a job with us);
- Publicly available sources, such as Companies House and social media networks (such as LinkedIn); and
- Analytics providers.
HOW WE USE THE INFORMATION WE COLLECT
The purposes for which we use your Personal Information
As a data controller, we will only use your Personal Information if we have a legal basis for doing so. The table at Annex 1 sets out how we use the Personal Information we collect about you and the legal basis which we rely on to process the Personal Information.
More generally, we process Personal Information:
- to answer your specific inquiry or respond to your complaints. For example, if you contact us with a technical question, we will use your contact information and technical information to resolve the issue;
- to administer and enhance the Site;
- for our general business purposes, such as the administration of your customer account, to invite you to events, to interact with you in the course of our business relationship, deal with your queries or for marketing or sales purposes;
- in connection with a proposed or actual sale, merger or transfer of all or a portion of a business or division;
- to process job applications;
- to satisfy legal or regulatory requirements;
- as otherwise described in this Notice; and
- at your option, to send you additional marketing materials relating to Goodfellow.
We would like to use your Personal Information to provide you with information about products and services which we think may be of interest to you or your employer. We will only send you such materials by email and/or contact you by telephone if you have given us your prior express consent to receive such communications (“opt in”).
If you no longer wish to receive marketing communications from Goodfellow, you can opt out at any time by clicking the opt-out link included in electronic communications, or by contacting us by email at: firstname.lastname@example.org.
COOKIES & OTHER TRACKING TECHNOLOGIES
WHO WE DISCLOSE YOUR INFORMATION TO
We work with third parties to help manage our business, deliver services and as otherwise required to achieve the purposes set out in Annex 1. We and our service providers (as defined below) disclose and share your Personal Information:
- among Goodfellow and our Affiliates;
- to third party service providers (“Service Providers”) that perform services for us or on our behalf (including those which may process job applicant information, provide courier services, help manage our IT and back office systems, or distribute marketing materials). Such Service Providers are required under their contract with us, to handle your Personal Information in accordance with applicable laws and principles related to privacy and data protection;
- for credit card payments we employ a third party to process these payments on our behalf. This third party will only have access to the Personal Information which you provide directly to them when you make a credit card payment. They are required under their contract with us to process this Personal Information securely and in accordance with all relevant Data Protection laws. We will not collect or store any credit card details; this third party being the sole data controller of that data. When you pay for any goods, you will be taken to a link to this third party’s website in order to conclude the sale;
- to a third party in connection with a proposed or actual sale, merger, or transfer of all or a portion of a business or division; and
- to other persons (such as law enforcement or regulators) where we are under a legal obligation to disclose your Personal Information, and only as permitted or required by applicable law or regulation. Such disclosure could be made to courts, to respond to lawful requests by public authorities, regulators and law enforcement agencies in the United Kingdom, European Union and around the world or to protect and defend our rights or property.
Any access to such information will be limited to the purpose for which such information was provided to us or our Service Providers, as explained in the "How we use the information we collect" section above.
Goodfellow’s Affiliates and Service Providers are located throughout the world. Accordingly, your Personal Information may be sent to countries which have different levels of data protection laws than your country of residence. For instance, if you inquire about services we provide in the USA and in China, we will forward your inquiry to our office in such countries. We may also make other disclosures of your Personal Information overseas, for example if we receive a legal or regulatory request from a foreign law enforcement body. Goodfellow complies with all applicable laws before transferring Personal Data to a recipient in a country with data protection laws that do not have a data protection standard equivalent to the laws where you live.
We will always take steps to ensure that any international transfer of information is carefully managed to protect your rights and interests:
- we will only transfer your Personal Information to countries which are recognised as providing an adequate level of legal protection or where we can be satisfied that alternative safeguards are in place to protect your privacy rights,
- transfers between Goodfellow and its Affiliates will be covered by intra-group data transfer agreements (based on EU Commission approved standard contractual clauses) which gives specific contractual protections designed to ensure that your Personal Information receives an adequate and consistent level of protection wherever it is transferred within Goodfellow;
- transfers to Service Providers and other third parties will always be protected by way of the standard contractual clauses (save where a derogation under applicable law applies).
We will, on request, provide you with further details regarding the categories of recipient of your Personal Information and the countries to which your Personal Information may be transferred. You have the right to ask us for more information about the safeguards we have put in place as mentioned above. Contact us as set out in “Contact Us” section if you would like further information.
HOW WE PROTECT AND STORE YOUR INFORMATION
We take the security of the information we collect seriously. We have implemented and we maintain technical and organisational security measures, policies and procedures intended to reduce the risk of accidental destruction or loss, or the unauthorized disclosure or access to such information appropriate to the nature of the data concerned. Some of the steps we take are: placing confidentiality requirements on our staff members and Service Providers; destroying or permanently anonymising Personal Information if it is no longer needed for the purposes for which it was collected.
Personal Information collected via this Site is stored on servers in the UK. You should be aware that your Personal Information once collected may be transferred to our servers in the USA, and the USA currently does not have uniform data protection laws. See the “International Transfers” section above for more detail about how we will protect such Personal Information.
RETENTION OF YOUR PERSONAL INFORMATION
We will retain your Personal Information for as long as is reasonably necessary for the purposes for which it was collected, as explained in this Notice. Customer data will be retained for a period of 7 years from the date of last transaction with us, after which it will be deleted, anonymised or pseudonymised if required. In some circumstances we may retain your Personal Information for longer periods of time, for instance where we are required to do so in accordance with legal, regulatory, tax or accounting requirements.
In specific circumstances we may retain your Personal Information for longer periods of time so that we have an accurate record of your dealings with us in the event of any complaints or challenges, or if we reasonably believe there is a prospect of litigation relating to your Personal Information or dealings.
Where we have obtained your Personal Information in order to provide you with marketing information for our products and services, your Personal Information will be stored by us only as long as you do not change your mind to receive such materials from Goodfellow, in order to avoid future contact with you for marketing purposes. We maintain a data retention notice which we apply to records in our care. Where your Personal Information is no longer required we will ensure it is securely deleted.
LINKS AND THIRD-PARTY WEB SITES
Applicability of this Notice
YOUR RIGHTS AND HOW TO OPT OUT OR REQUEST CHANGES
Subject to certain exemptions, and in some cases dependent upon the processing activity we are undertaking, you have certain rights in relation to your Personal Information:
- To access Personal Information: You have the right to obtain access to the Personal Information we hold about you.
- To rectify Personal Information: You have the right to obtain rectification of any inaccurate or incomplete Personal Information we hold about you without undue delay.
- To erase Personal Information: You have the right, in some circumstances, to require us to erase your Personal Information without undue delay if the continued processing of that Personal Information is not justified.
- To withdraw your consent: You have the right to withdraw your consent at any time to any processing carried out on the basis of your consent.
- To restrict the processing of your Personal Information: You have the right, in some circumstances, to require us to limit the purposes for which we process your Personal Information if the continued processing of the Personal Information in this way is not justified, such as where the accuracy of the Personal Information is contested by you.
- To transfer your Personal Information: You have the right, in certain circumstances, to receive a copy of the Personal Information you have provided to us in a structured, commonly used, machine-readable format that supports re-use, or to request the transfer of your Personal Information to another person.
- To object to the processing of Personal Information: You have a right to object to any processing based on our legitimate interests in certain circumstances.
- Right to object to how we use your Personal Information for direct marketing purposes: You can object to us processing your Personal Information for direct marketing purposes at any time by following the instructions in the “Direct Marketing” section above.
We may ask you for additional information to confirm your identity and for security purposes, before disclosing the Personal Information requested to you. We reserve the right to charge a fee where permitted by law, for instance if your request is manifestly unfounded or excessive.
You can exercise your rights by contacting us at: email@example.com. Subject to legal and other permissible considerations, we will make every reasonable effort to honour your request promptly or inform you if we require further information in order to fulfil your request.
We may not always be able to fully address your request, for example if it would impact the duty of confidentiality we owe to others, or if we are legally entitled to deal with the request in a different way.
Right to lodge a complaint with your local supervisory authority
For individuals based in the UK or EEA, you have a right to lodge a complaint with your local supervisory authority about our processing of your personal data. In the UK, this is the Information Commissioner’s Office (https://ico.org.uk/). If you are in the EEA, you can find your local supervisory authority here.
We ask that you please attempt to resolve any issues with us first, although you have a right to contact your supervisory authority at any time.
NOTIFICATION OF CHANGES
Privacy laws and practice are constantly developing and we aim to meet high standards. Our policies and procedures are, therefore, under continual review. We may, from time to time, update our security and privacy policies. If we want to make any significant changes in how we will use your personal data we will contact you directly and, if required, seek your consent.
Notwithstanding the above, we recommend that you check this Notice every time you visit our Site or provide us with your Personal Information offline as we may update this Notice from time to time, by posting the amended Notice on this Site. Any changes will be effective when posted and your continued use of the Site or not objecting to the use of your Personal Information will indicate your acknowledgement of any changes.
If you have any questions, concerns or complaints regarding our compliance with this Notice and the data protection laws or if you wish to exercise your rights, please contact us at: firstname.lastname@example.org.
For any complaints that cannot be resolved with us directly, Goodfellow has chosen to cooperate with EU data protection authorities (DPAs) and the Swiss Federal Data Protection & Information Commissioner (FDPIC) and comply with their advice with regard to data transferred from the EU and Switzerland. Please contact the relevant DPA contacts.
Questions regarding this Notice
If you have questions concerning this Notice, please contact our Global Compliance Manager at +44 1480 424800 or via email at: email@example.com or by writing to the Global Compliance Manager, Goodfellow Cambridge Limited, Unit C1-C3 Ermine Business Park, Huntingdon PE29 6WR, United Kingdom.