- Touch Systems Limited (“Touch Systems”, “us”, “we”, “our”), with its registered office at 7 The Pavilions, Cranmore Drive, Solihull, B90 4SB (company number 02430509) respects your privacy and is committed to protecting your Personal Data.
- Touch Systems is “Data Controller” in relation to the Personal Data that it collects through this Site. This means that we decide how and why your Personal Data is used and have a duty to ensure that your rights are protected.
- It is important that you read this Policy carefully together with any other privacy notices/policies or fair processing notices/policies we may provide on specific occasions when we are collecting or processing Personal Data about you so that you are fully aware of how and why we are using your data. This Policy supplements the other notices and is not intended to override them.
- Please use the Glossary which can be found at the end of this Policy to understand the meaning of some of the terms used in this Policy.
Changes to the Policy and your duty to inform us of changes
This Policy was last updated on 6 July 2018. Any changes to this Policy in the future will be posted here. However, we will not make any material changes to the way we process your Personal Data without where appropriate notifying you by email. You should review this Policy from time to time for any updates or changes.
It is important that the Personal Data we hold about you is accurate and current. Please keep us informed if your Personal Data changes.
This Site may include 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/policies. When you leave our Site, we encourage you to read the privacy notice/policy of every website you visit.
Information we collect from you
We may collect, use, store and transfer different kinds of Personal Data about you, which we have grouped together as follows:
- Identity Data which includes: first name, last name and job title
- Contact Data which includes: telephone number, e-mail address, place of work and work address.
- Technical Data includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, and other technology on the devices you use to access this website.
- Usage Data includes information about how you use our website, products and services.
- Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.
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.
How do we collect your Personal Data?
We collect information from you by you filling in forms on the Site and/or in person, or corresponding with us by phone, e-mail or otherwise. This includes Personal Data you provide when you place an order with us.
We also work closely with third parties (including analytics providers and search information providers) and may receive information about you from them. For more information about this please see the Google Analytics section below.
The purpose for processing your Personal Data?
We will process/use your Personal Data when you visit our Site for the following reasons:
- to ensure that content from the Site is presented in the most effective manner for you and for your computer;
- to provide you with information regarding our services that you request from us and with information about other products and services we offer that are similar to those that you have already enquired about;
- to communicate with you in general (including, for example and without limitation, via email, post or SMS) in order to provide our services, including sending information about changes to the services that we offer;
- to administer the Site and for internal operations, such as troubleshooting, data analysis, testing, research and survey purposes;
- to understand the buying behaviour of our registered users;
- to send newsletters, details of offers and promotions;
- to perform other general marketing and promotional activities focused on our products and services;
- to carry out our obligations arising out of any contracts entered into with you;
- to send updates regarding the status of your enquiry or order;
- as part of our efforts to keep our Site safe and secure;
- if you are a registered user, for customer service purposes to enable us to deal with any support requests that you may contact us about in relation to your use of our software;
- we may also use your personal information to recognise you when you return to the Site please view the section on cookies in this Policy for more information.
Legal basis for processing your Personal Data
We will only process your Personal Data when the law allows us to. The legal basis for processing your Personal Data for the above reasons will typically be one of the following:
- When we have your consent;
- Where we need to perform the contract we are to enter into or have entered into with you;
- 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; or
- Where we need to comply with a legal or regulatory obligation.
Who do we share your Personal Data with and why?
We may have to share your Personal Data with the following:
- those persons within our business on a ‘need to know’ basis for legal, business or administrative purposes;
- service providers who help us run the Site and our services, solely for the purposes of running the Site or administering our business;
- subject to your consent, to third parties who may offer products or services that may interest you and others;
- analytics and search engine providers that assist us in the improvement and optimisation of our Site;
- authorities and official bodies, where we are under a legal or regulatory obligation;
- our professional advisers for the purposes of seeking legal or other professional advice;
- 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 of ownership happens to our business, then the new owners may use your Personal Data in the same way as set out in this Policy.
We will only disclose your information to third parties with your consent or where we need to do so for the following reasons: either as required by law; or to provide you with a service you have requested; or to improve the service we provide to you.
- Transfer and Storage of Your Personal Data
- We currently do not transfer or store your Personal Data outside the European Economic Area (EEA). If this changes and we do need to store and/or transfer your Personal Data outside the EEA this Policy will be updated.
- We have put in place appropriate administrative, technical and physical 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. They will only process your Personal Data on our instructions and they are subject to a duty of confidentiality.
- We have put in place procedures to deal with any suspected Personal Data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.
- Of course, we cannot absolutely guarantee the security of the internet or external networks and any online communications (e.g. information provided by email or through our Site are at your own risk).
We will only retain your Personal Data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal requirements. This means that Personal Data is destroyed or erased from our systems when no longer required.
Your Legal Rights
Under certain circumstances, you have rights under data protection laws in relation to your Personal Data, such as:
- 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 your 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 the 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 your Personal Data. This enables you to ask us to suspend the processing of your Personal Data in the following scenarios: (a) if you want us to establish the data's accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) 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 (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
- Requests 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.
- Right to 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.
If you wish to find out more about the above rights or to exercise any of the above rights, please contact us by sending an e-mail to firstname.lastname@example.org. We will try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. If this case, we will notify you and keep you updated.
Please keep in mind there are exceptions to the rights set out above, though we will always try to respond to your satisfaction, there may be situations where we are unable to do.
Marketing and Communications
From time to time, we may wish to send you details regarding software updates, support information and other information which may be of interest to you. You can opt-in to receiving this information by contacting us using the contact details on the “Contact Us” section of our website or by ticking the relevant boxes when you complete any form to submit your details to us.
If you decide that you wish to stop hearing from us, or would like to change how we contact you, you can do by e-mailing email@example.com or by clicking on the unsubscribe link from the bottom of any e-mail sent to you by us.
A cookie is a small file of letters and numbers that we store on your browser or device if you agree. Pixel tags and web beacons are tiny graphic images placed on our Site pages or in our emails that allow us to determine whether you have performed specific actions. When you access these pages or open email messages, the pixel tags and web beacons generate a notice of that action to us or our service providers. These tools allow us to measure response to our communications and improve our web pages.
We use the following types of cookies:
- Strictly necessary cookies. These are cookies that are required for the operation of our Site and in order to enable you to move around the Site and use its features.
- Performance cookies. These cookies allow us to recognise and count the number of visitors and to see how visitors move around our Site. These cookies also tell us if you receive any error messages whilst on our Site. This helps us to improve the way our Site works, for example, by ensuring that users are finding what they are looking for easily. These cookies do not collect information that identifies a visitor. All information these cookies collect is aggregated and therefore anonymous.
- Functionality cookies. These cookies allow our Site to remember choices you make (such as your name).
Our Site uses Google Analytics to help monitor who is visiting our Site, to help us ensure our Site performs as well as possible for users and to ensure users get the best possible experience. Google Analytics may also be used to help us target advertising to you, you may see us in search results on Google; or on banner adverts on Gmail; or on other services run by Google.
Social Media Plug-Ins
We have various social media plug-ins on our Site these include Google+, Instagram, Twitter and Facebook. We use these plug-ins in order to make it easier for you to follow our content via your social media pages and/or to access our social media pages. These buttons are third-party cookies which are placed onto your device when you visit our Site. Even without you clicking on the relevant plug-in, these sites are aware that you have visited our Site, and may use this information when building their profile of you, and deciding what advertisements you might like to see. You should check the respective policies of each of these social media networks to see how exactly they use your personal information.
If you have any queries or questions about this Policy, including any requests to exercise your legal rights, please contact us at firstname.lastname@example.org.
You have the right to make a complaint at any time to the Information Commissioner's Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.
Legitimate Interest: means the interest of our business in conducting and managing our business to enable us to give you the best service/product and the best and most secure experience. 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).
Perform/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.
Comply with a legal or regulatory obligation: means processing your Personal Data where it is necessary for compliance with a legal or regulatory obligation that we are subject to.
Processing: Doing anything with Personal Data; this includes collecting it, storing it, accessing it, combining it with other data, sharing it with a third party, or even deleting it.
Personal Data: means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).
EEA: The EEA currently includes all European Union member states and Iceland, Liechtenstein and Norway.