This privacy notice will inform you how ETB Technologies Limited use, and protect your personal data and tell you about your rights and how the law protects you.
We may change this notice at any time but will notify you of any significant changes to it before they take effect.
What this policy covers
1. Who is collecting the data?
2. What data is being collected?
3. What is the legal basis for processing the data?
4. Will the data be shared with any third parties?
5. How will the information be used?
6. How long will the data be stored for?
7. What rights does the data subject have?
8. How can the data subject raise a complaint?
1. Who is collecting the data? (who we are)
This Privacy Statement Regarding Customer and Online User Information applies to ETB Technologies Limited and governs the personal Information we collect from our customers and from our website and other online visitors (“you” or “your”), as well as information we automatically collect from your online visits (e.g. data collected via cookies).
2. What data is being collected (what we collect)
We may collect the following information:
- Contact information including email address
- Demographic information such as postcode, preferences and interests
- Other information relevant to customer surveys and/or offers
- IP addresses, cookie identifiers and other tracking technologies such as pixels, and end-user website activity, specifically relating to AdRoll & StackAdapt advertising platforms.
For the exhaustive list of cookies we collect see the List of cookies we collect section.
3. What is the legal basis for processing the data (our reason for collecting your data)
Our legal basis for collecting and using your Personal Information as described in this Policy will depend on the Personal Information concerned and the specific context in which we collect it. In general, we collect and process your Personal Information on one or more of the following bases:
To comply with a contractual obligation (for example, using your shipment details to make delivery where you have bought a product from us or using your personal details where you have asked us to do something before making a purchase, such as providing you with a quote). We will advise you upon collection whether the provision of your personal information is mandatory and of the possible consequences if you do not provide us with your information.
For compliance with ETB Technologies Limited legal obligations, where other laws require the processing of your personal information (for example, health and safety, taxation and anti-money laundering laws) or where we need your personal information to protect your vital interests or those of another person.
ETB Technologies Limited (and its Business Partners’) legitimate interests which include the provision of our website and/or relevant products and services, and/or the carrying out of marketing and profiling activities, provided always that our legitimate interests are not outweighed by any prejudice or harm your rights and freedoms.
List of cookies we collect
The table below lists the cookies we collect and what information they store.
|COOKIE name||COOKIE Description|
|CART||The association with your shopping cart.|
|CATEGORY_INFO||Stores the category info on the page, that allows to display pages more quickly.|
|COMPARE||The items that you have in the Compare Products list.|
|CURRENCY||Your preferred currency|
|CUSTOMER||An encrypted version of your customer id with the store.|
|CUSTOMER_AUTH||An indicator if you are currently logged into the store.|
|CUSTOMER_INFO||An encrypted version of the customer group you belong to.|
|CUSTOMER_SEGMENT_IDS||Stores the Customer Segment ID|
|EXTERNAL_NO_CACHE||A flag, which indicates whether caching is disabled or not.|
|FRONTEND||You session ID on the server.|
|GUEST-VIEW||Allows guests to edit their orders.|
|LAST_CATEGORY||The last category you visited.|
|LAST_PRODUCT||The most recent product you have viewed.|
|NEWMESSAGE||Indicates whether a new message has been received.|
|NO_CACHE||Indicates whether it is allowed to use cache.|
|PERSISTENT_SHOPPING_CART||A link to information about your cart and viewing history if you have asked the site.|
|POLL||The ID of any polls you have recently voted in.|
|POLLN||Information on what polls you have voted on.|
|RECENTLYCOMPARED||The items that you have recently compared.|
|STF||Information on products you have emailed to friends.|
|STORE||The store view or language you have selected.|
|VIEWED_PRODUCT_IDS||The products that you have recently viewed.|
|WISHLIST||An encrypted list of products added to your Wishlist.|
|WISHLIST_CNT||The number of items in your Wishlist.|
|__adroll, __adroll_v4, __adroll_fpc||Enables us to identify your device when you move between different Digital Properties, so that we can serve targeted advertising to you.|
|StackAdapt Pixel||Enables us to identify your device, so that we can serve targeted advertising to you.|
4. Will the data be shared with any third parties? (who we share your data with)
We do not share or disclose any of your personal information without your consent, other than for the purposes specified in this notice or where there is a legal requirement.
ETB Technologies Limited use third parties to provide selected services and business functions; however, all processors acting on our behalf only process your data in accordance with instructions from us and comply fully with this privacy notice, the data protection laws and any other appropriate confidentiality and security measures. We will only share your personal data as follows and, when applicable, only with the appropriate contractual obligations in place:
Sharing with service providers and partners:
We engage service providers or partners to manage or support certain aspects of our business operations on our behalf. These service providers or partners may provide services such as credit card processing and fraud management services, human resources consultancy, product delivery, advertising and marketing activities (including digital and personalised advertising), IT services, debt collection and management or support of ETB Technologies Limited website. Our service providers and partners are required by contract to safeguard any personal data they receive from us and are prohibited from using the personal data for any purpose other than to perform the services as instructed by ETB Technologies Limited. We also take steps to provide adequate protection for any transfers of your personal data in accordance with applicable law such as signing EU Standard Contractual Clauses with the service provider or partner, relying on their Privacy Shield certification, other approved codes of conduct or certification mechanisms or binding and enforceable commitments of the service provider.
Sharing with third parties:
Circumstances may arise where, whether for strategic or other business reasons, ETB Technologies Limited decides to sell, buy, merge or otherwise reorganise businesses. In such transactions, we may disclose or transfer your personal data to prospective or actual purchasers or receive personal data from sellers. Our practice is to seek appropriate protection for your personal data in these types of transactions.
Compliance with Law
We may also share your personal data when we believe, in good faith, that we have an obligation to: (i) respond to duly authorised information requests of law enforcement agencies, regulators, courts and other public authorities, including to meet national security or other law enforcement requirements; (ii) comply with any law, regulation, subpoena, or court order; (iii) investigate and help prevent security threats, fraud or other criminal or malicious activity; (iv) enforce/protect the rights and properties of ETB Technologies Limited or its subsidiaries; or (v) protect the rights or personal safety of ETB Technologies Limited, our employees, and third parties on or using ETB Technologies Limited property when allowed and in line with the requirements of applicable law.
We do not share or disclose any of your personal information without your consent, other than for the purposes specified in this notice or where there is a legal requirement. ETB Technologies Limited use third-party/third-parties to provide contracted services and business functions; however, all processors acting on our behalf only process your data in accordance with instructions from us and comply fully with this privacy notice, the data protection laws and any other appropriate confidentiality and security measures.
5. How will the information be used? (how we use your data)
ETB Technologies Limited take your privacy very seriously and will never disclose, share or sell your data without your consent; unless required to do so by law. We only retain your data for as long as is necessary and for the purpose(s) specified in this notice. Where you have consented to us providing you with promotional offers and marketing, you are free to withdraw this consent at any time.The purposes and reasons for processing your personal data are detailed below:
We collect your personal data in the performance of a contract or to provide a service or product. We use the data in assisting to completing transactions and orders of our products or services, administering your account, processing payments, arranging shipments and deliveries and facilitating repairs and returns.
As part of our legal obligation for business accounting and tax purposes, and business operations.
For compliance with applicable laws, regulations, court orders, government and law enforcement requests, to operate our services and products properly and to protect ourselves, our users and our customers and to solve any customer disputes.
Communicating with you about our products. This could be responding to your enquiries or requests, service completion or warranty-related communications, communications required by law or applicable corporate updates related to mergers, acquisitions or divestitures.
We will occasionally send you marketing information where we have assessed that it is beneficial to you as a customer and in our interests. Such information will be non-intrusive and is processed on the grounds of legitimate interests.
Protect the security or integrity of our websites, our businesses, and our products or services.
Perform other functions or serve other purposes, as disclosed to you at the point of collection, or as required or permitted by law.
If you have any questions or need more information concerning the legal basis on which we collect your Personal Information, please contact us at [email protected].
6. How We Secure Your Personal Information and how long we keep it. (where and for how long)
ETB Technologies Limited take your privacy seriously and takes every reasonable measure and precaution to protect and secure your personal data. ETB Technologies Limited takes all reasonable steps to protect your Personal Information from misuse, interference and loss, as well as unauthorised access, modification or disclosure. The ways we do this include:
Using encryption when collecting or transferring sensitive information, such as credit card details;
Having in place technical and organisational measures designed to ensure the ongoing integrity, availability and resilience of processing systems and services;
Limiting physical access to our premises;
Limiting access to the information we collect about you;
Ensuring that we and our Business Partners have appropriate security safeguards to keep Personal Information secure.
Where required by law, destroying or de-identifying Personal Information.
We encourage you to keep any passwords you use confidential and to be careful to avoid “phishing” scams asking for your personal information. ETB Technologies Limited will not request your ID or password through email.
Transfers Outside the EU (if applicable)
ETB Technologies Limited utilise some products or services (or parts of them) that may be hosted/stored in non EU countries which means that we may transfer any information which is submitted by you outside the European Economic Area ("EEA") for the below purposes: - Online Helpdesk Support, Where data may be needed by USA Director’s Offices.
Therefore, when you share your personal data, the personal information you submit may be stored on servers or processed in the USA.
7. Your EU Data Protection Rights (your rights)
You have the right to access any personal information that ETB Technologies Limited processes about you and to request information about:
Access: you have the right to request information about how we process your Personal Information and to obtain a copy of that Personal Information.
Rectification: you have the right to request the rectification of inaccurate Personal Information about you and for any incomplete Personal Information about you to be completed.
Objection: you have the right to object to the processing of your Personal Information, which is based on our legitimate interests (as described above).
Erasure: you have the right to request the erasure of your Personal Information (subject to certain conditions).
Automated decision-making: you have the right not to have a decision made about you that is based solely on automated processing if that decision produces legal or similarly significant effects concerning you.
Restriction: you have the right to ask us to restrict our processing of your Personal Information, so that we no longer process that information until the restriction is lifted.
Portability: you have the right to receive your Personal Information, which you have provided to us, in a structured, commonly used and machine-readable format and to have that information transmitted to another organisation in certain circumstances.
In addition to the above, you have the right to lodge a complaint with a supervisory authority if you consider that our processing of your Personal Information infringes applicable data protection law.
If you have any questions about the type of Personal Information we hold about you or if you wish to request deletion or correction of Personal Information we hold about you, or exercise any other data subject right, please send a written request to [email protected] or to the postal address provided at the bottom of this Privacy Statement. While we will make reasonable efforts to accommodate your request, we reserve the right to reject such access requests or to impose restrictions or requirements upon such requests if required or permitted by applicable law.
If we receive a request from you to exercise any of the above rights, we may ask you to verify your identity before acting on the request; this is to ensure that your data is protected and kept secure.
Occasionally, ETB Technologies Limited would like to contact you with the updates on our services and products that we provide. If you consent to us using your contact details for this purpose, you have the right to modify or withdraw your consent at any time by using the opt-out/unsubscribe options or by contacting ETB Technologies Limited directly on [email protected].
8. How to opt-out of targeted advertising
We recognise and appreciate how important your online privacy is to you, so we offer the following options for controlling the targeted ads (sometimes called “interest-based ads”) you receive and how we use your data.
Opting-out of this type of advertising through the below methods will not prevent you from seeing ads, but those ads will be less relevant because they will not be tailored to your specific interests. The ads might, for instance, be randomly generated or based on the web page you are visiting.
- Web browser: You can opt-out of receiving personalised adverts (including retargeted ads) served by us or on our behalf by clicking on the blue icon that typically appears in the corner of the ads we serve and following the instructions provided or by clicking here. Please note that this “opt-out” function is browser-specific and relies on an “opt-out cookie”, thus, if you delete your cookies or upgrade your browser after having opted out, you will need to opt-out again. If you use a Safari browser, please also see directions regarding our cookie-less technology opt-out, below.
- Cross Device Opt-Out: In some cases, we may link multiple browsers or devices to you. If you opt-out on a browser or device and we have additional devices or browsers linked to you, we will extend your opt-out decision to any other linked browsers and devices. Since we only link users across browsers and devices in some conditions, there could be cases where you are still being tracked in a different browser or device we have not linked, and where we are treating you as a different user.
- Mobile Device Opt-Out: To opt-out of receiving targeted ads that are based on your behaviour across different mobile applications follow the below instructions, for iOS and Android devices: for iOS 7 or Higher: Go to your Settings > Select Privacy > Select Advertising > Enable the “Limit Ad Tracking” setting; and for Android devices with OS 2.2 or higher and Google Play Services version 4.0 or higher: Open your Google Settings app > Select Ads > Enable “Opt-out of interest-based advertising”.
- Note to Safari Users. When you opt-out on a browser, we, other advertising platforms, and other third parties, generally place a cookie on your browser instructing us not to use your other online behaviours to customize the ads you see. However, if you are using a Safari browser, opt-out cookies that are set for purposes of restricting this type of advertising may be deleted prior to their intended expiration date; we have no control over these browser controls or cookie deletions.
- Do Not Track Disclosure: Some internet browsers allow users to send a "Do Not Track" signal to websites they visit. We do not respond to this signal at the present time.
9. How can the data subject raise a complaint
ETB Technologies Limited only processes your personal information in compliance with this privacy notice and in accordance with the relevant data protection laws. If, however, you wish to raise a complaint regarding the processing of your personal data or are unsatisfied with how we have handled your information, you have the right to lodge a complaint with the supervisory authority.
ETB Technologies Limited
Edingham Industrial Estate Dalbeattie DG5 4NA
ICO – Information Commissioner’s Office
Head office: Wycliffe House Water Lane Wilmslow Cheshire SK9 5AF.
Tel: 0303 123 11
ETB Technologies Limited - Job Applicant Privacy Notice
As part of any recruitment process, ETB Technologies Limited collects and processes personal data relating to job applicants. The organisation is committed to being transparent about how it collects and uses that data and to meeting its data protection obligations.
What information does ETB Technologies Limited collect?
ETB Technologies Limited collects a range of information about you. This includes:
- your name, address and contact details, including email address and telephone number;
- details of your qualifications, skills, experience and employment history;
- information about your current level of remuneration, including benefit entitlements;
- whether or not you have a disability for which the organisation needs to make reasonable adjustments during the recruitment process;
- information about your entitlement to work in the UK; and
- equal opportunities monitoring information, including information about your ethnic origin, sexual orientation, health and religion or belief.
ETB Technologies Limited may collect this information in a variety of ways. For example, data might be contained in application forms, CVs or resumes, obtained from your passport or other identity documents, or collected through interviews or other forms of assessment.
ETB Technologies Limited may also collect personal data about you from third parties, such as references supplied by former employers, information from employment background check providers and information from criminal records checks. ETB Technologies Limited will seek information from third parties only once a job offer to you has been made and will inform you that it is doing so.
Data will be stored in a range of different places, including on your application record, in HR management systems and on other IT systems (including email).
Why does ETB Technologies Limited process personal data?
ETB Technologies Limited needs to process data to take steps at your request prior to entering into a contract with you. It may also need to process your data to enter into a contract with you.
In some cases, ETB Technologies Limited needs to process data to ensure that it is complying with its legal obligations. For example, it is required to check a successful applicant's eligibility to work in the UK before employment starts.
ETB Technologies Limited has a legitimate interest in processing personal data during the recruitment process and for keeping records of the process. Processing data from job applicants allows us to manage the recruitment process, assess and confirm a candidate's suitability for employment and decide to whom to offer a job. We may also need to process data from job applicants to respond to and defend against legal claims.
ETB Technologies Limited may process information about whether or not applicants are disabled to make reasonable adjustments for candidates who have a disability. This is to carry out its obligations and exercise specific rights in relation to employment.
Where ETB Technologies Limited processes other special categories of data, such as information about ethnic origin, sexual orientation, health or religion or belief, this is for equal opportunities monitoring purposes.
For some roles we are obliged to seek information about criminal convictions and offences. Where the organisation seeks this information, it does so because it is necessary for it to carry out its obligations and exercise specific rights in relation to employment.
We will not use your data for any purpose other than the recruitment exercise for which you have applied.
Who has access to data?
Your information may be shared internally for the purposes of the recruitment exercise. This includes members of the HR and recruitment team, interviewers involved in the recruitment process, managers in the business area with a vacancy and IT staff if access to the data is necessary for the performance of their roles.
ETB Technologies Limited will not share your data with third parties, unless your application for employment is successful and it makes you an offer of employment. We may then share your data with former employers to obtain references for you, employment background check providers to obtain necessary background checks and the Disclosure Scotland Service to obtain necessary criminal records checks.
ETB Technologies Limited will not transfer your data outside the European Economic Area.
How does ETB Technologies Limited protect data?
ETB Technologies Limited takes the security of your data seriously. It has internal policies and controls in place to ensure that your data is not lost, accidentally destroyed, misused or disclosed, and is not accessed except by our employees in the proper performance of their duties.
For how long does ETB Technologies Limited keep data?
If your application for employment is unsuccessful, ETB Technologies Limited will hold your data on file for 6 months after the end of the relevant recruitment process. After this period your data will be deleted or destroyed.
If your application for employment is successful, personal data gathered during the recruitment process will be transferred to your personnel file and retained during your employment. The periods for which your data will be held will be provided to you in a new privacy notice.
As a data subject, you have a number of rights. You can:
- access and obtain a copy of your data on request;
- require the organisation to change incorrect or incomplete data;
- require the organisation to delete or stop processing your data, for example where the data is no longer necessary for the purposes of processing; and
- object to the processing of your data where the organisation is relying on its legitimate interests as the legal ground for processing.
If you would like to exercise any of these rights, please contact [email protected]
If you believe that ETB Technologies Limited has not complied with your data protection rights, you can complain to the Information Commissioner.
What if you do not provide personal data?
You are under no statutory or contractual obligation to provide data to the organisation during the recruitment process. However, if you do not provide the information, ETB Technologies Limited may not be able to process your application properly or at all.
Recruitment processes are not based solely on automated decision-making.