Who we are
For the purpose of applicable data protection laws, the data controller is UBM (UK) Ltd of 5 Howick Place, London, United Kingdom, SW1P 1WG. Our Group Data Privacy Officer is Yasmeen Rahman.
Information covered by this policy
This policy covers all personal information collected and used by the Barbour ABI group. In this policy "personal information" means information that (either in isolation or in combination with other information held by us) enables you to be identified as an individual or recognised directly or indirectly. This may include your name, title, postal address, email address, computer IP address, phone number, credit card number, login information and technical information from the devices you use to receive our services.
Collection of personal information
We may collect information about you from different sources detailed below.
Information you give us:
When you access and browse our websites (including when you fill in forms on our websites), when you correspond with us by phone or email or other electronic means and when you enter into a contract with us or order our services, you may give us information about yourself.
The information you give us may include your name, postal address, email address, landline and/or mobile telephone number, payment processing information, information about your employment (including your job title, responsibilities and employer’s details) as well as other personal information.
You are not bound by any contractual or statutory obligation to provide personal data to us. However, if you choose to enter into a contract with us then we will need certain information for the purposes of entering into and performing that contract (which may include personal data) and we may not be able to conclude a contract with you without that information.
Information we collect about you:
• technical information, including the Internet protocol (IP) address used to connect your computer to the internet, your login information, browser type and version, time zone setting, browser plug-in types and versions, operating systems and platform; and
• information about your visit, including the full Uniform Resource Locators (URL) clickstreams to, on and from our websites, products you viewed or searched for, page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks and mouse-overs), methods used to browse away from the page and any phone number used to call us.
Information we receive and collect from other sources:
We may receive information about you from other websites operated by the Barbour ABI group or from the other services that we provide. We also work closely with third parties such as payment processors, app providers and suppliers of information and we may receive information about you from them. We may also collect information about you from publicly available sources, including planning applications, Companies House, the Official Journal of the European Union (OJEU) and publicly available content on social media.
Our use of your personal information
|We may use your personal information to:
||How do we use personal information for this purpose?
||What is the legal basis for us processing your information in this way?
|Provide you with services
||We will need to use your personal information where this is necessary for us to perform our obligations under a contract with you, for example where you have purchased services from us.
||Using your personal information in this way is necessary for us to perform our contractual obligations to you.
|Process enquiries you make through our website or by phone
||We will need to use your contact information (such as your email address, postal address and phone number) to contact you in response to a request you make and to otherwise deal with your enquiry.
||Using your personal information in this way is necessary for us to perform our contractual obligations to you or to take steps to enter into a contract with you.
|Process your payments and protect against fraudulent transactions
||We may need to process your personal information in order to keep your payments safe and secure and protect against fraudulent transactions.
||We need to process payments for performance of our contract with you. It is also in our legitimate interests to process personal information to keep our customers' payments secure.
|Contact you to tell you about our special offers or other products and services within our portfolio
||We will need to use your personal information (such as your email address and/or telephone number) to send you information about services that you may be interested in. Please note that we may also share your personal information with other entities in the Barbour ABI group for this purpose.
||It is in our legitimate interest to study how customers use our products and services and to promote, develop and grow our business. In some instances, we will process information for these purposes with your consent.
|Diagnose problems with our server or administer our websites
||We may need to use personal information, such as your IP address, to diagnose server problems or administer our websites.
|Analyse user traffic to measure use of our websites and to improve the content of our websites and our services
||We may sometimes use your personal information (e.g. your IP address) to measure use of our websites and assess the effectiveness of our site pages. We may also use this personal information to improve the content of our websites and services.
||It is in our legitimate interest to look at user traffic so that we can improve our websites and better meet your needs as a user.
|Comply with legal requirements and exercise or defend legal claims
||We may sometimes need to process personal information to comply with legal requirements to which we are subject.
||It is in our legitimate interest to process personal data for the purposes of complying with legal requirements to which we are subject.
|Undertake research, including relating to the nature and extent of building or construction projects or the commercial involvement of those providing (or interested in providing) services for those projects
||We may process personal information as part of such research or to contact you for the purposes of such research.
||It is in our legitimate interest to undertake such research to help us provide services to our customers and to enhance or verify the information we hold. In some instances, we will process information for these purposes with your consent.
|Administer our business and manage our relationship with you
||We may need to process personal information for the purposes of administering our business and managing our relationship with you.
||Processing personal information for these purposes may be necessary for the performance of a contract or to take steps to enter into a contract, or for the purposes of our legitimate interests in administering our business and managing our relationship with you.
|Collect intelligence about your interactions with our website
||We may sometimes use your personal information (e.g. your IP address) to share website behaviour with customers.
||It is in our legitimate interest to look at user traffic and website behaviour to develop intelligence for our customers.
Transfers of personal information
We may share your contact details and information about any building or construction project that you are associated with commercially to customers of ours, which may include building product manufacturers or distributors, contractors, subcontractors or installers, professional service providers or other companies allied to the construction industry.
Specifically regarding Barbour Product Search, we may share your personal information with third parties, which may include building product manufacturers, when you ask us to do so to request further information about their products or services.
We use other companies, agents or contractors ("Service Providers") to perform services on our behalf or to assist us with the provision of services to you. For example, we may engage Service Providers to provide market research, marketing (including competitions), advertising, communications, training, IT, hosting and other infrastructure, payment processing, and data cleansing and processing services. In the course of providing such services, these Service Providers may have access to your personal information. These third parties are contractually bound only to use personal information to perform the services that we hire them to provide. We will always use our best efforts to ensure that all the Service Providers we work with will keep your personal data secure.
We may also disclose your personal information to third parties:
• in the event that we sell or buy any business or assets, in which case we may disclose your personal data to the prospective seller or buyer of such business or assets;
• if any member of the Barbour ABI group or substantially all of its assets are acquired by a third party, in which case personal data about its customers will be one of the transferred assets; and
• if we are under a duty to disclose or share your personal data in order to comply with any legal obligation or in order to enforce our terms and conditions or other agreements, or to protect the rights, property or safety of the Barbour ABI group.
How long we store your data for
We will only retain your personal information for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.
To determine the appropriate retention period for personal information, we consider the amount, nature, and sensitivity of the personal information, the potential risk of harm from unauthorised use or disclosure of your personal information, the purposes for which we process your personal information and whether we can achieve those purposes through other means, and the applicable legal requirements.
Details of the periods for which we retain different aspects of your personal information are as follows:
• personal information held about you in connection with potential sales, including marketing prospect data, is held for a period of 3 years where there has been no positive interaction with you;
• personal information held about you in connection with contracts we have entered into with you is held for a period of 7 years after the expiry of termination of the contract;
• personal information held about you in connection with research we have undertaken is held for a period of 5 years after the last date on which there have been any changes in respect of the subject matter of such research and
• personal information held about you in connection with website interactions you have undertaken is held for a period of 5 years after the last date of positive interaction from you
In some circumstances you can ask us to delete your data: see the section on ‘Your Rights’ below for further information.
Where we store your data
Security of personal information
We use administrative, technical, and physical measures to safeguard personal information against loss, theft and unauthorised uses, access or modifications.
Certain areas of our websites may be password protected. Where we have given you (or where you have chosen) a password, you are responsible for keeping this password confidential. We ask you not to share your password(s) with anyone.
Payments made via our websites or processed by us whilst you are on the telephone are processed in a secure environment using software provided by third party providers.
Third party websites and apps
You have the rights set out below with respect to the personal information that we hold about you. To exercise any of these rights, you should contact us by using the contact details set out at the bottom of this policy.
You will not normally have to pay a fee to exercise any of these rights. However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.
We may need to request specific information from you to help us confirm your identity when you seek to exercise any of your rights. This is a security measure to ensure that personal information is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to help clarify the scope of your request.
We 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. In this case, we will notify you and keep you updated.
Your right to access the information we hold about you
You have the right to ask us whether or not we process your personal information and to request information on the purposes of data processing as well as confirmation on whether we use your personal information for these purposes only.
You can request access to the information we hold about you by contacting us using the contact details set out below. We will endeavour to make our file of your information available to you within 1 month, although occasionally we may not be able to give you access to the personal information we hold about you (for example, we may not be able to give you access if it would unreasonably affect someone else's privacy or if giving you access poses a serious threat to someone's life, health or safety).
Your right to have your information corrected or deleted
You can contact us to have any incomplete or inaccurate data we hold about you corrected, although we may need to verify the accuracy of the new data you provide to us.
You can also ask us to delete or remove your personal information 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 information 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 information to comply with local law. Please 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, after you make your request.
Your right to request restriction of the processing of your information
You may ask us to suspend the processing of your personal information:
• if you want us to establish the accuracy of the personal information;
• where our use of the personal information is unlawful but you do not want us to erase it;
• where you need us to hold the personal information 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 personal information but we need to verify whether we have overriding legitimate grounds to use it.
We will inform you when you decide to lift any such restriction on processing.
Your right to object to us processing your data
You have the right to ask us to stop processing your data:
• where the processing is based on legitimate interests (including any profiling we undertake to send you personalised offers, product recommendations and similar content) 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. We will comply with your right to object in these circumstances, unless:
• we can demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms; or
• the processing is for the establishment, exercise or defence of legal claims;
• for direct marketing (including any profiling we undertake for the purposes of direct marketing).
Where we contact you by email for direct marketing purposes, you can easily unsubscribe from those marketing communications at any time by following the instructions included in these marketing communications. You can also contact us at any time to inform us that you do not wish to be contacted for direct marketing purposes.
Please note that, if you have consented to receive offers from our partners, our partners are responsible for taking account of your rights, including your right to opt-out of receiving offers from them. If you had previously opted in, your personal information will cease to be transmitted to our partners from the time your request is processed.
You have the right not to be subject to a decision which is based exclusively on automated processing and produces a legal effect or a similarly significant effect on you. However, we do not make decisions on this basis and accordingly your personal data is not used in this way.
Where we are relying on your consent to process your personal information, you may withdraw consent at any time. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent, or any processing that we can lawfully undertake without needing your consent.
Your right to have your data transmitted to another organisation
Where we process personal information about you which:
• has been provided by you directly to us; and
• is processed by automated means; and
• is processed with your consent or for the performance of a contract with you,
you have the right to ask us to provide you with the personal information we hold about you in a structured, commonly used and machine-readable format or, where technically feasible, to transmit that data to another organisation.
Making a complaint
You have the right to lodge a complaint with the data protection authorities if you believe that we have not complied with applicable data protection laws. You also have a right to claim damages if processing of your personal information violates applicable data protection law.
Data Protection Manager
Barbour ABI, Hinderton Point, Lloyd Drive, Ellesmere Port, Cheshire, CH65 9HQ
email: [email protected]
Yasmeen Rahman, Group Data Privacy Officer
UBM (UK) Ltd, 5 Howick Place, London, United Kingdom, SW1P 1WG