GDPR: DATA PRIVACY NOTICE FOR CLIENTS AND SUPPLIERS

Introduction
At Bownet CMS Ltd we are committed to protecting and respecting your privacy.
This policy (together with our terms which are attached and any other documents referred to on it)
sets out the basis on which any personal data we collect from you, or that you provide to us, will be
processed by us. Please read the following carefully to understand our views and practices regarding
your personal data and how we will treat it.
The rules on processing of personal data are set out in the General Data Protection Regulation (the
“GDPR”).

1. Definitions
Data controller – A controller determines the purposes and means of processing personal data.
Data processor – A processor is responsible for processing personal data on behalf of a controller.
Data subject – Natural person

Categories of data: Personal data and special categories of personal data

Personal data – The GDPR applies to ‘personal data’ meaning any information relating to an
identifiable person who can be directly or indirectly identified in particular by reference to an identifier
(as explained in Article 6 of GDPR). For example name, passport number, home address or private
email address. Online identifiers include IP addresses and cookies.

Special categories personal data – The GDPR refers to sensitive personal data as ‘special categories
of personal data’ (as explained in Article 9 of GDPR). The special categories specifically include genetic
data, and biometric data where processed to uniquely identify an individual. Other examples include
racial and ethnic origin, sexual orientation, health data, trade union membership, political opinions,
religious or philosophical beliefs.

Processing – means any operation or set of operations which is performed on personal data or on sets
of personal data, whether or not by automated means, such as collection, recording, organisation,
structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission,
dissemination or otherwise making available, alignment or combination, restriction, erasure or
destruction.

Third party – means a natural or legal person, public authority, agency or body other than the data
subject, controller, processor and persons who, under the direct authority of the controller or processor,
are authorised to process personal data.

2. Who are we?
Bownet CMS Ltd is the data controller. This means we decide how your personal data is processed and
for what purposes. Our contact details are:
Tel: 01322 553822
Fax: 01322 553922
Registered Address:
23 Acorn Industrial Park
Crayford Road
Dartford
Kent, DA1 4AL
For all data matters contact the Data Protection Officer at the above contact or email;
admin@bownet.co.uk

3. The Purpose(s) of processing your personal data
We use your personal data for the following purposes:

  • To manage your account and ensure accuracy of administrative procedures.
  • To process your sales orders.
  • To create and send purchase orders.
  • To provide delivery information to suppliers and courier companies for order fulfilment
    purposes.
  • To send you quotations, order confirmations, invoices and delivery notifications.
  • To complete financial transactions.
  • To make contact regarding products and services we think may be of interest to you.
  • To network you with contacts who may be interested in your services.
  • To refine and personalise our offline and online product and service offerings.
  • Credit control and referencing.
  • To prevent fraud or other criminal activity.
  • To obtain and utilise online reviews from our service providers.
  • To provide sales performance and order status reports to our manufacturing partners.
  • To provide statistical information about our website users to third parties for analysis purposes
    only. This will not include information used to identify you. We use Google Analytics to analyse
    information and we comply with Google Analytics Terms of Service. Google Analytics does not
    identify individuals.
  • You may give us information about you by filling in forms on our site www.bownetcms.co.uk
    or by corresponding with us by phone, e-mail or otherwise. This includes information you
    provide when you register to use our site, subscribe to any of our services, search for a product,
    place an order on our site, participate in discussion boards or other social media functions on
    our site, enter a competition, promotion or survey and when you report a problem with our
    site.
  • To comply with an official information request to the extent required by the law.

4. The categories of personal data concerned
With reference to the categories of personal data described in the definitions section, we process the
following categories of your data:

    • All data you provide or we otherwise collect or generate when you apply for a trade account,
      register with our website or purchase any products from us, or when we or you communicate
      with the other in any way (such as quotation or other support requests), including the following.
    • Individual or corporate names, addresses and e-mail addresses.
    • Card or other payment details.
    • Passwords and usernames.
    • Purchase and payment history and transaction records.
    • Contact details for any other individuals who are representatives for any customer who is a
      business or other organisation.
    • Support, help and other communications exchanged.
    • CCTV records at our premises.
    • Online reviews and forum posts.
    • Information about your visits to and use of our website, including your computer IP address

and any other resources used.

  • Use of Cookies. Our website uses cookies. You consent to our use of cookies in accordance
    with the terms of this policy. Cookies are text files containing small amounts of information
    sent by a web server to a web browser when you visit a website and are stored on your
    device. Cookies are then sent back to the originating website on each subsequent visit, or to
    another site that recognises that cookie. Cookies enable a website to identify and track users,
    allow users to navigate different pages on a website efficiently, remember preferences,
    personalise or target advertisements which may be of particular interest to you and generally
    improve a user experience. Cookies are used to enable some of the features on our website
    such as the log-in facility, shopping cart and blogging or commenting systems.
    Cookies do not contain any information that personally identifies you but personal information
    that we store may be linked by us to information stored in and obtained from cookies. When
    you use our website, you may also be sent third party cookies such as those used by Google
    Analytics to generate statistical information and report about the use of our website. Google
    will store this information and their privacy policy is available at:
    http://www.google.com/privacypolicy.html. Most web browsers have the ability to allow you to
    vary the browser settings to decline to accept cookies. However, if you block cookies you may
    not be able to access or use certain features of our website.
    Cookies stored on your device can be deleted. The method of doing so will depend upon your
    web browser. Instructions are usually available from the support service of your web
    browser.

 

5. What is our legal basis for processing your personal data?
a) Personal data (article 6 of GDPR)
Our lawful basis for processing your general personal data:

☑ Consent of the data subject; e-mail request Bownet GDPR consent form
☑ Processing necessary for the performance of
a contract with the data subject or to take steps
to enter into a contract		 Where it is necessary to fulfil a request you
have made for assistance, information, goods or
services prior to completion of a GDPR consent
form.
☑ Processing necessary for compliance with a
legal obligation		 To comply with an official information request to
the extent required by the law.

6. Sharing your personal data
Your personal data will be treated as strictly confidential, and will be shared only when necessary with:

  • Contractors.
  • Service providers.
  • Payment Processors.
  • Customers.
  • Supplier and Manufacturing Partners.
  • Legal Entities.

7. How long do we keep your personal data?
We keep your personal data for no longer than reasonably necessary. We only retain your data for as
long as it is used to administer the purposes outlined in this notice, with the exception of where it is
required to comply with relevant or applicable law.

8. Data Security
Bownet CMS Ltd take our responsibility to keep your data secure seriously and all storage and
processing takes place at secure monitored location with all files on password protected servers and
any transfers made via secure links.

9. Providing us with your personal data
You are under no statutory or contractual requirement or obligation to provide us with your personal
data. But failure to do so will result in our being unable to fulfil our obligations to you with regards to
provision of services and information, supply or procurement of goods and financial transactions.

10. Your rights and your personal data

Unless subject to an exemption under the GDPR, you have the following rights with respect to your
personal data:

  • The right to request a copy of the personal data which we hold about you;
  • The right to request that we correct any personal data if it is found to be inaccurate or out of date;
  • The right to request your personal data is erased where it is no longer necessary to retain such
    data;
  • The right to withdraw your consent to the processing at any time, where consent was your lawful
    basis for processing the data;
  • The right to request that we provide you with your personal data and where possible, to transmit
    that data directly to another data controller, (known as the right to data portability), (where
    applicable i.e. where the processing is based on consent or is necessary for the performance of a
    contract with the data subject and where the data controller processes the data by automated
    means);
  • The right, where there is a dispute in relation to the accuracy or processing of your personal data,
    to request a restriction is placed on further processing;
  • The right to object to the processing of personal data, (where applicable i.e. where processing is
    based on legitimate interests (or the performance of a task in the public interest/exercise of official
    authority); direct marketing and processing for the purposes of scientific/historical research and
    statistics).

11. Transfer of Data Abroad
We do not transfer personal data outside the EEA.

12. Further processing
If we wish to use your personal data for a new purpose, not covered by this Data Privacy Notice, then
we will provide you with a new notice explaining this new use prior to commencing the processing and
setting out the relevant purposes and processing conditions.

13. Third Party Links
Third party links may be discovered on our site. These third party links have their own privacy policy,
which you agree to when you click on the link. We are not responsible nor do we accept responsibility
for third party links. Our liability covers us only on our site, and thus we do not accept liability for
third party links as we have no control over them.

14. Changes to our privacy policy
Any changes we may make to our privacy policy in the future will be posted on this page and, where
appropriate, notified to you by e-mail. Please check back frequently to see any updates or changes to
our privacy policy.

15. Information Accessibility
We cannot withhold data we collect about you, as per The Data Protection Act 1998. This act provides
you with access to any information we may hold on you. If you wish to have access about our data
collection on you please pay our fee of £10. The fee covers our costs for processing your request and
getting the data to you. Please use the contact details below to formulate your data access request.

16. How to make a complaint
To exercise all relevant rights, queries or complaints please in the first instance contact;
The Data Protection Officer
Bownet CMS Ltd
23 Acorn Industrial Park
Crayford Road

Dartford
Kent, DA1 4AL
Tel: 01322 553822
Fax: 01322 553922
E-mail: admin@bownet.co.uk

If this does not resolve your complaint to your satisfaction, you have the right to lodge a complaint
with the Information Commissioners Office on 03031231113 or via email
https://ico.org.uk/global/contact-us/email/ or at the Information Commissioner’s Office, Wycliffe
House, Water Lane, Wilmslow, Cheshire, SK9 5AF, England.