PORCELANOSA Group Limited Transparency Notice

1. About this notice

2. What information do we hold?

3. How do we collect personal information?

4. Our lawful basis for processing

5. How we use particularly sensitive personal information

6. Who do we share your personal information with?

7. International data transfers

8. How do we keep your personal information safe?

9. How long do we keep your personal information?

10. Your rights in connection with personal information

1. About this notice

1.1 This transparency notice describes how PORCELANOSA Group Limited, trading as PORCELANOSA, ('we') collect and use your personal information during and after your relationship with us.

1.2 We are a "data controller". This means that we are responsible for deciding how we hold and use personal information about you and explaining it clearly to you.

1.3 Where your information is collected online or via one of our stores, we are a joint data controller with the PORCELANOSA regional company you have contracted with. A full list of our regional companies is available at Consumer Terms and Conditions – please see section “WE ARE PORCELANOSA”.

1.4 This notice applies to prospective, existing and former customers of PORCELANOSA (including employees and representatives of our trade customers); individual and business contacts; individuals who request information or a quotation from u; any person who provides services to us, either as an individual or as the employee or representative of a corporate service provider.

1.5 It is important that you read this notice, together with any other privacy information or notices we may provide on specific occasions when we are collecting or processing personal information about you, so that you are aware of how and wy we are using such information.

1.6 We reserve the right to update this transparency notice at any time, we will provide appropriate notice of such changes and recommend that you regularly check our website for updates to this transparency notice. We may also notify you in ther ways from time to time about the processing of your personal information.

1.7 It is important that the personal information we hold about you is accurate and current. Please keep us informed if your personal information changes during the course of our engagement with you.

1.8 Our Privacy Officer is responsible for overseeing PORCELANOSA's compliance with data protection law. If you have any questions about this transparency notice or how we handle your personal information, please contact HR@porcelanosa.co.uk.

2. What information do we hold?

2.1 Personal data, or personal information, means any information about an individual from which that person can be identified.

2.2 There are special categories of more sensitive personal data which require a higher level of protection (see further at section 5. How we use particularly sensitive personal information).

2.3 We collect different information depending on your relationship with us (click on the appropriate link, below, to see more about the categories of personal information from you and the purposes for which we use it).

In each case we have identified our lawful basis for processing. These are described in more detail at section 4. Our lawful basis for using personal information

Retail Customers

2.4 We process:

2.4.1 Your name, address and contact details. Such processing is necessary for performance of the contract between us.

2.4.2 Information relating to your orders, including quotations, orders, deliveries and installations. Such processing is necessary for the purpose of performing the contract and providing our services.

2.4.3 Your credit card details or other payment information, for the purpose of taking payments. Such processing is necessary for the purpose of performing the contract.

2.4.4 Your bank account details, where applicable. If we are processing a refund, such processing is necessary to pay refunds to you.

2.4.5 Your marketing preferences and details of any services you have subscribed to and/or events you have attended. Such processing is necessary for the legitimate interest of promoting and growing our business.

2.4.6 Background information about you and your relationship with us, to inform and improve the service we provide to you. Such processing is necessary for the legitimate interest of informing and improving the service we provide to you.

2.4.7 Feedback you provide to us on our services. Such processing is necessary for the legitimate interest of managing our business and improving our services.

2.5 We may combine the information you give to us with information obtained from other sources and information we gather about you during the course of our relationship for the purpose of creating a customer profile which we may share within the PORCELANOSA Group, including for marketing purposes. Such processing is necessary for the legitimate interest of informing and improving the service we provide to you.

Trade Customers (sole traders)

2.6 If you are a trade customer we process the same details as we process for Retail Customers, and in addition:

2.6.1 we process details of your end customer, where necessary, to enable us to deliver and/or install products and respond to after sales enquiries; and

2.6.2 we may keep your credit card details or other payment information on file to enable us to take regular payments from you. We only do so with your consent.

2.7 We may perform due diligence in the form of credit checks and verification of your identity. We do this to comply with legal obligations and for the legitimate interest of protecting our business.

Individual prospects and other non-client contacts

2.8 We process:

2.8.1 your name, address and contact details;

2.8.2 your marketing preferences and details of any services you have subscribed to and /or events you have attended;

2.8.3 feedback you provide on events or marketing campaigns; and

2.8.4 background information about you and your relationship with us, to inform and improve the service we provide to you.

2.9 Such processing is necessary for the legitimate interest of promoting and growing our business and improving our services.

2.10 We may combine the information you give to us with information obtained from other sources and information we gather about you during the course of our relationship for the purpose of creating a customer profile which we may share within the PORCELANOSA Group, including for marketing purposes. Such processing is necessary for the legitimate interest of informing and improving the service we provide to you.

Individual service providers

2.11 We process:

2.11.1 your name, title and business contact information including addresses, telephone numbers and email addresses; and

2.11.2 details relating to the performance of the contract between us, including financial information and bank details for payment.

Such processing is necessary for performance of the contract between us.

2.12 We may perform due diligence in the form of credit checks and verification of your identity. We do this for the legitimate interest of protecting our business.

Corporate trade customers, suppliers and third party business contacts

2.13 We process names, titles and business contact information including addresses, telephone numbers and email addresses for your employees and representatives. Such processing is necessary for performance of the contract between us.

2.14 We may keep your credit card details or other payment information on file to enable us to take regular payments from you. We only do so with your consent We may perform due diligence in the form of credit checks on companies, including checking photographic identification and proof of address of directors and, in some cases, your shareholders, and verification of the company registration details. We do this for the legitimate interest of protecting our business

2.15 We process your marketing preferences and details of any services you have subscribed to and any events your employees and representatives have attended. Such processing is necessary for the legitimate interest of promoting and growing our business.

2.16 We process any feedback you (your employees or representatives) provide to us on our services. Such processing is necessary for the legitimate interest of managing our business and improving our services.

2.17 We process background information about you, and your employees and representatives, and your relationship with us. Such processing is necessary for the legitimate interest of informing and improving the service we provide to.

2.18 We may combine the information you give to us with information obtained from other sources and information we gather about you during the course of our relationship for the purpose of creating a customer profile which we may share within the PORCELANOSA Group, including for marketing purposes. Such processing is necessary for the legitimate interest of informing and improving the service we provide to you.

3. How do we collect personal information about you?

3.1 We collect personal information direct from you when you enquire about our services online, or obtain a quotation in the showroom, or where you contact us with feedback about our services.

3.2 We collect further information from you when you place an order with us, and during the period of our contractual relationship with you or for the duration of you providing services to us.

3.3 We may collect information from trade referrals or from third parties who we work with to provide the services to you, such as our delivery company.

3.4 We may collect information from other third parties, such as credit reference agencies.

3.5 We may collect information about you from public sources, such as Companies House or from an online search.

4. Our lawful basis for processing

4.1 We will only use your personal information when the law allows us to. Most commonly, we will use your personal information in the following circumstances:

4.1.1 Where we need to perform the contract we have entered into with you.

4.1.2 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. Where we rely on legitimate interests for our processing, we will advise you of the relevant interest.

4.1.3 Where we need to comply with a legal obligation.

4.1.4 Otherwise, with your consent.

4.2 We may also use your personal information in the following situations, which are likely to be rare:

4.2.1 Where we need to protect your vital interests (or someone else's interests).

4.2.2 Where it is needed in the public interest.

4.3 Some of the above grounds for processing will overlap and there may be several grounds which justify our use of your personal information.

4.4 We will only use your personal information for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If we need to use your personal information for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.

4.5 We may, from time to time, approach you for your consent to allow us to process your personal information for other purposes. If we do so, we will provide you with details of the information that we would like and the reason we need it, so that you can carefully consider whether you wish to consent.

4.6 Please note that we may process your personal information without your knowledge or consent where this is required or permitted by law.

5. How we use particularly sensitive personal information

5.1 Special categories of particularly sensitive personal information require higher levels of protection. We need to have further justification for collecting, storing and using the following types of personal information.

5.2 We do not process particularly sensitive personal information as part of our usual course of business. However, we may process information:

5.2.1 relating to a health condition or disability in order to make reasonable adjustments in the provision of our services; and

5.2.2 which may identify special category characteristics (such as gender, race, ethnicity, or religious beliefs) to ensure meaningful equal opportunity monitoring and reporting. We make every effort to anonymise such information.

5.3 We may process sensitive personal information (including information relating to allegations of criminal behaviour) where necessary for the purpose of legal proceedings or if we are under a legal obligation to do so, or if it becomes necessary to protect your vital interests or those of another person, if you have manifestly made the information public or for reasons of substantial public interest.

5.4 We may approach you for your written consent to allow us to process certain particularly sensitive information. If we do so, we will provide you with full details of the information that we would like and the reason we need it, so that you can carefully consider whether you wish to consent.

6. Who do we share your personal information with?

6.1 We may have to share your data with third-party service providers who provide services to us and act on our behalf (our data processors), and to other third parties who use your information, as data controller, for their own purposes.

6.2 Where we share information with other data controllers (such HMRC or other government or law enforcement agencies), they are responsible to you for their use of your information and compliance with the law.

6.3 We share your contact details with PORCELANOSA Grupo AIE (our Spanish parent company) for marketing purposes, provided that you are a retail customer or sole trader. PORCELANOSA Grupo will only send you electronic marketing if you agree to this. We do not share your details for marketing purposes outside the PORCELANOSA Group.

6.4 We share information, including customer orders and financial information, with our parent company and other members of the PORCELANOSA Group for the purpose of managing the business and ensuring compliance with group standards.

6.5 We share client information with our auditors, accountants, lawyers and other professional advisers for the purpose of auditing the business or obtaining legal or other professional advice.

6.6 We may share your personal information with other third parties in the context of the negotiations for a sale or restructuring of the business.

6.7 We use a third party payment service provider to process card payments.

6.8 The following activities are carried out by third-party service providers on our behalf: deliveries; IT support and maintenance; hosting our website (including analytics); marketing campaigns; carrying out surveys and obtaining feedback on our services.

6.9 All our third-party service providers are required to take appropriate security measures to protect your personal information in line with our policies. We do not allow our third-party service providers to use your personal information for their own purposes. We only permit them to process your personal information for specified purposes and in accordance with our instructions.

7. International data transfers

7.1 All our personal information is hosted on servers located within the UK or European Economic Area (EEA).

7.2 If you are based outside the UK or EEA we may transfer personal information to the correspondence address you provide to us. We will take all reasonable steps to ensure that such transfers are secure. By instructing us from outside the EEA you acknowledge and agree that such transfers are necessary for us to provide services to you.

7.3 If we are required to transfer information outside the UK or EEA, we have put in place appropriate measures to ensure that your personal information is treated by those third parties in a way that is consistent with and which respects the EU and UK laws on data protection.

8. How do we keep your personal information safe?

8.1 We have put in place measures to protect the security of your information. Details of these measures are available upon request.

8.2 Third parties will only process your personal information on our instructions and where they have agreed to treat the information confidentially and to keep it secure.

8.3 We have put in place appropriate security measures to prevent your personal information from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal information to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal information on our instructions and they are subject to a duty of confidentiality.

8.4 We have put in place procedures to deal with any suspected data security breach and will notify you and any applicable regulator of a suspected breach where we are legally required to do so.

9. How long do we keep your personal information?

9.1 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.

9.2 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.

9.3 Unless you have agreed otherwise, we only retain credit card details or other payment information for as long as necessary to confirm that payment has been received at which point the details are securely destroyed.

9.4 Where a minimum retention period is required by law (such as retaining records for HMRC purposes) we comply with that minimum period plus up to 12 months to allow time for us to anonymise or delete information in accordance with our internal data management processes. If you would like to know which periods apply to your specific information please contact HR@porcelanosa.co.uk.

9.5 If we are required to retain your information longer than our standard retention periods, we will let you know (unless we are prevented by law from doing so.)

9.6 In some circumstances we may anonymise your personal information so that it can no longer be associated with you, in which case we may use such information without further notice to you.

10. Your rights in connection with personal information

10.1 Under certain circumstances, by law you have the right to:

10.1.1 Request access to your personal information (commonly known as a "data subject access request"). This enables you to receive a copy of the personal information we hold about you and to check that we are lawfully processing it.

10.1.2 Request correction of the personal information that we hold about you. This enables you to have any incomplete or inaccurate information we hold about you corrected.

10.1.3 Request erasure of your personal information. This enables you to ask us to delete or remove 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 exercised your right to object to processing (see below).

10.1.4 Object to processing of your personal information 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. You also have the right to object where we are processing your personal information for direct marketing purposes.

10.1.5 Request the restriction of processing of your personal information. This enables you to ask us to suspend the processing of personal information about you, for example if you want us to establish its accuracy or the reason for processing it.

10.1.6 Request the transfer of your personal information to another party.

10.1.7 Withdraw consent. In the limited circumstances where you may have provided your consent to the collection, processing and transfer of your personal information for a specific purpose, you have the right to withdraw your consent for that specific processing at any time. Once we have received notification that you have withdrawn your consent, we will no longer process your information for the purpose or purposes you originally agreed to, unless we are required to continue to process your information in accordance with another lawful basis which has been notified to you.

10.2 To exercise any of the above rights, please contact HR@porcelanosa.co.uk.

10.3 You will not have to pay a fee to access your personal information (or to exercise any of the other rights). However, we may charge a reasonable fee if your request for access is clearly unfounded or excessive. Alternatively, we may refuse to comply with the request in such circumstances.

10.4 We may need to request specific information from you to help us confirm your identity and ensure your right to access the information (or to exercise any of your other rights). This is another appropriate security measure to ensure that personal information is not disclosed to any person who has no right to receive it.

11. Complaints Procedure

11.1 If you consider that we have not acted properly when using your personal information you can contact the Information Commissioner's Office: ico.org.uk.

Last Updated: 14 May 2018

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