Introduction
SVO (Calne) Limited (“SVO”, “we”, “us”), as well as our employees are committed to providing you with transparency and choice where your Personal Data (“Personal Data”) is concerned. SVO is committed to providing reliable and trustworthy information to our customers using a variety of means, which are supported by a comprehensive privacy program. We aim to process Personal Data in accordance with applicable legislation, while considering and transparently balancing our interests with those of our customers.
This Privacy Statement (“Statement”) provides an overview of how SVO handles privacy, and how we protect your Personal Data.
This Privacy Statement applies to all SVO services including order processing, installation and customer support, and describes how we handle Personal Data and the choices available to you regarding collection, process, access, and how to update, correct and delete your Personal Data.
If you are in the European Economic Area, and unless stipulated otherwise contractually, the Controller of your Personal Data is SVO (Calne) Limited which has its principal place of business at Unit K, Stanier Road, Porte Marsh Industrial Estate, Calne, Wiltshire SN11 9PX.
We also process personal data on behalf of Motability Operations for whom we act as a Data Processor.
What This Statement Covers
This Statement describes the following general aspects of our collection and processing of Personal Data concerning you. What Personal Data we collect;
• How Personal Data is used and for what purposes;
• How we maintain the accuracy, integrity and security of your Personal Data;
• How your Personal data is retained and destroyed;
• What individual rights available to you as it pertains to your Personal Data;
• Who you can contact if you have any questions regarding the use of your Personal Data.
Personal Data We Collect
When you use our products and services, we may collect data or ask you to provide certain data, including Personal Data, about you for the purpose of helping us manage our relationship with you. "Personal Data" is any data relating to an identified or identifiable individual, and may include name, address, email address, phone number, marketing preferences or payment card number. If we link other data with your Personal Data, we will treat that linked data as Personal Data.
This data may include:
• Contact details, such as name, mailing address, email address and phone number;
• Shipping and billing data, including credit card and payment data;
• Your transaction history;
• Data you provide to us to receive technical assistance or during customer service interactions;
How We Process Your Personal Data
We use your Personal Data on the following grounds:
On the basis of fulfilling our contract with you or entering into a contract with you on your request, in order to:
• Process your purchase transactions including but not limited to writing to confirm your order and telephone contact as necessary;
• Update you on the status of your orders, including but not limited to arranging an installation date, location and any required demonstration of products;
• Allow you to register products you purchase;
• Provide you with technical and customer support;
On the basis of legal obligations, we are obligated to, for instance, keep records for tax (VAT) purposes and for the purposes of product recall should the need arise.
On the basis of our legitimate interest in the effective delivery of our products, services and communications to you, in order to:
• Communicate commercial promotions;
• Provide quotes for our products and services;
We will only process any special categories of Personal Data (“Sensitive Personal Data”) relating to you for specific purposes outlined above, because you have given us your explicit consent to process that data.
On the basis of our legitimate interest, we may combine the data we collect from you over time with data obtained from other sources eg. Motability Operations. We combine your data with other sources in order to improve our service to you. This data is used to better understand your requirements and to ensure the accuracy of the data we hold.
Marketing
SVO has a legitimate interest in promoting our commercial offerings and to optimise the delivery of communications to that effect to our customers. We will therefore collect and process data to that end as explained below. However, where we are legally required to obtain your consent to provide you with certain marketing materials, we will only provide you with such marketing materials where we have obtained such consent from you. If you do not want to continue receiving any marketing materials from us, you can request that we do not send them to you by contacting us either by email to Info@svoptions.co.uk or by telephone on 01249 815141
Data from Third-Parties Third-parties may provide us with Personal Data they have collected about you from you or from further other sources. We are not liable for any processing of your Personal Data by such third-parties prior to, during or after them providing it to us.
We may combine such Personal Data with the Personal Data we already have about you to provide you with a better experience, evaluate your interest in our products or improve the quality of our offerings.
How We Disclose Your Personal Data
We will not sell, lease, rent or give away your Personal Data.
How We Protect Your Personal Data
Safeguards
We take reasonable and appropriate administrative, technical, organisational, and physical security and risk management measures in accordance with applicable laws to ensure that your Personal Data is adequately protected against accidental or unlawful destruction, damage, loss or alteration, unauthorised or unlawful access, disclosure or misuse, and all other unlawful forms of processing of your Personal Data in our possession.
We pay specific attention to the protection of Personal Data and the risks associated with processing this data.
These measures include:
Physical Safeguards We lock doors and file cabinets, control access to our facilities, implement a clean desk policy, and apply secure destruction to media containing your Personal Data.
Technology Safeguards We use network and information security technologies such as Trend anti-virus and endpoint protection software
Organisational Safeguards We conduct regular company-wide training and awareness programs on security and privacy, to make sure that our employees understand the importance of protecting your Personal Data, and that they learn and maintain the necessary knowledge and skills effectively to protect it in practice.
Storage of Your Personal Data
The data we collect from you may be stored, with risk-appropriate technical and organisational security measures applied to it, on in-house servers and for backup purposes in an encrypted state in the cloud.
Managing Your Personal Data
How long we retain or store your Personal Data We will hold your Personal Data on our systems for the longest of the following periods: 1. As long as necessary to maintain our ongoing business relationship, or as needed to provide you with the products, services or information which you are entitled to or can otherwise reasonably expect to receive from us; 2. For as long as necessary for the purpose for which we collected it or for which you supplied it to us in accordance with any product or service relevant activity or process; 3. Any retention period that is necessary to comply with our legal obligations, to resolve disputes or to enforce our agreements;
Where SVO is a data processor processing your Personal Data for the purposes and on the instructions of another data controller or data processor, we will comply with the time limits agreed with that other Controller or Processor.
Your Privacy Rights
You may have the right:
a) to ask us to provide you with information regarding the Personal Data we process concerning you;
b) to rectify, update or complement inaccurate or incomplete Personal Data concerning you;
c) to delete or request the erasure of Personal Data concerning you;
d) in certain circumstances to obtain of us that we restrict the way in which we process Personal Data concerning you;
e) to withdraw any consent, you may have given for us to process Personal Data concerning you;
f) to object to our processing of Personal Data concerning you on the basis of our, or of third-parties’ legitimate interests;
h) in the European Economic Area, to lodge a privacy complaint with a supervisory authority if you are unhappy with the way we have handled your Personal Data or any privacy query or request that you have raised with us.
Where your exercise of any of the rights above is dependent on SVO ’s action, we will abide by our legal obligation to take reasonable measures to ascertain your identity and the legitimacy of your request and may ask you to disclose to us any information necessary for that purpose. We will respond to legitimate request within 1 (one) calendar month or 31 (thirty-one) calendar days (whichever is longer).
Contact Us
To exercise any of your rights, or if you have any other questions or complaints about our use of your Personal Data and its privacy, write to or call our Data Protection Officer
SVO (Calne) Limited Unit K, Stanier Road, Porte Marsh Industrial Estate, Calne, Wiltshire SN11 9PX, info@svoptions.co.uk