Clevertronics International UK Ltd
1. Introduction and who we are
Clevertronics understands the importance of protecting the privacy of personal data. This privacy notice sets out how Clevertronics aims to protect the privacy of your personal data, your rights in relation to your personal data managed by Clevertronics and the way Clevertronics processes your personal data (including collecting, holding, using and disclosing your personal data).
It is important that you read this privacy notice together with any other privacy notice or fair processing notice Clevertronics may provide on specific occasions when Clevertronics is collecting or processing personal data about you so that you are fully aware of how and why Clevertronics is using your personal data. This privacy notice supplements the other notices and is not intended to override them.
This privacy notice is issued on behalf of the Clevertronics Group so when we mention “Clevertronics”, “we”, “us” or “our” in this privacy notice, we are referring to the relevant company in the Clevertronics Group responsible for processing your data.
The Clevertronics Group includes:
- Clevertronics Pty Ltd, a company a company incorporated in Australia with company number xxxxxxx at 195 Chesterville Road Moorabbin, Victoria
- Clevertronics International Pty Ltd, a company incorporated in Australia with company number 624 549 935 at 195 Chesterville Road Moorabbin, Victoria; and
- Clevertronics International UK Limited, a company incorporated in England and Wales with company number 11249539 at 843 Finchley Road, London, United Kingdom, NW11 8NA.
Each member of the Clevertronics Group will act as a controller and Clevertronics International Pty Ltd is responsible for this website.
The way in which the Clevertronics Group uses personal data is regulated by EU, UK, Australia and New Zealand data protection legislation, whereby Clevertronics International Pty Ltd will be regulated by the applicable Australian laws and Clevertronics International UK Limited will be regulated by the applicable UK and EU laws, which includes the General Data Protection Regulation (EU) 2016/679.
Further guidance on your rights are available from your local data protection regulator which may be (as applicable) the Information Commissioner’s Office (https://.ico.org.uk/) or the Office of the Australian Information Commissioner.
This privacy notice does not override any applicable national data privacy laws and regulations in countries where the Clevertronics Group operates.
Changes to the privacy notice and your duty to inform us of changes
We reserve the right to update this privacy notice at any time, for example if the law or regulatory requirements change, if technology changes or to make the Clevertronics Group’s operations and procedures more efficient. When such changes occur, an updated version will be made available and notified on the home page of the website. If you object to the changes, please notify Clevertronics via the contact details set out in paragraph 10. However, if such objection means that we cannot process your personal data, Clevertronics may not be able to provide its products and/or services to you and/or the entity you represent.
It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.
This website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy notices. When you leave our website, we encourage you to read the privacy notice of every website you visit.
2. What kinds of personal data does Clevertronics collect from you?
Personal data, or personal information, means any information or an opinion about an identified, or reasonably identifiable, individual. It does not include data where the identity has been removed (anonymous data).
During the provision of its products and services, Clevertronics generally only collects personal data about an individual to the extent they are acting as the representative and contact person (whether in their capacity as director, employee, contractor or otherwise) on behalf of a customer, supplier or other entity with which Clevertronics has a commercial relationship.
If you are a representative of a customer, supplier or other entity with which Clevertronics has a commercial relationship, we may collect, use, store and transfer different kinds of personal data about you. Generally, we have grouped together the kinds of personal data Clevertronics collects about you which include:
- Identity data includes your first name, last name, username or similar identifier, marital status, title, date of birth and gender.
- Contact data includes telephone numbers, fax numbers, email address and postal addresses.
- Technical data includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access this website.
- Profile data includes your username and password, purchases or orders made by you, your interests, preferences, feedback and survey responses and information about your role.
- Usage data includes information about how you use our website, products and services.
- Marketing and Communications data includes your preferences in receiving marketing from us and our third parties and your communication preferences.
We do not collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data). Nor do we collect any information about criminal convictions and offences.
3. How does Clevertronics collect personal data?
Generally, Clevertronics collects your personal data, including identity, contact and marketing data directly from you, through the completion of a manual or online form, an interaction or exchange in person or by way of telephone, facsimile, email, post or through the use of the Clevertronics website. There may be occasions when Clevertronics collects your personal data from other sources such as from:
- Automated technologies or interactions. As you interact with our website, we may automatically collect technical data about your equipment, browsing actions and patterns. We collect this personal data by using cookies, server logs and other similar technologies. We may also receive technical data about you if you visit other websites employing our cookies. Please see our [www.clevertronics.co.uk] for further details.
- Third parties. We may receive personal data, including identity, technical and contact data, about you from various third parties as set out below:
- the entity you represent, where necessary for Clevertronics to provide its products and/or services to that entity through you;
- a credit reference listed in a credit application form;
- an existing or potential customer or supplier where they provide your details for the purpose of being a credit reference;
- an information services provider; or
- a publicly maintained record or other publicly available sources of information including social media and similar websites.
Generally, Clevertronics will only collect your personal data from sources other than you if it is unreasonable or impracticable to collect your personal data from you.
4. Why does Clevertronics need your personal data?
Clevertronics will only use your personal data when the law allows us to. Most commonly, Clevertronics processes (including collects, holds, uses and discloses) your personal data where it is reasonably necessary for the purposes of:
- where we need to perform the contract we are about to enter into or have entered into with you;
- 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; or
- where we need to comply with a legal or regulatory obligation.
Purposes for which we will use your personal data
We have set out below, in a table format, a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.
Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your personal data. Please contact us if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below.
|Purpose/Activity||Type of data||Lawful basis for processing including basis of legitimate interest|
To register you as a customer, including:
(a) Identifying and liaising with you as a representative of a customer, supplier or other entity with which Clevertronics has or intends to have a commercial relationship;
(b) Establishing new points of contact with an existing or potential customer, supplier or other entity with which Clevertronics has or intends to have a commercial relationship
(a) Performance of a contract with you
(b) Necessary for our legitimate interests (to keep our records updated, to develop our products/services and grow our business)
To process and deliver your order including:
(a) Manage accounts, payments, billing fees and charges;
(b) Collect and recover money owed to us;
(c) Provide products and services including the design, supply and manufacture of emergency lighting, automated monitoring systems and sound evacuations solutions
(e) Marketing and Communications
(a) Performance of a contract with you
(b) Necessary for our legitimate interests (to recover debts due to us)
To manage our relationship with you which will include:
(b) Asking you to leave a review or take a survey;
(c) Assessing whether Clevertronics will buy products or services from, sell products or services to, or otherwise grant an application for credit from, a particular entity
(e) Marketing and Communications
(a) Performance of a contract with you
(b) Necessary to comply with a legal obligation
(c) Necessary for our legitimate interests (to keep our records updated, to recover debts and to study how customers use our products/services)
|To administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)||(a) Identity
|(a) Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise)
(b) Necessary to comply with a legal obligation
|To deliver relevant website content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you||(a) Identity
(e) Marketing and Communications
|Necessary for our legitimate interests (to study how customers use our products/services, to develop them, to grow our business and to inform our marketing strategy)|
|To use data analytics to improve our website, products/services, marketing, customer relationships and experiences||(a) Technical
|Necessary for our legitimate interests (to define types of customers for our products and services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy)|
|To make suggestions and recommendations to you about goods or services that may be of interest to you, including identifying and informing you of products and services from Clevertronics or selected third parties||(a) Identity
|Necessary for our legitimate interests (to develop our products/services and grow our business)|
Clevertronics may also use your personal data for purposes where you have consented, such as identifying you as the author of any testimonial provided by you and published on our website or elsewhere.
Where personal data is used or disclosed, Clevertronics ensures it is relevant to the purpose for which it is to be used or disclosed.
You are under no obligation to provide your personal information to Clevertronics. However, without certain information from you, Clevertronics may not be able to provide its products and/or services to you and/or the entity you represent. In this case, we may have to cancel a product or service you have with us but we will notify you if this is the case at the time.
Clevertronics may use and disclose your personal data in order to inform you of products and services that may be of interest to you. In the event you do not wish to receive such communications, you can opt-out by contacting Clevertronics via the contact details set out in paragraph 10 or through any opt-out mechanism contained in a marketing communication to you.
Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of a product purchase.
Change of Purpose
We will only use your personal data 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 you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.
If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.
Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.
5. To whom does Clevertronics disclose your personal data?
Clevertronics discloses your personal data for the purpose for which Clevertronics collects it. That is, generally, Clevertronics will only disclose your personal data for a purpose set out at paragraph 4. This may include disclosing your personal data to:
- credit references listed in a credit application form;
- third parties engaged to perform administrative or other business management functions;
- people or entities considering acquiring an interest in Clevertronics’ enterprise or assets;
- Clevertronics’ professional advisors, contractors, consultants and related bodies corporate;
- insurance providers; and
- regulatory bodies.
Clevertronics’ disclosures of your personal data to third parties are on a confidential basis and in accordance with law. Clevertronics may also disclose your personal data with your consent or if disclosure is required or authorised by law.
6. Overseas disclosure
Clevertronics operates in the United Kingdom, Australia and New Zealand.
In circumstances where only the UK Data Protection Act 2018 and GDPR apply (and the Australian Privacy Principles and the Australian Privacy Act 1998 do not apply), Clevertronics may disclose personal data to recipients in outside of the European Economic Area (EEA) to the extent necessary to provide its products and/or services and for administrative or other business management purposes.
Overseas recipients may have different privacy and data protection standards.
Whenever we transfer your personal data out of the EEA, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:
- We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data by the European Commission. For further details, see European Commission: Adequacy of the protection of personal data in non-EU countries.
- We may use specific contracts approved by the European Commission which give personal data the same protection it has in Europe. For further details, see European Commission: Model contracts for the transfer of personal data to third countries.
In circumstances where only the Australian Privacy Principles and the Australian Privacy Act 1998 apply (and the GDPR does not apply), before disclosing any personal information to an overseas recipient, Clevertronics will take steps reasonable in the circumstances to ensure the overseas recipient complies with the Australian Privacy Principles or is bound by a substantially similar privacy scheme unless you consent to the overseas disclosure or it is otherwise required or permitted by law.
If you have any queries or objections to overseas disclosures or require further information on the specific mechanism used by us when transferring your personal data out of the EEA, please contact Clevertronics’ Privacy Compliance Officer on the details set out in paragraph 10.
7. Security of your personal data
Clevertronics have put in place appropriate security measures to ensure that the personal data it holds is protected from misuse, interference and loss and from unauthorised access, modification or disclosure.
Clevertronics holds personal data in both hard copy and electronic forms in secure databases on secure premises, accessible only by authorised staff who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.
Clevertronics have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.
8. Data retention
Clevertronics will destroy or de-identify personal data in circumstances where it is no longer necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements, unless Clevertronics is otherwise required or authorised by law to retain the information.
To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.
By law we have to keep basic information about our customers (including Contact, Identity, Financial and Transaction Data) for six years after they cease being customers for tax purposes.
In some circumstances you can ask us to delete your data, see below for further information.
In some circumstances we may anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes in which case we may use this information indefinitely without further notice to you.
9. Your legal rights
Clevertronics takes steps reasonable in the circumstances to ensure personal data it holds is accurate, up-to-date, complete, relevant and not misleading.
In circumstances where only the UK Data Protection Act 2018 and GDPR apply (and the Australian Privacy Principles and the Australian Privacy Act 1998 do not apply), you have rights under data protection laws in relation to your personal data. These include:
- Request access to your personal data. This is commonly known as a “data subject access request” and it enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
- Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
- Request erasure of your personal data. This enables you to ask us to delete or remove personal data 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 data 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 data to comply with local law. 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, at the time of your request.
- Object to processing of your personal data 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 as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
- Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data: (a) if you want us to establish the data’s accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
- Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
- Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.
If you wish to exercise any of the rights set out above, please contact us and:
- you will have to provide proof of identity to ensure that personal data is provided only to the correct individuals and that the privacy of others is protected. This is a security measure to ensure that personal data 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 speed up our response;
- Clevertronics requests that you be reasonably specific about the information you require; and
- You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, Clevertronics may charge you a reasonable administration fee, which reflects the cost to Clevertronics, if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.
Clevertronics will endeavour to respond to legitimate requests within 30 days from your request. 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.
In circumstances where only the Australian Privacy Principles and the Australian Privacy Act 1998 apply (and the GDPR does not apply), you have a right to access and seek correction of your personal data that is collected and held by Clevertronics. If at any time you would like to access or correct the personal data that Clevertronics holds about you, or you would like more information on Clevertronics’ approach to privacy, please contact Clevertronics’ Privacy Compliance Officer on the details set out in paragraph 10 below. Clevertronics will grant access to the extent required or authorised by the Australian Privacy Act or other law and take steps reasonable in the circumstances to correct personal data where necessary and appropriate.
If Clevertronics refuses your request to access or correct your personal data, Clevertronics will provide you with written reasons for the refusal and details of complaint mechanisms. Clevertronics will also take steps reasonable in the circumstance to provide you with access in a manner that meets your needs and the needs of Clevertronics.
10. How to contact us
We have appointed a Privacy Compliance Officer who is responsible for overseeing questions in relation to this privacy notice.
For further information or enquiries regarding your personal data, if you wish to exercise your legal rights, or if you would like to opt-out of receiving any promotional or marketing communications, please contact Clevertronics ‘ Privacy Compliance Officer at firstname.lastname@example.org.
11. Privacy Complaints
Please direct all privacy complaints to Clevertronics’ Privacy Compliance Officer. At all times, privacy complaints:
- will be treated seriously;
- will be dealt with promptly;
- will be dealt with in a confidential manner; and
- will not affect your existing obligations or affect the commercial arrangements between you and Clevertronics.
Clevertronics’ Privacy Compliance Officer will commence an investigation into your complaint. You will be informed of the outcome of your complaint following completion of the investigation.
You have the right to complain to your local data protection regulator (which may be, as applicable, the Information Commissioner’s Office (https://.ico.org.uk/) or the Office of the Australian Information Commissioner) if you believe that your personal data has been processed unlawfully. If you would like the contact details of your local data protection regulator, please let us know. We would appreciate the chance to deal with your concerns before you approach the local data protection regulator so please contact us in the first instance.