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County Office Supplies Ltd - Privacy Policy – Updated 22/05/2018

County Office Supplies Limited is a controller of your personal data. We respect your data and your privacy is important to us. This Privacy Notice explains what personal data we collect and how it is used. This notice also explains what rights you have over your personal data and how you can use those rights. This document has been written to be as transparent and as concise as possible, using plain language for the users ease of understanding. We will never sell your personal data and we will never give personal data to third parties, other than to fulfil our obligations to you.

Who are we?

County Office Supplies Ltd is an Office Supplies Company that operates in the South of England and supply businesses all over the United Kingdom. Our Company Registration number is 2265059.

Definitions:

The following definitions are used in this policy.

Data Controller - A Data Controller determines the purposes and means of Processing Personal Data. For the purpose of managing your account and providing goods and services County Office Supplies Ltd would be defined as a Data Controller.

Data Processor - A Data Processor is responsible for Processing Personal Data on behalf of a Data Controller. For the purpose of sending an order direct to an End User on behalf of a Customer, County Office Supplies Ltd would be classed as a Data Processor.

Subprocessor - A 3rd party used by a Data Processor to fulfil purchase orders placed by the Data Controller. May include but not limited to couriers or hauliers, other suppliers and distributors. Processing - The term "processing" is very broad. It essentially means anything that is done to, or with, personal data (including collecting, storing or deleting data).

Data Subject - An identifiable natural person who can be identified, directly or indirectly, in particular by reference to data. For example, an employee, customer, end user etc.

Personal Data - Any information relating to an identified or identifiable natural person (‘Data Subject’).

Customer - Any organisation or individual who purchases goods or services directly from County Office Supplies Ltd.

End User - Any organisation or individual who purchases goods or services from a Supplier.

Contact Legitimate Interests:

Under the new data protection law starting in May 2018 we have a number of lawful reasons that we can use (or 'process') your personal information. For B2B accounts one of the lawful reasons is called 'legitimate interests'.

Broadly speaking Legitimate Interests means that we can process your personal information if we have a genuine and legitimate reason and we are not harming any of your rights and interests.

So, what does this mean? When you provide your personal details to us we use your information for our legitimate business interests to carry out our work of servicing businesses throughout our territory. Before doing this, though, we will also carefully consider and balance any potential impact on you and your rights.

Some typical examples of when we might use the approach are for preventing fraud, direct marketing, maintaining the security of our systems, data analytics, enhancing, modifying or improving our services, identifying usage trends and determining the effectiveness of our campaigns and sales.

We will process the personal information you have supplied to us to conduct and manage our business to enable us to give you the most appropriate marketing, information, service and products and provide the best and most secure experience. These are what we consider to be our 'Legitimate Interests'.

Our interests:

The following are some examples of when and why we would use this approach in our work:

Marketing: We will make best effort to ensure our marketing is tailored and relevant for you where-ever we deem you to be in the sales cycle.

Process Orders: In order for us to process an order, payment has to be taken and contact information collected, such as name, delivery address and telephone number, provided. Both the buyer and seller would need to record the transaction.

Your best interest:Processing your information to protect you against fraud when transacting on our website, and to ensure our websites and systems are secure.

Personalisation: Where the processing enables us to enhance, modify, personalise or otherwise improve our services/communications for the benefit of our customers and prospects.

Analytics: To process your personal information for the purposes of customer analysis, assessment, profiling and marketing, on a personalised or aggregated basis, to help us with our activities and to provide you with the most relevant information if this does not harm any of your rights and interests.

Research: To determine the effectiveness of promotional campaigns and advertising and to develop our products, services, systems and relationships with you.

Due Diligence: We may need to conduct investigations on supporters, potential customers and business partners to determine if those companies and individuals have been involved or convicted of offences such as fraud, bribery and corruption.

We will also hold information about you so that we can respect your preferences for being contacted by us.

Your interests:

When we process your personal information for our legitimate interests, we will consider and balance any potential impact on you and your rights under data protection and any other relevant law. Our legitimate business interests do not automatically override your interests – we will not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). Remember, you can change the way you hear from us or withdraw your permission for us to process your personal details at any time by using our online Preference Centre at the bottom of our emails.

What information is being collected?

As a customer of County Office Supplies Ltd we have a central system that collects your orders and delivery information so that we can deliver your order to you. We also store the following information:

Organisations legal and trading names

Individual’s names and job titles

Contact information such as telephone numbers and email addresses

Demographic details such as address and postcode

Other information relevant to providing our service to you

How is it collected?

County Office Supplies Ltd is mainly trading to B2B (Business to Business) and as such, if you are already a customer you will only hear from our sales team if you are a business and we think you will have a legitimate interest in the fantastic products/service we can offer you. However, we do offer the opportunity to buy from us without an account. We will not however contact you or retain your details other than when processing your order.

It is collected in the following ways:

When you place an order with us

Phone directories

Online web searches

Networking/business events

Enquiries & Quotations

Recommendations from customers

Local Advertising

How do we use your information?

As a limited company registered in England, we are legally required to keep your data on file for a minimum of 6 years since the end of the last company financial year. If you have traded with us in that time frame we will be unable to completely delete any data we hold on you. Our financial year runs from September to August. Other than this we also use your data to:

Your data is required to enable us to supply you with our goods/services, and;

For internal record keeping

Keep you informed about your order, to send you promotional emails, special offers or other information we think you may find interesting using the email address(es) you have provided (see further details in the marketing section further down this policy)

How do we share your information, and why?

Your details are never shared with any parties unnecessarily – parties we must share your data with will/may include:

Our suppliers and their couriers, to source and deliver goods to you

Our back office provider, so we can process your orders and invoice you accordingly

Entities to fulfil legal obligations (e.g. debt recovery; HMRC investigation)

If it is a ‘Public Task’ (e.g. the police require your information)

None of our 3rd Party suppliers or couriers can use the information to contact you directly. All information is held securely. No information will be passed by them to 3rd parties.

Who is collecting it?

The employees of County Office Supplies Ltd collect the data.

Marketing

We are not here to annoy you! You can unsubscribe to our marketing communications in the same way we deliver them – whether that be verbally over the phone, by email or in writing by post if you prefer. If you have unsubscribed to marketing emails and still receive unwanted communications, please inform our DPO (Data Protection Office) via email at mark@countyofficesupplies.co.uk who will update our lists accordingly to ensure this does not happen again. Our sales team may analyse your historic spend to establish products that you may be interested in, that you currently do not buy with us. How is

Your Personal Data Protected?

A range of administrative, electronic and physical security measures are used to protect Customer and End User Personal Data. These measures protect Personal Data against loss, unauthorised access or alteration without permission. Cloud services used by County Office Supplies Ltd for Processing Personal Data have a Data Processing Agreement that meets the requirements of the GDPR.

What will be the effect of this on the individuals concerned?

There should be no effect of this on any individual concerned.

Is the intended use likely to cause individuals to object or complain?

No. Customers of County Office Supplies Ltd are using us for the supply of Office Stationery and Office Furniture.

How can an individual make a complaint?

Telephone: 01273 513014

Email: mark@countyofficesupplies.co.uk

Write to: Mark Roberts, Managing Director. County Office Supplies Ltd, Unit 21 Euro Business Park. Newhaven. New Road. East Sussex. BN9 0DQ