1.2 We are committed to safeguarding the privacy of our website visitors. In this policy we explain how we will handle your personal data when you use our site.
2. How we use your “personal data”
2.1 In this Section 2 we have set out: (a) the general categories of personal data that we may process; (b) in the case of personal data that we did not obtain directly from you, the source and specific categories of that data; (c) the purposes for which we may process personal data; and (d) the legal bases of the processing.
2.2 We may process data about your use of our website and services (“usage data”). The usage data may include your IP address, geographical location, browser type and version, operating system, referral source, length of visit, page views and website navigation paths, as well as information about the timing, frequency, and pattern of your service use. The source of the usage data is our analytics tracking system (which system is only enabled with your explicit consent). This usage data may be processed for the purposes of analysing the use of the website and services. We ask for your consent before applying the tracking system but the legal basis for the processing of data collected by the tracking system is our legitimate interests, namely monitoring and improving our website and services.
2.3 We may process information contained in any enquiry you submit to us regarding goods and/or services (“enquiry data“). The enquiry data may be processed for the purposes of offering, marketing, and selling relevant goods and/or services to you. The legal basis for this processing is our legitimate interests, namely responding to your enquiry and/or the performance of a contract between you and us and/or taking steps, at your request, to enter into such a contract.
2.4 We may process information that you provide to us for the purpose of subscribing to our email notifications and/or newsletters (“notification data“). The notification data may be processed for the purposes of sending you the relevant notifications and/or newsletters.. We will ask for your prior consent to sending these types of communications unless we are relying on the “soft opt-in” exemption. This exemption applies when you already receive services/goods from us and we send you information on similar goods/ services. This is because it is necessary for our legitimate interests (to grow our business and to show-case our services). You can ask us to stop sending you email notifications and/or newsletters at any time by following any opt-out links on any relevant message sent to you or by contacting us at any time. Where you opt-out of receiving these messages, this will not apply to personal data provided to us for other purposes.
2.5 We may process information contained in or relating to any communication that you send to us (“correspondence data“). The correspondence data may include the communication content and metadata associated with the communication. Our website will generate the metadata associated with communications made using the website contact forms. The correspondence data may be processed for the purposes of communicating with you and record-keeping. The legal basis for this processing is our legitimate interests, namely the proper administration of our website and business and communications with users; and/or the performance of a contract between you and us and/or taking steps, at your request, to enter into such a contract.
2.6 We may process any of your personal data identified in this policy where necessary for the establishment, exercise or defence of legal claims, whether in court proceedings or in an administrative or out-of-court procedure. The legal basis for this processing is our legitimate interests, namely the protection and assertion of our legal rights, your legal rights and the legal rights of others.
2.7 We may process any of your personal data identified in this policy where necessary for the purposes of obtaining or maintaining insurance coverage, managing risks, or obtaining professional advice. The legal basis for this processing is our legitimate interests, namely the proper protection of our business against risks.
2.8 In addition to the specific purposes for which we may process your personal data set out in this Section 2, we may also process any of your personal data where such processing is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person.
2.9 We do not actively collect any special categories of personal data via the website (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, 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.
2.10 Where we need to collect personal data by law, or under the terms of a contract we have with you and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with goods or services).
3. Providing your personal data to others
3.1 We may disclose your personal data to any member of our group of companies this means our subsidiaries, our ultimate holding company and all its subsidiaries insofar as reasonably for the purposes, and on the legal bases, set out in this policy.
3.2 We may disclose your personal data to our insurers and/or professional advisers insofar as reasonably necessary for the purposes of obtaining or maintaining insurance coverage, managing risks, obtaining professional advice, or the establishment, exercise, or defence of legal claims, whether in court proceedings or in an administrative or out-of-court procedure.
3.5 Please see our Cookies Notice [insert link] for more information on any third party cookies used by our site.
4. International transfers of your personal data
4.1 In this Section 4, we provide information about the circumstances in which your personal data may be transferred to countries outside the United Kingdom. Where we do this, we will ensure that the transfer is to a country covered by a decision of the ICO or is otherwise made in circumstances where we have put appropriate safeguards in place to protect your personal data in accordance with the UK data protection laws.
4.2 We and our other group companies have offices and facilities in the United Kingdom.
4.3 The hosting facilities for our website are situated in the United Kingdom.
5. Retaining and deleting personal data
5.1 This Section 5 sets out our data retention policies and procedure, which are designed to help ensure that we comply with our legal obligations in relation to the retention and deletion of personal data.
5.2 Personal data that we process for any purpose or purposes shall not be kept for longer than is necessary for that purpose or those purposes.
5.3 Your enquiry data and correspondence data will usually be destroyed 6 months after we have dealt with your enquiry/correspondence unless it is required for an ongoing relationship that we may have with you.
5.4 Your notification data is retained for as long as you wish to receive relevant notifications and/or newsletters from us. If you opt-out we may be required to retain some of your data so that we can make sure that we do not contact you.
5.5 Your usage data does not usually identify you and therefore may be retained indefinitely without further notice to you.
5.6 In some cases it is not possible for us to specify in advance the periods for which your personal data will be retained. In such cases, we will determine the period of retention based on its necessity for the proper administration of our website and business and/or the performance of a contract between you and us and/or taking steps, at your request, to enter into such a contract.
5.7 Notwithstanding the other provisions of this Section 5, we may retain your personal data where such retention is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person.
5.8 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.
6.1 We may update this policy from time to time by publishing a new version on our website. It was last updated on 15th of February 2023.
6.2 You should check this page occasionally to ensure you are happy with any changes to this policy.
6.3 We may notify you of changes to this policy by email or other means of communication.
7. Your rights
7.1 In this Section 7, we have summarised the rights that you have under data protection law. Some of the rights are complex, and not all of the details have been included in our summaries. Accordingly, you should read the relevant laws and guidance from the regulatory authorities for a full explanation of these rights.
7.2 Your principal rights under data protection law are: (a) the right to access; (b) right to rectification; (c) the right to erasure; (d) the right to restrict processing; (e) the right to object to processing; (f) the right to data portability; (g) the right to complain to a supervisory authority; and (h) the right to withdraw consent.
7.3 You have the right to confirmation as to whether or not we process your personal data and, where we do, access to the personal data, together with certain additional information. That additional information includes details of the purposes of the processing, the categories of personal data concerned and the recipients of the personal data. Providing the rights and freedoms of others are not affected, we will supply to you a copy of your personal data. The first copy will be provided free of charge, but additional copies may be subject to a reasonable fee. You can request a copy of the personal data we hold by contacting us. Please note that we may in return request copies of valid identification.
7.4 You have the right to have any inaccurate personal data about you rectified and, taking into account the purposes of the processing, to have any incomplete personal data about you completed.
7.5 In some circumstances you have the right to the erasure of your personal data without undue delay. Those circumstances include: the personal data are no longer necessary in relation to the purposes for which they were collected or otherwise processed; you withdraw consent to consent-based processing; you object to the processing under certain rules of applicable data protection law; the processing is for direct marketing purposes; and the personal data have been unlawfully processed. However, there are exclusions of the right to erasure. The general exclusions include where processing is necessary: for exercising the right of freedom of expression and information; for compliance with a legal obligation; or for the establishment, exercise or defence of legal claims.
7.6 In some circumstances you have the right to restrict the processing of your personal data. Those circumstances are: you contest the accuracy of the personal data; processing is unlawful but you oppose erasure; we no longer need the personal data for the purposes of our processing, but you require personal data for the establishment, exercise or defence of legal claims; and you have objected to processing, pending the verification of that objection. Where processing has been restricted on this basis, we may continue to store your personal data. However, we will only otherwise process it: with your consent; for the establishment, exercise or defence of legal claims; for the protection of the rights of another natural or legal person; or for reasons of important public interest.
7.7 You have the right to object to our processing of your personal data on grounds relating to your particular situation, but only to the extent that the legal basis for the processing is that the processing is necessary for: the performance of a task carried out in the public interest or in the exercise of any official authority vested in us; or the purposes of the legitimate interests pursued by us or by a third party. If you make such an objection, we will cease to process the personal information unless we can demonstrate compelling legitimate grounds for the processing which override your interests, rights and freedoms, or the processing is for the establishment, exercise or defence of legal claims.
7.8 You have the right to object to our processing of your personal data for direct marketing purposes (including profiling for direct marketing purposes). If you make such an objection, we will cease to process your personal data for this purpose.
7.9 You have the right to object to our processing of your personal data for scientific or historical research purposes or statistical purposes on grounds relating to your particular situation, unless the processing is necessary for the performance of a task carried out for reasons of public interest.
7.10 To the extent that the legal basis for our processing of your personal data is:
(a) consent; or (b) that the processing is necessary for the performance of a contract to which you are party or in order to take steps at your request prior to entering into a contract,
and such processing is carried out by automated means, you have the right to receive your personal data from us in a structured, commonly used and machine-readable format. However, this right does not apply where it would adversely affect the rights and freedoms of others.
7.11 If you consider that our processing of your personal information infringes data protection laws, you have a legal right to lodge a complaint with the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.
7.12 To the extent that the legal basis for our processing of your personal information is consent, you have the right to withdraw that consent at any time. Withdrawal will not affect the lawfulness of processing before the withdrawal.
7.13 You may exercise any of your rights in relation to your personal data by contacting us.
7.14 You will not have to pay a fee to exercise any of your rights. However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.
7.15 We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). 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.
7.16 We try to respond to all legitimate requests within one month. 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.
8. Third party websites
8.1 Our website may include hyperlinks to, and details of, third party websites. 8.2 We have no control over, and are not responsible for, the privacy policies and practices of third parties.
9. Personal data of children
9.1 Our website and services are targeted at persons over the age of 16 and we do not knowingly collect data relating to children
9.2 If we have reason to believe that we hold personal data of a person under that age in our databases, we will delete that personal data.
10. Updating information
10.1 Please let us know if the personal information that we hold about you needs to be corrected or updated.
11. How to contact us
11.1 Our principal place of business is Archibald Hope House, Eskmills Park, Station Road , Musselburgh EH21 7PQ. ICHS Group Ltd is a wholly owned subsidiary of Dow Investments Plc.
11.2 You can contact us: (a) by post, to the postal address given above. (b) using our website contact form; (c) by telephone, on the contact number published on our website from time to time; or (d) by email, using the email address published on our website from time to time.
12. Data protection officer
12.1 You can contact our Data Protection Officer with respect to our obligations under data protection law using any of the contact methods listed in Section 12.