Privacy Policy

1       Introduction

This Privacy Policy of Walraven Limited, hereafter referred to as “Walraven” provides information about the personal data we process of website visitors, commercial contacts, customers and business partners of Walraven. Walraven considers it important to carefully process your personal data, and to provide you with clarity about the purposes for which we are processing your personal data, how we process your personal data and the legal rights you have regarding your personal data. We process your personal data in compliance with the EU GDPR (General Data Protection Regulation).

This Privacy Policy is subject to change. We will always publish the latest version of this Policy on our website(s).

Walraven Limited is the controller and responsible for your personal data (referred to as “Walraven”, “we”, “us” or “our” in this privacy notice).

We have appointed a data privacy manager who is responsible for overseeing questions in relation to this Privacy Policy. If you have any questions about this Privacy Policy, including any requests to exercise your legal rights, please contact the data privacy manager using the details set out below.

Contact details

Our full details are:

Full name of legal entity: Walraven Limited

Name or title of data privacy manager: Katherine Humphries

Email address: [email protected]

Postal address: Thorpe Way, Banbury, OX16 4UU

Telephone number: 01295 75 34 00

You have the right to make a complaint at any time to 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.

 

2       Your rights

Under certain circumstances, you have rights under data protection laws in relation to your personal data.

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

2.2   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.

2.3   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.

2.4   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.

2.5   Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios: (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.

2.6   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 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.

2.7   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 using the contact details set out above.

No fee usually required

You will not have to pay a fee to access your personal data (or to exercise any of the other 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.

What we may need from you

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 to speed up our response.

Time limit to respond

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.

 

3       Personal data we process

The types of personal data we collect  and what we do with it will depend  on your relationship(s) with Walraven. Below we describe the types of relationship(s) you may have with Walraven and how we collect and process personal data for each type of relationship.

3.1       Through electronic newsletters

You can subscribe to one or more of our electronic newsletters via our website. We will always ask for an ‘opt-in’, meaning that you will explicitly provide your consent that we may contact you via newsletters. At any time, you can unsubscribe to electronic newsletters by clicking the ‘unsubscribe’ link which is provided in each newsletter. After unsubscribing to our newsletter, your personal data will be removed from our records.

3.2       As a commercial relationship

Walraven’s marketing and sales teams aim to build good relationships with (a) customer contact persons and (b) contact persons of organisations who are not (yet) a customer. In building commercial relationships in most occasions, it is necessary that personal (contact) information is exchanged. For example during a marketing/sales activity or campaign, a meeting with Walraven, during a trade fair, exhibitions, symposia and through direct established contacts by a Walraven employee. Providing personal data in this context is always on a voluntary basis only. Personal data you provided in this context is maintained in our Customer Relationship Management system, and will be removed when no longer necessary for the purpose you provided this data, unless you notified us that you want to be kept up to date with our solutions and activities.

3.3       As a customer

Walraven is only active in the B2B market. This means that Walraven sells its solutions, products and services to organisations. If you acquire our solutions, products and/or services directly from Walraven you have become a customer. In this case you will be registered as a customer in our information systems. This registration will include the personal contact details of one or more contact persons of the customer. This personal data will be updated or removed if you are no longer a customer of Walraven and/or there is a change in contact person of your organisation. We do not collect any financial data over our website.

3.4       As a supplier / business partner / other business relationship

Walraven maintains relationships with suppliers of raw material, components, trade goods and also maintains relationships with business partners and other organisations (like accountancy / payroll / IT service providers). For these relationships, it is necessary to register the personal contact details of one or more contact person(s). This personal data will be updated or removed if the organisation is no longer a relation of Walraven and/or there is a change in contact person of that organisation.

3.5       As participant of training / visiting showroom

As a training participant or as a visitor to our showroom, on some occasions it is necessary that you leave your personal (contact) details. These details we may use to contact you for evaluation purposes, to notify you of changes in dates/course content or to send you additional information in case you requested this. Personal data you provided in this context will be removed when no longer necessary for the purpose you provided this data, unless you notified us that you want to be kept up to date with our solutions and activities.

3.6       Enquiries

If you approach Walraven with an enquiry or questions, for instance about our solutions, products or services, we will not record your personal information, unless we need to get back to you for additional support or enquiry. If this is the case, we will remove your personal data as soon as you have been provided with an answer. This includes enquiries via telephone, email, fax and the ‘Ask Your Question’ form on our website.

3.7       When visiting our website

For any person visiting our website, we gather usage statistics including IP address (anonymised, only traceable to a geographic area and not to a specific person/connection), geographical location and visiting statistics (including duration of visit and page views). We use these statistics to improve our website, solutions or services. Please also refer to 7, Cookie and tracking policy. Our 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 statements. When you leave our website, we encourage you to read the privacy policy  of every website you visit.

3.8       When visiting our premises

Our building and surroundings (parking space) may be secured with CCTV (camera). You are notified of this the moment you enter our premises. CCTV data is kept for security purposes only, for 72 hours at a maximum, unless there is a reason to keep this data longer (for instance for a police investigation).

 

We do not collect any Special Categories of Personal Data about you (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.

We may receive personal data about you from various third parties and public sources as set out below:

 

4       Retention of personal data

In any of the above relationships, we will not keep your personal data for longer than is necessary for that purpose or those purposes. However, we will retain documents (including electronic documents) containing personal data:

5       Sharing personal data

In any of the relationships described above, we will use your personal data for the sole purpose of this relationship. We never sell, trade or rent your personal details to others outside Walraven without your consent or share it with third parties other than in the circumstances described below.

5.1       Sharing of personal data within the Walraven Group

As an international business with common processes, information systems and employees working together internationally, we share data within the Walraven Group. The Walraven Group means our subsidiaries, our holding company and its subsidiaries. Personal data may be stored, processed in and transferred between any of the countries in which we operate in order to enable us to use the information in accordance with this Privacy Policy. This may include Walraven locations which do not have data protection laws equivalent to those in effect in the European Economic Area: United States

of America, Russia, Ukraine, United Arab Emirates, India, Turkey, China and Australia. This Privacy Policy applies equally to any subsidiary / legal entity within the Walraven Group.

5.2       Sharing of personal data

Walraven will not share personal data with third parties, unless this is under our control and under strict conditions. If we need a third party to access your information, we will ensure that this third party acts in accordance with this Privacy Policy and that a Non Disclosure Agreement is signed with this third party. Examples of third parties in this respect may include business partners, market survey agencies, HR service providers and consultancies.

5.3       Third parties processing personal data under our control

Walraven uses third parties like service providers (like payroll), external hosting providers or Software as a Service (SaaS) providers that process personal data under our control. In the case where a third party processes personal data under our control, Walraven ensures that a Data Processing Agreement (as described in the GDPR) is in place.

6       Securing personal data

We implemented appropriate technical and organizational measures to protect your personal data against accidental or unlawful destruction or accidental loss, alteration, unauthorized disclosure or access and against all other forms of unlawful processing. Also, we require our data processors to implement such appropriate technical and organizational measures. For this, we have implemented an Information Security Management System based on ISO/IEC 27001:2013. In the unlikely event of a (suspected) personal data breach we will notify you and the appropriate Data Protection Authority within 72 hours after discovery, according to the rules set out in the GDPR.

7       Cookie and tracking policy

www.walraven.com is the website owned and operated by Walraven. This section provides you with information on what cookies may be set when you visit the site and how to reject or delete those cookies. By continuing to use this website, you are agreeing to our use of cookies in the manner described in this policy.

7.1       What are cookies?

A cookie is a small data file that is placed on your computer or other device to allow a website to recognise you as a user when you return to the website using the same computer and web browser, either for the duration of your visit (using a ‘session cookie’) or for repeat visits (a ‘persistent cookie’). Other similar files work in the same way and we use the word ‘cookie’ in this policy to refer to all files that collect information in this way.

Cookies are an extremely common technology for remembering certain information about a visitor to a website. The vast majority of websites currently make use of cookies and they are commonly used for a wide range of tasks. We use the following cookies:

  1. Strictly necessary cookies: as necessary for website operation;
  2. Analytical/performance cookies: to analyse the use of the site, for example, recognising and counting the number of visitors and how they move around the site. This helps us to see what parts of the site are popular and which sections need improving to make the experience better for users;
  3. Functionality cookies: to recognise you when you return to the site so that content can be personalised for you, for example, by remembering your country and site preferences; and
  4. Targeting cookies: to record your visit to the site and the pages you have visited and links you have followed. We will use this to make the site more relevant to your interests.

This document gives you information on the specific cookies used on this site.

7.2       How to control and delete cookies

When you accessed the site, you were presented with a message that notified you of our use of cookies. We had to use a cookie to present you that notice (you can see details of this cookie under ‘Cookie Acceptance’ in the table below). If you continue to use the site, more cookies and other tracking technologies will be placed on your computer as described in the table above in order to enhance your user experience whilst on the site. By continuing to use the site and/or by accepting our Terms and our Privacy Policy, you are agreeing to the use of such cookies and tracking technology.

We will not use cookies to collect personally identifiable information about you. However, if you wish to restrict or block the cookies which are set by this site (or, indeed, on any other site) you can do this through your browser settings. The ‘Help’ function within your browser should tell you how. In respect of cookies that are set via this site, it may also be possible to disable these cookies by following the instructions provided in the section titled ‘Opting Out’ in each of the tables below.

Alternatively, you may wish to visit http://www.allaboutcookies.org/ which contains comprehensive information on how to do this on a wide variety of browsers. You will also find details on how to delete cookies from your computer, as well as more general information about cookies. Please note that, as these websites are not owned or operated by Walraven we are not responsible for any of the content on them.

Please be aware that restricting cookies may mean that you will not be able to take full advantage of all the features or services available on this site.

7.3       Main cookies used on our site

Below is a list of the main cookies used on the site and what each is used for

Cookie Name Google Analytics
ID _ga

_gat

Purpose This cookie enables us to:

collect information about your computer, including your IP
address, operating system and browser type, for system
administration and in order to create reports, estimate our
audience size and usage patterns; and anonymously track
actions around the Site.

Expires This is a persistent cookie, which remains on your device after your
browsing session has ended.
Source of Cookie Google
Further Information This Site uses Google Analytics; a web analytics service provided
by Google, Inc.  Google Analytics sets a cookie in order to evaluate
your use of this Site and compile reports for us on website activity.
This cookie does not collect information that identifies an individual.
For how to reject or delete these cookies see
https://tools.google.com/dlpage/gaoptout.

 

7.4       Third-party cookies

Please note that to improve your website experience third parties may also use cookies. For example, we sometimes embed video content from websites such as YouTube and YouTube may set cookies on your browser in order to display the video and monitor non-attributable statistical information.

As a result, when you visit a page with content embedded, you may be presented with cookies from these websites. We do not control the dissemination of these cookies and you should check the relevant third party website for more information about these.

Information on YouTube’s Privacy Policy can be found here: https://www.youtube.com/static?template=privacy_guidelines.

7.5       Email Tracking

Some of the emails we send to you may contain a ‘pixel’ or tracked links which allows us to identify when you have opened the email and to verify which links contained in the email you have accessed. We use this information to determine which parts of our emails are of most interest to you.

You can delete the pixel by deleting the email. If you do not wish to download the pixel to your computer or other devices, you can do so by selecting to receive emails from us in plain text rather than HTML.

Alternatively you can unsubscribe from our mailing list by clicking on the unsubscribe link in the email or by contacting us at [email protected]

7.6       Changes

We may make changes to this Cookie Policy at any time by posting a copy of the revised policy on the site. Any changes will take effect on the date on which we post the modified terms on the site. Your continued use of the site means that you agree to be bound by the modified policy.

7.7       Contact us

If you have any questions or concerns about cookies or your privacy when using this site, please contact us at [email protected]

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