TTG Global Limited (reg. no. 6792964) (“TTG”) and its group companies (together “we”, “us”, “our”) are committed to protecting and respecting your privacy.
The UK trading companies within the TTG group are:
- Simoco EMEA Limited (Reg. no. 04382515)
- Simoco Wireless Solutions Limited (Reg. no. 07038450)
- affini Technology Limited (Reg. no. 04574231)
This Privacy Notice applies to all EU based group companies and sets out the basis on which any personal data we collect from you, or that you provide to us, will be processed by us.
The person responsible for data protection across all group companies is the CEO.
The General Data Protection Regulation (Regulation (EU) 2016/679), known as the GDPR, is a new regulation which replaces the Data Protection Regulation (Directive 95/46/EC). The GDPR aims to harmonise data protection legislation across EU member states, enhancing privacy rights for individuals and providing a strict framework within which commercial organisations can legally operate.
Even though the UK has expressed its intention to leave the EU in March 2019, the GDPR will be applicable in the UK from 25th May 2018. The Government intends for the GDPR to continue in UK law post Brexit and has also introduced a Data Protection Bill to replace the current Data Protection Act in due course.
Your rights under the GDPR are set out in this Privacy Notice but will only apply once the GDPR becomes law on 25th May 2018.
Please read the following carefully to understand our views and practices regarding your personal information and how we will treat it. If you have any questions about this Privacy Notice or the use of your information by any group company, please contact us at email@example.com.
Who are we and what we do
We are a group of telecommunications, solutions and manufacturing businesses. We also provide managed IT services, outsourcing and consultancy services to our clients. We collect the personal data from the following sources to allow us to undertake our business;
- Websites which are owned or operated by TTG and have an address (or URL) which is operated by TTG (the "Websites") or TTG branded websites which are hosted by a third party (the "TTG branded Websites") the "Websites" and the "TTG branded Websites" together for the purposes of this policy are referred to as the "TTG Websites”.
- E-mail or other electronic messages between you and TTG;
- Mobile or desktop applications that you download from TTG Websites or from an app store;
- Software or services you use or used by your employer under license from TTG; or
- From interactions with advertising or application accessible on other third-party websites.
We collect information about you to carry out our core business and ancillary activities.
How we obtain your Personal Data
- Information you give us, or we may collect from you
We may collect information about you when you fill in forms on a group company website, for example www.affini.co.uk or by corresponding with us by phone, e-mail or otherwise. It includes information you provide when you or your company register to use our site, to enter our database, subscribe to our services, attend our events, participate in discussion boards or other social media functions on our site or enter a competition, promotion or survey.The information you give us, or we collect about you may include:
- Information contained in your CV or business card such as your name, address, private and corporate e-mail address and phone number;
- Information contained in any documents that you send to any of us for identity verification purposes such as your passport or driving licence;
- Links to your professional profiles available in the public domain e.g. LinkedIn, Twitter, business Facebook or corporate website,
- Information that you provide about yourself when negotiating or entering into a contract with us.
- Processing data required to fulfil obligations to either yourself such as employment contracts or obligations to regulatory or governmental bodies.
- Information collected to fulfil contractual agreements such as in relation to telematics contracts.
- Information we collect about you when you visit our websites
With regard to each of your visits to our websites, for example, www.affini.co.uk, we will automatically collect the following information:
- Information that you provide by filling in forms on any of our websites. This includes information provided to us at the time of registering to use any of our websites (where applicable), subscribing to any of our services (where applicable), personalising any of our websites with your preferences or requesting further services;
- Technical information relating to your visits including, but not limited to, traffic data, location data, blogs, other communication data and the resources that you access;
- Information when you respond to a survey and/or when you report a problem with one any of our websites.
- Information we obtain from other sources
This is information that we obtained about you from other sources such as LinkedIn, corporate websites, job boards, online CV libraries, your business card, personal recommendations or via agreements and contracts with our clients.In this case, we will inform you by sending you this Privacy Notice within a maximum of 30 days of collecting the data of the fact that we hold personal data about you, the source of the personal data and whether it comes from publically available sources, and for what purpose we intend to retain and process your personal data.
- Information you give us, or we may collect from you
Why we hold your Personal Data and how we use it
We may use personal information to facilitate order processing; to contact you if a problem arises with your order; to facilitate the employment application process; or for other uses consistent with this Statement.
We do not provide your personal information to third parties without your consent.
With your consent;
- We share the information you provide with TTG subsidiaries and related companies.
- We may also share your personal information with third-party business partners so that they may provide services to TTG that are consistent with this Statement, or as part of a specific product, service, or promotion.
- We may disclose personal information in special cases, such as when we believe in good faith that the law requires it.
- If you are a customer or other third party, we may use information held about you in the following ways:
- To carry out our obligations arising from any contracts entered into with us;
- To notify you about changes to any of our services;
- For customer service, customer satisfaction, product analysis and market research purposes;
- To ensure that content from our websites is presented in the most effective manner for you and for your computer;
- To provide you with information or services that you expressly request from us or which we feel may interest you, where you have consented to be contacted for such purposes;
- To meet any of our obligations under any applicable laws or regulations;
- To carry out any obligations or provide you with any other services, functionality or content which you specifically agree to on any of our websites;
- To help us establish, exercise or defend legal claims.
- Except for the mailing list activities which each group company runs on some parts of our websites, where you explicitly consent to receive materials from us, we will not use your personal information collected from our websites to carry out unsolicited marketing activities.
You may change your marketing preferences at any time by contacting us at DPO@affini.co.uk.
The legal basis for processing your Personal Data
Depending on the purpose for which we hold and process your data, we will rely on one or more of the following legal grounds to process your data:
- Legitimate Interests
Legitimate Interests means the interests of TTG and/or any of its group companies in conducting and managing our business. For example, we have an interest in ensuring that the information provided is correct or that we can meet our client’s requirements.Legitimate Interests can also apply to the processing of data that is in your interests. For example, we only wish to communicate relevant product updates and service notices that you require for products or services provided by us.When we process your personal information, we make sure we consider and balance any potential impact on you (both positive and negative), and your rights under data protection laws. 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).
- Necessary for the performance of a contract
Where we have commercial contracts we will hold data that is required for us to fulfil those contracts.
- Necessary for compliance with a legal obligation
If we are legally required to hold information on you to fulfil our legal obligations. For example, if you are a limited company contractor engaged with us and HMRC requires that we submit regular reports to them detailing the payments which we make to you and other information as set out in The Income Tax (Pay as You Earn)(Amendment No.2) Regulations 2015.
We will ask for your explicit consent to pass your personal data onto third parties. We will request your consent orally, by email or by an online process.Should we want or need to rely on consent for other processing activities, we will request consent orally, by email or by an online process for the specific activity we require consent for.Your responses will be recorded on our system.Where consent is the lawful basis for our processing, you have the right to withdraw your consent to this particular activity at any time by emailing DPO@affini.co.uk
- Children and consent
Our services are not intended for children and we do not actively process or collect data relating to children under 16.If the business does undertake data processing or collection in the case of children under 16 verifiable parental consent is required and will be sort prior to processing of such data.
- Legitimate Interests
Who do we share your Personal Data with?
We may share your personal data with:
- Any of our group companies located in the EEA;
- Clients and/or their third-party agents in relation to services you wish to be provided. We will only ever provide your details to a client/third parties in relation to a service you have contracted us to perform and if you have consented to us doing so;
- Third parties to enable the completion of checks for example; credit checking if we are providing credit services, We will notify you in advance of the checks we will undertake and seek your permission to us carrying them out;
- Managed service suppliers if our clients have a managed service programme;
- If you are engaged as a contractor your personal information will be provided to HMRC and/or third parties in order to meet our and the third party’s reporting obligations under The Income Tax (Pay as You Earn)(Amendment No.2) Regulations 2015;
- If you agree to us sending you documents electronically for signing your email address and/or a copy of the relevant document will be stored by salesforce.com CRM (operated by Salesforce) whose servers are located in the US. A Data Processing Agreement (based on the EU model clauses) is in place between TTG and Salesforce to cover the transfer of this data.
- Any third-party organisation to enable us to fulfil our contractual obligations; however we will ensure your data is protected to the same level as we undertake to you.
We may disclose your personal data to third parties:
- In the event that TTG sell or buy any business or assets, we may disclose your personal information to the prospective seller or buyer of such business or assets;
- In the event that we outsource any of our business functions under which we collect or store your information we will ensure that any such service provider adheres to at least the same obligations of security with regard to your information as undertaken by us;
- Where we use your information to carry out credit assessments we will need to share your information with credit reference agencies to assess your eligibility to trade with us.
- We may share your information with our associates, UK and overseas law enforcement agencies or regulatory authorities and other relevant bodies for crime prevention purposes.
The lawful basis for the third-party processing will include:
- Their own legitimate business interests in processing your personal data, in most cases to fulfil our obligations to you;
- Satisfaction of their contractual obligations to us as data controller;
- For a contract in place or in contemplation;
- To fulfil legal obligations.
Where do we store your Personal Data?
We will take all steps reasonably necessary to ensure that your information is treated securely and in accordance with this Privacy Notice.
All information that you provide to us in physical form such as documents will be stored securely at our offices or at a secure storage facility.
All information you provide to us electronically is stored on our secure servers located in the United Kingdom or on GDPR Compliant third-party servers.
Where a group company has given you (or where you have chosen) a password which enables you to access certain parts of our websites, you are responsible for keeping this password confidential. You must not share your password with anyone.
Unfortunately, sending information to us via post, fax, email or the internet is not completely safe and secure. Although we will do our best to protect your personal information, we cannot guarantee the security of your information sent to us by any of these means and any information sent to us in this way is at your own risk.
Once we have received your information, we will use strict procedures and security features to try to prevent unauthorised access and require our suppliers to do the same.
How long will we store your Personal Data for?
We understand our legal duty to retain accurate data and only retain personal data for as long as we need it for our legitimate business interests or where you are happy for us to do so. Accordingly, we have a data retention policy and run data routines to remove data that we no longer have a legitimate business interest in maintaining.
We segregate your data so that we keep different types of data for different time periods. The criteria we use to determine whether we should retain your personal data includes:
- The nature of the personal data
- Its perceived accuracy
- Our legal obligations
- Our expertise and knowledge of the industry by country and sector.
When we refer to "meaningful contact", we mean, for example, communication between us (either verbal or written), or where you are actively engaging with our services. We may archive part or all of your personal data or retain it on our financial systems only, deleting all or part of it from our systems. We may pseudonymise parts of your data, particularly following a request for suppression or deletion of your data to ensure that we do not re-enter your personal data on to our database, unless requested to do so.
For your information, Pseudonymised Data is created by taking identifying fields within a database and replacing them with artificial identifiers, or pseudonyms.
Our current Data Retention Policy is available on request.
You have the right to ask us not to process your personal information for marketing purposes. We will inform you (before collecting your information) if we wish to use your information for such purposes or if we intend to disclose your information to any third party for such purposes and we will collect your express consent from you if legally required prior to using your personal data for marketing purposes.
You can exercise your right to accept or prevent such processing by checking certain boxes on the forms we use to collect your information.
You can also exercise the right at any time by contacting firstname.lastname@example.org.
Our websites may, from time to time, contain links to and from the websites of our partner networks, advertisers and affiliates. If you follow a link to any of these websites, please note that these websites have their own privacy policies and that we do not accept any responsibility or liability for these policies.
Please check these policies before you submit any personal information to these websites.
The GDPR provides you with the following rights. To:
- Request correction of personal information that we hold about you. This enables you to have any incomplete or inaccurate information we hold about you corrected.
- Request deletion of your personal information. This enables you to ask us to delete or removed personal information where there is no good reason for us continuing to process it.
- Object to processing of your personal information 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. You also have the right to object where we are processing your personal information for direct marketing purposes.
- Request the restrictions of processing of your personal information. This enables you to ask us to suspend the processing of personal information about you, for example if you want us to establish its accuracy or the reason for processing it.
- Request the transfer of your personal information to another party in certain formats, if practicable.
- Make a complaint to a supervisory body which in the United Kingdom is the Information Commissioner’s Office. The ICO can be contacted at: https://ico.org.uk/concerns/
If you want to contact us to exercise any of your rights, you can write to any group company via: TTG Global Limited, Field House, Uttoxeter Old Road, Derby, DE1 1NH or contact us by email at: DPO@affini.co.uk.
Subject Access to information
The Data Protection Act 1998 (the “Act”), which is the current UK data protection law until 25th May 2018, and the GDPR, which comes into effect on 25th May 2018, give you the right to access information held about you.
You may contact us to ensure your data is accurate and complete.
Your right of access can be exercised in accordance with the Act (until 25th May 2018) and the GDPR (on and after 25th May 2018).
We will provide a copy of the information free of charge. However, we will charge a ‘reasonable fee’ when a request is manifestly unfounded or excessive, particularly if it is repetitive.
We may also charge a reasonable fee to comply with requests for further copies of the same information, the fee will based on the administrative cost of providing the information.
A subject access request should be sent to DPO@affini.co.uk.
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Changes to our Privacy Notice
Any changes we may make to our Privacy Notice in the future will be publicised on this page and may be notified by email.
Questions, comments and requests regarding this Privacy Notice are welcomed and should be addressed to DPO@affini.co.uk.
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