Privacy Statement

Stannah Group Privacy Statement

Last updated: July 2021

1. Introduction

This is the privacy statement for the Stannah Group of companies. When we refer to Stannah we mean:

• Stannah Lifts Holdings Limited
• Stannah Lift Services Limited
• Stannah Stairlifts Limited
• Stannah Lifts Limited
• Stannah Management Services Limited
• Global Upholstery Solutions Limited
• All UK businesses wholly owned by Stannah Lifts Holdings Limited

Overseas Stannah subsidiaries operate according to privacy statements relevant to their local markets.

Contact details

Data Protection Team
Stannah
Watt Close
East Portway
Andover
SP10 3SD

Tel: 01264 364311
Email: dataprotection@stannah.co.uk

We comply with current requirements to notify our data processing activities to the Information Commissioner’s Office and are registered as follows:

• Stannah Lift Services Limited (Z5828389)
• Stannah Lifts Holdings Limited (Z5829398)
• Stannah Lifts Limited (Z564749X)
• Stannah Management Services Limited (Z5229073)
• Stannah Microlifts Limited (Z5828270)
• Stannah Stairlifts Limited (Z5647441)

2. Information we hold

Stannah may hold the following details about you:

• Personal information such as your name and address and any information you may have given us when discussing your needs or submitted in writing which may include sensitive personal data
• The number that you telephoned us on or email address that you contacted us from
• Digital information, including your IP address and how you found us online
• Contact preferences
• Recordings of calls you have made to us
• Information pertaining to your contract
• Transaction records (but note no bank or card details are recorded or retained)
• Details of any sales or service visits we may have made to you and any calls or contact we may have with each other
• Technical information regarding your product and/or installation

3. Sensitive personal data

For some products it is helpful to collect and process information defined as ‘sensitive’, such as information about health conditions. This information may be used by our sales consultants to help them specify the product, by our installation teams, service teams or other teams to offer you the most appropriate product or service. We will always ask for your permission to store and process sensitive information and it will always be held securely.

4. Where do we collect personal data

Much of the data we hold about you will be data you provide to us directly.  However, we may also collect data about from the following sources:

• a mobility shop or other referrer
• a Local Authority if they are providing any funding
• any relatives or other contacts you nominate to liaise with us on your behalf
• information you may make available via social media

5. How do we use personal data

We will only use personal data when the law allows us to do so and relying on a relevant basis for lawful processing in each instance.  We will use your personal data in the following circumstances, relying on the basis of processing indicated:

Basis of processing: Where we need to perform a contract we are about to enter into or have entered into with you.

• To manage your enquiry and provide you with information, products or services that you request from us, along with any follow-up services (contact details).
• To carry out our obligations arising from any contracts entered into between you and us (contact details, payment information and any information relating to personalisation status).

Basis of processing:  Where it is necessary for our legitimate interests (or those of a third party and we have undertaken an assessment to determine that processing for those interests (listed below) does not outweigh your interests and fundamental rights, considering the nature and impact of the processing and any relevant safeguards we can put in place.

• To ensure that content from our website is presented in the most effective manner for you and for your device (online identifiers, location data and other technical information).
• To provide you with information, products or services that we feel may interest you (where you have consented to be contacted for such purposes to the extent consent is required by law) (contact details and any information relating to personalisation preferences).
• To allow you to participate in interactive features of our service, when you choose to do so (online identifiers, location data and other technical information).
• To share certain data with credit agencies in order to verify the funding for your purchase (contact details, date of birth, addresses, bank account or payment card details).
• To notify you about changes to our service (contact details).
• To maintain a basic amount of information about you and your transaction history, in order to provide you with a service tailored to your preferences (contact details, payment history and any information relating to personalisation status).
• To send you invites to review our products or services through third party services (email address). Where we share data for this purpose, third parties will not be able to use your data for any other purpose and we will do so subject to a written agreement that ensures suitable protections are in place. You have the right to withdraw consent to such use at any time by contacting us.

Basis of processing: Where we need to comply with a legal or regulatory obligation.

• To retain basic transaction details for the purpose of tax reporting (contact details and transaction history).

Basis of processing: Where you have consented to the processing.

• To use any information you provide to us relating to your health or medical conditions (see above) where that information is helpful in ensuring you receive the most appropriate products and services (information relating to medical conditions and health).
• In cases where we are unable to provide a product directly but we have a distributor who may be able to help you we will ask for your permission to pass over your data and we will maintain a record for administrative and accounting purposes (contact details and any information relating to personalisation status.
• To use non-essential cookies on our website (see “Cookies” section below for further information) (online identifiers, location data and other technical information).  You have the right to withdraw consent to such use at any time by contacting us. You have the right to withdraw consent to such use at any time by contacting us but please note that some or all parts of our website may no longer be accessible to you.
• To send you direct marketing communications via email, text message, post or telephone call (contact details).  You have the right to withdraw consent to any such use at any time by contacting us.

Other notes about how we use personal data:

• Please note that we may process your personal data for more than one lawful basis depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal basis we are relying on to process your personal data.
• 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. Please contact us if you would like further details of any additional purposes of processing.  If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis that allows us to do so.
• 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 services). If this happens, we may have to cancel, or be unable to provide, any services you have requested.
• Please note that we may process your personal data without your knowledge or consent where required or permitted by law.
• We may collect, use and share aggregated data such as statistical or demographic data for any purpose. Aggregated data may be derived from your personal data but is not considered “personal data” in law as this data does not directly or indirectly reveal your identity. For example, we may aggregate your website usage data to calculate the percentage of users accessing a specific website feature.  However, if we combine or connect aggregated data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy policy.
• If you provide us with any personal data relating to relatives, partners or other individuals it is your duty to make such persons aware that their personal data may be shared with us and to provide them with appropriate information about how their personal data may be processed by us.

6. Hoax requests

It is unfortunate but we often receive hoax requests for brochures. Mostly these are done in the spirit of jest but occasionally these are malicious. It is with regret that in all of these cases we cannot provide any information about who submitted the request, including photocopies of coupons, call recordings, IP addresses etc., except to police or, where applicable, regulatory authorities.

7. Data retention

We will not keep personal data in a form which permits identification of individuals for longer than is necessary for the purpose or purposes for which they were collected.  We will take all reasonable steps to destroy, or erase from our systems, all data which is no longer required. 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 personal data, the purposes for which we process information and whether we can achieve those purposes through other means, and the applicable legal requirements.

We will only keep personal data for as long as is necessary for the purpose or purposes for which that personal data is processed; and we will let anyone about whom we process data know how long that is or the criteria that go into deciding how long that is.

We may sometimes 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.

If you enquire with us we will hold your data for five years from the date we received your enquiry unless you ask us to remove your information beforehand. If you ask us to remove your data we will then hold your information in a suppression file to match against any third party data we may buy in and you will not be marketed to or receive any information from us.

If you purchase a product or service from us we will still hold your data following the expiration of the warranty period for the purposes of any future retrofit, product or service liability claims.

8. Call recordings

We record some calls for training and monitoring purposes. Where calls are recorded, you will be notified prior to connection to an agent.

Our systems automatically record the telephone number that you dialled in from. We do not use this data for contact purposes without consent other than we will use this number in the event you did not get through to us and we return your call to establish the nature of your enquiry.

9. Social media

We monitor social media feeds and may respond to relevant comments.

10. Marketing

Your details may be used to send you marketing information relevant to your enquiry for a period of a maximum of five years following your initial contact.

If you make a request for product or service information and provide us with your details we will use these to fulfil your request and periodically follow up your enquiry. You can tell us to stop following up at any time.

We will ask for your specific consent for any additional marketing activity, for example if we wanted to send you something we thought you might be interested in but was unrelated to your original enquiry. We will maintain a record of when and how we obtained your consent. You can withdraw your consent at any time.

We will ensure that any data that we purchase is from a reputable source, that data has been screened against preference services and has been collected and maintained in compliance with data protection legislation.

We periodically undertake market research, either directly or via independent third parties to help us better understand our market and how we can improve our products and services. We may profile our data based on the information you provide and any data we may acquire externally to identify relevant groups to contact.

Customer satisfaction

It is incredibly helpful for us to understand how satisfied you are with your experience of Stannah. We may ask you to complete a Stannah customer satisfaction survey, either in print or online, which we will use to monitor our performance and any concerns our customers raise.

We may invite you to complete an online customer review via a third-party service. These organisations will process your data on our behalf and cannot use your data for their own purposes.

Occasionally, as part of our commitment to independent accreditation services, we may invite you to complete surveys that will be used by these third parties to monitor our performance against their criteria. We will not, however, share your data with these organisations.

Profiling and automated decision making

Based on the information that you provide to us and information we may obtain through cookies that you consent to and  third party services, we may profile your data e.g. customer type, location, demographics, product and service interest areas to enable us to tailor our sales and marketing communications to you. You have the right to object to profiling and automated decision making.

We may conduct credit checks where necessary for contractual purposes.

11. Cookies and web tracking

Our websites use a range of cookies and tracking pixels to help us ensure our websites provide information effectively. Please see the cookie statement for each of our websites for full details.

www.stannah.com/cookies

corporate.stannah.com/stannah-lifts-holdings-ltd-website-cookie-privacy-information/

www.stannahlifts.co.uk/cookies

12. Your rights

Every individual has rights regarding the use of their data. These are:

• The right to be informed
• The right of access
• The right to rectification
• The right to erasure
• The right to restrict processing
• The right to data portability
• The right to object
• Rights around automated individual decision making including profiling

Certain rights are not available in all situations but we would be happy to advise if you have any queries about your rights at any time.

Exercising your rights

If you do not wish to receive any marketing materials from Stannah or exercise any of your rights over your data you can email, telephone or write to us at the addresses below:

Data Protection Team
Stannah
Watt Close
East Portway
Andover
SP10 3SD

Tel: 01264 364311
Email: dataprotection@stannah.co.uk

We aim 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.

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.

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 for further information in relation to your request to speed up our response.

Correcting your details

It is important that any data we hold is up-to-date and correct so please inform us of any changes. You have the right to correct any incorrect data and can do so by writing to or emailing the Data Protection Team.

Making a request to see your data

If you wish to see a copy of the data that we hold on you, please write to Data Protection Team. Please include your customer number if possible and details of the information you require.

13. Processing information outside the UK

Some of the third party tools and services that we use process our data on servers outside the UK.  If you deal directly with any such parties by following links from our site, you are providing your data to them as a data controller in their own right and you should ensure you are comfortable with the privacy policy on their website. If we are sharing the data, we shall ensure that it is secure and done under contractual arrangements that offer the same level of protection as in the UK.

14. Sharing your details

Within Stannah

Information about you and the products you hold with us may be used across the Stannah Group in order for us to fulfil your enquiry and/or our contract with you and for:

• Understanding your requirements
• Making decisions about the suitability of product to be offered
• Legal and regulatory compliance
• Tracking debtors and collecting debts

With other organisations

We may share information with other organisations if the following applies:

• they provide products, services or research on behalf of Stannah, for example sub-contractors supplying electrical services. Our contract with them will not allow them to use your information for anything other than the fulfilment of our contract with you.they provide administrative, processing, development, analytical or other services to help us in our sales, marketing, digital, administration and product development activities.
• we need to contact credit agencies to check your creditworthiness prior to committing to a purchase you wish to make.
• your data has been passed to us by a third party such as a mobility shop or other paid lead generator we will share sufficient information with them for accounting and administration purpose.
• they provide market research services to help us improve our product, marketing and services.
• they provide review services and may ask you on our behalf to complete a product or service review or questionnaire.
• we transfer rights or obligations of our contract with you.
• we have asked and been given your consent.
• we are required or permitted to do so by law or regulation.
• Where we share data with agents and sub-contractors we will ensure that is supported by a written contract and that your data is treated confidentially and securely, and in accordance with data protection legislation.

Stannah will not sell, share or give any data to external companies for the marketing purposes of those companies.

15. Security of your data

All our data is held on secure servers or secure private cloud storage. We take data security very seriously and use a range of tools, protocols and services to ensure data is protected.

16. Complaints about how we have used your data

If you have a complaint about how we have used your data please contact the

Data Protection Team
Stannah
Watt Close
East Portway
Andover
SP10 3SD

Tel: 01264 364311
Email: dataprotection@stannah.co.uk

If you are unhappy with our response you may lodge a complaint with the Information Commissioner’s Office.

Data Protection Team
Information Commissioner’s Office
Wycliffe House
Water Lane
Wilmslow
Cheshire SK9 5AF

Tel: 0303 123 1113

Alternative formats available on request.