This policy explains:
- who we are
- why we collect personal data about you
- what kinds of personal data we collect
- where we get it from
- how we use it;
- direct marketing;
- who we might share it with;
- how we store and secure it;
- how long we keep it;
- your rights; and
- how to complain about our use of personal data.
Who we are
Ace Aquatec Limited (“we”, “us”) is a limited company registered in Scotland
Company number: SC335694
Registered office address: 1 Water's Edge, Camperdown Street, Dundee, DD1 3HY
We act as a ‘controller’ of the personal data that you give to us. We are registered with the UK’s Information Commissioner’s Office, registration number ZB394042.
Why we collect personal data
To serve you or your organisation, we need to store your name and contact details.
We also collect names and contact details of potential clients so that we can market our services directly to them.
We never sell personal data to anyone for any purpose. We will not give your data to others for their own use without your permission.
Kinds of personal data we collect
We do everything possible to minimise the amount of personal data we collect.
Personal data we always collect:
- Names and contact details, such as telephone numbers and email addresses
- Details about when and why you contacted us or we contacted you
Personal data we sometimes collect, depending on the circumstances:
- Your industry sector and geographic area
- Information you share publicly about yourself
- Where you apply for a job, details from your CV, such as work history, education, and qualifications.
Where we get your personal data from
Most of the time, we collect personal data about you directly from you. Sometimes we get the information from others in your organisation. Occasionally, we collect information from third parties, including:
- publicly accessible sources such as Companies House;
- social media sites such as LinkedIn; and
- referrals from organisations you have previously dealt with.
How we use your personal data
Under the law, we must process your data lawfully, fairly, and transparently. We must also explain our “lawful basis” under the UK GDPR for each kind of processing:
|Why we process your personal data||Lawful basis for processing|
Marketing, lead generation, and providing customer service by the following means:
Our legitimate interests to grow and run a profitable business by
|Receiving and assessing job applications, interviewing, skills testing, seeking and receiving references.||Our legitimate interests to grow and run a profitable business by finding suitable candidates for employment.|
|Pre-employment checks: Right to Work in the UK||To comply with our legal duties.|
Some of your legal rights will depend on which legal basis we are relying on for processing. Please see the Your Rights section below.
If you are an existing or previous client, we may send you promotional emails about goods or services that are similar to what you have bought from us before. You have the right to opt out of receiving these emails at any time by:
- contacting us by email at ; or
- using the ‘unsubscribe’ link at the bottom of the email.
In all other circumstances, we will only send marketing emails to your individual email if you have explicitly opted in to our marketing list in advance.We never sell personal data to anyone for any purpose. Also, we will not give your data to others for their own use without your permission.
How we store and secure personal data
We hold personal data at our office in Scotland and on the servers of our IT service providers. Only those with a genuine business need have access to your data, and all are under a legal duty of confidentiality.
We use the following external services to store and process data on our behalf:
|Service provider||Type of processing||Where data is stored|
|Microsoft||general file storage, email||UK|
|Hubspot||customer relationship management, email marketing campaign management, website chat records||USA (protected by standard contractual clauses)|
We only store data with a provider if we are satisfied they protect it with robust policies and cybersecurity measures.
All external processors have contracts with us. They are required not to reuse your personal data for their own purposes unless they are also listed as a controller within this policy.
Transferring your personal data out of the EEA
In general, we store and process data in the UK. However, sometimes we need to send personal data outside the European Economic Area (EEA), such as:
- to a non-EEA office in our corporate group;
- if one of our service providers is located outside the EEA; or
- if you are located outside the EEA.
These transfers are subject to special rules under UK data protection law.
If we need to send data to a non-EEA country that the UK has not assessed as having adequate data protection laws, we will only send the data after agreeing with the recipient the standard data protection contract clauses approved by UK law.
How long we keep personal data
We will keep your personal data after we have finished corresponding with you, for one of these reasons:
- to respond to any questions or complaints
- to pursue or defend existing or future legal claims
When it is no longer necessary to retain your personal data, we will delete or irreversibly anonymise it.
If you have any questions in this regard, or any concerns about how long we keep your information for, please contact us using the details below.
|Type of personal data||Retention period|
|Records of direct marketing emails and responses||2 years|
|CVs and other data about unsuccessful job applicants||6 months after the hiring decision is completed|
|Customer emails, chat transcripts, etc||
6 years after:
|Other website chat records||2 years|
You can exercise any of your rights in this section free of charge by contacting us by email at firstname.lastname@example.org.
You can ask us to:
- provide you with a copy of your personal data;
- correct mistakes in data we hold about you;
- delete your personal data from our records (subject to some exceptions in the UK GDPR and Data Protection Act 2018 or another applicable privacy law);
- restrict the processing of your personal data in some circumstances, such as where you contest the accuracy of the data; and
- in certain situations, provide you with a copy of the personal data you provided to us in an easily portable format.
You can object:
- at any time to your personal data being processed for direct marketing;
- to our continued processing of your personal data in some other situations, such as where we rely on “legitimate interest” as a legal basis for processing.
For further information on your rights, please contact us. You can also reiew the Information Commissioner’s Office webpage on Individual Rights by clicking here: https://ico.org.uk/for-organisations/guide-to-data-protection/guide-to-the-general-data-protection-regulation-gdpr/individual-rights/]
You can complain about our use of personal data to the Information Commissioner on their website (www.ico.org.uk/concerns) or by calling +44 303 123 1113. However, we would appreciate the chance to deal with your concerns before you approach the Information Commissioner so please contact us in the first instance.
If you are resident in the EEA (which includes the EU), the GDPR also gives you right to lodge a complaint with your local data protection regulator.
How to contact us
Please contact us by post, email, or telephone if you have any questions about either this policy or the information that we hold about you:
Ace Aquatec Ltd
1 Waters Edge