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    Privacy policy

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    Please read this notice carefully. It sets out the basis on which any personal data (‘data’) we collect, or that you provide to us, will be processed by us whether we receive that personal data further to your use of this website or because you are a customer, contact, sub-contractor or supplier.

    If you visit our website, you are accepting and consenting to this privacy notice including how we use your personal data when you visit our website.

    We collect, use and are responsible for certain personal data about you.  We are subject to the UK General Data Protection Regulation (UK GDPR).  

     

    Personal data we collect about you

    The personal data we collect about you depends on whether you are making an enquiry, you are, or maybe, a customer, browsing our website or you are, or may be, a supplier or business contact.   We usually get your personal data directly from you, but we may also obtain your personal data from other sources as necessary, depending on our relationship with you and the relevant products and services that we are providing (as applicable).

     

    We will collect and use some or all of the following personal data about you

     

    INFORMATION TYPE

    DETAILS

    Personal information

    Name, title, address, phone number(s), email address, gender, job title, work address, details of company you work for, professional experience, qualifications

     

    Payment method information

    Billing information, transactional history and purchases, amount paid for services, bank information

     

    Newsletter information

    Email address provided to sign up for our newsletter

     

    Website use & communications

    In addition to the personal information described above, we may collect your user name, account ID and password, IP address, website use information, browser information, device type, location, image and video and audio recording

     

    Other information

    Any information that is relevant to your interaction with us, your visit to our website, and making an enquiry.

     

     

    We collect and use this personal data for the purposes described in the section ‘How and why we use your personal data’ below.


    How your personal data is collected


    We collect most of this personal data directly from you, but we may also collect information:

    • from publicly accessible sources, e.g. Companies House
    • from your company website(s) and other online sources
    • from cookies on our website.  See our Cookie Notice for more information.

     

    How and why we use your personal data


    Under data protection law, we can only use your personal data if we have a proper reason, e.g.:

    • where you have given consent;
    • to comply with our legal and regulatory obligations;
    • for the performance of a contract with you or to take steps at your request before entering into a contract; or
    • for our legitimate interests or those of another.

     

    We have a legitimate interest when we have a business or commercial reason to use your personal data, so long as this is not overridden by your own rights and interests.


    The table below explains what we use your personal data for and why.

     

    What we use your personal data for

    Our reasons

    Processing your enquiry, contact with you and communications

    Legitimate interests

    To set you up as a prospect, customer or supplier

    Legitimate interests

    Providing products and/or services to you

    To comply with the contract with you

    Communicating with you about information that directly relates to you in the course of providing services to you and/or in connection with your communication with us

    Legitimate interests

    Preventing and detecting fraud against you or us

    Legitimate interest, i.e. to minimise fraud that could be damaging for you and/or us

    Conducting checks to identify our customers and/or suppliers and verify their identity


    Screening for financial and other sanctions or embargoes
     

    Depending on the circumstances:

    • to comply with our legal and regulatory obligations
    • legitimate interests

     

    Other activities necessary to comply with legal and regulatory obligations that apply to our business, e.g. under health and safety law or rules issued by our professional regulator

    To comply with our legal and regulatory obligations

     

    To enforce legal rights or defend or undertake legal proceedings

    Depending on the circumstances:

    • to comply with our legal and regulatory obligations
    • in other cases, legitimate interests, i.e. to protect our business, interests, and rights

    Gathering and providing information required by or relating to audits, enquiries or investigations by regulatory bodies

    To comply with our legal and regulatory obligations

    Ensuring business policies are adhered to, e.g. policies covering procurement, ethical trading and security

    Legitimate interests, i.e. to make sure we are following our own internal procedures so we can deliver the best service to you

    Operational reasons, such as improving efficiency, training and quality control

    Legitimate interests, i.e. to be as efficient as we can so we can deliver the best service to you at the best price

    Ensuring the confidentiality of commercially sensitive information

    Depending on the circumstances:

    • legitimate interests, i.e. to protect trade secrets and other commercially valuable information
    • to comply with our legal and regulatory obligations

    Statistical analysis to help us manage our business, e.g. in relation to our financial performance, customer and supplier base, product range or other efficiency measures

    Legitimate interests, i.e. to be as efficient as we can so we can deliver the best service to you at the best price, or to ensure cost-effectiveness and efficiency in the supply chain

    Preventing unauthorised access and modifications to systems

    Depending on the circumstances:

    • legitimate interests, i.e. to prevent and detect criminal activity that could be damaging for you and/or us
    • to comply with our legal and regulatory obligations

    Protecting the security of systems and data used to provide the goods and/or services

    To comply with our legal and regulatory obligations


    We may also use your personal data to ensure the security of systems and data to a standard that goes beyond our legal obligations, and in those cases our reasons are for our legitimate interests, i.e. to protect systems and data and to prevent and detect criminal activity that could be damaging for you and/or us

    Updating customer and/or supplier records

    Depending on the circumstances:

    • to perform our contract with you or to take steps at your request before entering into a contract
    • to comply with our legal and regulatory obligations
    • legitimate interests, e.g. making sure that we can keep in touch with our customers about existing orders and new products

    Statutory returns

    To comply with our legal and regulatory obligations

    Ensuring safe working practices, staff administration and assessments

    Depending on the circumstances:

    • to comply with our legal and regulatory obligations
    • legitimate interests, e.g. to make sure we are following our own internal procedures and working efficiently so we can deliver the best service to you

    Marketing our products and/or services to:

    • existing and former customers;
    • third parties who have previously expressed an interest in our services

    Legitimate interests, i.e. to promote our business

    Credit reference checks via external credit reference agencies

    Legitimate interests, i.e. to ensure our customers are likely to be able to pay for our products and services

    External audits and quality checks, e.g. for ISO or Investors in People accreditation and the audit of our

    Depending on the circumstances:

    • legitimate interests, i.e. to maintain our accreditations so we can demonstrate we operate at the highest standards
    • to comply with our legal and regulatory obligations

    To share your personal data with members of our group and third parties that will or may take control or ownership of some or all of our business (and professional advisors acting on our or their behalf) in connection with a significant corporate transaction or restructuring, including a merger, acquisition, asset sale, initial public offering or in the event of our insolvency.  In such cases information will be anonymised where possible and only shared where necessary

    Depending on the circumstances:

    • to comply with our legal and regulatory obligations
    • in other cases, for our legitimate interests, i.e. to protect, realise or grow the value in our business and assets

     

    Artificial Intelligence (AI) Tools

    We use AI tools which utilise large language models (LLMs), a type of artificial intelligence algorithm that uses deep learning techniques to understand, summarise, predict, and generate content.

    The personal data used in AI tools is limited to the categories of personal data shown in the table above.  We restrict how much personal data is processed by AI tools and avoid using any sensitive personal data, such as health or disability information, where we can.  If we need to process special category (sensitive) information about you, we will seek your consent before doing so unless an exemption applies.  We may, for example, process your sensitive information in an emergency if you are unable to give consent yourself.  An exemption also applies if we need to establish, exercise, or defend a legal claim or for judicial proceedings.  

    AI Tools help us to improve the efficiency, quality, and speed of our business processes.  We carry out a number of these processes already but using AI to automate these activities allows us to optimise our resources.  For example, AI can help us by summarising information (such as in emails, Teams chat messages and meeting transcripts, documents) and prepare for meetings, create and format documents, analyse data such as public consultation responses, and generate draft emails or presentations. AI also assists with notetaking and idea generation to support efficient communication and decision-making.

    Any data, used in AI is stored and stays within our secure UK Microsoft 365 and Azure tenants, and is not used for training foundation models. 

    Where we use your personal data, it is processed under the lawful basis of legitimate interest to enhance and improve response times and efficiency, for example in relation to service delivery, complaint handling, providing you with guidance, or investigating a breach.  Alternatively, we may use your information in order to enter into and/or perform a contract with you.

    We use AI tools to assist our staff do their job and we do not solely use AI to make automated decisions. Our policy requires that there is always a human intervention to review and approve outputs from the AI tools. 

    We will continue to monitor our use of AI tools to review the risks and benefits of this deployment. Any extension of our use will be considered under our risk assessment processes and this privacy notice will be updated accordingly.

     

    Marketing

    We have a legitimate interest in using the personal data of personnel who work for a customer or supplier for marketing purposes.  This means we do not usually need your consent to send you marketing information.  If we change our marketing approach in the future so that consent is needed, we will ask for this separately and clearly.


    We give such personnel the right to opt out of receiving marketing communications at any time by:

    • contacting our marketing team; or
    • using the ‘unsubscribe’ link in emails.

    We may ask commercial personnel to confirm or update marketing preferences if they ask us to provide further products and/or services in the future, or if there are changes in the law, regulation, or the structure of our business.
     

    We will always treat personal data with the utmost respect and never sell or share it with other organisations outside the Natural Power group.


    Who we share your personal data with

    Where necessary we routinely share personal data with:

    • External hosting providers for the administration of our website, for example our video chat host and our newsletter distributor
    • Mailing houses; we transfer your name and address to mailing houses to send out brochures
    • Our employees and contractors, selected third parties and service providers, including marketing agencies, marketing research agencies, PR agencies and data hosting service providers, so that we can develop, enhance and promote our services and provide you with information and marketing messages about products and services that may be of interest to you
    • Our affiliates and companies in the Natural Power family of companies, who may use your information in the same way as we can under this notice
    • Credit reference agencies and other third parties required to comply with law and law enforcement, to enforce our terms, to protect the security or integrity of our services), and to exercise or protect the rights, property, and safety of us and other third-parties
    • Third parties we use to help deliver our products and/or services to you, e.g. warehouses and delivery companies;
    • Our professional advisors, our insurers and bank(s) and auditors for the purpose of seeking professional advice or to meet our audit responsibilities.

    We only allow those organisations to handle your personal data if we are satisfied they take appropriate measures to protect your personal data.


    We or the third parties mentioned above occasionally also share personal data with:

    • our and their external auditors, e.g. in relation to the audit of our or their accounts, in which case the recipient of the information will be bound by confidentiality obligations;
    • our and their professional advisors (such as lawyers and other advisors), in which case the recipient of the information will be bound by confidentiality obligations;
    • law enforcement agencies, courts, tribunals and regulatory bodies to comply with our legal and regulatory obligations;
    • Members of our group and third parties that will or may take control or ownership of some or all of our business (and professional advisors acting on our or their behalf) in connection with a significant corporate transaction or restructuring, including a merger, acquisition, asset sale, initial public offering or in the event of our insolvency (anonymised where possible).

     


    Where your personal data is held

    Personal data may be held at our offices and those of our group companies, third party agencies, service providers, representatives and agents as described above.


    `Some of these third parties may be based outside the UK/EEA. For more information, including on how we safeguard your personal data when this happens, see below: ‘Transferring your personal data out of the UK’.

     

    How long your personal data will be kept

    We will not keep your personal data for longer than we need it for the purpose for which it is used.

    If you no longer have an account with us, you no longer provide goods and/or services to us or we are no longer providing goods and/or services to you, we will delete or anonymise your data after 7 years.

     

    Transferring your personal data out of the UK and EEA

    It is sometimes necessary for us to transfer your personal data to countries outside the UK and EEA. In those cases, we will comply with applicable UK and EEA laws designed to ensure the privacy of your personal data.


    Your rights

    You have the following rights, which you can exercise free of charge:

    Access

    The right to be provided with a copy of your personal data

    Rectification

    The right to require us to correct any mistakes in your personal data

    Erasure (also known as the right to be forgotten)

    The right to require us to delete your personal data (subject to exemptions)

    Restriction of processing

    The right to require us to restrict processing of your personal data in certain circumstances, e.g. if you contest the accuracy of the data

    Data portability

    The right to receive the personal data you provided to us, in a structured, commonly used and machine-readable format and/or transmit that data to a third party (in certain situations)

    To object

    The right to object:

    • at any time to your personal data being processed for direct marketing (including profiling);
    • in certain other situations to our continued processing of your personal data, e.g. processing carried out for the purpose of our legitimate interests unless there are compelling legitimate grounds for the processing to continue or the processing is required for the establishment, exercise or defence of legal claims

    Not to be subject to automated individual decision making

    The right not to be subject to a decision based solely on automated processing (including profiling) that produces legal effects concerning you or similarly significantly affects you


    For more information on each of those rights, including the circumstances in which they apply, please see the Guidance from the UK Information Commissioner’s Office (ICO) on individuals’ rights.


    If you would like to exercise any of those rights, please:

    • email, call or write to us - see below: ‘How to contact us’; and
    • provide enough information to identify you and any additional identity information we may reasonably request from you;
    • let us know what right you want to exercise and the information to which your request relates.

     

    Keeping your personal data secure

    We have appropriate security measures to prevent personal data from being accidentally lost, or used or accessed unlawfully. We limit access to your personal data to those who have a genuine business need to access it. Those processing your personal data will do so only in an authorised manner and are subject to a duty of confidentiality.

    We also have procedures to deal with any suspected data security breach. We will notify you and any applicable regulator of a suspected data security breach where we are legally required to do so.

     

    Data Protection Complaints

    If you are unhappy with how we handle your personal data, you have the right to lodge a complaint. Please contact the Data Protection Team at Dataprotection@fredolsen.co.uk.

    We will acknowledge your complaint within 30 days and will aim to resolve it without undue delay. You also have the right to complain to the Information Commissioner’s Office if you are dissatisfied with our response. You can contact the ICO at https://ico.org.uk/.

     

    How to contact us

    You can contact us and/or our Data Protection Officer by post, email or telephone if you have any questions about this Notice or the information we hold about you, to exercise a right under data protection law or to make a complaint.

     

    Our contact details are shown below:

    Our contact details

    Our Data Protection Officer's contact details

    The Greenhouse, Forrest Estate Dalry, Castle Douglas, DG7 3XS, Scotland, UK

    sayhello@naturalpower.com

    01644 430008

    Fred. Olsen House, White House Road, Ipswich, IP1 5LL

    dataprotection@fredolsen.co.uk

    07826 924470


    For our UK operations Natural Power Consultants (Ireland) Limited is our data protection representative within the EEA. They can be contacted at Suite 202, Q House, 76 Furze Road, Sandyford, Dublin 18, D18 V1K5.

     

    Changes to this Notice

    We may change this privacy notice from time to time.  You are encouraged to revisit our website from time to time to ensure you are reading the current version of this notice. 

     

     

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