Privacy Policy
1. Introduction
At UAP Ltd, we are committed to safeguarding the personal data of all of our customers, website visitors and app users. As a data controller, we are dedicated to ensuring that the processing of personal data of a data subject, such as the name, address, e-mail address, or telephone number, and we shall always be in line with the General Data Protection Regulation (GDPR), and in accordance with the United Kingdom (UK) data protection regulations. By means of this data protection declaration, UAP would like to inform the general public of the nature, scope, and purpose of the personal data we collect, use and process. Furthermore, data subjects are informed, by means of this privacy policy, of the rights to which they are entitled.
In this policy, when we talk about UAP Limited and each of their respective subsidiaries (collectively “UAP”, “we”, “our” or “us”) we are referring to the company which provides the goods and services.
As the data controller, we have implemented numerous technical and organisational measures to ensure the most complete protection of personal data processed through this website. However, Internet-based data transmissions may in principle have security gaps, so absolute protection may not be guaranteed. For this reason, every data subject is free to transfer personal data to us via alternative means, e.g. by telephone.
2. Definitions
Our privacy policy is based on the terms used by the European legislator for the adoption of the General Data Protection Regulation (GDPR). Our data protection declaration aims to be legible and understandable for the general public, as well as our customers and business partners. To ensure this, we would like to first explain the terminology used.
In this privacy policy, we use, among other things, the following terms:
(a) Personal data
Personal data means any information relating to an identified or identifiable natural person (hereinafter referred to as “data subject”). An identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.
(b) Data subject
Data subject is any identified or identifiable natural person, whose personal data are processed by the data controller responsible for the processing.
(c) Processing
Processing is any operation or set of operations which is performed on personal data or on sets of personal data, whether or not by automated means, such as collection, recording, organisation, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction.
(d) Profiling
Profiling means any form of automated processing of personal data consisting of the use of personal data to evaluate certain personal aspects relating to a natural person, in particular to analyse or predict aspects concerning that natural person’s performance at work, economic situation, health, personal preferences, interests, reliability, behaviour, location or movements.
(e) Pseudonymisation
Pseudonymisation is the processing of personal data in such a manner that the personal data can no longer be attributed to a specific data subject without the use of additional information, provided that such additional information is kept separately and is subject to technical and organisational measures to ensure that the personal data are not attributed to an identified or identifiable natural person.
(f) Data controller
The data controller or controller responsible for the processing is the natural or legal person, public authority, agency or other body which, alone or jointly with others, determines the purposes and means of the processing of personal data; where the purposes and means of such processing are determined by Union or UK law, the controller or the specific criteria for its nomination may be provided for by Union or UK law.
(g) Data processor
The data processor is a natural or legal person, public authority, agency or other body which processes personal data on behalf of the controller.
(h) Recipient
The recipient is a natural or legal person, public authority, agency or another body, to which the personal data are disclosed, whether a third party or not. However, public authorities which may receive personal data in the framework of a particular inquiry in accordance with Union or UK law shall not be regarded as recipients; the processing of those data by those public authorities shall be in compliance with the applicable data protection rules according to the purposes of the processing.
(i) Third party
Third party is a natural or legal person, public authority, agency or body other than the data subject, data controller, data processor and persons who, under the direct authority of the data controller or data processor, are authorised to process personal data.
j) Consent
Consent of the data subject is any freely given, specific, informed and unambiguous indication of the data subject’s wishes by which he or she, by a statement or by a clear affirmative action, signifies agreement to the processing of personal data relating to him or her.
3. Name and address of the Data Controller
The data controller for the purposes of General Data Protection Regulation (GDPR) and other data protection laws is:
UAP Limited
Unit 1 Albert Close Trading Estate,
Whitefield,
Manchester,
M45 8EH,
United Kingdom
Telephone: 0044 (0)161 796 7268
Fax: 0044 (0)161 796 7410
Website: www.uapcorporate.com
Email: marketing@uapcorporate.com
4. Cookies
Cookies are text files that are stored in a computer system via an Internet browser.
Many Internet sites and servers use cookies. Many cookies contain a cookie ID, which is the unique identifier of the cookie. It consists of a character string through which Internet pages and servers can be assigned to the specific Internet browser in which the cookie was stored. This allows visited Internet sites and servers to differentiate the individual browser of the data subject from other Internet browsers that contain other cookies. A specific Internet browser can be recognised and identified using the unique cookie ID.
Through the use of cookies, UAP can provide the users of our websites with more user-friendly services that would not be possible without the cookie setting.
By means of a cookie, the information and offers on our website can be optimized with the user in mind. Cookies allow us, as previously mentioned, to recognise our website users. The purpose of this recognition is to make it easier for users to utilise our websites. The website user that uses cookies may not have to enter access data each time the website is accessed, because this is taken over by the website and the cookie is stored on the user’s computer system.
The data subject may, at any time, prevent the setting of cookies through our website by means of a corresponding setting of the Internet browser used, and may thus permanently deny the setting of cookies. Furthermore, already set cookies may be deleted at any time via an Internet browser or other software programs. This is possible in most Internet browsers. If the data subject deactivates the setting of cookies in the Internet browser used, not all functions of our website may be entirely usable.
5. Collection of general data
Our websites collect a series of general data and information, when a data subject or an automated system calls up the website.
This general data and information are stored in the log files of the server. Collected data may include:
(a) the browser types and versions used
(b) the operating system used by the accessing system
(c) any language preferences you may have
(d) the website from which an accessing system reaches our website (so-called referrers)
(e) the sub-websites, which are controlled by an accessing system on our website
(f) the date and time of access to the Internet site
(g) an Internet protocol address (IP address)
(h) the Internet service provider of the accessing system
(i) any other similar data and information that may be used in the event of attacks on our information technology systems.
When using these general data and information, UAP does not draw any conclusions about the data subject. Rather, this information is needed to:
(a) deliver the content of our website correctly
(b) optimise the content of our website as well as its advertisement
(c) ensure the long-term viability of our information technology systems and the technology of our website
(d) provide the law enforcement authorities with the information necessary for criminal prosecution in case of a cyber-attack
Therefore, UAP analyses these anonymously collected data and information, on one hand, statistically and besides with the aim of increasing the data protection and data security of our enterprise and, ultimately, to ensure an optimal level of protection for the personal data processed by us. The anonymous data of the server log files are stored separately from all personal data provided by a data subject.
6. Collection of personal data
The data subject has the possibility to register on the website of the data controller with the provisions of personal data. Which personal data is transmitted to the data controller is determined by the respective input mask used for the registration.
By registering on the website of the data controller, the IP address assigned by the Internet service provider (ISP) and used by the data subject, date and time of the registration are also stored. The storage of this data takes place in the background as this is the only way to prevent the misuse of our services and, if necessary, to make it possible to investigate committed offenses. Insofar, the storage of this data is necessary to secure the data controller. This data is not passed on to third parties, unless there is a statutory obligation to pass on the data or the transfer serves the aim of the criminal prosecution.
The controller shall at any time provide information on the request to each data subject as to what personal data are stored about the data subject. In addition, the data controller shall rectify or erase personal data on the request or at indication of the data subject, insofar as there are no statutory storage obligations. A data protection officer particularly designated in this data protection declaration and the entirety of the employees of the controller are available to the data subject in this respect as contact persons.
UAP may collect and receive the following information:
(a) Registration account creation information: Data subjects may provide information such as an email address, phone number, address, company name, supplier name, receipt reference number, date of purchase, name of installing company and password to create an account.
(b) Cylinder registration information: When a data subject registers a product on our website, in addition to the registration account creation information, we may also collect we may collect general data such as a key number, key description and key photo.
(c) Billing and other information: For data subjects that purchase products or services either through our websites or any other means, our corporate affiliates and our third party payment processors may collect and store billing address and credit card information on our behalf or we may do this ourselves. We will also collect data relating to orders and deliveries.
(d) Customer relationship management: This information may include administrative and support communications with us and information about products, orders, support, features, content, and links you interact with, and what third party integrations you use (if any).
(e) Contact information: With your permission, any contact information you choose to share with us is collected (such as an email, telephone number or physical address) when using our products and services.
(f) Third party data: We may also receive information from affiliates in our corporate group, our partners, or others that we use to make our own information better or more useful. This might be aggregate level information, such as which IP addresses go with which postcodes, or it might be more specific information, such as about how well an online marketing or email campaign performed, which also includes information on how you interacted with the email and any links you clicked on.
7. How we use your personal data
The personal data entered by the data subject are collected and stored exclusively for internal use by UAP and for our own purposes. We, the data controller may request the transfer of personal data to one or more processors, for example, a parcel service, who also uses the personal data for an internal use, which is attributable to the data controller.
We may use your personal data for one of the following reasons:
(a) To understand and improve our services: We carry out research and analyse trends to better understand how customers are using our websites to help improve them.
(b) To communicate with you by responding to your requests: If you contact us with a problem or question, we will use your information to respond.
(c) To communicate with you by sending emails and messages: We may send you product and administrative emails and messages. We may also contact you to inform you about changes in our products, our service offerings, and important customer service related notices, such as security and fraud notices. These emails and messages are considered part of our service and you may not opt-out of them. In addition, we sometimes send promotional emails about new product features or other news about UAP. You can opt out of these at any time.
(d) Communicating with you and marketing: We often need to contact you for invoicing, account management and other similar reasons. We may also use your contact information for our own marketing or advertising purposes. You can opt out of these at any time.
(e) Billing and account management: We use account data to administer accounts and keep track of orders, billing and payments. This data may include your contact details, your payment details and the transaction details. The data may be processed for the purpose of supplying the purchased goods or served and keeping proper records of those transactions. The legal basis for this processing is, at your request, the performance of a contract between you and us.
(f) Publication data: We may use information that you submit to us for publication on our website or in our magazines, for example generating a PR article when your company starts to take a new product from us. We will always get your full consent before any information is publicised, and you can opt out of these at any time.
(g) Investigating and preventing bad stuff from happening: We work hard to keep all of our services secure and to prevent abuse and fraud.
8. Providing your data to third parties
We may disclose your personal data to any member of our group of companies, which includes all of our subsidiaries including, but not limited to, Fullex Locks, MAX6MUM SECURITY, Quality Locks, Cars, Keys and Locks, Tradelocks, CitySafe and Genuine Lishi, insofar as reasonably necessary for the purposes and legal bases set out in this policy.
We may disclose your personal data to our insurers or professional advisors for the purposes of maintaining insurance, managing risks, obtaining professional advice, and exercise of defence of legal claims, whether it be court proceedings or in an administrative or out-of-court procedure.
Financial transactions relating to our websites and services are handles by our payment service providers, which are Sagepay and Paypal. The Sagepay privacy policy can be found at https://www.sagepay.co.uk/policies/privacy-policy, and the Paypal privacy policy can be found at https://www.paypal.com/uk/webapps/mpp/ua/privacy-full. We will share transaction data with our payment service providers for the purpose of processing your payments, refunds, and dealing with complaints and queries relating to such payments and refunds.
Furthermore, it may be necessary to transfer personal data to a third country or to an International organisation. Where this is the case, the data subject shall have the right to be informed of the appropriate safeguards relating to the transfer. If a data subject wishes to avail himself of this right of access, he or she may at any time contact our data protection officer or another employee of the data controller.
In addition, we may disclose your personal data where such disclosure is necessary for compliance with a legal obligation to which we are subject, or in order to protect your personal interests, or the vital interests of another natural person.
9. Rights of a data subject
Request of personal data
Each data subject shall have the right, as granted by the European legislator, to request and obtain for free from the data controller what personal data concerning a data subject are being held and processed by the data controller.
Furthermore, the data subject can have access to the following information:
(a) the purposes for the personal data processing
(b) the categories of personal data concerned
(c) the recipients or categories of recipient to whom the personal data has been or will be disclosed, in particular recipients in third countries or International organisations
(d) where possible, the envisaged period for which the personal data will be stored, or, if not possible, the criteria used to determine that period
(e) the existence of the right to lodge a complaint with a supervisory authority
(f) where personal data are not collected directly from the data subject, any available information as to the source of the personal data
Each data subject shall have the right to receive the personal data concerning them, which was provided to a data controller, in a structured, commonly used and machine-readable format.
If a data subject wishes to request personal data, they may at any time contact our data protection officer or another employee of the data controller either through our website portal found at www.uapcorporate.com/preference, through email by emailing marketing@uapcorporate.com or by telephone on 0044 (0)161 796 7268. Once a request has been submitted, the data subject will be emailed to confirm that they still wish to go ahead with the request of their personal data. Once confirmed, they will be sent as soon as possible what personal data concerning a data subject are being held and processed by UAP.
Right to amendments
Each data subject shall have the right, as granted by the European legislator, to obtain from the data controller without undue delay the rectification of inaccurate personal data concerning a data subject. Taking into account the purposes of the data processing, the data subject shall have the right to have incomplete personal data completed, including by means of providing a supplementary statement.
If a data subject wishes to rectify and update personal data, they may at any time contact our data protection officer or another employee of the data controller either through our website portal found at www.uapcorporate.com/preference, through email by emailing marketing@uapcorporate.com or by telephone on 0044 (0)161 796 7268. Once a request has been submitted, the data subject will be emailed to confirm that they still wish to go ahead with the rectification of their personal data. Once confirmed, UAP will without undue delay rectify any inaccurate personal data concerning a data subject.
Right to erasure (right to be forgotten)
Each data subject shall have the right, as granted by the European legislator, to obtain from the data controller the erasure of personal data concerning the data subject without undue delay, and the data controller shall have the obligation to erase personal data without undue delay where one of the following grounds applies and as long as the processing is not is necessary:
(a) The personal data is no longer necessary in relation to the purposes for which they were collected or otherwise processed
(b) The data subject withdraws consent on which the processing is based, and where there is no other legal ground for the processing
(c) The data subject objects to the processing and there are no overriding legitimate grounds for the processing, or the data subject objects to the processing of the GDPR
(d) The personal data has been unlawfully processed
(e) The personal data has to be erased for compliance with a legal obligation in UK or EU law to which the data controller is subject
If one of the above-mentioned reasons applies and a data subject wishes to request the erasure of personal data stored by UAP, they may at any time contact our data protection officer or another employee of the data controller either through our website portal found at www.uapcorporate.com/preference, through email by emailing marketing@uapcorporate.com or by telephone on 0044 (0)161 796 7268. Once a request has been submitted, the data subject will be emailed to confirm that they still wish to go ahead with the rectification of their personal data. Once confirmed, the data protection officer shall promptly ensure that the erasure request is compiled as soon as possible, but this can take up to 1 month from the date of request.
Where UAP has made the personal data public and is obliged to erase the personal data, UAP will take in to account the availability of technology and the cost of implementation, and take reasonable steps, including technical measures, to inform other data controllers which are processing the personal data that the data subject has requested the erasure of any links to, or copy or replication of, those personal data, as far as data processing is not required. The data protection officer for UAP or another employee will arrange the necessary measures in individual cases.
Right to restrict processing of data
Each data subject shall have the right, as granted by the European legislator, from the controller restriction of processing where one of the following applies:
(a) The accuracy of the personal data is contested by the data subject, for a period enabling the data controller to verify the accuracy of the personal data
(b) The data processing is unlawful and the data subject opposes the erasure of the personal data and requests instead the restriction of their use instead
(c) The data controller no longer needs the personal data for the purposes of the processing, but they are required by the data subject for the establishment, exercise or defence of legal claims.
(d) The data subject has objected to processing pending the verification whether the legitimate grounds of the data controller override those of the data subject
If one of the abovementioned conditions is met and a data subject wishes to request the restriction of the processing of personal data stored by UAP, they may at any time contact our data protection officer or another employee of the data controller by emailing marketing@uapcorporate.com or by telephone on 0044 (0)161 796 7268. The data protection officer of UAP or another employee will arrange the restriction of the processing.
Right to object
Each data subject shall have the right, as granted by the European legislator, to object to personal data processing on grounds relating to their particular situation. This also applies to profiling based on these provisions.
UAP shall no longer process the personal data in the event of the objection, unless we can demonstrate compelling legitimate grounds for the processing which override the interests, rights and freedoms of the data subject or for the establishment, exercise or defence of legal claims.
If UAP processes personal data for direct marketing purposes, the data subject shall have the right to object at any time to the processing of personal data concerning them for such marketing. This applies to profiling to the extent that it is related to such direct marketing. If the data subject objects to UAP to the processing for direct marketing purposes, UAP will no longer process the personal data for these purposes.
The data subject has the right, on grounds relating to his or her particular situation, to object to processing of personal data concerning them by UAP for scientific or historical research purposes or statistical purposes, unless the processing is necessary for the performance of a task carried out for reasons of public interest.
In addition, the data subject is free in the context of the use of information society services, to use their right to object by automated means using technical specifications.
If a data subject wishes to object to their personal data being processed, they may at any time contact our data protection officer or another employee of the data controller either through email by emailing marketing@uapcorporate.com or by telephone on 0044 (0)161 796 7268. Once a request has been submitted, the data subject will be emailed to confirm that they still wish to go ahead with the rectification of their personal data. Once confirmed, UAP will without undue delay rectify any inaccurate personal data concerning a data subject.
Right to withdraw data protection consent
Each data subject shall have the right, as granted by the European legislator, to withdraw their consent to processing of their personal data at any time. If the data subject wishes to exercise the right to withdraw the consent, they may at any time contact our data protection officer or another employee of the data controller either through email by emailing marketing@uapcorporate.com or by telephone on 0044 (0)161 796 7268.