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Privacy policy

Altro Privacy Notice

Last Updated: May 2024

Overview

In this Privacy Policy We (as defined below) explain who We are, how We process your personal data and how you can exercise your data subject rights. We respect the protection of your privacy and strictly adhere to the legal requirements of data protection. Please read this Privacy Policy carefully to understand your rights vis-à-vis Us and the approach to the processing of your personal data.

This Privacy Policy applies to all individuals

  • accessing our Website at www.altro.com/ie (hereinafter referred to as "Website");
  • interacting with Us (as defined below) by using our telephone support or in another way, including face-to-face meetings and other forms of communication (e.g. meetings at events, trade fairs or when contacting us by e-mail or chat);
  • who are subject to our marketing; and
  • becoming our Customers

We, that is Altro Limited, Works Road, Letchworth Garden City in Hertfordshire SG6 1NW, UK ("Altro", "We", "Us") and with the company number 00154159, are responsible for processing your personal data within the meaning of the General Data Protection Regulation ("GDPR").

From time to time, We may update this Privacy Policy to adapt it to changing legal or factual situations. If We make an update, We will notify you in an appropriate manner, depending on the extent of the change. You can see at the top of the page when We last updated this Privacy Policy.

1. Processing of personal data when visiting the Website

1.1 Personal data collected automatically

When you visit our Website, We automatically collect and process personal data about you from your device.

Specifically, the data We collect automatically can include personal data like your IP address, device type, unique device identification number, browser-type, broad geographic location (e.g. country or city-level location) and other technical information.

This helps make the Website usable by enabling basic functions such as page navigation and access to secure areas of the Website. This data is technically necessary for Us to display the Website to you and to ensure stability and security. In this context We process your personal data based on our legitimate interest in the functioning of the Website.

Some of this personal data is collected using cookies and similar tracking technologies such as web beacons. For more information about the cookies We use, the data We collect using the cookies and other tracking technologies and the legal basis for these activities, please visit the Privacy Preference Center by clicking on the cookie banner at the bottom of the Website or visit the Cookie Policy on the Website.

1.2 Personal data you provide via the Website

Registering on the Website (MyAltro) / Keep in touch

In order to receive a quicker and more tailored experience on the Website, e.g. to order samples and get exclusive content, you can choose to register for MyAltro. The personal data We process for the MyAltro registration include:

  • Name;
  • Contact data;
  • Job data;
  • Country; and
  • Customer Type.

If you are an employee of a business registering for MyAltro the legal basis for processing personal data in this context is our legitimate interest as part of our commercial relationship. You have the right to object to the processing of your data by de-registering from MyAltro at any time by using the contact details in section 8 or by clicking on the "unsubscribe" link provided in each e-mail or text message you receive from Us.

If you are a consumer registering for MyAltro the legal basis for processing your personal data in this context is your consent. You can withdraw your consent at any time (see section 8 for contact details). Please note that this does not affect the lawfulness of processing for the time prior to our receipt of your withdrawal of consent. For text messages and e-mails you can withdraw your consent by clicking on the "unsubscribe" link provided in each e-mail or text message you receive from Us.

Surveys and Competitions

From time to time, We collect personal data on the Website through surveys or competitions. Participation in such surveys or competitions is voluntary. You are free to choose whether you want to participate and provide your personal data. This data includes contact information and supplementary information about your business interests, opinions, and interests (for example, selection of publications, working practices, opinions on industry issues, feedback on the Altro Website, etc.). We will only use your personal data to respond to your survey responses or to notify the winners of competitions – your personal data from surveys and competitions will not be used for advertising purposes.

In this context, we process your data, as an employee of a business, based on our legitimate interest in B2B commercial prospecting activities.

If you are a consumer the legal basis for participating in surveys is your consent. Your personal data is only processed for the participation with your consent. You can withdraw your consent at any time by sending a message to the contact details provided below in section 8. Please note that this does not affect the lawfulness of processing for the time prior to our receipt of your withdrawal of consent. For your participation in competitions the legal basis is the performance of a contract to which you are a party as a consumer if you have agreed to the terms of the competition.

Contacting Us via the Website

If you would like to contact Us to enquire about our products or services or to give feedback you can contact Us by e-mail, telephone or via the contact form on the Website. We will use any details which you provide (including your name, e-mail address, telephone number) to investigate and resolve your query or complaint and to improve our service in the future.

In this context, We process your data based on our legitimate interest in interacting with you following your contact requests and to improve our service in the future if you are an employee of a business. If you are a consumer the legal basis is the contract if your query is contract related. Otherwise, it is our legitimate interest in replying to your query.

Newsletter registration

To stay up to date with all of Altro's latest news, you can choose to register for the newsletter. The personal data We process for the newsletter registration include:

  • Name;
  • Contact data;
  • Job data; and
  • Country.

The legal basis for processing your personal data in this context is consent. You can withdraw your consent at any time in which you object to the further sending of information (see section 8 for contact details). Please note that this does not affect the lawfulness of processing for the time prior to our receipt of your withdrawal of consent. You can withdraw your consent by clicking on the "unsubscribe" link provided in each e-mail you receive from Us.

Use of Google reCAPTCHA

We use the Google reCAPTCHA tool, a service provided by Google Inc., 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA ("Google"), to detect bots on the Website.

Google reCAPTCHA is integrated into this Website to ensure that entries made in online forms, for example, are actually made by real persons and are not automated by software (or bots). For this purpose, reCAPTCHA will display a clickable checkbox "I am not a robot". In addition, you may have to click on the checkbox to display various images, which must be assigned to a given image theme by clicking on the relevant images (e.g. selection of all images with cars).

The personal data that is processed includes:

  • Browser and device information, e.g. IP address;
  • The length of your Website visit; and
  • Information about your use of our Website.

The legal basis is our legitimate interest in preventing fraudulent activities and protecting ourselves against them.

Google reCAPTCHA analyses the behaviour of visitors of this Website using different characteristics. Google reCAPTCHA processes personal data such as your IP address, your length of stay on our Website and further information about your use of this Website.

If personal data is transferred to the service provider Google in the USA when using Google reCAPTCHA, the data is transferred on the basis of the adequacy decision of the European Commission EU-U.S. Data Privacy Framework (EU-U.S. DPF) within the meaning of Art. 45 para. 3 GDPR.

The privacy policy with the description of data processing by Google can be accessed here.

2. Processing of personal data from Customers and potential Customers/contacts

2.1 Customers

When you purchase products from Us we refer to you as a "Customer" and this section explains how We process your personal data in your capacity as a Customer of Altro.

You contacting Us and Us contacting our Customers:

When you contact Us by e-mail or via telephone, the personal data you provide (e.g. name, phone, e-mail, job type, address, postcode and industry type) will be stored by Us in order to answer any queries you might have or any matters We need to resolve with you regarding our products and services. The personal data We process include:

  • Name;
  • Contact details; and
  • Job data.

The legal basis is our legitimate interest in interacting with you whether or not as part of a pre- or post-sales service if you are an employee of a business Customer. If you are a consumer the legal basis is the performance of a contract.

We delete the data accruing in this context after the storage is no longer necessary or restrict the processing if there are legal retention obligations.

Ordering and products

When you order products or samples from Us, We will ask you for personal data so that We can process the order and send you the samples and products. The personal data We process about you includes:

  • Name;
  • Contact data;
  • Job data; and
  • Financial details.

The legal basis is our legitimate interest in the management of product or sample orders placed by you if you are an employee of a business Customer. If you are a consumer the legal basis is the performance of a contract.

Customer relationship management

Once you are a Customer of Altro, We process your personal data for the execution of Customer contracts, including Customer management, Customer administration, order processing, deliveries, invoicing of material and immaterial services. The personal data We process about you for these purposes includes:

  • Name;
  • Contact data;
  • Job data; and
  • Financial details.

The legal basis is our legitimate interest in managing the commercial relationship if you are an employee of a business Customer. If you are a consumer the legal basis is the performance of a contract.

Marketing and commercial relations

Where permitted by law, We use your personal data to learn about your personal interests and to send you information about our products that may be of interest to you. The personal data We process about you includes:

  • Name;
  • Contact data;
  • Job data; and

The legal basis for data processing hereunder is our legitimate interest in interacting with you, as an employee of a business, if you have purchased similar products from Us in the past. If this is not the case the legal basis is your consent as well as for consumers. You can withdraw your consent to receiving marketing emails (see section 8 for contact details) at any time. Please note that this does not affect the lawfulness of processing for the time prior to our receipt of your withdrawal of consent. The legal basis for contacting you as a consumer about our products and services is the contractual necessity.

Events, trade fairs and meetings

If you visit Altro at events or trade shows or We hold a meeting with you as our Customer, you can provide Us with more personal data about yourself, your business and your needs. Altro uses this data as part of its business records to contact you following our meetings and send you advertising about our products and services. The personal data We process about you includes:

  • Name;
  • Contact data;
  • Job data; and

The legal basis for contacting you as an employee of a business Customer is our legitimate interest in interacting with you. If you are a consumer our legal basis is the performance of a contract. The legal basis for sending you advertisement hereunder is your consent. You can withdraw your consent to receiving advertising (see section 8 for contact details) at any time. Please note that this does not affect the lawfulness of processing for the time prior to our receipt of your withdrawal of consent.

Testimonials / "Snippets" Voice of the Customer (VotC)

We use Customer testimonials or snippets of your feedback for internal and external purposes. Internally We use this data for our Customer service and to improve our products and services and to process Customer requests and opinions. Externally We use these in an anonymous form on our social media channels such as Xing or LinkedIn as well as on the Website to display quotas and analyses, for example:

  • Which "snippets" come from which areas (e.g. federal state) and from which Customers (e.g. professional group) as well as content of the "snippets";
  • Trends; and
  • Results of "Snippets".

The data We process for these purposes are:

  • Company name; and
  • Your comment.

In some cases, We will conduct case studies for specific projects. For these We will ask if We can use your pictures, comments and likewise to show how We have worked in a partnership with you and to promote our products and services. This information will be utilised on our marketing channels, including, but not exclusive to, the Website, social media, e-mails, and printed literature. The personal data We process about you includes:

  • Your name;
  • Job title and company; and
  • Your comment.

The legal basis for data processing hereunder is your consent. You can withdraw your consent to the publishing of your personal data (see section 8 for contact details) at any time. Please note that this does not affect the lawfulness of processing for the time prior to our receipt of your withdrawal of consent.

2.2 Potential Customers / contacts

You contacting Us as a potential Customer

When you contact Us by e-mail or via telephone, the personal data you provide (e.g. name, phone, e-mail, job type, address, postcode and industry type) will be stored by Us in order to answer any queries you might have or any matters we need to resolve with you regarding our products and services. The personal data we process include:

  • Name;
  • Contact details; and
  • Job data.

The legal basis is our legitimate interest in interacting with you whether or not as part of a pre- or post-sales service if you are an employee of a business Customer. If you are a consumer the legal basis is the performance of a contract.

We delete the data accruing in this context after the storage is no longer necessary or restrict the processing if there are legal retention obligations. Please note that your withdrawal of consent to marketing e-mails does not affect necessary e-mails We send you in relation to our Customer relationship we have with you, for example to send you a confirmation e-mail for a product ordered by you.

Ordering of samples

When you order samples from Us, We will ask you for your personal data so that We can process the order and send you the samples. The personal data We process about you includes:

  • Name;
  • Contact details; and
  • Job data.

The legal basis is our legitimate interest in interacting with you whether or not as part of a post-sales service if you are an employee of a business Customer. If you are a consumer the legal basis is the performance of a contract.

Marketing and commercial relations

Where permitted by law, We use your personal data to learn about your personal interests and to send you information about our products that may be of interest to you. The personal data We process about you includes:

  • Name;
  • Contact details; and
  • Job data.

The legal basis for data processing hereunder is our legitimate interest in interacting with you as part of the management of sample orders placed if you are an employee of a business Customer. If you are a consumer the legal basis for data processing hereunder is your consent. You can withdraw your consent to the publishing of your personal data (see section 8 for contact details) at any time. Please note that this does not affect the lawfulness of processing for the time prior to our receipt of your withdrawal of consent.

Events, trade fairs and meetings

If you visit Altro at events or trade shows or We hold a meeting with you, you can provide Us with more personal data about yourself, your business, and your needs. Altro uses this data as part of its business records to contact you following our meetings and send you advertising about our products and services. The personal data We process about you includes:

  • Name;
  • Contact details; and
  • Job data.

The legal basis is our legitimate interest in interacting with you in a business context if you are an employee of a business. If you are a consumer the legal basis for interacting with you is the performance of a contract. The legal basis for sending you advertisement hereunder is your consent. You can withdraw your consent to receiving advertising (see section 8 for contact details) at any time. Please note that this does not affect the lawfulness of processing for the time prior to our receipt of your withdrawal of consent. The legal basis for contacting you as a consumer about our products and services is the contractual necessity.

3. Recipients of personal data from Us

We do not sell or rent your personal data to third parties. Your personal data will be disclosed to the following categories of recipients:

  • our group companies for purposes consistent with this Policy. Altro takes precautions to allow access to personal data only to those staff members who have a legitimate business need for access and with a contractual prohibition of using the personal data for any other purpose;
  • our agent in Northern Ireland to whom We pass on personal data from Customers at the Customer's request if they want to receive a quote for our products in Ireland;
  • our point of contact in the Republic of Ireland to process contact data through our CRM system;
  • our third party vendors, service providers and partners who carry out data processing operations for Us. This includes disclosures to support Us in areas such as accounting, IT platform management or support services, infrastructure and application services, marketing, data analytics;
  • any competent law enforcement agency, regulator, federal agency, court or other third party, if Altro believes disclosure is necessary (i) to comply with applicable law or regulation, (ii) to exercise, establish or defend our legal rights, or (iii) to protect your vital interests or those of any other person;
  • potential buyers (and their agents and advisors) in the event of purchase offers, mergers or acquisitions of parts of our business, provided that Altro informs the buyer that they may only use personal data for purposes disclosed in this Privacy Policy; and
  • any other third party for whom Altro has obtained your consent.

4. International data transfers

Countries outside the European Union ("EU") (and the European Economic Area "EEA") handle the protection of personal data differently than countries within the EU. Data processing outside the EU is only permitted if the level of protection of your data guaranteed by the GDPR is also maintained outside the EU. Our servers are located in the United Kingdom of England ("UK") and We process and store your personal data exclusively in the EEA and the UK.

Insofar as We process data in a third country - i.e. outside the EU or EEA - or the processing takes place in the context of the use of third-party services or the disclosure or transfer of data to other persons, bodies or companies outside of the EU or EEA, this is only done in accordance with the legal requirements.

If We need to transfer your personal data to a party outside the EEA at any given time, We take special measures to ensure that your personal data is processed in third countries as securely as within the EU. We therefore only transfer your data to third countries if We either have your express consent to do so, or if this is contractually or legally required. With service providers in third countries, We conclude the Standard Contractual Clauses provided by the Commission of the EU.

The Website is hosted in the UK, but We use services from the following US company:

  • Adobe Inc.: We use Adobe’s Marketo Engage marketing automation software to track Customer behaviour to send you more tailored e-mail communications where We have your consent to do so. Please see our cookie policy for more information about how Marketo uses cookies to improve Customer experience.

5. Security of your personal data

We use appropriate technical and organizational measures to protect your personal data from unauthorized access, misuse or disclosure, unauthorized alteration or unlawful destruction or accidental loss. The measures We use are designed to provide a level of security appropriate to the risk of processing your personal data.

6. Retention of your personal data

We will retain personal data We collect from you where We have an ongoing legitimate business need to do so (for example, to fulfil our contractual obligations to you if you are our Customer or to comply with applicable legal, tax or accounting requirements).

When We have no ongoing legitimate business need to process your personal data, We will either delete or anonymise it or, if this is not possible (for example, because your personal data has been stored in backup archives), We will securely store your personal data and isolate it from any further processing until deletion is possible.

If you have questions about, or need further information concerning, our data retention periods, you can contact Us by sending a message to the contact details provided below.

7. Your data protection rights

Regarding your personal data, you can exercise the following rights:

  • You have the right to access, rectify or delete your data or restrict the processing of your personal data;
  • In addition, you can request portability of your personal data;
  • You have the right to object to the use of your personal data where we base the processing on our legitimate interests. For marketing purposes, you can exercise this right by clicking on the "unsubscribe" or "opt-out" link that appears in every marketing e-mail We send you. To object to other forms of marketing (for example, by post or telephone), please contact Us using the contact details set out below;
  • You can also withdraw your consent to the collection and processing of personal data at any time. This does not affect the lawfulness of the processing of personal data carried out until the withdrawal of your consent, nor does it affect the processing of your personal data based on a legal basis other than your consent; and
  • You have the right to lodge a complaint with a data protection authority about our collection and use of your personal data. For more information, please contact your local data protection authority:
    • Contact details for the ICO, the UK's data protection authority, are available here.
    • Contact details for data protection authorities in the EEA are available here.
    • The contact details for the Irish Data Protection Commission, Ireland's Data Protection Authority, are available here.

To exercise all the above rights, please contact Us using the options set out in section 8 below. Please understand that in order to process your request, We may first require proof of your identity.

We will process and honour your requests to enforce your rights as described above in accordance with the law.

8. Contact us

If you have any questions about this Privacy Policy, any queries or complaints about the way in which your personal data is used, or if you wish to exercise any of your rights as set out above, please contact Us by e-mail at mydata@altro.com or via the Customer Care Centre on 01462 489516.