General Information
At Holdan, we take your privacy seriously.
We will only ever collect, keep, use or share your data where you have given us your consent, or if we are legally obliged to do so.
This Privacy Policy:
- provides information about the collection of personal data when using our website. Personal data is all data that can be related to you personally, e.g. name, address, e-mail addresses, user behaviour; and
- sets out how we comply with UK and European Union data protection requirements. This applies to the entire website, including our campaign microsites.
- explains what personal information we collect, why we collect it, how we use it, the control you have over your personal information and the procedures we have in place to protect your personal information. It applies to personal information we collect through websites for Holdan.
- By sharing your personal information with us, and by continuing to use our websites you confirm that you have read and understood the terms of this Privacy Policy. We take responsibility for the personal information we collect about you, and we aim to be transparent about how we handle it, and give you control over it.
You can also access this privacy statement via our homepage.
Controller
The controller is:
- Midwich Limited, Vinces Road, Diss, Norfolk, IP22 4YT
Who do I contact if I have a question or concern?
The contact details for the person responsible for data protection within our organisation are as follows:
- Stephen Power
- Email: dataprotection@midwich.com
- By Post: Mr. Stephen Power, Midwich Ltd, Vinces Road, Diss, Norfolk, IP22 4YT
If your question or concern relates to Marketing, please contact the following: in the first instance.
The Marketing Department, Holdan, Brookfield House, Brookfield Industrial Estate, Peakdale Road, Glossop, Derbyshire, SK13 6LQ, United Kingdom
Email: marketing@holdan.co.uk
Complaints
You have the right to make a complaint at any time to the Information Commissioner's Office (ICO), the UK regulator for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO, so please contact us in the first instance.
For your protection, we are registered with the office of the Information Commissioner and have given all appropriate notifications.
General use of the website
The term "personal data" is defined as “any information relating to an identified or identifiable natural person” ("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. This includes, for example, your name, address, telephone number or date of birth.
If you only use the website for information purposes, i.e. if you do not register or otherwise provide us with information, we only collect the personal data that your browser transmits to our server. If you wish to view our website, we collect the following data, which is technically necessary for us to display our website to you and to ensure stability and security:
| Data Collected | Purpose |
|---|---|
| Operating System | Evaluation by device to ensure optimised display of the website |
| Product and version information of the browser used | Evaluation of the browsers used to optimise our websites for this purpose |
| Internet service provider of the user | evaluation of the Internet service provider) IP address (display of the website on the respective device |
| Date, time, access status - file found, not found, etc. - and the request that your browser has made to the server | to ensure the proper operation of the website |
| If applicable, manufacturer and type designation of the smartphone, tablet or other end devices | evaluation of device manufacturers and types of mobile end devices for statistical purposes |
| the amount of data transferred and the website from which you came to the requested page | to ensure the proper operation of the website |
| the individual pages of our website that you call up | ensuring the proper operation of the website |
The collection of data for the provision of the website and the storage of data in log files is absolutely necessary for the operation of the website. Consequently, the user has no option to object.
The data is deleted as soon as it is no longer required to fulfil the purpose for which it was collected. In the case of the collection of data for the provision of the website, this is the case when the respective session has ended.
If the data is stored in log files, this is the case after 7 days at the latest. Storage beyond this period is possible. In this case, the IP addresses of the users are deleted or anonymised so that it is no longer possible to identify the accessing client.
What we collect via Direct Interactions
- Registering for an account. (via the Midwich website)
- Ordering Products. Name, contact and billing information, transaction and credit card information.
- Marketing. We may ask you to provide us with marketing interests and contact preferences in order to provide you with further correspondence about our products and services.
- Events. When you attend one of our events, you may choose to provide us with your personal information (name, email address, mailing address) and let us know what you are interested in receiving further information from us. By doing so, you are giving us permission to enter your details into our systems on your behalf and share your details with our supplier partners who presented at the event you attended.
- Newsletter
- Cookies. Some pages use cookies, a data analysis technique.
- Competitions, Promotions or Surveys. Name, contact information.
- Giving us Feedback or Contacting Us.
- Other
What we collect via Automated Technologies or Interactions
As you interact with our website, we will automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies and other similar technologies.
We may also receive Technical Data about you if you visit other websites employing our cookies, such as our campaign microsites. Please see the Cookies section of the privacy notice for more information on how we use cookies.
How we use personal data
We will only use your personal data when the law allows us to. We use this information to operate our business activities effectively, understand your needs and provide you with a better service, and in particular for the following reasons:
- Improve our products and services;
- From time to time, we may also use your information to contact you for market research purposes. We may contact you by e-mail, phone, fax, or mail.
Data Retention
We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.
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 your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements.
By law, we have to keep basic information about our customers (including Contact, Identity, Financial and Transaction Data) for six years after they cease being customers for tax purposes.
In some circumstances you can ask us to delete your data.
In some circumstances we will 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.
Lawful basis for the processing of personal data
In accordance with Article 6 of the UK GDPR, we rely on one of the following lawful bases whenever we process your personal data:
- Consent. You have given clear consent for us to process your personal data for a specific purpose.
- Contract. The processing is necessary for a contract we have with the you, or because you have asked us to take specific steps before entering into a contract.
- Legal obligation. The processing is necessary for us to comply with the law (not including contractual obligations).
- Legitimate interests. The processing is necessary for our legitimate interests or the legitimate interests of a third party, unless there is a good reason to protect an individual’s personal data which overrides those legitimate interests.
Purposes of which we will use your personal data
We have set out below all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.
Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal grounds, we are relying on to process your personal data where more than one ground has been set out in the table below.
| Purpose/Activity | Type of data | Lawful basis for processing including basis of legitimate interest |
|---|---|---|
| To register you as a new customer | (a) Identity (b) Contact |
Performance of a contract with you |
| To process and deliver your order including: (a) Manage payments, fees and charges (b) Collect and recover money owed to us |
(a) Identity (b) Contact (c) Financial (d) Transaction (e) Marketing and Communications |
(a) Performance of a contract with you (b) Necessary for our legitimate interests (to recover debts due to us) |
| To manage our relationship with you which will include: (a) Notifying you about changes to our terms or privacy policy (b) Asking you to leave a review or take a survey |
(a) Identity (b) Contact (c) Profile (d) Marketing and Communications |
(a) Performance of a contract with you (b) Necessary to comply with a legal obligation (c) Necessary for our legitimate interests (to keep our records updated and to study how customers use our products/services) |
| To enable you to partake in a prize draw, competition or complete a survey | (a) Identity (b) Contact (c) Profile (d) Usage (e) Marketing and Communications |
(a) Performance of a contract with you (b) Necessary for our legitimate interests (to study how customers use our products/services, to develop them and grow our business) |
| To administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data) | (a) Identity (b) Contact (c) Technical |
(a) Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise) (b) Necessary to comply with a legal obligation |
| To deliver relevant website content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you | (a) Identity (b) Contact (c) Profile (d) Usage (e) Marketing and Communications (f) Technical |
Necessary for our legitimate interests (to study how customers use our products/services, to develop them, to grow our business and to inform our marketing strategy) |
| To use data analytics to improve our website, products/services, marketing, customer relationships and experiences | (a) Technical (b) Usage |
Necessary for our legitimate interests (to define types of customers for our products and services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy) |
| To make suggestions and recommendations to you about goods or services that may be of interest to you | (a) Identity (b) Contact (c) Technical (d) Usage (e) Profile (f) Marketing and Communications |
Necessary for our legitimate interests (to develop our products/services and grow our business) |
Your rights
You have the following rights towards us in relation to your personal data:
- General rights. You have the right to information, rectification, erasure, restriction of processing, objection to processing and data portability. If processing is based on your consent, you have the right to withdraw this consent with effect for the future.
- Rights in data processing according to legitimate interest. You have the right to object at any time, on grounds relating to your particular situation, to the processing of personal data concerning you which is based on Article 21 of the UK GDPR. If you object, we will no longer process your personal data unless we can demonstrate compelling legitimate grounds for the processing which override your interests, rights and freedoms, or the processing serves the establishment, exercise or defence of legal claims.
- Rights in direct marketing. If we process your personal data for direct marketing purposes, you have the right to object at any time to the processing of personal data concerning you for such marketing, which includes profiling to the extent that it is related to such direct marketing.
- If you object to processing for the purposes of direct marketing, we will no longer process your personal data for these purposes.
- Right to lodge a complaint with a supervisory authority. You also have the right to complain to a competent data protection supervisory authority about the processing of your personal data by us. We would, however, appreciate the chance to deal with your concerns before this, so please contact us in the first instance.
Data transfer and third countries
Your data will not be transferred to third parties unless we are legally obliged to do so, or the transfer of data is necessary to fulfil the contractual relationship, or you have previously expressly consented to the transfer of your data. External service providers and partner companies such as online payment providers or a shipping company commissioned with the delivery will only receive your data if this is necessary to process your order. In these cases, however, the scope of the transmitted data is limited to the necessary minimum. Insofar as our service providers process your personal data on our behalf, we ensure that they comply with the provisions of the data protection laws, in the same way as part of order processing. Please also note the data protection notices of the respective providers. The respective service provider is responsible for the content of external services, whereby we check the services for compliance with the legal requirements within the scope of reasonableness.
If we use service providers who process data outside the UK, we ensure that an appropriate level of data protection comparable to the standards within the UK and EU is established at the recipient before your personal data is transferred. This can be achieved, for example, by using appropriate safeguards in accordance with Article 46 of the UK GDPR, for example, by means of standard contracts or binding corporate rules or special agreements to which the company may be subject.
Forwarding of data
Your personal data will not be transferred to third parties for purposes other than those listed.
We only pass on your personal data to third parties if:
- you have given your express consent,
- the disclosure is necessary for the assertion, exercise or defence of legal claims and there is no reason to assume that you have an overriding interest worthy of protection in the non-disclosure of your data;
- in the event that there is a legal obligation for disclosure; and
- this is legally permissible and necessary for the processing of contractual relationships with you.
Cookies
Cookies are data that are stored on your computer by a website that you visit and enable your browser to be reassigned . Cookies are used to transmit information to the organisation that sets the cookie. Cookies can store various information, such as your language setting, the duration of your visit to our website or the entries you make there. This prevents you from having to re-enter required form data each time you use the website, for example. The information stored in cookies can also be used to recognise preferences and target content according to areas of interest.
There are different types of cookies:
- Session cookies. These are data sets that are only temporarily stored in the working memory and are deleted when you close your browser.
- Permanent or persistent cookies. These are automatically deleted after a specified period, which may vary depending on the cookie. With this type of cookie, the information can also be stored in text files on your computer. However, you can also delete these cookies at any time via your browser settings.
- First-party cookies. These are set by the website you are currently visiting. Only this website is authorised to read information from these cookies.
- Third-party cookies. These are set by organisations that do not operate the website you are visiting. These cookies are used by marketing companies, for example.
We use cookies to ensure the proper operation of the website, to provide basic functionalities, to measure reach and - with your consent - to tailor our services to your preferred areas of interest. We use both transient cookies and persistent cookies for this purpose.
The legal basis for possible processing of personal data using cookies and their storage duration may vary., for example, you have given us your consent, or our overriding legitimate interests.
We use the following cookies:
- Google Analytics. Google Analytics cookies collect information on how visitors use our website, including details of the site where the visitor has come from and the total number of times a visitor has been to our website. We use this information to improve our website and to enhance the user experience.
- Google Ads. Google Ads Cookies allow us to show you ads based on your interaction on our website. We may show you adverts on other sites because you have shown an interest in certain products or services (known as remarketing – see our Remarketing Policy below). We also use Google Ads Cookies to track conversions so that we can understand how our Google Ads are performing to better tailor them to our audience.
- LinkedIn. We use the LinkedIn Insight Tag to understand how our social presence drives traffic to our website, and how users interact with our website. We also track how our LinkedIn Ads are performing to better tailor them to our audience.
- Twitter. We use Twitter’s Universal Website Tag to understand how our social presence drives traffic to our website, and how users interact with our website. We also track how our Twitter Ads are performing to better tailor them to our audience.
- Facebook. We use Facebook’s Pixel to understand how our social presence drives traffic to our website, and how users interact with our website. We also track how our Facebook and Instagram Ads are performing to better tailor them to our audience.
You can delete cookies already stored on your device at any time. If you want to prevent the storage of cookies, you can do this via the settings in your Internet browser. You can find instructions for common browsers here:
- Internet Explorer. Change or reset Internet Explorer settings - Microsoft Support
- Firefox. Firefox options, preferences and settings | Firefox Help
- Google Chrome. Google Chrome Help
- Google Chrome mobile. Change site settings permissions - Android - Google Chrome Help
- Microsoft Edge. How to Manage and Clear Your Cache and Cookies | Edge Learning Center
- Safari. Change preferences in Safari on Mac – Apple Support (UK) Customize your Safari settings on iPad – Apple Support (UK)
- Safari mobile. Browse the web privately in Safari on iPhone – Apple Support (UK)
Alternatively, you can also install so-called ad blockers. Please note that individual functions of our website may not work if you have deactivated the use of cookies.
Links to other websites
Our website may contain links to enable you to visit other third-party websites of interest easily. However, once you have used these links to leave our site you should note that we do not have any control over that other website. Therefore, we cannot be responsible for the protection and privacy of any information which you provide whilst visiting such sites and such sites are not governed by this privacy statement. You should exercise caution and look at the privacy statement applicable to the website in question.
Those sites may not provide appropriate safeguards, or enforceable rights and effective legal remedies for you.
Changes to the privacy policy
We reserve the right to amend or adapt this privacy policy at any time in compliance with the applicable data protection regulations.
This version was last updated on 02/12/2024. Historic versions can be obtained by contacting us.
