Last updated on October 2019
Turner & Co (Glasgow) Limited and its subsidiary companies (referred to as “Turner”) are committed to safeguarding your privacy and ensuring that you continue to trust Turner with your personal data. When you interact with us, you may share personal information with us which allows identification of you as an individual (e.g. name, email address, address and telephone number). This is known as “personal data”.
This notice (Privacy Notice) sets out:
- Scope & Acceptance
- Personal Data Collected
- Sensitive Personal Data
- Why we collect personal data and how we use it
- Sharing of personal data
- Your rights
- Data Security & retention
- How to contact us
1. Scope and acceptance of this Privacy Notice
This Privacy Notice applies to the personal data that we collect about you for the purposes of providing you with our products and services we offer.
By using Turner websites or through Turner branded pages or applications on third party social networks (e.g. Facebook) or by giving us your personal data, you accept the practices described in this Privacy Notice. If you do not agree to this Privacy Notice, please do not use Turner Sites or give us any personal data.
Turner reserves the right to make changes to this Privacy Notice at any time. We encourage you to regularly review this Privacy Notice to make sure you are aware of any changes and how your personal data may be used, however, if changes relating to this Privacy Notice include any significantly different use of your personal data we will let you know and give you the option to agree to the new use
2. Data collected by Turner
Turner may collect personal data about you from a variety of sources, including through:
- requests from our websites, email, phone calls or from visits to our sites/offices
- social media and other digital channels
- trade shows or visits to customer, supplier and sub-contractor sites. This includes business cards & LinkedIn details
- RFP/RFQ’s, quotes, contracts, statement of works and other general business practices
- normal day to day activities where we regularly have interaction with employees, customers (existing & leads), suppliers (existing & potential) etc.
- direct marketing activities & other marketing analysis processes
- credit checks and other financial activities e.g. BACS payments, direct debit collections
2.1 Data that you provide to us directly
This is data that you provide to us with your express permission for a specified purpose, including:
- Personal contact information, including any information allowing Turner to contact you in person (e.g. name, home or (e)mail address, and phone number);
- Demographic information, including date of birth, age, gender, location (e.g. post code, city and state and geo-location), favourite products etc.;
- Payment information, including to make purchases (e.g. credit card number, expiration date, billing address) or to collect payments for products and/or services supplied;
- Driver’s license number and expiration date;
- Account login information, including any information that is required for you to establish a user account with Turner’s (e.g. login ID/email, user name, password and security question/answer);
- Consumer feedback, including information that you share with Turner about your experience in using Turner products and/or services (e.g. your comments and suggestions, testimonials and other feedback related to Turner products and/or services);
2.2 Data that we collect when you interact with Turner web sites & social media channels
We do use other tracking tools on our websites e.g Google Analytics, however, these tools do not collect any of your personal data.
3. Special Category data
Generally Turner does not knowingly solicit or collect Special Category data. If Turner discovers that it has accidentally collected Special Category data, it will remove that personal data from its records as soon as reasonably possible or if you are asked to supply any sensitive personal data either via an on-line channel or direct from a Turner employee or affiliate please contact us at email@example.com.
4. Why Turner collects personal data and how it uses it
Turner collects and uses personal data only as necessary for the purposes for which it was obtained. Turner may use your personal data for some or all of the following purposes:
- Orders – to effectively deal with any sales inquiries or information about our products or services; to effectively deliver our products & services; and to inform you about the status of your orders;
- Account maintenance – to create and maintain your accounts with us, including administering any consumer loyalty or rewards programs that are associated with your account.
- Customer Service – to provide you with customer service, including responses to your inquiries, complaints and general feedback about our products. Customer service may be provided through various forms of communication, including via email, letter & telephone.
- Customer Engagement – to get you more actively engaged with our products and services. This may involve the use or publication of consumer-generated content.
- Marketing communications – to provide you with marketing communications to receive information about Turners, its products and/or services, and promotions. These can be shared via electronic means (e.g. SMS, emails and online advertising) and via post.
- CCTV footage – as part of our general security and Health & Safety activities
- Building entry card records – as part of our general security and Health & Safety activities.
Turner will ensure that all personal data that we collect will be covered by a specific lawful basis to enable the processing of any personal data, as set out by the ICO. These will be:
- Legal Obligations
- Legitimate Interest e.g. our Marketing activities
If you require further information around any of these lawful bases more detail can be found on the ICO website here.
5. Sharing of personal data by Turner
Turner will never share or sell your personal data with any third party that intends to use it for direct marketing purposes, unless you have provided specific consent in relation to this.
Turner may share your personal data with third parties for other purposes, but only in the following circumstances:
5.1 Group Companies
Turner may provide your personal data to its related companies for legitimate business purposes.
Turner may engage agents or contractors to provide services on its behalf, including administering services & Turner Sites available to you. These third parties may come to access or otherwise process your personal data in the course of providing these services.
Turner requires such third parties to comply with all relevant data protection laws and security requirements in relation to your personal data, usually by way of a written agreement.
5.3 Legal requirements and business transfer
Turner may disclose your personal data if it is required to do so by law or if, in Turners good faith judgment, such legal disclosure is reasonably necessary to comply with legal processes or respond to any claims.
5.4 Transferring of Data outside the EEA
We do not routinely transfer or store any personal data outside of the EEA.
In certain circumstances we may securely transfer data to our Turner Engine Control Systems satellite offices in the Middle East to enable the effective delivery of products & services.
6. Your rights
6.1 Right to opt-out of marketing communications
You have the right to opt-out of receiving marketing communications about Turners and can do so by:
(a) following the instructions for opt-out in the relevant marketing communication;
(b) if you have an account with Turner, you may have the option to change your opt-in/opt-out preferences under the relevant edit-account section of the account; or
(c) contact your relevant account or customer service team within the specific Turner company by email, telephone or post
Please note that even if you opt-out from receiving marketing communications, you may still receive administrative communications from Turners, such as order confirmations and notifications about your account activities (e.g. account confirmations).
6.2 Access and rectification
You have a right to request access to your personal data. You may send us a request for access.
You also have the right to request that Turner correct any inaccuracies in your personal data. If you have an account with Turner for a Turner Site, this can usually be done through the appropriate “your account” or “your profile” section(s) on the Turner’s Site (if available). Otherwise, you can send us a request to rectify your data. You also have the right to be forgotten if there is no longer a lawful reason for Turners to hold your data.
All requests can be sent to firstname.lastname@example.org.
7. Data security and retention
7.1 Data security
In order to keep your personal data secure, Turner has implemented a number of security measures, including:
- Secure operating environments – Turner stores your data in secure operating environments and only accessible to Turner employees, agents and contractors on a need-to-know basis. Turner also follows generally accepted industry standards in this respect and is accredited to Cyber Essentials+.
- Encryption for payment information – Turner uses industry-standard encryption to provide protection for sensitive financial information, such as credit card information sent over the Internet (e.g. when you make payments through Turner online stores).
Turners will only retain your personal data for as long as it is necessary for the stated purpose, taking into account our need to answer queries or resolve problems, provide improved and new services, and comply with legal requirements under applicable laws.
This means that we may retain your personal data for a reasonable period after your last interaction with us. When the personal data that we collect is no longer required in this way, we destroy or delete it in a secure manner.
If you require further information around retention periods that we follow, please contact us email@example.com.
7. Contact us
Turner acts as “data controller” for the personal data it processes in the framework of this Privacy Notice. If you have any questions or comments regarding this Privacy Notice or Turner personal data collection practices, please contact us at firstname.lastname@example.org , or in writing to Group QHSE Manager, Turner & Co (Glasgow) Ltd, 65 Craigton Road, Glasgow, G51 3EQ
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