Privacy Notice & Cookie Policy

1. Important information and who we are

Purpose of this privacy notice

This privacy notice aims to give you information on how we collect and process your personal data as a customer or supplier of ours, as well as through your use of our website, including any data you may provide through our website when you contact us, sign up to our newsletter, book a demo, or purchase a product or service. 

Our website is not intended for children and we do not knowingly collect data relating to children.

It is important that you read this privacy notice together with any other privacy notice we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. This privacy notice supplements other notices and is not intended to override them. 

Controller

We are the controller and responsible for your personal data when you use our websites and directly engage with us on behalf of your organisation as a customer or supplier. However, when we provide our services to our customers we act as a data processor and, therefore, such processing is subject to a contract and outside of scope of this notice.

We are registered in England and Wales under company number 03875632 and have our registered office and main trading address at Matrix House, Kingsway, Haslingden, Rossendale, Lancashire, BB4 4QJ

We have appointed a Data Protection Office (DPO) who is responsible for overseeing questions in relation to this privacy notice. If you have any questions about this privacy notice, including any requests to exercise your legal rights, please contact the DPO using the details set out below. 

Contact details

Our full details are:

Full name of legal entity: Matrix Platinum Limited

Name or title of DPO: Data Protection Officer

Email address: dpo@matrix247.com

Postal address: Matrix House, Kingsway, Haslingden, Rossendale, Lancashire, BB4 4 QJ

Telephone number: 0345 030 5669 

Should you have any concerns, we would appreciate the chance to deal with them in the first instance. If you would like to speak to us in relation to any concerns you have, please contact us using the details above.

You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk). 

Changes to the privacy notice and your duty to inform us of changes

This version of the privacy notice was last updated on 23.12.2021.  

It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.

Third-party links

This website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy notice of every website you visit.

2. The data we collect about you

Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).

We may collect, use, store and transfer different kinds of personal data about you that you give us through our Website, purchasing our services, supplying to us, or corresponding with us by phone, e-mail or otherwise, which we have grouped together as follows:

• Identity Data includes title, first name, middle name, maiden name, last name, username or similar identifier, photograph.
• Contact Data includes billing address, delivery address, email address and telephone numbers. 
• Financial Data includes bank account and payment card details (though this usually relates to your organisation).
• Transaction Data includes details about payments to and from you and other details of products and services you or your organisation have purchased from us.
• Technical Data includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, and other technology on the devices you use to access this website. 
• Profile Data includes purchases or orders made by you, your interests, preferences, feedback and survey responses.  
• Usage Data includes information about how you use our website, products and services. 
• Marketing and Communications Data includes your preferences in receiving marketing from us (and our third parties if applicable) and your communication preferences.

However, please note that most information we obtain when contracting to supply products and services relates to your organisation and is not personal data about you. 

We also collect, use and share anonymous and aggregated data (Aggregated Data) such as statistical or demographic data for any purpose. Aggregated Data could be derived from your personal data but is not considered personal data in law as this data will not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature, or to understand customer engagement with our services. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy notice.

We do not usually collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health, and genetic and biometric data). Nor do we collect any information about criminal convictions and offences. In the event we do process such data we will ensure we have an appropriate legal basis or obtain your consent, as well as keeping you informed in both instances.

If you fail to provide personal data

Where we need to collect personal data by law, or under the terms of a contract we have with you, and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with goods or services). In this case, we may have to cancel a product or service you have with us, but we will notify you if this is the case at the time. In other circumstances you may not be able to receive the full benefit of our websites and related functions.

If you apply for a job with us

Matrix is the data controller for the information you provide to us during the recruitment process, unless you are informed otherwise. Please refer to the section below entitled ‘Job applicants’ for more information on how we process your data. However if you have any queries about the process or how we handle your information, please contact us at dpo@matrix247.com. 

3. How is your personal data collected?

We use different methods to collect data from and about you including through:

• Direct interactions. You may give us your Identity, Contact and Financial Data by filling in forms or by corresponding with us by post, phone, email, social media, through our website or otherwise. This includes personal data you provide when you:

• purchase our products or services;
• interact with us on social media;
• submit an enquiry to us regarding our services and/or products or request a demo;
• subscribe to our newsletters; 
• request marketing to be sent to you, or inform us that you no longer wish to receive marketing from us;
• if you apply for a job with us; 
• enter a competition, promotion or survey; or
• give us feedback. 

• 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 operate cookies settings in website and please refer to this for further details on cookies. We may engage third party data analytics services to helps us better understand these interactions and use of our sites, and to understand who may be interested in our products. If any of these analytics services involve the use of cookies or online identifiers we will request your consent in advance of their use.  
• Third parties or publicly available sources. 
• Technical Data from analytics providers such as Google based outside the EU. 
• Contact, Financial and Transaction Data from providers of technical, payment and delivery services based inside or outside the EU.
• Identity and Contact Data from publicly available sources based inside the EU such as Companies House and LinkedIn.
• Data aggregators, who have collated and analysed businesses who may be interested in our products. We may then receive contact information for business owners or key decision makers, for whom we believe we have a legitimate interest to contact. For such aggregators we will conduct due diligence to ensure compliance with the UK GDPR and will also contact you within 30 days of receiving any personal data about you, to ensure you are fully aware and are able to exercise your rights (see Your Legal Rights below).

4. How we use your personal data

We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:

• Where we or your organisation need to perform the contract we are about to enter into or have entered into with you.
• Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
• Where we need to comply with a legal or regulatory obligation, such as tax reporting or fraud risks.
• Where we need to share with the purchaser (or prospective purchaser) of any business or asset that we are (or are contemplating) selling.

We may also use your personal data to understand your needs and provide you with a better service, and in particular for the following reasons:

• Internal record keeping.
• To improve our products and services.
• To contact you for market research purposes. We may contact you by email, phone or mail. We may use the information to customise the website according to your interests.

Generally, we do not usually rely on consent as a legal basis for processing your personal data.  However, in the event we would like to send third party direct marketing communications to you via email or text message, we will request your consent in advance, unless we reasonably believe we have a legitimate interest to market to you under the ‘soft opt in’ rules or as a business customer. In cases where we do rely on consent, please note that you have the right to withdraw consent/opt out to marketing at any time by contacting us.

Purposes for which we will use your personal data

We have set out below, in a table format, a description of 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 (Please see paragraph 10 (Glossary) for a definition of legitimate interest.

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 ground we are relying on to process your personal data where more than one ground has been set out in the table below. 

For the avoidance of doubt, you may fall into one or more of the below-detailed categories (i.e. customer, supplier or website user).

Profiling 

Profiling is a form of automated processing of personal data consisting of the use of personal data to evaluate certain personal aspects relating to you, for example to analyse or predict aspects concerning that natural person’s performance at work, economic situation, health, personal preferences, interests, reliability, behaviour, location or movement. 

Please note; we do not currently use profiling or take automated decisions about you.

Customers

For individual and business customers, we may collect and process your personal data as follows:

Job applicants

For job applicants, we may collect and process your personal data as follows:

Suppliers

For suppliers, in order to receive goods and/or services from your organisation, we may need to process your personal data as follows:

Website users

For website users, we may collect and process your personal data as follows:

Marketing 

We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising. 

Promotional offers from us 

We may use your Identity, Contact, Technical, Usage and Profile Data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which products, services and offers may be relevant for you (we call this marketing). If you have registered for an event or webinar, or purchased (or your organisation has purchased) products or services from us previously, we will rely on our legitimate interests to market to you in relation to similar products or services and information on our offers and news.

You will also receive marketing communications from us if you have signed up for a newsletter, email lists or otherwise requested information from  us (provided consent).

Third-party marketing 

We do not share your personal data with any third party for marketing purposes. 

Business to Business Communications/Marketing

We do not usually collect personal data for our business customers, beyond business emails and a telephone number of you or your employees, as well as recording a history of contact.

We rely on legitimate interest to store and use this information, because we need to communicate with you in order to market to you, provide our products or services and perform our functions, as well as responding to requests for information and placing orders.  We believe it is within your reasonable expectations that we will process this minimal contract information and this will not impact the legal rights and freedoms of you and/or your employees. We also provide the opportunity for you to opt out of any marketing communications and you may exercise your data rights (set out below).

Opting out

You can ask us or third parties to stop sending you marketing messages at any time by contacting us at any time. 

Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of a product/service purchase, warranty registration, product/service experience or other transactions.

Change of purpose 

We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us. 

If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.

Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

5. Disclosures of your personal data

We may share your personal data with the parties set out below for the purposes set out in the table in paragraph 4 above.

• Internal Third Parties such as our employees or officers. 
• External Third Parties including specialist IT support, help desk providers, data analytics and technology providers, suppliers and sub-contractors for the performance of our website, our applications and any contract we enter into with them or you.
• Professional advisers including lawyers, bankers, marketing agencies, auditors and insurers who provide consultancy, banking, legal, insurance and accounting services.
• Credit reference agencies, law enforcement and fraud prevention agencies to help us prevent and deal with fraud.
• HM Revenue & Customs, regulators and other authorities who require reporting or processing activities in certain circumstances.
• Third parties to whom we may choose to sell, transfer or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy notice. 

We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions. For more information on the people we may share data with, please contact us at dpo@matrix247.com.

6. International transfers

We do not usually transfer personal data outside the UK as part of operating our business or performing our services.

In the event we do transfer your personal data out of the UK, we will ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:

• We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data by the UK Government (e.g. the EEA). 
• Where we use certain service providers, we may use specific contracts approved by the UK Government and ICO which give personal data the same protection it has in the UK, as well as conducting an appropriate risk assessment. 

Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the UK.

Please note our employees and officers will be able to access emails and our IT systems whilst outside the UK, in the course of their employment.  This does mean that your personal data is accessible whilst outside the EEA, however, we have assessed the risk and ensured adequate safeguards are in place. For further details please contact us. 

7. Data security

We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality. 

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

8. Data retention

How long will you use my personal data for?

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 requirements. 

Customer Personal data

Your personal customer (including the relevant employee contact at companies) data will be stored for no longer than 7 years from when you last engaged us, or 2 weeks following a request for this information to be deleted, providing we have no other legal basis or requirement to retain it. 

Record of sale data

Data relating to purchase(s) will be stored for no longer than 7 years from when you last purchased a service from us, or 2 weeks following a request for this information to be deleted, providing we have no other legal basis or requirement to retain it.

Email & Marketing data

If you have requested product or service information then we will keep your personal data for 2 years from the last time we have communicated with you or provided marketing information. However, we will regularly contact you to ensure you are aware of our processing of your data, your data rights and options to stop communications. If you do not want to continue to receive emails, we will no longer send you updates and will automatically delete your personal data at that time, providing we have no other legal basis or requirement to retain it.

For website users, we will usually keep data for 2 years.

For job applicants, we will usually keep data for 12 months.

In some circumstances you can ask us to delete your data: see ‘Deletion of information’ below for further information.

In some circumstances we may 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.

9. Your legal rights

Under certain circumstances, you have rights under data protection laws in relation to your personal data. 

1. Marketing

2. We will inform you (before collecting your data) if we intend to use your data for marketing purposes. We will only use your data for this if you have agreed in advance. 

1. Correction of Information

2. If you notify us that the personal data we hold is complete or inaccurate we will correct or complete the information as soon as possible.

1. Deletion of Information

2. You have the right to request that your personal data be deleted; including if we no longer need it for the purpose we collected it, or you withdraw your consent.

Following such a request we will erase your personal data without undue delay unless continued retention is necessary and permitted by law. If we made the personal data public, we will take reasonable steps to inform other data controllers processing your personal data about your erasure request.

• Object to Processing

You have the right to object to us processing your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.

• Restriction on Processing

You have the right to request that we suspend processing your personal data, but hold it for you, in the event the personal data we hold is inaccurate, the processing is unlawful or we no longer need the personal data. Once the processing is restricted, we will only continue to process your personal data if you consent or we have another legal basis for doing so.

• Access to Information

You have the right to access information held about you and any access request will usually be free of charge. We will endeavour to provide information in a format requested, but we may charge you a reasonable fee for additional copies.

• Data Portability

You have the right to receive a copy of your personal data which you gave to us. The copy will be provided in a commonly used and machine-readable format.  You can also have it transmitted directly from us to another data controller, where technically possible.

If you wish to exercise any of the rights set out above, please contact us.

No fee usually required

You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we could refuse to comply with your request in these circumstances.

Withdraw consent at any time

You may withdraw your consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.

What we may need from you

We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

Time limit to respond

We try to respond to all legitimate requests within one month. Occasionally it could take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated. 

10. Glossary

LAWFUL BASIS

Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give you the best service/product and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us.

Performance of Contract means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.

Comply with a legal or regulatory obligation means processing your personal data where it is necessary for compliance with a legal or regulatory obligation that we are subject to.