1.     Introduction

This Privacy Notice sets out the basis on which any personal data we collect from you, or that you provide to us will be processed, shared and used by us whether that is personal data you provide through your use of the Britwind website; when you make enquiries to Britwind or any other activity connected with our products and/or services we may provide to you.

Please read this Privacy Notice carefully as it contains important information about who we are, together with how and why we process the personal data that you provide to us, through our website, by post, by email, by phone or in person or when you otherwise communicate with us.  The Privacy Notice also explains your rights in relation to your personal data and how to contact us or the Information Commissioner’s Office (“ICO”) in the event you have a complaint about how we have processed your personal data. If you have any questions of comments about this Privacy Notice, you are able to contact us using the details set out in Section 15 ‘Contact Us’.

2.     Britwind

This Privacy Notice applies to personal data collected and processed by Britwind Limited, a company incorporated in England & Wales (company number 09040997) with its registered office at Lion House, Rowcroft, Stroud, England GL5 3BY.  Britwind Limited is registered with the ICO with registration number ZB339200. In the Privacy Notice ‘Britwind’, ‘we’, ‘our’ or ‘us’ means Britwind Limited, and ‘you’ or ‘your’ means you, our customer.

For the purpose of Data Protection Legislation (“DPL”), together with any other applicable laws relating to the protection of personal data as amended, updated or replaced from time to time, Britwind are the data controller of your personal data for the purpose of providing our services, which means when we process your personal data, we are responsible for looking after and protecting your data.

3.     Personal Data we may Collect from you

Personal Data means any information about a living individual from which that person can be identified.  It does not include data where the identity has been removed, which is called anonymised data.

We may collect, use, store and transfer different types of personal data about you as follows:

·       Identity Data – Full name, username or similar identifier, title;

·       Contact Data – Billing address, home address, email, contact number(s);

·       Financial Data – Bank account and payment card details; data relating to your eligibility for credit;

·       Transaction Data – Details about payments to and from you; other details of products/services you have purchased from us;

·       Correspondence Details – General correspondence exchanges with you; call logs, promotions, surveys, feedback;

·       Technical Data – Your internet protocol (IP) address; your login data, browser type and version; time zone setting and location; browser plug-in type and version; operating system and platform device ID; other technology on the device you use to access this website;

·       Profile Data – Your username and password; purchase or orders made by you; your preferences;

·       Usage Data – Information about how you use our website, products and services;

·       Marketing and Communications Data – Your preferences in receiving marketing from us and third parties; your communication preferences

 

The personal data that you are asked to provide and the reasons why you are asked to provide it will be made clear to you at the point we ask you to provide it. Please note that you do not have to provide your personal data to us. However, if you do not provide the personal data we ask for, we may not be able to provide the service to you.

We do not process personal data of children, defined under the UK GDPR as anyone under the age of 18.

4.     How we Collect your Personal Data

The circumstances in which we will collect your Personal Data will include when:

·       the personal data is provided to us by you (e.g. when you agree to sign up to join our mailing list or enter a competition or contact us via email, trade shows etc);

·       the personal data is collected in the normal course of our relationship with you;

·       the personal data has been made public by you (e.g. contacting us via a social media platform) or obtained from a publicly accessible source (e.g. Companies House);

·       the personal data is received by us from third parties (e.g. third-party resellers, credit reference agencies;

·       the personal data is collected via our IT systems, such as: automated monitoring of our website, on-board Wi-Fi services and other technical systems including our computer networks and connections;

·       CCTV that operates in our locations;

·       cookies (please refer to section 6 below for further information).

 

5.     How and Why we will use Your Personal Information

We will only collect, use and share your personal information where we are satisfied that we have an appropriate legal basis to do so. The purposes for which we may use your personal data and the legal basis on which we may perform such processing are set out below.

Where necessary for the performance of a contract with you, or to take steps linked to a contract:

·       To provide the services or information that you have requested from us (e.g. processing or resolving any matters connected with your order, handling operational issues or engagement with customer services etc.);

·       To exercise our legal rights with respect to our contract with you.

Where you give us consent to process your information:

·       For example, consent to receive promotional materials. You have the right to withdraw consent at any time. This will not affect our lawfulness of processing based on your consent prior to withdrawal. If you wish to withdrawn consent, please follow the details given at the time of consent or via contacting us using the details in section 13.

For purposes which are required by law:

·       In response to requests from law enforcement authorities conducting an investigation;

·       Other processing necessary to comply with professional, legal and regulatory obligations that apply to our business e.g. health and safety obligation and requirements to ensure the safety and wellbeing of our workers and our customers (and any third parties) including where necessary for the purpose of safeguarding against the impact of a health-related issue (for example, coronavirus or other epidemic, pandemic, disease or outbreak), or in respect of any measures we are required to take from time to time during a national or international emergency.

Where necessary for Britwind’s or third parties’ legitimate interests and where the interests are not overridden by your data protection rights, such as:

·       To manage, facilitate and/or improve the provision of our services to you, including but not limited to administering our website; managing enquiries, complaints and feedback; investigating, preventing and detecting fraud against you or;  

·       For health and safety purposes; or security purposes, such as preventing unauthorised access and modifications to systems and protecting our workers, service users, premises and vehicles with the use of CCTV, call recording;

·       For business development, management and analysis or quality assurance purposes such as improving efficiency, training and quality control of our products and services including by reviewing call recordings for training or quality purposes;

·       For research, marketing or promotional purposes, for instance, promotion of our services via by email, telephone, social media, post or in person or otherwise that might be of interest to you;

·       To support business and administrative functions of the business and/or ensure business policies are adhered to;

·       To prevent, investigate, detect and/or report fraud, misrepresentation, security incidents, crime and other related matters;

·       In connection with a business transaction such as merger, restructuring or sale of the business;

·       For legal claims, compliance, regulatory and investigative purposes as may be necessary (including disclosure of such information in connection with legal process or litigation).

In some cases, your personal information may be aggregated and anonymised where relevant to the service usage, performance, and delivery.

6.     Cookies

We use cookies on our site. Cookies are small text files that are downloaded onto your device when you visit a website. Our website uses cookies to distinguish you from other users of our website. This helps us to provide you with a good experience when you browse our website and also allows us to improve our website. For detailed information on the cookies we use and the purposes for which we use them, please see our cookie banner on the Britwind website.

7.     Direct Marketing

Where you have consented to such communication, we will use your personal information to send you updates by email, text message, telephone or post as appropriate about our products and services including newsletters, offers, events or promotions that we believe will be of interest to you.

We will always treat your personal information with the utmost respect and never sell your information or share with other organisations without your prior permission for marketing purposes. We will take steps to limit direct marketing to a reasonable and proportionate level and only send you communications which we believe may be of interest or relevance to you.

You have the right to opt out of receiving marketing communications by:

·       using the unsubscribe option included on all our marketing correspondence; or

·       sending us an email to sales@britwind.co.uk. Please ensure your email is marked ‘Unsubscribe: Marketing Contact List’ and include your full name, email and telephone number to ensure your details are fully deleted from our direct marketing system.

If you choose not to receive updates about our services, we will be unable to keep you informed of any new products, exclusive offers, events or promotions that may interest you.

8.     CCTV

We currently have closed circuit television (CCTV) operating at the Britwind factory site for public and worker health and safety and for security. For these reasons, the information processed may include visual images of personal appearance and behaviours, and in certain circumstances various sound recordings of workers and members of the public who were in the immediate vicinity of the area under surveillance.

We display signs to inform visitors and workers that they are under surveillance and there may be video and/or sound recording in operation. This information is kept in secure environments and access is restricted to designated Britwind employees.

9.     Sharing Your Personal Information with Others

We will only disclose personal information to a third party in very limited circumstances, or where we are permitted or required to do so by law. The third parties to whom we provide your personal data include:

·       other organisations within the group of companies, where such disclosure is necessary to provide you with our services or to manage our business;

·       third parties we use to help deliver our products and services to you e.g. third-party resellers, service partners, subcontractors.

 

We may transfer your personal information to third parties in connection with a reorganisation, restructuring, merger, acquisition, sale or transfer of assets.

Less commonly, we may process and share your personal data where it is needed to protect your interests (or someone else's interests) and you are not capable of giving your consent.

We also impose data protection obligations on contracted third parties to ensure they can only use your data when providing services to us for the purposes listed above.  These third parties cannot pass your details on to any other parties unless instructed to by us unless they are required to do so by law. 

We do not currently transfer your personal data outside of the UK or the European Economic Area (“EEA”). In the event your personal information may need to be transferred outside of the UK/EEA, we will take appropriate steps to ensure that transfers of personal data are in accordance with applicable law(s) and carefully managed to protect your privacy rights and interests and transfers are limited to countries which are recognised as providing an adequate level of legal protection, or where we are satisfied that alternative arrangements are in place to protect your privacy rights.

Our standard practice when transferring personal data outside the UK/EEA is to:

·       put in place written agreements, which will include the relevant adopted standard contractual clauses for transferring personal information outside the UK/EEA, to ensure that your information is safeguarded;

·       ensure that the country in which your personal information will be handled has been recognised as providing an adequate level of legal protection, or where we are satisfied that alternative arrangements are in place to protect your privacy rights.

10.  Security of Your Personal Information

We take precautions including administrative, technical and physical measures to safeguard your personal information against loss, theft and misuse, as well as against unauthorised access, modification, disclosure, alteration and destruction.  We protect personal data using a variety of security measures including (but not limited to): password protected access; data back-up; encryption; firewalls; and secure storage facility with appropriate security restrictions.

Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted to our site; any transmission is at your own risk. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorised access.

11.  How Long We Keep Your Personal Information

We will store your personal information for as long as is reasonably necessary for the purposes for which it was collected, as explained in this Privacy Notice. Where your information is no longer needed, we will ensure that it is disposed of in a secure manner.

Listed below are the general criteria we use to determine how long we will keep your personal information, where upon we will either delete or anonymise the data:

·       we will continue to keep your personal information while we are providing goods and services, or if we have an ongoing relationship with you; 

·       we retain CCTV recordings centrally for up to 30 days, and for a longer period if they are relevant to an incident, complaint, investigation, legal proceedings or for as long as legally required by regulatory bodies and law enforcement agencies;

·       we retain purchase orders, invoices and receipts for six years;

·       We will retain contracts for the lifetime of the product that the customer has purchased;

·       We will retain general correspondence including emails for the lifetime of the product that the customer has purchased.

In some circumstances we may store your personal information for longer periods of time, for instance where we are required to do so in accordance with contractual, legal, regulatory, tax and/or accounting requirements.

12.  Your Rights in Respect of Your Personal Information

You have certain rights set out in the data protection law in connection with your personal information:

·       Request access to your personal information (commonly known as a “data subject access request”). This enables you to receive a copy of the personal information we hold about you;

·       Request correction of the personal information that we hold about you;

·       Portability of the personal information you provided us, in certain situations;

·       Request erasure of your personal information;

·       Object to processing of your personal information by us or on our behalf;

·       Request the restriction of processing of your personal information;

·       Request the transfer of your personal information to another party;

·       Withdraw consent to processing where the legal basis for processing is solely justified on the grounds of consent.

Please be aware that these rights do not apply in all circumstances, but we will always look to fulfil your request where possible. Please note, to ensure security of personal information, we may ask you to verify your identity before proceeding with any such request.

If you would like to exercise any of these rights, please submit your requests to the Data Protection Officer as detailed below in section 15. Subject to legal and other permissible considerations, we will make every effort to honour your request promptly to inform you if we require further information in order to fulfil your request.

We try to respond to all legitimate requests within one month. Occasionally it can take longer than one 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.

No fee is usually required for this activity unless your request is clearly unfounded, repetitive or excessive, when we may then charge a reasonable fee.  Alternatively, we may refuse to comply with your request in these circumstances.

13.  Complaints

Whilst you have the right to contact the Information Commissioner’s Office (ICO) at any time, we ask that you please contact us initially so that we can try to resolve the issue or concern you may have regarding our use of your personal data.  Contact details are in Section 15 Contact Us

In the event that you are unhappy with our response, you can contact the ICO and file a complaint detailing where you believe there has been an infringement of data protection laws. 

The contact details for the ICO are available at https://ico.org.uk/concerns or via phone at 0303 123 1113

14.  Changes to the Privacy Notice

We update this Privacy Notice periodically to keep up to date with applicable data protection and associated legislation or the reflect changes in our privacy practices. Please regularly check this page for the latest version of this Privacy Notice. Any changes will be effective when posted and your continued use of this site will indicate your acceptance of these changes. If we make significant changes to this Privacy Notice, we may notify you of these via our home page or by email.

This Privacy Notice was last reviewed and updated in May 2025.

15.  How to Contact Us

For further information regarding your personal data or about Britwind’s approach to data protection in general please contact our Data Protection Officer at:

Data Protection Officer, Britwind Limited, Lion House, Rowcroft, Stroud GL5 3BY

Or by email: dataprotectionofficer@GreenBritainGroup.com

01453 572050

 

Outside the UK:

+44 3338 005 500

For data subjects based in the European Union, please contact our European Representative. Details are as follows:

Company Name: Instant EU GDPR Representative Ltd

Company Number: 665191

Contact Name: Adam Brogden

Contact Email: contact@gdprlocal.com

Contact Tel: +353 (0) 15549700

EU Dublin Address: INSTANT EU GDPR REPRESENTATIVE LTD, Office 2, 12A Lower Main Street, Lucan Co. Dublin, K78 X5P8 Ireland

 

Version 2.0 09 May 2025