This Customer Privacy Policy governs the collection and use of personal information relating to potential and existing customers of Barbour EHS Limited (“Barbour EHS”).
Barbour EHS is committed to abiding by this Customer Privacy Policy, as well as the requirements of applicable laws, in the operation of its business.
Your privacy is critically important to us. At Barbour, we have a few fundamental principles:
This Privacy Policy applies to information that we collect about you when:
Throughout this Privacy Policy we’ll refer to our website and other products and services collectively as “Services.”
Below we explain how we collect, use, and share information about you, along with the choices that you have with respect to that information.
Please note that this Privacy Policy does not apply to any of our products or services that have a separate privacy policy. These will be presented to you as appropriate should these products or services relate to you.
If you have any questions about this Privacy Policy, please contact us as described in the Contact Section below.
Personal data: “personal data” means any information relating to an identified or identifiable natural person (known as the ‘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;
Data Subject: The “Data Subject” is the individual that the personal data relates to and identifies.
Data Controller: “Controller” This is the decision maker who decides how, when and where data under their control will be processed.
Data processor: “Processor” refers to the individual or organisation that carries out data processing activities under instruction from the Data Controller. The Data Controller may also be the Data Processor.
Processing: “Processing” processing relates to any activity carried out on personal data and includes manipulating, sharing, copying, viewing and storage of data or simply the activity of making a decision based on that data. Decision making may also include automated decision making.
Filing System: “Filing System” basically means any form of data that can be interrogated or searched, and can be digital (like a database or email system) or hard copy (like files in a filing cabinet or contact details in a rolodex).
Consent: “Consent” of the Data Subject relates to the permission to use their personal information following a clear explanation of how that data will be processed and why.
Legitimate Interest: “Legitimate interest” relates to the processing of personal on the basis that the organisation feels that their data processing activities will not infringe upon anyone’s rights or freedoms and that there is a reasonable expectation that these activities will take place.
Special Category: “Special Category” data is personal data which reveals racial or ethnic origin, political opinions, religious or philosophical beliefs, or trade union membership, and the processing of genetic data, biometric data for the purpose of uniquely identifying a natural person, data concerning health, sex life or sexual orientation.
Data Breach: “Personal Data Breach” means a breach of security leading to the accidental or unlawful destruction, loss, alteration, unauthorised disclosure of, or access to, personal data transmitted, stored or otherwise processed.
We only collect information about you if we have a reason to do so; for example, to provide our Services, to communicate with you, or to make our Services better.
We collect information in three ways: if and when you provide information to us, automatically through operating our services, and from outside sources. Let’s go over the information that we collect.
Information You Provide to Us
The amount and type of information depends on the context and how we use the information.
Personal data held includes:
Information We Collect Automatically
We also collect some information automatically:
Log Information: Like most online service providers, we collect information that web browsers, mobile devices, and servers typically make available, such as the browser type, IP address, unique device identifiers, language preference, referring site, the date and time of access, operating system, and mobile network information. We collect log information when you use our Services in order to assess the performance of our systems.
Usage Information: We collect information about your usage of our Services. For example, we collect information about what users are viewing.
We use this information to provide our Services to you, as well as get insights on how people use our Services, so we can make our Services better.
Location Information: We may determine the approximate location of your device from your IP address. We collect and use this information to, for example, calculate how many people visit our Services from certain geographic regions.
Information from Cookies & Other Technologies: A cookie is a string of information that a website stores on a visitor’s computer, and that the visitor’s browser provides to the website each time the visitor returns. Barbour EHS uses cookies to help us identify and track visitors, usage, and access preferences for our Services, as well as track and understand e-mail campaign effectiveness and to deliver targeted ads.
Most browsers accept cookies automatically, but you can alter the settings to prevent automatic acceptance. If you reject the use of cookies please note that the efficient operation of the web site that you are using may be affected. If you are using Barbour you can use the privacy options to determine how you would like to share your information with others.
We use information about you as mentioned above and as follows:
How We Share Personal Data
We do not sell our users’ private personal information.
We share your personal data in the limited circumstances spelled out below and with appropriate safeguards on your privacy:
Subsidiaries, Employees, and Independent Contractors: We may disclose information about you to our other Marlowe plc subsidiaries, our employees, and individuals who are our independent contractors that need to know the information in order to help us provide our Services or to process the information on our behalf. We require our subsidiaries, employees, and independent contractors to follow this Privacy Policy for personal information that we share with them.
With Your Consent: We may share and disclose information with your consent or at your direction. For example, we may share your information with third parties with which you authorise us to do so. Where we require your consent to share your data with 3rd parties you will find these listed under Sharing with Third Parties.
We may also request your consent to process limited elements of your data in specific ways. Where we require this consent, it will be presented to you in a way that allows you to have a clear understanding of what you are consenting to and enable you to agree to this in a clear and positive way.
Sharing with Third Parties: We may share information about you with third-party vendors who need to know information about you in order to provide their services to us. This group includes vendors that help us provide our Services to you (like payment providers that process payment information) and those that help us understand and enhance our Services (like analytics providers). We require vendors to agree to privacy commitments in order to share information with them.
With your consent or when considered a legitimate interest that does not negatively affect your rights and freedoms as an individual, we may also share your data with other third parties. These third parties and the reason for sharing your data with them is listed below:
To provide you with our services:
To Support our Infrastructure
Maintenance of Network, IT Support and Security – Flywheel
As Required by Law: We may disclose information about you in response to a court order, or other governmental request.
To Protect Rights and Property: We may disclose information about you when we believe in good faith that disclosure is reasonably necessary to protect the property or rights of Barbour EHS, third parties, or the public at large. For example, if we have a good faith belief that there is an imminent danger of death or serious physical injury, we may disclose information related to the emergency without delay.
Business Sale or Transfers: In connection with any merger, sale of company assets, or acquisition of all or a portion of our business by another company, or in the unlikely event that Barbour EHS goes out of business or enters bankruptcy, user information would likely be one of the assets that is transferred or acquired by a third party. If we are reorganised or sold to another organisation, we may transfer information we hold about you to them so they can continue to provide the services to you.
If any of these events were to happen, this Privacy Policy would continue to apply to your information and the party receiving your information may continue to use your information, but only consistent with this Privacy Policy.
Aggregated and De-Identified Information: We may share information that has been aggregated or reasonably de-identified, so that the information could not reasonably be used to identify you. For instance, we may publish aggregate statistics about the use of our Services.
Published Support Requests: If you send us a request (for example, via a support email or one of our feedback mechanisms), we reserve the right to publish that request in order to help us clarify or respond to your request or to help us support other users.
Subscribers: We may share your personal data with the entity who contracts with us for the provision of services. We will share this data for usage, reporting and as necessary for the provision of the services as laid out in our contract with that entity.
While no online service is 100% secure, we work very hard to protect information about you against unauthorized access, use, alteration, or destruction, and take reasonable measures to do so. To enhance the security of your account, we encourage you to observe good security best practices with your account information, such as choosing strong passwords when registering with our systems and keeping this information secret.
We employ a range of security controls throughout our organisation to ensure that we look after your personal data and protect it from loss, corruption or unauthorised access.
We only retain data for as long as is necessary to satisfy the following requirements: Legal Requirements: We are required to meet legal obligations in terms of retention periods for some data, such as financial records and information.
Contractual: Your data will be retained for the duration of your contract, as required by us to fulfil our contractual obligations. Following the end of the contract term, we retain your information for a period of 7 years for business analysis purposes.
Marketing: Where data is held for marketing purposes, then we hold this for 3 years of inactivity prior to destruction.
Business Analysis: Where data is held for business analysis purposes, data is limited to only that necessary to perform the analysis. We retain business analysis data for 7 years.
We always aim to keep the amount of personal data we hold to a minimum and so, unless we have received a specific request from you to erase any of your data before the retention periods expire, we will destroy/erase with an expired retention period as soon as the retention period has expired.
You have several choices available when it comes to information that we hold about you.
Limit the Information that You Provide: If you have an account with us, you can choose not to provide the optional account information, profile information, and transaction and billing information. Please keep in mind that if you do not provide this information, certain features of our Services may not be accessible (contact us for more information).
Opt-Out of Electronic Communications: You may opt out of receiving promotional messages from us. Just follow the instructions in those messages. If you opt out of promotional messages, we may still send you other messages, like those about your account and legal notices (operational messages).
Set Your Browser to Reject Cookies: You can usually choose to set your browser to remove or reject browser cookies before using Barbour EHS websites, with the drawback that certain features of our websites may not function properly without the aid of cookies.
When it comes to personal data you have defined rights regarding how your data is collected, processed and shared. These rights are explained below:
The Right of Access: You have the right to request that we show you what personal data of yours we hold and process.
The Right to Withdraw Consent: Where you have specifically given us consent to process your data then you have the ability to withdraw that consent at any time. Please be aware that where that data is used to provide you with services, then withdrawal of consent to use this data may negatively impact on our ability to provide those services for you.
The Right to Erasure: In specific circumstances, you have the right to request that any data we hold on you be erased. This includes where:
The Right to Object: There are cases where we may process some of your data in order to help us assess and improve our business. This type of processing may not be supported by a contractual requirement or your consent, but would have been carefully assessed to ensure that we have a clear legitimate interest in doing so that does not adversely affect you as an individual.
In these instances, we make you aware of these activities along with your right to object to this kind of processing should you wish.
The Right to rectification: If you become aware that any data we hold is incorrect you have the right to request that this data be corrected.
The Right to Data Portability: You have the right to request that we provide you with an electronic copy of any data you have given to us as part of a contractual relationship or following your consent. This also includes any data about you that has been generated automatically as part of these agreements.
The Right to Restrict Processing: In some situation you may require us to restrict processing, such as following an objection or if data accuracy is in question. Where you exercise your right to restrict processing we shall not recommence processing without first notifying you.
Automated Decision Making: We do not ordinarily use personal information for the purposes of automated decision making. However, we may do so in order to fulfil compelling obligations imposed by law, in which case we will inform of any such processing and provide you with an opportunity to object.
Exercising your rights
If you wish to exercise any of your rights we would be happy to help you. Please use the contact details below to communicate your requirements.
For our website to function properly we use cookies. To obtain your valid consent for the use and storage of cookies in the browser you use to access our website and to properly document this we use a consent management platform: CookieFirst. This technology is provided by Digital Data Solutions BV, Plantage Middenlaan 42a, 1018 DH, Amsterdam, The Netherlands. Website: https://cookiefirst.com referred to as CookieFirst.
When you access our website, a connection is established with CookieFirst’s server to give us the possibility to obtain valid consent from you to the use of certain cookies. CookieFirst then stores a cookie in your browser in order to be able to activate only those cookies to which you have consented and to properly document this. The data processed is stored until the predefined storage period expires or you request to delete the data. Certain mandatory legal storage periods may apply notwithstanding the aforementioned.
CookieFirst is used to obtain the legally required consent for the use of cookies. The legal basis for this is article 6(1)(c) of the General Data Protection Regulation (GDPR).
We have concluded a data processing agreement with CookieFirst. This is a contract required by data protection law, which ensures that data of our website visitors is only processed in accordance with our instructions and in compliance with the GDPR.
Our website and CookieFirst automatically collect and store information in so-called server log files, which your browser automatically transmits to us. The following data is collected:
Transfer of Information outside of the EEA
From time to time we may transfer your personal information to our group companies, suppliers or service providers based outside of the EEA for the purposes described in this privacy policy. If we do this your personal information will continue to be subject to one or more appropriate safeguards set out in the law. These might be the use of model contracts in a form approved by regulators, or having our suppliers sign up to an independent privacy scheme approved by regulators (like the US ‘Privacy Shield’ scheme).
Ads and Analytics Services Provided by Others
Ads appearing on any of our Services may be delivered by advertising networks. Other parties may also provide analytics services via our Services. These ad networks and analytics providers may set tracking technologies (like cookies) to collect information about your use of our Services and across other websites and online services. These technologies allow these third parties to recognise your device to compile information about you or others who use your device. This information allows us and other companies to, among other things, analyse and track usage, determine the popularity of certain content, and deliver advertisements that may be more targeted to your interests. Please note this Privacy Policy only covers the collection of information by Barbour EHS and does not cover the collection of information by any third-party advertisers or analytics providers.
Registering a Complaint
If you have any complaints about the way in which your personal data is being handled, then please contact us using the contact details below. Alternatively, you may also contact the national supervisory authority to register a complaint, their details can be found here.
Contact Details
To make a request to amend your details/preferences, please send an e-mail to: marketing@barbour-ehs.com or to write us at: Barbour EHS Database Manager, Barbour EHS, 20 Grosvenor Place, London, SW1X 7HN, United Kingdom.
CHANGES TO PRIVACY POLICY
We reserve the right to add to or amend this privacy policy at our sole discretion, without prior notice to you. Please review our privacy policy on a regular basis to make sure you have read the latest version and you understand what we do with your personal information. Your continued use of our services or our web sites following the posting of changes to these terms means that you consent to those changes.
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