Enercon Industries Ltd are committed to protecting and respecting your privacy.
We ask that you read this privacy notice carefully as it contains important information on who we are, how and why we collect, store, use and share personal information, your rights in relation to your personal information and on how to contact us and supervisory authorities in the event you have a complaint.
Who we are
Enercon Industries Ltd collects, uses and is responsible for certain personal information about you. When we do so we are regulated under the General Data Protection Regulation which applies across the European Union (including in the United Kingdom) and we are responsible as ‘controller’ of that personal information for the purposes of those laws.
The personal information we collect and use
Information collected by us
In the course of provision of our services and contractual obligations we collect the following personal information when you provide it to us:
- First name
- Last name
- Email address
- Business name
- Job function
- Business telephone numbers
Information collected from other sources
We also obtain personal information from other sources as follows:
- Any publicly available information from LinkedIn, Facebook or Twitter.
No sensitive personal data will be collected or processed in any way.
How we use your personal information
We use your personal information to:
- Progress any enquiry you make of us in a sales, support or after-sales category
- Fulfil any sales order you make with us
- Undertake any after-sales support you may require of us
Who we share your personal information with
We routinely share your name and delivery address details with our third party suppliers. This data sharing enables the delivery of our goods to you. Some of those third party recipients may be based outside the European Economic Area — for further information including on how we safeguard your personal data when this occurs, see ‘Transfer of your information out of the EEA’.
We will share personal information with law enforcement or other authorities if required by applicable law.
We will not share your personal information with any other third party.
Whether information has to be provided by you, and if so why
The provision of personal data such as your name, address, delivery address etc is required from you to enable us to perform our services in the provision of Induction Heat Sealing Equipment and Plasma Surface Treatment technologies. We will inform you at the point of collecting information from you, whether you are required to provide the information to us.
Six Lawful Basis for Processing Personal Data
Under the EU General Data Protection Regulation (GDPR) there are six lawful basis for processing personal data. These are detailed as follows:
The processing is necessary for a contract you have with the individual, or because they have asked you to take specific steps before entering into a contract
The individual has given clear consent for you to process their personal data for a specific purpose
- Legal Obligation
The processing is necessary for you to comply with the law (not including contractual obligations)
- Vital Interests
The processing is necessary to protect someone’s life
- Public Task
The processing is necessary for you to perform a task in the public interest or for your official functions, and the task or function has a clear basis in law
- Legitimate Interest
The processing is necessary for your legitimate interests or the legitimate interests of a third party unless there is a good reason to protect the individual’s personal data which overrides those legitimate interests. (This cannot apply if you are a public authority processing data to perform your official tasks.)
Source: ico.org.uk, February 2018.
The information relating to the six lawful basis for processing personal data is taken from the ICO website and the GDPR regulation documentation. Further information regarding the lawful basis for processing personal data can be found at ico.org.uk
Legitimate Interest Assessment (LIA)
We rely on these six grounds as the lawful basis on which we collect and use your personal data. Our legitimate interests are set out below.
The rights and freedoms of the data subjects would not be overridden in our processing of the personal data and that in no way would a data subject be caused harm by the Enercon processing. Based upon our segmentation by organisation and by specific job function, coupled with our processing of personal data within the context of a business environment, it is deemed that any processing of data will be limited to business matters, and therefore any risk of personal compromise is extremely unlikely. It is also deemed that direct marketing and sales is necessary in the context of following up with website contact requests, telephone enquiries and trade-show enquiries to better serve enquirers and to generate business sales.
Per the ICO guidance, Enercon can confirm:
- We have checked that legitimate interests is the most appropriate basis
- We understand our responsibility to protect the individual’s interests
- We have identified the relevant legitimate interests
- We have checked that the processing is necessary and there is no less intrusive way to achieve the same result
- We have done a balancing test, and are confident that the individual’s interests do not override those legitimate interests
- We only use individuals’ data in ways they would reasonably expect We are not using people’s data in ways they would find intrusive or which could cause them harm
- We do not process the data of children
- We have considered safeguards to reduce the impact where possible
- We will always ensure there is an opt-out / ability to object
- Our LIA did not identify a significant privacy impact, and therefore we do not require a DPIA
- We keep our LIA under review every six months, and will repeat it if circumstances change We include information about our legitimate interests in our privacy notice
Enercon procures this personal data in the following ways:
- Primary research – Enercon’s marketing team based in the UK gathers data relating to key decision makers at organisations from publicly available sources including the website of each business.
- Secondary research – Enercon’s marketing team based in the UK use existing publicly available sources to gather the information relating to key decision makers including the Directors’ Register at Companies House, Dun & Bradstreet, Duedil and LinkedIn.
- Purchase – Enercon purchases data from selected third party data vendors with key segmentation criteria to ensure that only decision makers from registered businesses are procured. All third-party data vendors have been checked for GDPR compliance and to ensure the validity and accuracy of data.
Keeping your personal information secure
We have appropriate security measures in place to prevent personal information from being accidentally lost, or used or accessed in an unauthorised way. We limit access to your personal information to those who have a genuine business need to know it. Those processing your information will do so only in an authorised manner and are subject to a duty of confidentiality.
We also have procedures in place to deal with any suspected data security breach. We will notify you and any applicable regulator of a suspected data security breach where we are legally required to do so.
If you want detailed information from Get Safe Online on how to protect your information and your computers and devices against fraud, identity theft, viruses and many other online problems, please visit www.getsafeonline.org. Get Safe Online is supported by HM Government and leading businesses.
How we Ensure Data Validity and Currency
Enercon’s UK-based marketing team verify new data through an opt-in preference centre using Gator mail and the resultant information is stored as GDPR compliant with the appropriate basis: either Contract for exiting customers or Legitimate Business Interest for Prospects, Agents and Representatives, Partners, Associated Industry Partners and suppliers in our CRM Workbooks.
The marketing team continuously monitor Workbooks to identify any data approaching permission expiry date is automatically requested to opt-in for a further period. If permission is not gained the data is deleted.
Transfer of your information out of the EEA
We may transfer your personal information to the following which are located outside the European Economic Area (EEA) as follows:
- The USA, in order to provide your name and address details so that our overseas partner company Enercon Industries Inc. can help with your enquiry as you are located outside of our sales territories.
Such countries do not have the same data protection laws as the United Kingdom and EEA. Whilst the European Commission has not given a formal decision that such countries provide an adequate level of data protection similar to those which apply in the United Kingdom and EEA, any transfer of your personal information will be subject to an appropriate or suitable relevant safeguards of the General Data Protection Regulation that are designed to help safeguard your privacy rights and give you remedies in the unlikely event of a misuse of your personal information.
There are several exemptions where we can transfer personal data even if there is no adequate protection. We can transfer personal data overseas if we have the individual’s consent; or where it is necessary for carrying out certain types of contract; or if the transfer is necessary to set up the contract. In addition, we can transfer personal data overseas where it is necessary for reasons of substantial public interest; or where it is necessary to protect the vital interests of the individual; or where it is necessary in connection with any legal proceedings. We can transfer overseas part of the personal data on a public register.
If you would like further information please contact our Data Protection Officer (see ‘How to contact us’ below). We will not otherwise transfer your personal data outside of the EEA or to any organisation (or subordinate bodies) governed by public international law or which is set up under any agreement between two or more countries.
Data Storage and Retention
The data held by Enercon is processed and stored in the UK within a secure environment – that of our CRM Workbooks and/or securely on premise at 62 – 62 Edison Road, Aylesbury, HP198UX.
How long your personal information will be kept
- We will hold the name, address and contact details of customers who have purchased equipment from us for the lifetime of the machine
- We will hold the name, address and contact details of non-customers for a period of two years
Under the General Data Protection Regulation you have a number of important rights free of charge. In summary, those include rights to:
- fair processing of information and transparency over how we use your use personal information
- access to your personal information and to certain other supplementary information that this Privacy Notice is already designed to address
- require us to correct any mistakes in your information which we hold
- require the erasure of personal information concerning you in certain situations
- receive the personal information concerning you which you have provided to us, in a structured, commonly used and machine-readable format and have the right to transmit those data to a third party in certain situations
- object at any time to processing of personal information concerning you for direct marketing
- object to decisions being taken by automated means which produce legal effects concerning you or similarly significantly affect you
- object in certain other situations to our continued processing of your personal information
- otherwise restrict our processing of your personal information in certain circumstances
For further information on each of those rights, including the circumstances in which they apply, see the Guidance from the UK Information Commissioner’s Office (ICO) on individuals rights under the General Data Protection Regulation.
If you would like to exercise any of those rights, please:
- email, call or write to our Data Protection Officer
- let us have enough information to identify you (e.g. account number, user name, registration details),
- let us have proof of your identity and address (a copy of your driving licence or passport and a recent utility or credit card bill), and
- let us know the information to which your request relates
Request to Object
Any individual whose data is held by Enercon has the right to object to receiving correspondence from Enercon by contacting us directly and requesting to object.
Should you wish to withdraw from Enercon processing your personal data, please make your request in writing:
By emailing: firstname.lastname@example.org
Or by writing to: Data Compliance, Enercon Industries Ltd, 62-64 Edison Road, Aylesbury, HP19 8UX.