Policy version: July 2024

Water 365 Limited is provided by Left The Building Consulting (‘we’). We are the controller of personal data obtained via our website, meaning we are the organisation legally responsible for deciding how and for what purposes it is used.

We take your privacy very seriously. Please read this privacy policy carefully as it contains important information on who we are and how and why we collect, store, use and share any information relating to you (your personal data) in connection with your use of our website. It also explains your rights in relation to your personal data and how to contact us or a relevant regulator in the event you have a complaint.

Introduction: 

We collect, use and are responsible for certain personal data about you. When we do so we are subject to the UK General Data Protection Regulation (UK GDPR). We are also subject to the EU General Data Protection Regulation (EU GDPR) in relation to goods and services we offer to individuals and our wider operations in the European Economic Area (EEA).

Applicable data protection regime: 

Given the nature of our website, we do not expect to collect the personal data of anyone under 18 years old. If you are aware that any personal data of anyone under 18 years old has been shared with our website please let us know so that we can delete that data.

Minimum age: 

This version of our privacy policy is primarily written for adults, including parents and guardians of child users. If you are a child (under 18 years old) you are welcome to read this policy if you find it useful..

This privacy policy is divided into the following sections:

•  What this policy applies to

•  Personal data we collect about you

•  How your personal data is collected

•  How and why we use your personal data

•  Marketing

•  Who we share your personal data with

•  How long your personal data will be kept

•  Transferring your personal data out of the UK and EEA

•  Cookies and other tracking technologies

•  Your rights

•  Keeping your personal data secure

•  How to complain

•  Changes to this privacy policy

•  How to contact us

•  Do you need extra help?

This privacy policy relates to your use of our website only.

Throughout our website we may link to other websites owned and operated by certain trusted third parties (e.g. to mak services available to you). Those third party websites may also gather information about you in accordance with their own separate privacy policies. For privacy information relating to those third party websites, please consult their privacy policies as appropriate.

The personal data we collect about you depends on the particular activities carried out through our website. We will collect and use the following personal data about you:

•  your name, address and contact information, including email address and telephone number and company details

•  any delivery addresses specified for your order

•  location data, if you choose to give this to us

•  your billing information, transaction and payment card or other payment method information

•  bank account and payment details

•  details of any information, feedback or other matters you give to us by phone, email, post or via social media

•  your account details, such as username and login details

•  your activities on, and use of, our website

•  your professional interests

•  your professional online presence, eg LinkedIn profile

•  information about the services we provide to you

•  your contact history, purchase history and saved items

•  information about how you use our website and technology systems

•  your responses to surveys, competitions and promotions

You may provide this personal data unless we tell you that you have a choice. 

Sometimes you can choose if you want to give us your personal data and let us use it. Where that is the case we will tell you and give you the choice before you give the personal data to us. We will also tell you whether declining to share that personal data will have any effect on the services that we can provide to you.

We collect and use this personal data for the purposes described in the section ‘How and why we use your personal data’ below.

We collect personal data from you: 

•  directly, when you enter or send us information, such as when you register with us, contact us (including via email), send us feedback, purchase products or services via our website, post material to our website and complete customer surveys or participate in competitions via our website, and 

•  indirectly, such as your browsing activity while on our website; we will usually collect information indirectly using the technologies explained in the section on ‘Cookies’ below

Under data protection law, we can only use your personal data if we have a proper reason, e.g.:

•  where you have given consent

•  to comply with our legal and regulatory obligations

•  for the performance of a contract with you or to take steps at your request before entering into a contract, or

•  for our legitimate interests or those of a third party

A legitimate interest is when we have a business or commercial reason to use your personal data, so long as this is not overridden by your own rights and interests. We will carry out an assessment when relying on legitimate interests, to balance our interests against your own. You can obtain details of this assessment by contacting us (see ‘How to contact us’ below).

Certain personal data we collect is treated as a special category to which additional protections apply under data protection law:

•  include as relevant to the data collected: personal data revealing racial or ethnic origin, political opinions, religious beliefs, philosophical beliefs or trade union membership

Where we process such special category personal data, we will also ensure we are permitted to do so under data protection laws. 

See ‘Who we share your personal data with’ for further information on the steps we will take to protect your personal data where we need to share it with others.

We will use your personal data to send you updates (by email, text message, telephone or post) about our products AND/OR services, including exclusive offers, promotions or new products AND/OR services.

We have a legitimate interest in using your personal data for marketing purposes (see above ‘How and why we use your personal data’). This means we do not need your consent to send you marketing information. If we change our marketing approach in the future so that consent is needed, we will ask for this separately and clearly.

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

•  contacting us at info@water-365.com 

•  using the ‘unsubscribe’ link in emails or ‘STOP’ number in texts

We may ask you to confirm or update your marketing preferences if you ask us to provide further products AND/OR services in the future, or if there are changes in the law, regulation, or the structure of our business.

We will always treat your personal data with the utmost respect and never sell OR share it with other organisations for marketing purposes.

For more information on your right to object at any time to your personal data being used for marketing purposes, see ‘Your rights’ below.

We routinely share personal data with:

•  third parties we use to help deliver our products AND/OR services to you, e.g. payment service providers, warehouses and delivery companies

•  other third parties we use to help us run our business, e.g. marketing agencies or website hosts and website analytics providers

•  We only allow those organisations to handle your personal data if we are satisfied they take appropriate measures to protect your personal data.

We or the third parties mentioned above occasionally also share personal data with:

•  Our external auditors, e.g. in relation to the audit of our accounts, in which case the recipient of the information will be bound by confidentiality obligations

•  our and their professional advisors (such as lawyers and other advisors), in which case the recipient of the information will be bound by confidentiality obligations

•  law enforcement agencies, courts, tribunals and regulatory bodies to comply with our legal and regulatory obligations

•  other parties that have or may acquire control or ownership of our business (and our or their professional advisers) in connection with a significant corporate transaction or restructuring, including a merger, acquisition, asset sale, initial public offering or in the event of our insolvency—usually, information will be anonymised but this may not always be possible. The recipient of any of your personal data will be bound by confidentiality obligations.

•  We will not share your personal data with any other third party.

If you would like more information about who we share our data with and why, please contact us (see ‘How to contact us’ below).

We will not keep your personal data for longer than we need it for the purpose for which it is used. For example.

Different retention periods apply for different types of personal data.

If you stop using your account we will delete or anonymise your account data after seven years.

Following the end of the of the relevant retention period, we will delete or anonymise your personal data.

The EEA, UK and other countries outside the EEA and the UK have differing data protection laws, some of which may provide lower levels of protection of privacy.

It is sometimes necessary for us to transfer your personal data to countries outside the UK and EEA. In those cases we will comply with applicable UK and EEA laws designed to ensure the privacy of your personal data.

We will transfer your personal data to:

•   our service providers located outside the UK

•  As we are based in the UK we will also transfer your personal data from the EEA to the UK.

Under data protection laws, we can only transfer your personal data to a country outside the UK/EEA where:

•  in the case of transfers subject to UK data protection law, the UK government has decided the particular country ensures an adequate level of protection of personal data (known as an ‘adequacy regulation’) further to Article 45 of the UK GDPR. A list of countries the UK currently has adequacy regulations in relation to is available here.

•  in the case of transfers subject to EEA data protection laws, the European Commission has decided that the particular country ensures an adequate level of protection of personal data (known as an ‘adequacy decision’) further to Article 45 of the EU GDPR. A list of countries the European Commission has currently made adequacy decisions in relation to is available here. 

•  there are appropriate safeguards in place, together with enforceable rights and effective legal remedies for you, or

•  a specific exception applies under relevant data protection law

Where we transfer your personal data outside the UK we do so on the basis of an adequacy regulation or (where this is not available) e.g. legally-approved standard data protection clauses recognised or issued further to Article 46(2) of the UK GDPR. In the event we cannot or choose not to continue to rely on either of those mechanisms at any time we will not transfer your personal data outside the UK unless we can do so on the basis of an alternative mechanism or exception provided by UK data protection law and reflected in an update to this policy.

Where we transfer your personal data outside the EEA we do so on the basis of an adequacy decision or (where this is not available) a legally-approved standard data protection clauses issued further to Article 46(2) of the EU GDPR. In the event we cannot or choose not to continue to rely on either of those mechanisms at any time we will not transfer your personal data outside the EEA unless we can do so on the basis of an alternative mechanism or exception provided by applicable data protection law and reflected in an update to this policy.

If you would like further information about data transferred outside the UK/EEA, please contact us OR our Data Protection Officer(see ‘How to contact us’ below).

A cookie is a small text file which is placed onto your device (eg computer, smartphone or other electronic device) when you use our website. We use cookies on our website. These help us recognise you and your device and store some information about your preferences or past actions.

For further information on cookies and our use of ‘cookies’ and/or to relevant similar technologies, when we will request your consent before placing them and how to disable them.

You generally have the following rights, which you can usually exercise free of charge.

For further information on each of those rights, including the circumstances in which they do and do not apply, please contact us (see ‘How to contact us’ below). You may also find it helpful to refer to the guidance from the UK’s Information Commissioner on your rights under the UK GDPR.

If you would like to exercise any of those rights, please email, call or write to us—see below: ‘How to contact us’. When contacting us please:

•  provide enough information to identify yourself (eg your full name, address and customer or matter reference number) and any additional identity information we may reasonably request from you, and

•  let us know which right(s) you want to exercise and the information to which your request relates

We have appropriate security measures to prevent personal data from being accidentally lost, or used or accessed unlawfully. We limit access to your personal data to those who have a genuine need to access it. 

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 personal data and other 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.

Please contact us if you have any queries or concerns about our use of your personal data (see below ‘How to contact us’). We hope we will be able to resolve any issues you may have.

You also have the right to lodge a complaint with:

•  the Information Commissioner in the UK

•  a relevant data protection supervisory authority in the EEA state of your habitual residence, place of work or of an alleged infringement of data protection laws in the EEA

The UK’s Information Commissioner may be contacted using the details at https://ico.org.uk/make-a-complaint or by telephone: 0303 123 1113.

For a list of EEA data protection supervisory authorities and their contact details see here.

We may change this privacy policy from time to time—when we make significant changes we will take steps to inform you.

You can contact us and/or our Data Protection Officer by email or telephone if you have any questions about this privacy policy or the information we hold about you, to exercise a right under data protection law or to make a complaint.

Our contact details are shown below:

Our Data Protection Officer’s contact details:

Rob Nicoll at rob.nicoll@water-365.com +44 7931 542310