Data Protection, Privacy Policy & GDPR

Arbil Ltd. is committed to the protection of the personal information that we hold about our customers, suppliers, employees and other third parties.
The purpose of this policy is to provide transparency about the type of data that we hold, how we use it, and who it may be shared with.

Customers
Business details (such as contact names, email addresses and postal addresses) are collected in order to provide the products and services that the customer has requested from us.
Financial information (such as bank account details, trade references) is also collected for the purpose of billing, and in order to set up credit account facilities.

Suppliers
Business details (such as contact names, email addresses and postal addresses) are held to allow us to obtain quotations and carry out business transactions with suppliers.
Financial information is also held to allow us to make payment to our suppliers.

Third Parties
Personal Information about other third parties will only be kept when this has been given willingly by the third party. The information will only be used for legitimate business reasons.

Personal Information is stored securely at our premises, both electronically and within our hard copy filing system. 

Personal Information is stored securely at our premises, both electronically and within our hard copy filing system.

We never sell personal data, nor do we use it for marketing purposes. We may share personal data with our data processors. Examples of these include the provider of the cloud storage facility, the software support service for our software and our accountancy service provider, alternatively third parties who are facilitating the delivery of Arbil services . Information is transferred to data processors securely, and we retain full responsibility for the personal data as the data controller. These activities are carried out under a contract which imposes strict requirements on our suppliers to keep all personal data confidential and secure.We may share personal data where we are legally required to do so for prevention of crime or for taxation purposes (for example, with the police, HMRC) or if where we  believe that it is necessary to do so, it may be obtained  as a result of you being on our premises or using our systems (for example, CCTV footage).

Personal information we collect
When you visit the Site, we automatically collect certain information about your device, including information about your web browser, IP address, time zone, and some of the cookies that are installed on your device. Additionally, as you browse the Site, we collect information about the individual web pages or products that you view, what websites or search terms referred you to the Site, and information about how you interact with the Site. We refer to this automatically-collected information as “Device Information”.

We collect Device Information using the following technologies:
• “Cookies” are data files that are placed on your device or computer and often include an anonymous unique identifier. For more information about cookies, and how to disable cookies, visit http://www.allaboutcookies.org.
• “Log files” track actions occurring on the Site, and collect data including your IP address, browser type, Internet service provider, referring/exit pages, and date/time stamps.
• “Web beacons”, “tags”, and “pixels” are electronic files used to record information about how you browse the Site.
• Google Analytics, Facebook and Campaign Monitor (in conjunction with Shopify) tracking.

Additionally when you make a purchase or attempt to make a purchase through the Site, we collect certain information from you, including your name, billing address, shipping address, payment information (including partial credit card numbers) email address, and phone number. We refer to this information as “Order Information”.

Existing Ordering or Account information
As most of our customers have already set-up an Account with ourselves, the email and name data from the persons stated within our CRM are used within our email platforms; all existing accounts have had and continue to have the option to unsubscribe at any time. New customers ordering online can also decide to opt into our email platform if they wish, which operates a double opt in method.

When we talk about “Personal Information” in this Privacy Policy, we are talking both about Device Information and Order Information.

How do we use your personal information? 
We use the Order Information that we collect generally to fulfill any orders placed through the Site (including processing your payment information, arranging for shipping, and providing you with invoices and/or order confirmations).
Additionally, we use this Order Information to: 

• Communicate with you; 

• Screen our orders for potential risk or fraud; and

• When in line with the preferences you have shared with us, provide you with  information or advertising relating to our products or services

• Google, Facebook and Shopify ordering (including Campaign Monitor) analytics.

We use the Device Information that we collect to help us screen for potential risk and fraud (in particular, your IP address), and more generally to improve and optimize our Site (for example, by generating analytics about how our customers browse and interact with the Site, and to assess the success of our marketing and advertising campaigns). 
We use Advertising and Retargeting options with Google and Facebook; below you can control these tracking preferences.

Sharing you personal Information 
We share your Personal Information with third parties to help us use your Personal Information, as described above. For example, we use Shopify to power our online store-you can read more about how Shopify uses your Personal Information here: https://www.shopify.com/legal/privacy. We also use Google Analytics to help us understand how our customers use the Site -- you can read more about how Google uses your Personal Information here: https://www.google.com/intl/en/policies/privacy/. You can also opt-out of Google

Analytics here: https://tools.google.com/dlpage/gaoptout. 

Finally, we may also share your Personal Information to comply with applicable laws and regulations, to respond to a subpoena, search warrant or other lawful request for information we receive, or to otherwise protect our rights. 

Behavioural advertising 
As described above, we use your Personal Information to provide you with targeted advertisements or marketing communications we believe may be of interest to you. For more information about how targeted advertising works, you can visit the Network Advertising Initiative’s (“NAI”) educational page at http://www.networkadvertising.org/understanding-online-advertising/how-does-it-work. 

You can opt out of targeted advertising by using the links below: 

• Facebook: https://www.facebook.com/settings/?tab=ads 

• Google: https://www.google.com/settings/ads/anonymous 

• Bing: https://advertise.bingads.microsoft.com/en-us/resources/policies/personalized-ads 

Additionally, you can opt out of some of these services by visiting the Digital Advertising Alliance’s opt-out portal at: http://optout.aboutads.info/. 
Do not track 
Please note that we do not alter our Site’s data collection and use practices when we see a Do Not Track signal from your browser. 

Your rights 
If you are a European resident, you have the right to access personal information we hold about you and to ask that your personal information be corrected, updated, or deleted. If you would like to exercise this right, please contact us through the contact information below. 

Additionally, if you are a European resident we note that we are processing your information in order to fulfil contracts we might have with you (for example if you make an order through the Site), or otherwise to pursue our legitimate business interests listed above. Additionally, please note that your information will be transferred outside of Europe, including to Canada and the United States. 

Data retention 
When you place an order through the Site, we will maintain your Order Information for our records unless and until you ask us to delete this information. 

Changes
We may update this privacy policy from time to time in order to reflect, for example, changes to our practices or for other operational, legal or regulatory reasons. 

A company or individual can assess or update the personal data that Arbil Ltd. holds about them by making the request in writing, either by sending an email to info@arbil.co.uk by writing to Arbil Limited, Providence Street, Nr Lye, Stourbridge. West Midlands. DY9 8HS. This is also the method to be used to request the erasure of personal data from our records.

Should you not agree with the way that we are handling your data, you have the right to contact the Information Commissioners Office (Information found below).
Information Commissioner's Office
Wycliffe House
Water Lane
Wilmslow. Cheshire.
SK9 5AF
Telephone Number 03031231113
Email: registration@ico.org.uk

Introduction
Arbil needs to gather and use certain information about individuals.
These can include customers, suppliers, business contacts, employees and other people the organisation has a relationship with or may need to contact.
This policy describes how this personal data must be collected, handled and stored
to meet the company’s data protection standards — and to comply with the law.

Why this policy exists
This data protection policy ensures Arbil Ltd
• Complies with data protection law and follow good practice
• Protects the rights of staff, customers and partners
• Is open about how it stores and processes individuals’ data
• Protects itself from the risks of a data breach

Data protection law
The General Data Protection Regulation (GDPR) describes how organisations — including Arbil Ltd — must collect, handle and store personal information.
These rules apply regardless of whether data is stored electronically, on paper or on other materials.
To comply with the law, personal information must be collected and used fairly, stored safely and not disclosed unlawfully.
The General Data Protection Regulation is underpinned by six important principles. These say that personal data must:
1. Be processed lawfully, fairly and in a transparent manner. 
2. Collected for specified, explicit and legitimate purposes and not further processed in a manner that is incompatible with those purposes.
3. Be adequate, relevant and limited to what is necessary in relation to the purposes for which they are processed. 
4. Be accurate and, where necessary, kept up to date.
5. Be kept in a form which permits identification of data subjects for no longer than is necessary for the purposes for which the personal data are processed.
6. Be processed in a manner that ensures appropriate security of the personal data, including protection against unauthorised or unlawful processing and against accidental loss, destruction or damage, using appropriate technical or organisational measures.

People, risks and responsibilities Policy scope
This policy applies to:
• The head office of Arbil Ltd
• All branches of Arbil Ltd
• All staff and volunteers of Arbil Ltd
• All contractors, suppliers and other people working on behalf Arbil Ltd
It applies to all data that the company holds relating to identifiable individuals, even if that information technically falls outside of the General Data Protection Regulation. This can include:
• Names of individuals
• Postal addresses
• Email addresses
• Telephone numbers
• Medical Questionnaires
• Driver License Details
• Training Certificates

Data protection risks
This policy helps to protect Arbil Ltd from some very real data security risks, including:
• Breaches of confidentiality. For instance, information being given out inappropriately.
• Failing to offer choice. For instance, all individuals are free to choose how the company uses data relating to them.
• Reputational damage. For instance, the company could suffer if hackers successfully gained access to sensitive data.

Responsibilities
• Everyone who works for or with Arbil Ltd has some responsibility for ensuring data is collected, stored and handled appropriately.
• Each team that handles personal data must ensure that it is handled and processed in line with this policy and data protection principles.
• However, these people have key areas of responsibility:
The board of directors is ultimately responsible for ensuring that Arbil Ltd meets its legal obligations.
The data protection officer, Kevin French is responsible for:
• Keeping the board updated about data protection responsibilities, risks and issues.
• Reviewing all data protection procedures and related policies, in line with an agreed schedule.
• Arranging data protection training and advice for the people covered by this policy.
• Handling data protection questions from staff and anyone else covered by this policy.
• Dealing with requests from individuals to see the data Arbil Ltd holds about them (also called ‘subject access requests’).
• Checking and approving any contracts or agreements with third parties that may handle the company’s sensitive data.

Arbil Ltd, is responsible for:
• Ensuring all systems, services and equipment used for storing data meet acceptable security standards.
• Performing regular checks and scans to ensure security hardware and software is functioning properly.
• Evaluating any third-party services the company is considering using to store or process data. For instance, cloud computing services.
• Approving any data protection statements attached to communications such as emails and letters.
• Addressing any data protection queries from journalists or media outlets like newspapers.
• Where necessary, working with other staff to ensure marketing initiatives abide by data protection principles.

General staff guidelines
• The only people able to access data covered by this policy will be those who need it for their work.
• Data will not be shared informally. When access to confidential information is required, employees can request it from their line managers.
• Arbil Ltd will provide training to all employees to help them understand their responsibilities when handling data.
• Employees are instructed to keep all data secure, by taking sensible precautions and following the guidelines below.
• In particular, strong passwords must be used and they will never be shared.
A clean desk policy has been implemented to ensure personal data cannot be viewed by unauthorised people. Such as Customers visiting the Trade Counters
Personal data is not to be disclosed to unauthorised people, either within the company or externally.
• Data will be regularly reviewed and updated if it is found to be out of date. If no longer required, it will be deleted and disposed of.
• Employees can request help from their line manager or the data protection officer if they are unsure about any aspect of data protection.

Data storage 
These rules describe how and where data will be safely stored. Questions about storing data safely can be directed to the IT manager or data controller.
When data is stored on paper, it will be kept in a secure place where unauthorised people cannot see it.

These guidelines also apply to data that is usually stored electronically but has been printed out for some reason:
• When not required, the paper or files will be kept in a locked drawer or filing cabinet.
• Employees to ensure paper and printouts are not left where unauthorised people could see them, like on a printer.
• Data printouts must be shredded and disposed of securely when no longer required.

When data is stored electronically, it must be protected from unauthorised access, accidental deletion and malicious hacking attempts:
• Data will be protected by strong passwords that are changed regularly and never shared between employees.
• If data is stored on removable media (like a CD or DVD), these are kept locked away securely when not being used.
• Data is only to be stored on designated drives and servers, and will only be uploaded to our approved hosted Software Company.
• Servers containing personal data are sited in a secure location, away from general office space.
• Data is backed up daily. Those backups are tested regularly, in line with the company’s standard backup procedures.
• Data will never be saved directly to laptops or other mobile devices like tablets or smart phones.
• All servers and computers containing data will be protected by approved security software and a firewall.


Data use 
Personal data is of no value to Arbil Ltd unless the business can make use of it. However, it is when personal data is accessed and used that it can be at the greatest risk of loss, corruption or theft:
• When working with personal data, employees will ensure the screens of their computers are always locked when left unattended.
• Personal data will not be shared informally. In particular, it will never be sent by email, as this form of communication is not secure.
• Personal data will never be transferred outside of the European Economic Area.
• Employees are not allowed to save copies of personal data to their own computers.
Always access and update the central copy of any data.


Data accuracy 
The law requires Arbil Ltd to take reasonable steps to ensure data is kept accurate and up to date.
The more important it is that the personal data is accurate, the greater the effort Arbil Ltd will put into ensuring its accuracy.
It is the responsibility of all employees who work with data to take reasonable steps to ensure it is kept as accurate and up to date as possible.
• Data will be held in as few places as necessary. Staff will not create any unnecessary additional data sets.
• Staff will take every opportunity to ensure data is updated. For instance, by confirming a customer’s details when they call.
• Arbil Ltd will make it easy for data subjects to update the information Arbil Ltd holds about them. For instance, via the company website.
• Data will be updated as inaccuracies are discovered. For instance, if a customer can no longer be reached on their stored telephone number, it will be removed from the database.
• It is the marketing manager’s responsibility to ensure marketing databases are checked against industry suppression files every six months.

Subject access requests 
All individuals who are the subject of personal data held by Arbil Ltd are entitled to:
• Ask what information the company holds about them and why.
• Ask how to gain access to it.
• Be informed how to keep it up to date.
• Be informed how the company is meeting its data protection obligations.
If an individual contacts the company requesting this information, this is called a subject access request.
Subject access requests from individuals will be made by email, addressed to the data controller at Arbil Ltd e-mail address. The data controller can supply a standard request form, although individuals do not have to use this.
A copy of the requested information will be given free of charge. 
The data controller will always verify the identity of anyone making a subject access request before handing over any information. In some cases this may be the legal parent or guardian of anyone under the age of 13.
For simple subject access requests we will aim to provide the information within 14 days.

Disclosing data for other reasons 
In certain circumstances, the General Data Protection Regulation allows personal data to be disclosed to law enforcement agencies without the consent of the data subject.
Under these circumstances, Arbil Ltd will disclose requested data. However, the data controller will ensure the request is legitimate, seeking assistance from the board and from the company’s legal advisers where necessary.


Providing information 
Arbil Ltd aims to ensure that individuals are aware that their data is being processed, and that they understand:
• How the data is being used
• How to exercise their rights
To these ends, the company has a privacy statement, setting out how data relating to individuals is used by the company.
This is available on request. A version of this statement is also available on the
company’s website. Arbil.co.uk

Data Breaches 
In the unlikeliest event that there is a data breach, Arbil Ltd will ensure that procedures are in place to ensure that, where appropriate, the correct authorities are informed within 72 hours of being made aware of the breach.
Where a breach is likely to result in a high risk to the rights and freedoms of the individual or individuals then they will also be notified without delay.
Arbil Ltd will investigate any breach of personal data to ensure the appropriate corrective actions are put in place to prevent a re-occurrence on the breach.

Context and overview Key details
• Policy prepared by: Kevin French
• Approved by board / management on: 25.5.18
• Policy became operational on: 31.5.18
• Next review date: 31.5.20