We are delighted that you have shown interest in our company and products. National Framework Partnership Ltd (as defined below) takes your data protection rights very seriously and we are committed to improving your customer experience in compliance with all applicable data protection laws and regulations. Please find below our Privacy Notice, which explains the way we process your personal data.
In light of the above, National Framework Partnership Ltd , a company incorporated under the laws of England and Wales, having its registered office in International House,24 Holborn Viaduct, London, EC1A 2BN, United Kingdom.
(“NFP”, “us” or “we”), in its capacity as data controller, intends to provide individuals, including but not limited to the users (“Users”, “you” or “your”) of this website (“Website”), with information concerning the methods used for collecting and processing personal data, in accordance, with the European General Data Protection Regulation no. 679/2016 (“Regulation”) and any other applicable local laws and regulations.
INFORMATION WE COLLECT
(1) personal data that you have voluntarily shared with us
(2) data concerning your activity on the Website and
(3) information provided or collected through other sources.
We do not collect special categories of personal data relating to you (e.g., health or judicial data).
HOW DO WE USE YOUR DATA
We use your personal data to provide you with the services requested, including but not limited to, allowing you to surf through the Website, respond to requests and to interact with our services.
Only with your consent, we may also process your personal data to send you customized marketing communications including offers and discounts from us and from our trusted partners.
ON WHAT GROUND DO WE USE YOUR DATA
We use your data to allow you to use the Website and the relevant services.
Your personal data is also collected to comply with legal obligations or to protect the legitimate interests of NFP.
Without certain data we may be unable to offer you the services or grant you access to the Website, as the case may be.
For further information click here.
FOR HOW LONG WE RETAIN YOUR DATA
We use your personal data for the period strictly necessary to achieve the intended purposes.
For further information click here.
WHAT WE DO TO PROTECT YOUR DATA
The security of your data is a priority for us. For this purpose, we have implemented adequate administrative, technical and physical measures designed to safeguard your personal data against loss, theft and unauthorized use, disclosure of modification.
For further information click here.
WITH WHOM DO WE SHARE YOUR DATA
We may share your data with (1) service providers, (2) our affiliated companies, and (3) public authorities, when allowed by applicable laws.
Upon your consent, we may also share your personal data with our trusted partners for their marketing purposes.
For further information click here.
TRANSFERS OF YOUR DATA OUTSIDE EEA
Your data will not be transferred to subjects located outside European Economic Area (EEA).
You have among others the right to access, integrate, update, amend and delete your personal data.
You can contact us by sending us an email at email@example.com. We may modify or update this Privacy Notice also in order to comply with applicable laws.
1. TYPE OF PERSONAL DATA PROCESSED
NFP will process the following categories of data:You can contact us using our contact us form. We may modify or update this Privacy Notice also in order to comply with applicable laws.
Data relating to you
NFP processes personal data about you collected or provided through a number of sources, including but not limited to, personal data provided by you directly at the use of a framework.
Such data is processed only to the extent that it is necessary to pursue the purposes set out in this Privacy Notice. NFP is required to keep the personal data anonymous and to remove such data where it does not need to process personal data in identifiable form for processing purposes.
The Website collects personal data of the Users for technical and functioning reasons. Such data is not collected for the purpose of identifying the User, but it may imply the identification of the same should, for instance, the data be compared to other data held by third parties. Such category of data includes the IP address and the domain name of the User’s computer, the URI (Uniform Resource Identifier) addresses of the requested resources, the time of the request, the method used to submit the request to the server, the size of the file received as reply, the numerical code related to the reply status from the server and other parameters related to the operating system used by the User’s device. Such data is used only to collect anonymous statistical information on the use of the Website and to control its correct operation and it is retained in accordance with our records retention requirements. Such data may be used for ascertaining liability in the event of possible computer-related crimes against the Website. We may also collect personal data on our Website by means of different categories of cookies. For more information about cookies, please visit our Cookie Notice.
2. PURPOSES OF THE PROCESSING
Where applicable, we will process your personal data we have collected or been provided with for the following purposes:
allowing you to register on the Website by opening a personal account, to register a product on the Website and to purchase a product on the Website;
completing the online purchase of the product (the prevention of fraud, the management of returns);
providing you with any requested services;
managing the requests for information you send us, including handling complaints and communications received via our interactive chat service;
entering a prize promotion / competition;
complying with the statutory provisions and regulations and enforcing our own rights before the courts;
upon your consent, and without prejudice to NFP’s legitimate interest, sending you customized marketing communications related to our products and services electronically (including email, SMS, MMS, social network notifications, mobile applications);
unless you opt-out, contacting you for marketing purposes by phone (non-automated) and via paper mail;
for the purpose of sending you customer care communications concerning products registered by you or which you showed interest in and in order to carry out customer satisfaction surveys;
upon your consent, sharing your personal data for customized marketing communication with our selected trusted partners as set forth in Section 6 below; and
carrying out activities useful for the transfers of business and business branches, takeovers, mergers, demergers or other transformations and for the execution of such transactions.
3. LEGAL BASIS FOR THE PROCESSING
The provision of the personal data for the purposes under Section 2, para. a), b), c), d), e) and f) is necessary for the purpose the data was provided or shared with us which includes but is not limited the registration on the Website, the online purchase of products and the use of ancillary specific services, as well as the participation to prize promotions and competitions;
The provision of personal data for the purposes under Section 2, para. g) is mandatory since required by the applicable laws;
The provision of the personal data for the purposes under Section 2, para. h) and k) is optional. In the absence of your consent, NFP, will not be able to send you customized marketing communications via automated means. In any event, upon the withdrawal of the Users’ consent we will no longer process the personal data for the purposes of para. h) and k) above. Our expectation is that consent to receive marketing communications and data sharing (where applicable) is given by the data subject whose personal data has been provided;
The provision of personal data for the purposes under Section 2, para. i), j) and l) is necessary to pursue the legitimate interests of NFP, which will be appropriately balanced with your interests.
We may also use, in compliance with the applicable data protection laws, your electronic contact details (email, phone number) we collected in the context of a sale of a product or service, in order to send you customized marketing communications related to similar products or services. In such a case, you may object to such use of your electronic contact details by clicking the “unsubscribe” link at the bottom of the email / SMS at each time the customized marketing communication is sent; or in accordance with Section 9 of this Privacy Notice below.
4. DATA RETENTION
NFP will process the personal data for as long as it is necessary to achieve the intended purposes pursuant to Section 2 above. In any case, the following retention periods shall apply:
the data collected for the purposes of Section 2, para. a), b) and c), d), e) and f) will be retained for the period strictly necessary in order to respond to data subjects’ requests and comply with applicable laws and regulations;
the data collected for the purpose of Section 2, para. g) will be retained for the period mandatorily prescribed by the applicable law provisions (e.g., for tax purposes);
the data collected for the purposes of Section 2, para. h) and k) will be retained for the maximum data retention period set forth by the applicable law provisions; and
the data collected for the purposes of Section 2, para. i), j) and l) will be retained for the period strictly necessary in order to pursue NFP legitimate interests.
Please consider that data retention periods may vary, depending on the applicable local laws.
5. DATA PROCESSING PROCEDURES
Your personal data is processed with the support of Information Technology and/or paper means and it is protected by appropriate security devices suitable to ensure the secrecy and safety of the personal data. In particular, NFP adopts the appropriate administrative, technical, personal and physical measures designed to safeguard the personal data held against any loss, theft as well as unauthorised use, disclosure or change in the personal data.
6. COMMUNICATION OF DATA
We will share your personal data with our trusted partners, such as our extended warranty providers, that intend to use it for direct marketing purposes only when we have specifically informed you and you have given us specific consent to do this.
We may share your personal data with:
NFP located in the EEA, acting as autonomous controllers;
our carefully chosen third party suppliers located in the EEA and outside the EEA, such as call centre operators, shippers, suppliers of services or technicians assigned to assistance and other suppliers working on our behalf in the role of duly appointed data processors for the purposes described in this notice; other third parties as part of a corporate transaction such as a merger or sale of assets.
In the above cases, these companies must abide by our data privacy and security requirements and are not allowed to use personal data they receive from us for any other purpose.
Should an extra-EEA transfer occur, we will implement suitable safeguards in accordance with the Regulation. See in particular Section 7 below.
8. MINORS UNDER THE AGE OF 18
The Website does not address subjects under the age of 18, nor is NFP knowingly collecting personal data from people under the age of 18.
9. RIGHTS OF DATA SUBJECTS
You, at any time and at no charge, can have and/or exercise the following rights:
the right to be informed on the purposes and methods of the processing of your personal data;
the right of access to your personal data (commonly known as “data subject access request”). This enables you to receive a copy of the personal data we hold about you;
the right to ask for updating or rectification of the personal data we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us;
the right to request erasure of your personal data. This enables you to ask us to delete or remove your personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request;
the right to restrict the processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios: (a) if you want us to establish the data’s accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it;
the right to object to the processing, wholly or partly, of your personal data where we are relying on legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms;
where we are relying on consent to process your personal data, the right to revoke the consent to the processing of your personal data freely and at any time, also by clicking on the unsubscribe option at the bottom of our marketing communications;
the right to data portability of your personal data to you or to a different provider. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format;
the right to contact us by sending us an email at firstname.lastname@example.org
the right to lodge a complaint in front of the competent national data protection or judicial authority.
If you wish to exercise the rights mentioned above, or raise any questions about the personal data we hold about you, please send us an email at email@example.com for the attention of the Data Protection Office.
10. AMENDMENTS AND UPDATES
We keep this Privacy Notice under regular review. We may update this Privacy Notice to reflect changes to our privacy practices. If we make any material change, we will inform you by updating this Privacy Notice prior to its effective date. We encourage you to periodically review our Privacy Notice for the latest information on our privacy practices. This Privacy Notice was last updated on 23.11.2019