Data Privacy Notice
Code QA010 Authorised By Timothy Goodson Managing Director
Date February 2018 Signed

Reason for Amendment GDPR Review

DVS Ltd PRIVACY NOTICE

DVS Ltd takes privacy seriously. The following principles underpin our approach to respecting your privacy:

We value the trust that you place in us by giving us your personal information. We will always use your personal information in a way that is fair and lawful.

We will provide clear information about how we use your personal information. We shall always be transparent with you about what information we collect, what we do with it, with whom we share it and who you should contact if you have any concerns.

We will take all reasonable steps to protect your information from misuse and keep it secure.

We will comply with all applicable GDPR laws and regulations and we will co-operate with data protection authorities. In the absence of data protection legislation, we will act in accordance with generally accepted principles governing data protection.

This Privacy Notice explains the types of personal information we collect and how we use, disclose and protect that information.
 

Data Controller Details

The Company is a data controller, meaning that it determines the processes to be used when using your personal data. Our contact details are as follows: DVS Ltd; Unit 3 Neptune Point; Vanguard Way; Cardiff; CF24 5PG

Privacy Officer

The Company’s Privacy Officer details can be obtained by emailing contact@dvs.co.uk

What does this Privacy Notice apply to?

This Privacy Notice applies to personal information collected by DVS Ltd in connection with the services they offer. Find out more about DVS Ltd at https://www.DVS.Co.UK. This may include information collected through, employment applications, direct marketing campaigns, sweepstakes and competitions, and online through our website, applications and branded pages on third party platforms and applications accessed or used through such websites or third-party platforms.

This Privacy Notice also applies to targeted DVS Ltd content, including offers and advertisements for DVS Ltd products and services, which we (or a service provider acting on our behalf) may send to you on third party websites, platforms and applications (“Third Party Sites”) based on your Site Usage Information (as defined below). These third-party Sites may have their own privacy policies and terms and conditions. We encourage you to read them before using those third-party Sites.

This Privacy Notice is hereby incorporated into and forms part of the terms and conditions of use of the applicable DVS Ltd. For information about DVS Ltd who are responsible for protecting your personal information, see “your privacy rights and who to contact” below.

Data Protection Principles

In relation to your personal data, we will:

• Process it fairly, lawfully and in a clear, transparent way
• Collect your data only for reasons that we find proper for the course of your employment in ways that have been explained to you
• Only use it in the way that we have told you about
• Ensure it is correct and up to date
• Keep your data for only as long as we need it
• Process it in a way that ensures it will not be used for anything that you are not aware of or have consented to (as appropriate), lost or destroyed

Your consent

By using the DVS Ltd website, you are consenting to DVS Ltd collecting, using and disclosing your personal information in accordance with this Privacy Notice. If you do not agree to the collection, use and disclosure of your personal information in this way, please do not use the DVS Ltd Sites or otherwise provide DVS Ltd with your personal information.

DVS Ltd will only collect, use or disclose your personal information where it is fair and lawful to do so. If consent is required to collect and use an individual’s information it now needs to be freely given, specific, informed and unambiguous. There must be a positive opt-in – consent cannot be inferred from silence, pre-ticked boxes or inactivity. Any consent given needs to be recorded as the individual has the right to change their mind at any time and withdraw their consent. Processes will need to be in place to manage consent and also to manage the withdrawal of consent.

We may ask you to provide additional consent if we need to use your personal information for purposes not covered by this Privacy Notice. You are not obliged to provide such consent but if you decide not to then your participation in certain activities may be restricted. If you provide additional consent, the terms of that consent shall prevail in the event of any conflict with the terms of this Privacy Notice.

Please note, however, that we may process your personal information without consent if we have a legitimate reason to do so, provided that such use will not have a prejudicial effect on your own rights, freedoms and interests. Any such use shall be in accordance with the DVS Ltd Privacy Principles set out above.

You can opt out of receiving communications from us at any time. Any direct marketing communications that we send to you will provide the information and means necessary to opt out.

To provide you with products or services that you request from us., we may use your personal information:

• for the purposes of competitions or promotions that you have entered
• to send you information, products or samples that you have requested
• to respond to your queries or comments

In order to protect information from accidental or malicious destruction, when we delete information from our services we may not immediately delete residual copies from our servers or remove information from our backup systems.

Children

DVS Ltd website is designed and intended for use by adults. Should DVS Ltd be intended for use by a younger audience, we will obtain consent from a parent or guardian before we collect personal information where we feel it is appropriate to do so or where it is required by applicable laws and regulations (the age at which consent is necessary varies from country to country). If you are a child over the age where parental consent is required in your country, you should review the terms of this Privacy Notice with your parent or guardian to make sure you understand and accept them.

If we discover that we have collected information from a child without consent from a parent or guardian where such consent should have been obtained, we will delete that information as soon as possible.

Access to certain parts of DVS Ltd and/or eligibility to receive prizes, samples or other rewards may be limited to users over a certain age. We may use your personal information to carry out age verification checks and enforce any such age restrictions.

What information do we collect?

You can provide your personal data if you wish. We only collect personal data that YOU want to provide to us or that is needed to provide (and improve) our service to you. We collect personal data directly such as name, age, gender, address and e-mail address as well as connection and system information, but can also include other information such as IP address, shopping habits, information about your lifestyle or preferences such as your hobbies and interests.

The legal basis for the processing of your personal data is your consent and/or any other applicable legal basis, such as our legitimate interest in engaging in commerce and offering products and services of value to you. Any consent you provide may be withdrawn at any time by following the contact methods listed in ‘Your Privacy Rights and Who to Contact’. We may collect personal information about you from different sources, including:

• Information you give us directly
• Information collected automatically when you use the DVS Ltd Site
• Information we collect from other sources

You may want to give us your e-mail address, name, telephone number etc. so that we can provide you with information on our products; enter you into our competitions or surveys; respond to your questions or comments; or just keep you updated about exciting DVS developments that you are interested in. Some website functionality may be unavailable to users who do not provide their data, or who do not consent to the use of Cookies and similar technologies on this site. Additionally, if you choose not to provide your personal data, we will not be able to provide you with our products or services or with other support or responses.

Alternatively, you may want to develop your career with DVS Ltd and apply for job vacancies by Sending your CV to us directly or via a recruitment site.

How do we use your personal information?

We may use your personal information to:

• improve our products and your experience on the DVS Ltd Site
• evaluate the use of the DVS Ltd Site, products and services
• analyse the effectiveness of our advertisements, competitions and promotions
• personalise your website experience, as well as to evaluate (anonymously and in the aggregate) statistics on website activity, such as what time you visited it, whether you’ve visited it before and what site referred you to it
• make the DVS Ltd Site easier to use and to better tailor the DVS Ltd Site and our products to your interests and needs
• help speed up your future activities and experience on the DVS Ltd Site. For example, a site can recognise that you have provided your personal information and will not request the same information a second time
• collect information about the device you are using to view the DVS Ltd Site, such as your IP address or the type of Internet browser or operating system you are using, and link this to your personal information so as to ensure that the DVS Ltd Site presents the best web experience for you
• to contact you regarding products and services which may be of interest to you, provided you have given us consent to do so or you have previously requested a product or service from us and the communication is relevant or related to that prior request and made within any timeframes established by applicable laws.
• suggest products or services (including those of relevant third parties) which we think may be of interest to you
• offer you the opportunity to take part in competitions or promotions

How Long We Keep Your Data For

In line with data protection principles, we only keep your data for as long as we need it for, which will be at least for the duration of your contract with us though in some cases we will keep your data for a period after your contract has ended. Retention periods can vary depending on why we need your data, as set out in our Data Retention Schedule which is available from DVS Ltd; Unit 3 Neptune Point; Vanguard Way; Cardiff; CF24 5PG.

Mobile Message Services

We may make available a service through which you can receive text or other types of messages from DVS Ltd such as SMS (short message service), MMS (multimedia message service) or EMS (enhanced message service) on your wireless or mobile device (“Mobile Message Service”). If you subscribe to one of our Mobile Message Services, you agree to receive such messages from DVS Ltd at the address or mobile number you provide for that purpose (unless and until you have elected to opt out of receiving such messages by following the instructions in the “Your privacy rights and who to contact” section below.

You understand that your wireless carrier’s standard rates apply to these messages, and that you may change your mind at any time by following the instructions in the “Your privacy rights and who to contact” section below.

You represent that you are the owner or authorised user of the wireless device you use to sign up for the Mobile Message Service, and that you are authorised to approve the applicable charges. In addition to meeting certain age restrictions and any other terms and conditions associated with each Mobile Message Service, you may be required to register personal information such as your name, text message, wireless address or mobile phone number. We may also obtain the date, time and content of your messages in the course of your use of the Mobile Message Service.

We will use the information we obtain in connection with our Mobile Message Service in accordance with this Privacy Notice. Please note, however, that your wireless carrier and other service providers may also collect data about your wireless device usage, and their practices are governed by their own policies.

You acknowledge and agree that the Mobile Message Service is provided via wireless systems which use radios (and other means) to transmit communications over complex networks. We do not guarantee that your use of the Mobile Message Service will be private or secure, and we are not liable to you for any lack of privacy or security you may experience. You are fully responsible for taking precautions and providing security measures best suited for your situation and intended use of the Mobile Message Service.

We may also access the content of your wireless and/or mobile phone account with your carrier for the purpose of identifying and resolving technical problems and/or service-related complaints.

Who do we share your personal information with?

DVS has expertise in delivering vision to the UK CCTV distribution industry. (More information about DVS Ltd can be found at www.dvs.co.uk).  DVS Ltd may share your personal information with trusted third parties based outside the country in which you live so that they may process that data on our behalf.

We share your data with:

• People Apps Limited (PeopleHR Human Resources Management System) for employee administration purposes (including information relating to sickness related absences and equal opportunities monitoring);
• HMRC for the payment of Income Tax and National Insurance Contributions on your behalf
• ACAS for employee conciliation and dispute resolution purposes;
• Goldenhello Ltd trading as Psytech (via Genesys Online) for employee psychometric testing purposes;
• Pulse HR Consulting Ltd for obtaining external HR advice
• Infinity Occupational Health Ltd for obtaining occupational health advice
• Watts Gregory LLP (Payroll/Pension Provider)
• Campaign Monitor (Marketing email provider)
• Spindogs (Website form provider)

We may share your personal information with:

• our advertising, marketing and promotional agencies to help us deliver and analyse the effectiveness of our advertising campaigns and promotions
• third parties required to deliver a product or service to you, such as a delivery or postal service delivering a product that you have ordered
• law enforcement or government authorities where they have followed due legal process to request us to disclose the information
• third parties who wish to send you information about their products and services, but only if you have given us consent to do so
• third party providers of services, such as data processing, to DVS Ltd
• web analytics tool providers, such as Google

If we do share your personal information with a trusted third party, we shall use our best efforts to ensure that they keep your information secure, take all reasonable steps to protect it from misuse and only use it in a manner consistent with our instructions, this Privacy Notice and applicable data protection laws and regulations.

We may also share your personal information with companies, organisations or individuals outside of DVS Ltd if we believe that disclosure of the information is necessary for legal reasons.

We may share your personal information to:

• enforce applicable terms of use of the DVS Ltd site
• conduct investigations into possible breaches of applicable laws
• detect, prevent and protect against fraud and any technical or security vulnerabilities
• comply with applicable laws and regulations, co-operate in any legal investigation and meet enforceable governmental requests

It is not practical to list all of the countries where personal information is processed and stored as those countries frequently change depending on operational requirements. If you have any questions, comments or concerns about how we handle your personal information, then see “Your privacy rights and who to contact” below.

DVS Ltd does not sell personal information, except to an entity to which we divest all or a portion of our business (for example, in connection with our sale of a brand), or otherwise in connection with a merger, consolidation, change in control, reorganisation or liquidation of all or a portion of our business.

Transferring your personal information

Your data will be shared with colleagues within the Company where it is necessary for them to undertake their duties. This includes, for example, your line manager for their management of you, the HR department for maintaining personnel records and the payroll department for administering payment under your contract of employment, etc.

We may also share your data with third parties as part of a Company sale or restructure, where we there is a statutory or contractual requirement to provide the data or for other reasons to comply with a legal obligation upon us.

Protecting Your Data

We may transfer your personal information to servers located outside the country in which you live or affiliates to or other trusted third parties based in other countries so that they may process personal information on our behalf. By using the DVS Ltd Site or otherwise providing DVS Ltd with personal information, you agree to us doing so in accordance with the terms of this Privacy Notice and applicable data protection laws and regulations.

We are aware of the requirement to ensure your data is protected against accidental loss or disclosure, destruction and abuse. We have implemented processes to guard against such.

Where we share your data with third parties, we provide written instructions to them to ensure that your data is held securely and in line with GDPR requirements. Third parties must implement appropriate technical and organisational measures to ensure the security of your data.

You should be aware that many countries do not afford the same legal protection to personal information as you might enjoy in your country of origin. While your personal information is in another country, it may be accessed by the courts, law enforcement and national security authorities in that country in accordance with its laws. Subject to such lawful access requests, we promise that anyone processing your personal information outside your country of origin is required to implement measures to protect it and is only entitled to process it in accordance with DVS Ltd instructions.

Safeguarding your personal information

We take all reasonable precautions to keep your personal information secure and require any third parties that handle or process your personal information for us to do the same. Access to your personal information is restricted to prevent unauthorised access, modification or misuse and is only permitted among our employees and agents on a need-to-know basis.

Cookies

A cookie is a piece of text which asks permission to be placed on your computer’s hard drive. Once you agree, your browser adds that text in a small file. A cookie helps analyse web traffic or lets you know when you visit a particular site. Cookies allow web applications to respond to you as an individual. The web application can tailor its operations to your needs, likes and dislikes by gathering and remembering information about your preferences. For example, when you visit an electronic store, a cookie makes it easier to shop, by allowing you to place things into a shopping basket; the basket itself is not the cookie, the cookie is placed on your hard drive and keeps track of your basket versus others in use at the same time.

We use traffic log cookies to identify which pages are being used. This helps us analyse data about web page traffic and improve our website in order to tailor it to customer needs. We only use this information for statistical analysis purposes and then the data is removed from the system. Denial of a traffic log cookie should not prevent you from using one of these sites.

Overall, cookies help us provide you with a better website, by enabling us to monitor which pages you find useful and which you do not. A cookie in no way gives us access to your computer or any information about you, other than the data you choose to share with us. This practice is strictly in force. We know that people have concerns about cookies, but we believe that the benefit we both gain from their proper use is worthwhile. You may set your web to notify you of cookie placement requests or decline cookies completely. You can delete the files that contain cookies – those files are stored as part of your internet browser.

As part of our internet pages, we use cookies. You must consent to the use of cookies if you wish to use our web page(s). Cookies, also known as browsers or tracking cookies, are small text files that are added to your computer when you visit a website. They help websites to perform certain functions e.g. to know who you are if you log into a restricted part of a website, for shopping carts, and for tracking purposes.

Cookies are small files that can be stored on your hard drive and store specific information that can be retrieved by the server that has placed the cookie on your computer. The cookies used may be session cookies, which are automatically deleted as soon as you close your browser window, and/or cookies that are valid for a longer period. The information stored in cookies may concern, in particular, the login (your visit, if you log in), the date and time of your visit to us, the cookie number, and the URL of the website from which you reached our site.

The use of cookies allows us to recognise you and thereby adapt our offerings optimally to your individual needs and requirements. Cookies also make it possible to record the statistical frequency of retrieval of the various pages of our Internet presence and the general navigation.

If you wish to prevent the use of cookies, however, which has no influence over the performance of our promotions or other offerings associated therewith on our part, please adjust your browser settings accordingly before you use our pages. You can prevent new cookies from being accepted and stored in these settings. For further information, please consult your browser’s help pages or contact the producer or provider of the browser.

Necessary Cookies

Necessary cookies enable core functionality such as page navigation and access to secure areas. The website cannot function properly without these cookies, and can only be disabled by changing your browser preferences. We use a third party cookie PayPal to enable core functionality on the website.

Remarketing Policy

DVS uses a Google and Facebook Pixels remarketing cookie on our website – this allows us to collate lists of visitors who have visited our website, and show tailored, targeted adverts to them at a later date.

DVS may show adverts about our services to you if you have previously visited our website and are viewing a website that is part of the Google Display network or Facebook.

Third-party vendors, including Google and Facebook Pixels, use cookies to serve ads based on someone’s past visits to the DVS website. Any data collected will be used in accordance with our own privacy policy and Google’s and Facebook’s privacy policy.

Deletion of Cookies

As a user, you can decide for yourself at any time which cookies you wish to accept or delete. You can adjust your individual settings for this yourself, right in your internet browser settings. You can either delete all of your cookies (Clear history) or limit yourself to cookies from certain domains. For further information, please contact the provider of your internet browser.

Your privacy rights and who to contact

If you have any questions, comments or concerns about how we handle your personal information, then you may contact us by clicking the “Contact Us” link on the DVS Ltd website that directed you to this Privacy Notice. Your request will be directed to the appropriate person at DVS Ltd. Alternatively, please go to www.dvs.co.uk, select and click on the “Contact Us” link. Your request will be directed to the appropriate DVS ltd person.

The law on data protection gives you certain rights in relation to the data we hold on you. These are:

• The right to be informed. This means that we must tell you how we use your data, and this is the purpose of this privacy notice
• The right of access. You have the right to access the data that we hold on you. To do so, you should make a subject access request
• The right for any inaccuracies to be corrected. If any data that we hold about you is incomplete or inaccurate, you are able to require us to correct it
• The right to have information deleted. If you would like us to stop processing your data, you have the right to ask us to delete it from our systems where you believe there is no reason for us to continue processing it
• The right to restrict the processing of the data. For example, if you believe the data we hold is incorrect, we will stop processing the data (whilst still holding it) until we have ensured that the data is correct
• The right to portability. You may transfer the data that we hold on you for your own purposes
• The right to object to the inclusion of any information. You have the right to object to the way we use your data where we are using it for our legitimate interests
• The right to regulate any automated decision-making and profiling of personal data. You have aright not to be subject to automated decision making in way that adversely affects your legal rights.

Where you have provided consent to our use of your data, you also have the unrestricted right to withdraw that consent at any time. Withdrawing your consent means that we will stop processing the data that you had previously given us consent to use. There will be no consequences for withdrawing your consent.

There are exceptions to these rights, however, for example, access to personal data may be denied in some circumstances if making the information available would reveal personal information about another person or if DVS is legally prevented from disclosing such information. In addition, DVS may be able to retain data even if you withdraw your consent, where DVS can demonstrate that it has a legal requirement to process your data.

If you wish to exercise any of the rights explained above, please contact DVS Ltd; Unit 3 Neptune Point; Vanguard Way; Cardiff; CF24 5PG. Tel: 029 20 455 521 e-mail: contact@dvs.co.uk

Automated Decision Making 

No decision will be made about you solely on the basis of automated decision making (where a decision is taken about you using an electronic system without human involvement) which has a significant impact on you.
 

Changes to our Privacy Notice

We may change this Privacy Notice from time to time by posting the updated version of the Privacy Policy on the DVS Ltd site. We will give you reasonable notice of any material change. We encourage you to visit frequently to stay informed about how we use your personal information.

Other DVS Ltd privacy notices

In addition to this Privacy Notice, there may be specific campaigns or promotions which will be governed by additional privacy terms or policies. We encourage you to read these additional terms or policies before participating in any such campaigns or promotions as you will be required to comply with them if you participate. Any additional privacy terms or policies will be made prominently available to you.

Making a Complaint

The supervisory authority in the UK for data protection matters is the Information Commissioner Office (ICO). If you think your data protection rights have been breached in any way by us, you are able to make a complaint to the ICO.