Below, you will find information about which data we collect, why, for what period and how you have control over it.
The Data Protection Act 1998 and the EU Regulation 2016/679 of 27 April 2016 (on the protection of natural persons with regard to the processing of personal data and on the free movement of such data, known as the General Data Protection Regulation or 'GDPR') and the associated implementing decisions govern the protection of your personal data. We undertake to comply with our obligations and to respect your rights whenever we process your data. If you would like to explore this subject in greater detail, we recommend consulting the website of the Information Commissioner’s Office [https://ico.org.uk/].
2. What does 'data processing' mean, and who is responsible for it?
We interpret 'data processing' as any processing of personal data. The concept of 'processing' covers the collection, establishment, classification, saving, updating, amending, retrieval, consultation, use, dissemination or making available, combination, archiving, deletion or ultimately destruction of personal data.
Ecowater UK, a company incorporated and existing under the laws of the United Kingdom whose registered office is at [Office 1, Regents Park Booth Drive, Park Farm Industrial Estate, Wellingborough, Northamptonshire, England, NN8 6GR and registered with RPR/RPM in Northamptonshire under registered number 01376182 ] (hereinafter referred to as “EcoWater”) is responsible for the processing of your personal data.
3. Which data do we process?
We interpret 'personal data' as data relating to an identifiable person (the 'person concerned'), and which (i) you provide to us yourself, (ii) which we allocate to you for the use of our products and services (iii) that we obtain through the use of our products and services, including the use by end-users and (iv) that we have received via third parties. All data that we collect may be combined together to match our offerings and services better to your personal requirements.
We make a distinction between various types of personal data. They enable us to offer our products and services and to improve them where possible:
- User data: this data enables us to identify or contact you. For example: your name, address, telephone number, your language preference, gender, e-mail address, the composition of your household and any other preferences that you make known via social media, campaigns, mobile apps, etc. including your financial data and creditworthiness data;
- Technical data: we need this to be able to ensure proper operation of our products and services. For example: the model and installation date of your water softener;
- Data about your usage: the data that we receive when you use our products and services. For example: when your last maintenance was carried out;
- We do not process any sensitive data such as data about your racial or ethnic origin, political views, sexual preferences or health.
4. What do we use this data for?
We process personal data for different purposes, and in each case, the data processed is that which is necessary to achieve the intended purpose.
We use personal data:
- If we have received permission;
- In the context of the preparation or performance of our contract;
- If EcoWater has a legitimate interest in it, in which case we always endeavour to maintain a balance between that interest and respect for the privacy of the person concerned.
With permission, where this is required, we collect personal data for the following concrete purposes:
In order to process your request for our products and services.
If you visit our website to collect and/or request information about our products and services or if, for example, you register to receive our newsletter, then in any case we will need your address details. All information that we receive about you in this pre-contractual phase is only used to provide you with the information requested, in the way that you want that. When you ultimately decide to become an EcoWater customer, we will ask you to provide some personal details such as your name, address, telephone number and e-mail address, and allocate data to you, such as a customer number and login details.
To offer you the best possible service and inform you about your usage options.
We use your data to set up, maintain and support your products and services and for our administration. For example: we use your data to schedule regular maintenance. By recording certain phone calls with our call centers, we can train our staff and continually improve the service.
To inform you about our (new) products and services.
To combat fraud.
Depending on the EcoWater products and/or services that you choose, we will also check your credit record. We carry out this check to prevent you taking on financial commitments with us that you cannot afford. We also want to avoid EcoWater invoices not being paid. For this purpose, we may request information from internal and external databases.
To guarantee everyone's security.
In and around our offices and buildings, you will also be filmed by our surveillance cameras. These images will only be stored with a view to the security of goods and persons and to prevent our customers and ourselves becoming victims of abuse, fraud and other offences (we announce the presence of cameras with pictograms that give our contact details).
To monitor our performance.
We can use your data and consumer profile to evaluate our products and services. That includes: requesting feedback about our services (for example via market research), data that we obtain during our maintenance or servicing, our replies to customers' questions, detection of fraud and quality assurance, for example by recording calls at our call centers (this is mentioned at the start of the call).
To meet our statutory obligations.
In a number of cases, we have a statutory obligation to keep certain personal data about you and/or to pass it on to government bodies. This concerns mainly general tax and accounting obligations.
To update studies, tests and statistics, for purposes including trend analysis.
We can use your anonymous, aggregated data to report internally and externally about the use of our services, for example how many maintenance visits were booked in a given period. The data used in this case cannot be linked to a particular individual. The information that we derive from these analyses will be used to evaluate our current product and services portfolio and adapt them to new developments.
5. How do we protect your data?
We do everything in our power to protect your personal data and privacy.
Our staff are trained in handling confidential data correctly. In projects where privacy is a sensitive issue, an assessment is made about security and protection of personal data. To ensure the security of your data, we employ specific staff to monitor compliance with the legislation and our ethical aspirations. We also employ specialist staff to ensure the security of our network, our infrastructure and our IT systems. Moreover, we use all kinds of technical measures to protect your personal data, such as: password-protection, hard disk encryption software, firewalls, anti-virus, intrusion and fault detection software and access controls for our staff. If a data leak should occur with detrimental repercussions for your personal data, then as a customer, you will be personally informed in the circumstances foreseen by law.
The number of employees at our company who have access to your personal information is limited. These employees are only granted access to your personal information where they need that information to carry out their work properly.
6. Do we sell your data to third parties or do we pass on the data?
We neither sell personal data to third parties nor do we pass them on to third parties except:
- To our lawful successors and other companies within the Marmon group.
- This is necessary for our service provision.
For some aspects of our products and services, we work with third parties or use subcontractors. A good example here are EcoWater certified dealers. The transmission of your data only occurs for the same purposes as at EcoWater itself. We ensure that they, just like us, manage your data securely, respectfully and with due care.
- That is a legal obligation.
- There is a legitimate interest for EcoWater or the third party concerned.
This is only done provided that your interest or your fundamental rights and freedoms do not override that interest.
- You give us your permission for this.
If EcoWater should pass on personal data to third parties in another way (this does not happen at present), then that will be done with explicit communication, providing explanation about the third party, the purposes of the transmission and the processing. Where required by law, we will obtain your express permission. You always have the possibility of objecting.
Concerning passing on your personal data internationally, we protect your data in accordance with the protection level required by European regulation.
In some cases, we use anonymous, aggregated data for commercial purposes or for external reporting. This data cannot be linked to a particular individual.
7. What are your rights and how can you exercise them?
Your right of access
You are entitled to access the data about you (free of charge). You can ask us:
You can exercise this right via the procedure described below, which we refer to as a 'Subject Access Request' or 'SAR', based on the legal terminology.
You need to exercise your right of access in writing, for the attention of Ecowater UK, Privacy Office, Solar House, Mercury Park, Wooburn Green, High Wycombe, HP10 OHH or by e-mail to email@example.com.
In order to exercise your right of access, and to prevent any unauthorised disclosure of your personal data, you need to provide evidence of your identity. You should preferably attach a copy of the front side of your identity card with your request.
EcoWater has 30 days to respond to your request. Please bear in mind that this period only starts once EcoWater has received your written request and is in possession of all the required information to accede to your request.
If you have any reason to suppose that EcoWater has not dealt with your request properly, please take the matter up initially with the Privacy Office of EcoWater via firstname.lastname@example.org so that we can examine the options with you.
For the sake of completeness we inform you that, if EcoWater fails to respond to your request, refuses to do so or our response does not meet your expectations, you always have the right to file a complaint with the Information Commissioner’s Office, via https://ico.org.uk/concerns/, who will then intervene as part of its role as a mediator.
Your right to correction and deletion
You have the right to have incomplete, incorrect, inappropriate or outdated personal data deleted or corrected. To arrange this, you can contact our customer service. Then we will amend this information as necessary or remove it within the period required by law. Please bear in mind that sometimes, depending on your request, we can no longer provide some services. For legal reasons, we can also not always delete all the data requested.
So as to keep your data up-to-date, we request you to notify us of any change.
Your right to object to the use of your data for direct marketing
You always have the right to object, without having to give your reasons, to the use of your personal data for direct marketing purposes. To do this, you can always contact the EcoWater customer service and selectively disable our option to inform you of special promotions and/or campaigns via telephone, post or e-mail, or you can, in the case of commercial emails, exercise your unsubscribe right in the e-mail concerned. To make e-mail campaigns more efficient, we use software to measure whether our e-mails are opened and which links are clicked.
Please note: we reserve the right to contact you via electronic mail as part of the performance of your contract or if we are required to do so by law.
8. How long do we retain your personal data?
EcoWater takes appropriate organisational and technical measures to secure personal data. We are not allowed to keep personal data for longer than is necessary for the purpose for which we collected it. Therefore, the retention period can vary per purpose, and sometimes is laid down by law (for example, we are compelled to keep your invoicing data for a maximum of 7 years).
After the expiry of the statutory retention period(s), personal data is anonymised.
Certain data relating to former customers may be used during a 2-year period after the ending of the contract in order to identify the former customer and keep them informed about the activities of EcoWater, unless the customer has indicated that he/she does not agree to this under the procedure described in point 7.
9. What about our websites, cookies and mobile apps?
You can visit our websites without giving us your personal data. With your permission (where necessary) we can inform you, as a visitor to our websites, about a personalised offering of products and services.
In order to optimize our service provision, we can supplement your customer data with data that we derive from cookies that result from your use of our websites.
What are cookies?
Cookies can be put on the site by EcoWater or by other parties. When we allow third parties to put cookies on our websites, those parties must give a contractual guarantee that the data will be exchanged over a secure connection.
What kind of cookies do we use?
Essential cookies: are necessary to use the website and ensure secure identity control. For example: browsing on the website, ...
Functional cookies: make the functioning of the website easier and ensure a personalised surfing experience by remembering preferences like the language setting.
Performance cookies: collect data about visitors in order to improve the website. For example: count visitors, list popular web pages, etc.
Advertising cookies: adapt the advertisements based to your surfing behaviour, your demographic and user data. This means we can make our advertisements more efficient and tailor them to your interests.
Management of cookies
If you choose this, you can refuse our cookies on your first visit. After that, you can disable or delete all cookies from your computer or mobile device via your browser settings (usually under 'Help' or 'Internet options'). Each type of browser has its own way to manage cookies. You can find this information on the website of the browser that you use.
Bear in mind that changing the settings may cause the EcoWater websites and other websites to stop working properly.
Other technological resources
In order to measure and improve the success of our advertising campaigns, technologies like web beacons and action tags count the number of visitors on our websites and/or apps as a result of an advert on a third-party site. Certain pages on our websites also work with pixel tags. These pixels see, among other things, which products you look at on our site. Based on that information, we can then display relevant advertisements on Facebook and Google, for example.
10. How can I contact EcoWater?
11. Keep informed about changes
The personal data that we collect via various channels is included in the EcoWater databases. We have declared this processing to the Information Commissioner’s Office. You can consult these declarations online in the public registers of the ICO.