Legal

Privacy Policy

Amari Metals Limited

Public Privacy Statement 03 May 2018

Here at Capalex we take your privacy seriously and this privacy policy describes how we make use of and protect the information you give us.

If you are asked to provide information, it will only be used in the ways described in this privacy policy.

This policy is updated from time to time, the latest version is published on this page.

This privacy policy was updated on: 25 May 2018

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Contents

• Introduction
• What data we gather
• How we use this data
• Sharing your data with others
• International Transfers
• How long we keep data
• Legal basis for processing customer personal data
• Our legitimate interests
• Requesting details of what information we hold on you
• Security
• Links from our website
• Telephone call recording

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Introduction

Maintaining the security of your data is very important to Capalex. We are committed to respecting data privacy rights. We pledge to use your data fairly and legally. We will be transparent with what we do with data, what we collect and how we use it.

What data we gather

Capalex receive data in a number of ways, including but not limited to website activity, marketing sources and exhibitions.

We may collect the following information:

• Your name, the name of the business you work at and the contact details relating to said business
• Your business information including email address and phone details
• Demographic information such as postcode, preferences and interests
• Website & communication usage data
• When you enquire or place an order with us, relevant product requirements and interests
• Communication and marketing preferences
• Other information pertaining to special offers and surveys
• Other publicly available information you have shared via a public platform, (such as Twitter, LinkedIn etc.)
• We do not intentionally or knowingly collect or maintain information relating to children

This list is not exhaustive and we may collect other information for the purposes set out in this document.

How we use this data

Collecting this data helps us understand what you are looking for from us, enabling us to deliver improved products and services.

Specifically, we may use data:

• For our own internal records
• To improve the products and services we provide
• To contact you in response to a specific enquire
• To customise the website for you
• To send you promotional emails about products, services, offers and other things we think might be relevant to you
• To send you promotional mailings or to call you about products, services, offers and other things we think might be relevant to you
• To contact you via email, telephone or mail for market research reasons

Sharing your data with others

In order to make certain services available to you, we may need to share your data with some of our service partners. These include IT, our investors, delivery and marketing service providers.

Service providers handling data we share with them will have been subject to appropriate data protection and security checks. Contractual obligations on service providers are also in place to ensure data is only used in order to provide the appropriate services to Capalex.

Other third parties

Additional to our service providers, we may share data with:

• Credit reference agencies, where necessary for credit checking
• Government bodies, regulators and law enforcement agencies, courts/tribunals and insurers, where we are required to.

International Transfers

It is occasionally necessary to share your data outside of the European Economic Area (EEA). This is typically for support services located outside of the EEA. These transfers are subject to special rules and data protection laws. Our standard practice will be to use standard data protection clauses, as defined by European Commission for such transfers.

How long we keep data

We will not retain your data for longer than necessary and only for the purposes outlined in this policy. Retention periods differ, based on what data we hold. It is not expected that we will hold personal data longer than 6 years.

Legal basis for processing customer personal data

Capalex collects and uses customers’ data because is it necessary:

• to conduct our legitimate interests (as set out below)
• for exercising our rights under a contract of sale
• for addressing our legal obligations

Generally, we only rely on consent as a legal basis for processing in relation to sending direct marketing communications to customers.

Customers and data subjects have the right to withdraw consent at any time. Where consent is the only legal basis for processing, we will cease to process data after consent is withdrawn. To withdraw consent, write or email the contact at the end of this document.

Our legitimate interests

The legal basis under normal conditions, for processing customer data, is that it is necessary for the legitimate interests of Capalex, including:

• The supply of goods and services to our customers
• Managing safety, health and welfare of our customers, staff and others
• Promoting, marketing and advertising products and services
• Sending relevant and tailored promotional communications to individual customers
• Understanding customer behaviour, activities, preferences, and needs
• Developing new products and services and improving existing products and services
• Legal and regulatory obligations
• Detecting, investigating and preventing crime, fraud and prosecuting offenders, including working with law enforcement agencies
• Managing customer contacts, queries, complaints or disputes
• Protecting the organisation, its staff and customers, by taking appropriate legal action against third parties who have committed criminal acts or are in breach of legal obligations to us
• Handling legal claims or regulatory enforcement actions taken against us
• Undertaking our duties to our customers, colleagues, investors and stakeholders

Requesting details of what information we hold on you

You have the right to request details of personal information which we hold on you under the General Data Protection Regulations. If you would like a copy of the information held on you, please apply in writing either by email or to the postal address shown above, providing your contact details including an email address, which must match the one held on our records. We may contact you to confirm your identity.

We will use reasonable endeavours to provide information held about you within 1 calendar month of the receipt of your written request.

Security

We will always hold your information securely.

To prevent unauthorised disclosure or access to your information, we have implemented suitable physical, electronic and managerial procedures to safeguard and secure the information we collect online.

Links from our website

Our website may contain links to other websites.

Please note that we have no control of websites outside of our domain. If you provide information to a website to which we link, we are not responsible for its protection or privacy.

Always be wary when submitting data to websites. Read the website’s data protection and privacy policies in full.

Telephone call recording and email monitoring

Telephone calls may be recorded and emails monitored for the following purposes:

• Establishing facts and evidence for business transactions
• Ensuring compliance with regulatory or self-regulatory practices
• Ascertaining and demonstrating that standards are being met
• Defending national security
• Preventing or detecting crime
• Investigating or detecting the unauthorised use of that or any other telecommunication system
• Safeguarding the effective operation of the telecommunications system

All telephone recordings are subject to data protection and security requirements, outlined in this document. Recordings are intended for internal use only.

If you have any questions about this policy, please email gdpr@amari-metals.com or write to:

Capalex
Parkway House
Unit 6 Parkway Industrial Estate
Pacific Avenue
Wednesbury
West Midlands
WS10 7WP