- IMPORTANT INFORMATION AND WHO WE ARE
This Policy is issued on behalf of Strongwell, a company based in the USA with office at 400 Commonwealth Avenue, Bristol, Virginia 24201.
For the purposes of data protection laws, Strongwell is the data controller and is responsible for your personal data.
We have appointed a Data Privacy Manager who is responsible for overseeing questions in relation to this Policy. If you have any questions about this Policy, please contact the Data Privacy Manager using the details set out below.
Full name of legal entity: Strongwell Corporation
Name of Data Privacy Manager: Barry Myers
Email address: [email protected]
Postal address: 400 Commonwealth Ave., Bristol, VA 24201
Changes to the Policy and your duty to inform us of changes
Amendments and updates to this Policy may be made from time to time. Any revisions will be posted on the Website and where appropriate notified to you by email, so you will always be aware of what personal data we collect and how we use that personal data. Please review the Website regularly so that you are aware of any changes
It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.
- THE PERSONAL DATA WE COLLECT ABOUT YOU
“Personal data”, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymized data).
Information you give to us
We will collect personal data from you when you:
- Submit an enquiry about our services via the website;
- Enter into a contract with us where we will sell you products and/or provide you with services;
- Engage with us through social media;
- Register on the website in order to sign up for our design tools here https://www.strongwell.com/member-signup/.
This personal data may include your title, first name, surname, date of birth, email address, telephone number, home address, job title, and employer name.
Information we collect about you
We may also collect information through your use and browsing of the Website including the internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access this Website. For specific information about the tracking cookies used, please refer to ‘Section 12 – Cookies’.
If you fail to provide personal data
Where we need to collect personal data by law, or under the terms of a contract we have with you and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you. In this case, we may have to cancel a service you have with us but we will notify you if this is the case at the time.
- HOW WE USE YOUR PERSONAL DATA
We will only use your personal data when the law allows us to and in accordance with the purpose for which it was collected. Most commonly, we will use your personal data in the following circumstances:
- where we need to perform the contract we are about to enter into or have entered into with you;
- where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests;
- where we need to comply with a legal or regulatory obligation;
- where you have provided your consent.
We may use your personal data in the provision and administration of the services that you have requested and/or to respond to your queries. Where you don’t provide us with certain information we may be unable to provide you with the services requested.
We may also use your personal data to meet our legal obligations, to deal with any complaints and for the enforcement of our terms and conditions.
We may use your personal data for our legitimate business interests which include security purposes, improvements to our Website, improvements to our products and services and for general marketing purposes. We will not do so though where our interests are outweighed by your interests, rights and freedoms.
Purposes for which we will use your personal data
We plan to use your personal data to:
- Respond to your enquiry about our services;
- Carry out our obligations arising from any contracts entered into between you and us and to provide you with the information, products and services that you request from us;
Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data.
Change of purpose
If we need to use your personal data for purpose unrelated to the original one we collected your personal data for, we will notify you and we will explain the legal basis which allows us to do so.
Please note that we may process your personal data without your knowledge or consent, in compliance with this Policy where this is required or permitted by law.
- DISCLOSURES OF YOUR PERSONAL DATA
We may have to share your personal data in the following circumstances:
- Business partners, suppliers and sub-contractors for the performance of any contract we enter into with them or you;
- Advertisers and advertising networks that require the data to select and serve relevant adverts to you and others;
- Analytics and search engine providers that assist us in the improvement and optimization of our Website;
- Credit reference agencies for the purpose of assessing your credit score where this is a condition of us entering into a contract with you;
- Third parties to whom we may choose to sell, transfer, or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this Policy;
- We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.
You can ask us or third parties to stop sending you marketing messages at any time by following the unsubscribe links on any marketing message we send you. Additionally, if you have registered for our Design Tools and wish to amend your personal data, you can do so at any time when logged in. You can also request Strongwell to delete your account (and all personal data), however that will also remove your access to our Design Tools.
- DATA SECURITY
We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorized way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.
We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.
- DATA RETENTION
Where we are providing you with good or services under a contract, we will keep your personal data for a period of 6 years after expiry of the contract. In all other cases we will retain your personal data only for as long as is necessary for the purpose for which it was provided to us or collected. Where processing is based on your consent we shall only process it until such time as you withdraw your consent.
- DATA STORAGE
Personal data you provide to Strongwell is stored on third party servers located in the USA. In collecting and storing your personal data on these servers we will either rely on (i) your consent provided at the time we collected your personal data or (ii) the basis that it is necessary for the performance of a contract. We take measures to ensure that any third parties hosting our Website and other services have adequate security measures in place to protect personal data.
As part of our recruitment processes, where you e-mail or send by post to us your curriculum vitae and/or job application. We will collect personal data including your name, your home address, email address and telephone number, your employment details (including the name of your current employer, job role, work email address, work telephone number and work postal address), and your education and qualification details.
In this situation we will use your personal data to assess your suitability for the work or advertised role and to carry out our internal recruitment procedures.
- INTERNATIONAL TRANSFERS
We will transfer your personal data outside the European Economic Area ("EEA"). If we need to do this, we will only transfer your personal data outside the EEA where the organization receiving the personal data has provided appropriate safeguards.
- YOUR LEGAL RIGHTS
You have the right to:
- Request access to your personal data (commonly known as a "data subject access request").
- Request correction of any inaccuracies in the personal data that we hold about you.
- Request erasure of your personal data under certain circumstances.
- Object to processing of your personal data under certain circumstances.
- Request restriction of processing of your personal data in certain circumstances.
- Request the transfer of your personal data to you or to a third party in certain circumstances.
- Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent.
- Make a complaint at any time to the relevant supervisory authority.
If you wish to exercise any of the rights set out above, please contact us by phone on 001 276.645.8000.
No fee usually required
You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.
What we may need from you
We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.
Time limit to respond
We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.
- THIRD-PARTY LINKS
Strongwell's website uses Google Analytics, as well as Salesfusion, to collect visitor data and analyses traffic on our website. This information helps us understand customer interests and helps us improve our website. If you are accessing this website from within the EU, we have installed a plug-in called OneTrust which keeps the tracking scripts for collecting any personally identifiable information turned off unless and until you allow these.
When you visit our website, the pages that you look at, and a short text file called a cookie, are downloaded to your computer. A cookie is used to store small amounts of information. This information is collected for traffic analysis only. The cookie does not contain personal details unless you provide them.