Privacy Policy | Platinum International Limited
 0845 063 9999      info@platinuminternational.com Manchester, England, M17 1SA
Platinum Privacy Notice – Master (GDPR 02)

 

The General Data Protection Regulations (GDPR) supports us in looking after your privacy. 

 

We issue this privacy notice in the interests of transparency as to how we collect and use (‘Process’) the personal data that we collect, whether we are in the process of exploring potential business opportunities by looking to do business together, continuing our relationship with you once we have provided goods or services, receiving goods or services from you, using your data to ask for your assistance in relation to one of our employees, ex-employees or applicants, or you are visiting our website. Our data security means that we hold all personal data securely and limit access to those who need to see it.

 

This document describes how we collect, use and process your personal data, and how, in doing so, we comply with our legal obligations to you. This Privacy Policy applies to the personal data of our Website Users, Customers, Suppliers and other people whom we may contact in order to provide our goods and services. It also applies to the emergency contacts of our Staff (next of kin). However, if you are an Applicant, Employee or Ex-employee you should refer to the Platinum Privacy Notice for Employees which is available on both the Platinum Intranet and on this website.

 

For the purpose of applicable data protection legislation (including but not limited to the General Data Protection Regulation (Regulation (EU) 2016/679) (the “GDPR”) and the DPA 2018, the company responsible for your personal data is Platinum International (‘Platinum’ or ‘us’). This Privacy Policy applies in relevant countries throughout our international network. We will ensure compliance with all applicable data privacy protections legislation, no matter where you are.

 

It is important to point out that we may amend this Privacy Policy from time to time. To stay up to date, please visit this page to stay up to date, as we will post any changes here.

 

If you are dissatisfied with any aspect of our Privacy Policy, you may have legal rights and, where relevant, we have described these as well.

 

DEFINITIONS

Candidates – includes applicants for all roles advertised by Platinum International, including permanent, part-time and temporary positions; as well as people who have supplied a speculative CV to Platinum International not in relation to a specific job. Individual contractors, freelance workers and employees of suppliers or other third parties put forward for roles with Platinum International will be treated as candidates for the purposes of this Privacy Policy.

 

Company – Platinum International Ltd, the Company’s Subsidiaries or Holding Companies and any Subsidiary of any holding Company.

 

Customers – this category covers our customers, clients, and others to whom Platinum International provides goods and/ or services in the course of its business.

 

Data Controller – means the person or organisation who determines the purposes for which and the manner in which any personal data is processed.

 

General Data Protection Regulation (GDPR) – a European Union statutory instrument which aims to harmonise European data protection laws. It has an effective date of 25 May 2018, and any references to it should be construed accordingly to include any national legislation implementing it.

 

Personal data – means any information relating to an identified or identifiable living person.

 

Personal Data – Sensitive/ Special categories – means personal data consisting of information as to:

  1. the racial or ethnic origin of the individual;
  2. their political opinions;
  3. their religious or philosophical beliefs;
  4. their membership of a trade union;
  5. their physical or mental health or condition;
  6. their sexual life;
  7. the commission or alleged commission by them of any offence;
  8. any proceedings for any offence committed or alleged to have been committed by them, the disposal of such proceedings or the sentence of any court in such proceedings;
  9. genetic data; and
  10. biometric data where processed to uniquely identify a person (for example a photo in an electronic passport).

 

Staff – includes employees and interns engaged directly in the business of Platinum International (or who have accepted an offer to be engaged) as well as certain other workers engaged in the business of providing services to Platinum International (even though they are not classed as employees). Independent contractors and consultants performing services for Platinum International fall within the definition of a ‘Supplier’ for the purposes of this Privacy Policy.

 

Suppliers – refers to partnerships and companies (including sole traders), and atypical workers such as independent contractors and freelance workers, who provide services to Platinum International. In certain circumstances Platinum International will sub-contract the services it provides to Clients to third party suppliers who perform services on Platinum International’s behalf. In this context, suppliers that are individual contractors, freelance workers, or employees of suppliers will be treated as Candidates for data protection purposes. Please note that in this context, Platinum International requires Suppliers to communicate the relevant parts of this Privacy Policy (namely the sections directed at Candidates) to their employees.

 

Website Users – any individual who accesses any of the Platinum International websites.

 

WHAT KIND OF INFORMATION DO WE COLLECT?

  1. As an independent battery and lubricants distributor, we collect personal data from our Website users, Customers, Suppliers and other people whom we may contact in order to provide our goods and services. The information described below is in addition to any personal data we are required by law to process in any given situation.
    1. Customer Data: We collect a very limited amount of customer data. We generally only need to have your contact details or the details of individual contacts at your organisation (such as their names, telephone numbers, addresses and email addresses), business details for credit checking purposes and Bank payment details, to enable us to process credit payments and to prove your business credentials. These are all to ensure that our relationship runs smoothly. We also hold information relating to your online engagement and other material published by Platinum International, which we use to ensure that our marketing communications to you are relevant and timely. We may also hold extra information that someone in your organisation has chosen to tell us. In certain circumstances, such as when you engage with our Finance and Customer Services teams, the calls with you may be recorded or monitored, depending on the applicable local laws and requirements. If you visit any of our sites you will be asked to ‘sign in’ so that we know who is in the building. In addition, we use CCTV in and around all our Company controlled buildings and locations to monitor behaviour for security and Health & Safety purposes. If we need any additional personal data for any reason, we will let you know.
      1. When you access our website we will also collect certain data from you. If you would like more information about this, please see our Cookie Policy on our website.

 

  1. Supplier Data: The data we collect about our suppliers is also very limited as we simply need to make sure that our relationship runs smoothly. We will collect the details for our contacts within your organisation, such as names, telephone numbers and email addresses. We’ll also collect bank details, so that we can pay you. In certain circumstances, such as when you engage with our Finance and Customer Services teams, the calls with you may be recorded or monitored, depending on the applicable local laws and requirements. If you visit any of our sites you will be asked to ‘sign in’ so that we know who is in the building. In addition, we use CCTV in and around all our Company controlled buildings and locations to monitor behaviour for security and Health & Safety purposes. If we need any additional personal data for any reason, we will let you know. If we need any additional personal data for any reason, we will let you know.
    1. When you access our website we will also collect certain data from you. If you would like more information about this, please see our Cookie Policy on our website.

 

  1. People whose data we receive from applicants and staff, such as referees and emergency contacts/ next of kin: From referees we need confirmation of what you know about our employee or prospective employee, so that we can confirm their work history. Emergency contact/ Next of kin details give us somebody to make contact with in an emergency. To ask for a reference, we need the referee’s contact details (such as name, address, email address and telephone number). We also need these details if an employee has put you down as their emergency contact, so that we can contact you in the event of an accident or an emergency.

 

  1. Website Users: We collect data from our Website Users which we use to help us to improve your experience when using our website and to help us manage the services we provide. This includes information such as how you use our website, the frequency with which you access our website, your browser type, the location you view our website from, the language you choose to view it in and the times that our website is most popular. If you contact us via the website, for example by using a chat function, we will collect any information that you provide to us, for example your name and contact details.
    1. When you access our website we will also collect certain data from you. If you would like more information about this, please see our Cookie Policy on our website.

 

HOW DO WE COLLECT YOUR INFORMATION?

  1. We collect personal data in a number of ways, but it is usually provided by you directly to us:
    1. Personal data we receive from you:
      1. When you proactively contact us, usually by phone or email and give us personal data. Please note all our phone call make to any Platinum International controlled location may be logged, monitored or recorded for training, verification or Health & Safety purposes.
      2. When we contact you, by phone, email or through our employees’ (usually a member of our sales team) business development activities.
    2. Personal data we receive from other sources:
      1. As appropriate, we may seek more information about you from other sources, generally by way of due diligence or other market intelligence including from third party market research and by analysing online and offline media (which we may do ourselves, or employ other organisations to do for us); and
      2. From other limited sources and third parties (for example from other customers to the extent that they provide us with your details).
    3. Personal data we collect via our website:
      1. When you access our website we may collect your data automatically or through you providing it to us. When you visit our website there is certain information that we may automatically collect, whether or not you decide to use our services. This includes your IP address, the date and the times and frequency with which you access the website and the way you browse its content. We will also collect data from you when you contact us via the website. We also collect your data automatically via cookies, in line with cookie settings in your browser. If you are also a Customer, Supplier or third party of Platinum International, we may use data from your use of our websites to enhance other aspects of our communications with or service to you. If you would like to find out more about cookies, including how we use them and what choices are available to you, please see our Cookie Policy on our website.

 

HOW WILL YOUR INFORMATION BE USED?

Business Activities

  1. As a business, the Company needs to keep and process personal information as part of our normal business of selling and distributing batteries and lubricants, and returning scrap. We store your details on our systems (and update them when necessary), so we can make contact in relation to doing business together (purchase, sales and distribution activities and services);
    1. Keep records of conversations and meetings, so that we can better purchase or provide products and services from/ to you;
    2. Undertake customer and supplier satisfaction surveys;
    3. Processing your data to enable us to send you targeted, relevant marketing materials or other communications which we think are likely to be of interest to you.
    4. Assessing data about business requirements and opportunities which we may think are suitable for you;
    5. Allowing you to participate in specialist online training;
    6. Allowing you to participate in the interactive features of our services, when you choose to do so;
    7. Carrying out our obligations arising from any contracts entered into between us;
    8. Carrying out our obligations arising from any contract entered into between Platinum International and third parties in relation to conducting business;
    9. Facilitating our payroll and invoicing processes;
    10. Verifying details you have provided, using third party resources (such as credit safe or Companies House), or to request information (such as references, potentially any criminal convictions, to the extent that is appropriate and in accordance with local laws);
    11. Complying with our legal obligations in connection with the detection of crime or the collection of taxes or duties; and

 

  1. We may use your personal data for the above purposes if we deem it necessary to do so for our legitimate interests. If you are not happy about this, in certain circumstances you have the right to object and can find out more about how and when to do this in this document.

 

  1. We may periodically send you information that we think you may find interesting or relevant. In particular, we may wish to use your data for the purposes listed below, where appropriate and in accordance with any local laws and requirements. Please note that this list is not exhaustive. To:
    1. enable us to develop and market other products and services;
    2. market our full range of products, services and activities to you;
    3. send you details of reports, promotions, offers, networking and customer events, and general information about the industry sectors which we think might be of interest to you;
    4. display promotional excerpts from your details on Platinum International’s website(s) and/ or Company Magazine as a success story (only where we have obtained your express consent to do so); and
    5. provide you with information about certain discounts and offers that you are eligible for, by virtue of your relationship with Platinum International.

 

  1. We need your consent for some aspects of these activities which are not covered by our legitimate business interests (in particular, the collection of data via cookies and the delivery of direct marketing to you through digital channels) and, depending on the situation, we will ask for this via an opt-in or soft-opt-in.

 

  1. Soft opt-in consent is a specific type of consent which applies where you have previously engaged with us (for example by submitting an Account Opening form, or by purchasing our goods or services), we would be marketing other battery or lubricant related products, services or activities. Under ‘soft opt-in’ consent, we will take your consent as given unless or until you opt out. For most people, this is beneficial as it allows us to suggest other products and services to you alongside the specific one you contacted us for. This significantly increases the likelihood of us being able to provide you with a better level of product or service which you may require. For other types of e-marketing, we are required to obtain your explicit consent.

 

  1. If you are not happy about our approach to marketing, you have the right to withdraw your consent at any time and can find out more about how to do so in this document. If you have opted out from our marketing communications through our preference centre, it is possible that your details may be recaptured through public sources in an unconnected marketing campaign. We will try to make sure this does not happen, but if it does, we are sorry and we would ask that in those circumstances you opt out again.

 

  1. All our marketing is based on what we think will serve our Customers best. We will always try to get it right, but we know it will not always be right for everyone. We may use your data to show you Platinum International adverts and other content on other websites, for example Facebook. If you do not want us to use your data in this way, please turn off the “Advertising Cookies” option (please refer to our Cookies Policy). Even where you have turned off advertising cookies, it is still possible that you may see a Platinum International advert, but in this case it will not have been targeted at you personally, but rather at an anonymous audience.

 

  1. We may use personal data to help us establish, exercise or defend legal claims.

 

  1. We use CCTV in and around all our Company controlled buildings and locations to monitor behaviour and for security and Health & Safety purposes. In addition we use locational tracking devices in company computers, phones and in Company controlled vehicles to monitor a device’s physical location for the purposes of performance management reviews, security, Health & Safety information and for delivery information purposes which may be supplied to third parties within Europe (EEA).

 

Customer Data

  1. We may use your personal data for our business purposes, if we deem this to be necessary for our legitimate interests.
    1. If you are not happy about this, in certain circumstances you have the right to object and can find out more about how and when to do in this document.

 

  1. We will not, as a matter of course, seek your consent when sending marketing materials to a corporate postal or email address.
    1. If you are not happy about this, you have the right to opt out of receiving marketing materials from us and you can find out more about how and when to do in this document.

 

  1. In certain and more unusual circumstances, we may use your personal data to help us to establish, exercise or defend legal claims.

 

Supplier Data

  1. We will only use your information to:
    1. Store (and update when necessary) your details on our database, so that we can contact you in relation to our agreements;
    2. Offer products and services to you or to obtain your support, products and services from you;
    3. Perform certain legal obligations;
    4. Help us to target appropriate marketing campaigns; and
    5. In more unusual circumstances, to help us to establish, exercise or defend legal claims.

 

  1. We may use your personal data for these purposes, if we deem this to be necessary for our legitimate interests.

 

  1. We will not, as a matter of course, seek your consent when sending marketing messages to a corporate postal or email address.
    1. If you are not happy about this, in certain circumstances you have the right to object and can find out more about how to do so here.

 

People whose data we receive from Applicants and Colleagues, such as Referees and Emergency Contacts

  1. We will only use the information that an Applicant or a Platinum Colleague gives us about you, for the following purposes:
    1. If our a candidates or Platinum colleague puts you down on our form as an emergency contact, we may contact you in the case of an accident or emergency affecting them; or
    2. If you were put down by an applicant, prospective member of Staff or a Platinum colleague as a referee, we will contact you in order to take up a reference. This is an important part of our quality assurance process and could be the difference between the individual getting a job or not.

 

  1. We may use your personal data for these purposes if we deem this to be necessary for our legitimate interests.
    1. If you are not happy about this, you have the right to object and can find out more about how to do so here.

 

Website Users

  1. We use your data to help us to improve your experience of using our website, for example by analysing your recent search criteria to help us to present products and services to you that we think you will be interested in.
    1. If you would like to find out more about cookies, including how we use them and what choices are available to you, please see our Cookies Policy.

 

OUR LEGAL BASES FOR PROCESSING YOUR DATA?

LEGITIMATE INTERESTS

  1. Article 6(1)(f) of the GDPR sets out that we can process your data where it “is necessary for the purposes of the legitimate interests pursued by [us] or by a third party, except where such interests are overridden by the interests or fundamental rights or freedoms of [you] which require protection of personal data.”

 

  1. We do not think that any of the following activities prejudice individuals in any way rather they enable us to offer you a more tailored, efficient service to our customers, suppliers and to other third parties. However, you do have the right to object to us processing your personal data on this basis. If you would like to know more about how to do so, please see ‘Your Rights’.

 

Customer Data

  1. We believe that it is reasonable to expect that if you are looking to do business with us, you are happy for us to collect and otherwise use your personal data to offer or provide our business services to you. Once it is looking like we may do business, we may also want to double check any information you have provided to us business references and credit checks. We need to do these things so that we can function as a profit-making business.

 

  1. We want to provide you with tailored product recommendations and relevant articles to read to help you serve your customers better. We therefore think it’s reasonable for us to process your data to make sure that we send you the most appropriate content.

 

  1. In order for our business to run smoothly, we also need to use your data for our internal administrative activities, such as Finance (where invoicing and credit insurance is relevant), Sales Management and Customer Services (so we can make contact with you and maintain our relationship).

 

  1. We have our own legal obligations and if we believe, in good faith, that it is necessary we may share your data in connection with crime detection, tax collection or actual or anticipated litigation.

 

  1. To ensure that we provide you with the best service possible, we store your personal data and/ or the personal data of individual contacts at your organisation as well as keeping records of our conversations, meetings, registered jobs and placements. From time to time, we may also ask you to undertake a customer satisfaction survey. We think this is reasonable – we deem these uses of your data to be necessary for our legitimate interests as an organisation providing various recruitment services to you.

 

Supplier Data

  1. We use and store the personal data of individuals within your organisation in order to facilitate the receipt of products and services from you, as one of our Suppliers. We also hold your financial details, so that we can pay you for your products and services. We deem all such activities to be necessary within the range of our legitimate interests as a recipient of your services.

 

  1. To ensure that we can provide consistent and robust supply chains, we store your personal data and/ or the personal data of individual contacts at your organisation as well as keeping records of our conversations, meetings, and registered product and service orders. We think this is reasonable and we deem these uses of your data to be necessary for our legitimate interests as an organisation providing product and service orders to you.

 

People whose data we receive from applicants and staff, such as Referees and Emergency Contacts:

  1. If you have been put down by an applicant or by a prospective member of Staff as one of their referees, we use your personal data in order to contact you for a reference. This is a part of our quality assurance procedure and so we deem this to be necessary for our legitimate interests as an organisation which employs people.

 

  1. If an applicant or staff member has given us your details as an emergency contact, we will use these details to contact you in the case of an accident or emergency. We are sure you will agree that this is a vital element of our people-orientated organisation, and so is necessary for our legitimate interests.

 

CONSENT

  1. In certain circumstances, we are required to obtain your consent to the processing of your personal data in relation to certain activities. Depending on exactly what we are doing with your information, this consent will be opt-in consent or soft opt-in consent.

 

  1. Article 4(11) of the GDPR states that (opt-in) consent is “any freely given, specific, informed and unambiguous indication of the data subject’s wishes by which he or she, by a statement or by a clear affirmative action, signifies agreement to the processing of personal data relating to him or her.” In plain language, this means that:
    1. you have to give us your consent freely, without us putting you under any type of pressure;
    2. you have to know what you are consenting to – so we’ll make sure we give you enough information;
    3. you should have control over which processing activities you consent to and which you do not. We provide these finer controls within our privacy preference centre; and
    4. you need to take positive and affirmative action in giving us your consent – we are likely to provide a tick box for you to check so that this requirement is met in a clear and unambiguous fashion.

 

  1. We will keep records of the consents that you have given in this way.

 

  1. We have already mentioned that, in some cases, we will be able to rely on soft opt-in consent. We are allowed to market products or services to you which are related to the services we provide, as long as you do not actively opt-out from these communications.

 

  1. As we have mentioned, you have the right to withdraw your consent to these activities. You can do so at any time, and details of how to do so can be found here.

 

ESTABLISHING, EXERCISING OR DEFENDING LEGAL CLAIMS

  1. Sometimes it may be necessary for us to process personal data and, where appropriate and in accordance with local laws and requirements, sensitive personal data in connection with exercising or defending legal claims. Article 9(2)(f) of the GDPR allows this where the processing “is necessary for the establishment, exercise or defence of legal claims or whenever courts are acting in their judicial capacity”.

 

  1. This may arise for example where we need to take legal advice in relation to legal proceedings or are required by law to preserve or disclose certain information as part of the legal process.

 

WHO DO WE SHARE PERSONAL DATA WITH?

  1. Where appropriate we may share your personal data, in various ways and for various reasons, with the following categories of people:
    1. Any of our group companies;
    2. Individuals and organisations who hold information related to a business reference or application to do business with us, such as current or past suppliers, customers and insurers etc.;
    3. Tax, audit, or other authorities, when we believe in good faith that the law or other regulation requires us to share this data (for example, because of a request by a tax authority or in connection with any anticipated litigation);
    4. Third party service providers who perform functions on our behalf (including external consultants, business associates and professional advisers such as lawyers, auditors and accountants, technical support functions and IT consultants carrying out testing and development work on our business technology systems);
    5. Third party outsourced IT and document storage providers where we have an appropriate processing agreement (or similar protections) in place;
    6. Marketing technology platforms and suppliers;

 

HOW DO WE SAFEGUARD YOUR PERSOANL DATA?

  1. We are committed to taking all reasonable and appropriate steps to protect the personal information that we hold from misuse, loss, or unauthorised access. We do this by having in place a range of appropriate technical and organisational measures. These include measures to deal with any suspected data breach.

 

  1. If you suspect any misuse or loss of or unauthorised access to your personal information please let us know immediately. Details of how to contact us can be found below.

 

HOW DO WE STORE AND TRANSFER YOUR DATA INTERNATIONALLY?

  1. To enable us to conduct international business, your data may be transferred:
    1. between and within Platinum International entities and employees;
    2. to third parties (such as suppliers, customers and advisors to the Platinum International business);
    3. to a cloud-based storage provider; and
    4. to other third parties, as referred to here.

 

  1. We want to make sure that your data are stored and transferred in a way which is secure. We will therefore only transfer data outside of the European Economic Area or EEA (i.e. the Member States of the European Union, together with Norway, Iceland and Liechtenstein) where it is compliant with data protection legislation and the means of transfer provides adequate safeguards in relation to your data or where it is necessary for the conclusion:
    1. For the performance of a contract between ourselves and a third party and the transfer is in your interests for the purposes of that contract (for example, if we need to transfer data outside the EEA in order to meet our obligations under that contract if you are a customer or supplier of ours); or
    2. where you have consented to the data transfer.

 

  1. To ensure that your personal information receives an adequate level of protection, we have put in place appropriate procedures with the third parties we share your personal data with to ensure that your personal information is treated by those third parties in a way that is consistent with and which respects the law on data protection.

 

HOW LONG DO WE KEEP YOUR PERSONAL DATA FOR?

  1. We will keep personal data for no longer than is necessary, having regard to the original purpose for which the data was processed. In some cases we will be legally obliged to keep your data for a set period.

 

YOUR RIGHTS – HOW TO ACCESS, AMEND OR TAKE BACK THE PERSONAL DATA?

  1. One of the General Data Protection Regulation’s (GDPR’s) main objectives is to protect and clarify the rights of EU citizens and individuals in the EU with regards to data privacy. Under the GDPR and The Data Protection Act 2018 (DPA) you have a number of rights with regard to your personal data. In summary of the below:
    1. You have the right to request from us access to and rectification or erasure of your personal data, the right to restrict processing, object to processing as well as in certain circumstances the right to data portability. This means that you retain various rights in respect of your personal data, even once you have given it to us. These are described in more detail below.
    2. If you have provided consent for the processing of your data you have the right (in certain circumstances) to withdraw that consent at any time which will not affect the lawfulness of the processing before your consent was withdrawn.
    3. We can refuse to comply with any request if we can demonstrate compelling and legitimate grounds for processing, which override your interests, rights and freedoms or where there is another legitimate or legal reason for keeping the data. These include but are not limited to where we can demonstrate compelling legitimate grounds for the processing, which override your interests, rights and freedoms; or if the processing is for the establishment, exercise or defence of legal claims.

 

  1. To get in touch about these rights, please contact us (for further information please see the ‘Complaints’ section). We will seek to deal with your request without undue delay, and in any event within one month (subject to any extensions to which we are lawfully entitled). Please note that we may keep a record of your communications to help us resolve any issues which you raise.

 

  1. Right to object: this right enables you to object to us processing your personal data where we do so for one of the following four reasons: (i) our legitimate interests; (ii) to enable us to perform a task in the public interest or exercise official authority; (iii) to send you direct marketing materials; and (iv) for scientific, historical, research, or statistical purposes.

 

  1. The “legitimate interests” and “direct marketing” categories above are the ones most likely to apply to our Website Users, Customers and Suppliers. If your objection relates to us processing your personal data because we deem it necessary for your legitimate interests, we must act on your objection by ceasing the activity in question unless:

 

  1. we can show that we have compelling legitimate grounds for processing which overrides your interests; or
  2. we are processing your data for the establishment, exercise or defence of a legal claim.

 

  1. If your objection relates to direct marketing, we must act on your objection by ceasing this activity.

 

  1. Right to withdraw consent: Where we have obtained your consent to process your personal data for certain activities (for example, for our marketing activities), you may withdraw this consent at any time and we will cease to carry out the particular activity that you previously consented to unless we consider that there is an alternative reason to justify our continued processing of your data for this purpose in which case we will inform you of this condition.

 

  1. Data Subject Access Requests (DSAR): You may ask us to confirm what information we hold about you at any time, and request us to modify, update or delete such information. We may ask you to verify your identity and for more information about your request. If we provide you with access to the information we hold about you, we will not charge you for this unless your request is “manifestly unfounded or excessive”. If you request further copies of this information from us, we may charge you a reasonable administrative cost where legally permissible. Where we are legally permitted to do so, we may refuse your request. If we refuse your request we will always tell you the reasons for doing so.

 

  1. Right to erasure: You have the right to request that we erase your personal data in certain circumstances. Normally, the information must meet one of the following criteria:
    1. the data are no longer necessary for the purpose for which we originally collected and/ or processed them;
    2. where previously given, you have withdrawn your consent to us processing your data, and there is no other valid reason for us to continue processing;
    3. the data has been processed unlawfully (i.e. in a manner which does not comply with the GDPR);
    4. it is necessary for the data to be erased in order for us to comply with our legal obligations as a data controller; or
    5. if we process the data because we believe it necessary to do so for our legitimate interests, you object to the processing and we are unable to demonstrate overriding legitimate grounds for our continued processing.

 

  1. We would only be entitled to refuse to comply with your request for one of the following reasons:
    1. to exercise the right of freedom of expression and information;
    2. to comply with legal obligations or for the performance of a public interest task or exercise of official authority;
    3. for public health reasons in the public interest;
    4. for archival, research or statistical purposes; or
    5. to exercise or defend a legal claim.

 

  1. When complying with a valid request for the erasure of data we will take all reasonably practicable steps to delete the relevant data.

 

  1. Right to restrict processing: You have the right to request that we restrict our processing of your personal data in certain circumstances. This means that we can only continue to store your data and will not be able to carry out any further processing activities with it until either: (i) one of the circumstances listed below is resolved; (ii) you consent; or (iii) further processing is necessary for either the establishment, exercise or defence of legal claims, the protection of the rights of another individual, or reasons of important EU or Member State public interest.

 

  1. The circumstances in which you are entitled to request that we restrict the processing of your personal data are:
    1. where you dispute the accuracy of the personal data that we are processing about you. In this case, our processing of your personal data will be restricted for the period during which the accuracy of the data is verified;
    2. where you object to our processing of your personal data for our legitimate interests. Here, you can request that the data be restricted while we verify our grounds for processing your personal data;
    3. where our processing of your data is unlawful, but you would prefer us to restrict our processing of it rather than erasing it; and
    4. where we have no further need to process your personal data but you require the data to establish, exercise, or defend legal claims.

 

  1. If we have shared your personal data with third parties, we will notify them about the restricted processing unless this is impossible or involves disproportionate effort. We will, of course, notify you before lifting any restriction on processing your personal data.

 

  1. Right to rectification: You also have the right to request that we rectify any inaccurate or incomplete personal data that we hold about you. If we have shared this personal data with third parties, we will notify them about the rectification unless this is impossible or involves disproportionate effort. Where appropriate, we will also tell you which third parties we have disclosed the inaccurate or incomplete personal data to. Where we think that it is reasonable for us not to comply with your request, we will explain our reasons for this decision.

 

  1. Right of data portability: If you wish, you have the right to transfer your personal data between data controllers. In effect, this means that you are able to transfer your Platinum International account details to another online platform. To allow you to do so, we will provide you with your data in a commonly used machine-readable format that is password-protected so that you can transfer the data to another online platform. Alternatively, we may directly transfer the data for you. This right of data portability applies to: (i) personal data that we process automatically (i.e. without any human intervention); (ii) personal data provided by you; and (iii) personal data that we process based on your consent or in order to fulfil a contract.

 

  1. Right to lodge a complaint with a supervisory authority: You also have the right to lodge a complaint with your local supervisory authority. Details of how to contact them can be found in the ‘Complaints’ section).

 

  1. If you would like to exercise any of these rights, or withdraw your consent to the processing of your personal data (where consent is our legal basis for processing your personal data), details of how to contact us can be found in the ‘Complaints’ section. Please note that we may keep a record of your communications to help us resolve any issues which you raise.

 

  1. You may ask to unsubscribe from your marketing activities at any time.

 

  1. It is important that the personal information we hold about you is accurate and current. Please keep us informed if your personal information changes during the period for which we hold your data.

 

 

 

COMPLAINTS

  1. If you think we have not complied with the requirements of the GDPR or DPA 18 with regard to your personal data, you have a specific right to lodge a complaint with the relevant supervisory authority. The supervisory authority will then inform you of the progress and outcome of your complaint. The supervisory authority in the UK is the Information Commissionaire’s Office (ICO).

 

  1. Platinum International Ltd and Platinum International BV (Platinum International Ltd, Platinum House, Bailey Rd, Trafford Park, Manchester, M17 1SA. Company Registration Number 4397197) is the controller and processor of data for the purposes of the DPA 18 and GDPR.

 

  1. If you have any concerns as to how your data is processed you can contact: Mark Broomhead – HR, Quality & Systems Manager at GDPR@platinuminternational.com or you can write using the address of Platinum International Ltd, Platinum House, Bailey Rd, Trafford Park, Manchester, M17 1SA.

 

  1. You can notify Platinum International Ltd of any changes to your personal data, by contacting the HR Department or emailing HR@platinuminternational.com