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PRIVACY POLICY


LANGLEY HOLDINGS PLC

Updated at: 24/05/2018



1.Overview1.1.The Company takes the security and privacy of your data seriously.
We gather and use information or ‘data’ about you as part of our business and to
manage, develop and enhance our relationship with you. We intend to comply with
our legal obligations under the Data Protection Act 2018 (the ‘2018 Act’) and
the EU General Data Protection Regulation (‘GDPR’) in respect of data privacy
and security. We have a duty to notify you of the information contained in this
policy.1.2.This general policy applies to all personal data we may hold.1.3.The
Company has measures in place to protect the security of your data as set out in
this policy.1.4.The Company will hold data for as long as is necessary for the
purposes for which it was collected, or until a subject access request (see
section 7) is received to delete it.1.5.This policy explains how the Company
will hold and process your information and explains your rights in respect of
the data we hold.2.Data Protection Principles2.1.Personal data must be processed
in accordance with six ‘Data Protection Principles.’ It must:

be processed fairly, lawfully and transparently;
be collected and processed only for specified, explicit and legitimate purposes;
be adequate, relevant and limited to what is necessary for the purposes for
which it is processed;
be accurate and kept up to date. Any inaccurate data must be deleted or
rectified without delay;
not be kept for longer than is necessary for the purposes for which it is
processed; and
be processed securely.

We are accountable for these principles and must be able to show that we are
compliant.3.How we define personal data3.1.‘Personal data’ means information
which relates to a living person who can be identified from that data (a ‘data
subject’) on its own, or when taken together with other information which is
likely to come into our possession.3.2.This policy applies to all personal data
whether it is stored electronically, on paper or on other materials.3.3.If you
visit our web site it is standard procedure for our web servers to store your
internet service provider details, the web site from which you are visiting,
details as to which of our sites you are visiting and the date and duration of
your visit.3.4.Personal data we hold will have come into our possession in the
ordinary course of business.3.5.The personal data we hold may include some or
all of the following information categories:

name;
email address;
Company name;
Company address
your gender;
skype address;
mobile phone number;
job title;3.6.Note. Our employee data is more extensive but a separate policy
applies.3.7.We do not hold any information which is considered under GDPR as
Special Category Data.3.8.When using our web site data will be collected by
Google Analytics. Information about what they collect and how this can be
avoided can be found on their web site at
https://policies.google.com/privacy?hl=en3.9.You may also be invited to access
videos via our web site. This facility is provided by You Tube and details of
their policies can be found at https://policies.google.com/privacy?hl=en4.How we
define processing4.1.‘Processing’ means any operation which is performed on
personal data such as:

collection, recording, organisation, structuring or storage;
adaption or alteration;
retrieval, consultation or use;
disclosure by transmission, dissemination or otherwise making available;
alignment or combination; and
restriction, destruction or erasure.

This includes processing personal data which forms part of a filing system and
any automated processing.5.How will we process your personal data?5.1.The
Company will process your personal data in accordance with our obligations under
the 2018 Act.5.2.We will protect your data by implementing technical and
organisational safety measures in order to avoid accidental or deliberate
manipulation, loss, damage or access by unauthorised persons. Our processing
includes data encryption, pass-wording and secure storage of back-up
media.5.3.We may use personal data :

whilst performing contractual obligations (sale and purchase contracts including
quotations);or
where we believe we have a legitimate interest in making you aware of
developments to our products or appraising you of the activities of the Company
or Group of companies.
Where we become legally obliged to do so.

We will not use your personal data for any other unrelated purpose without
telling you about it and the legal basis that we intend to rely on for
processing it.6.Sharing your personal data6.1.Sometimes we might share your
personal data with group companies or our contractors and agents to carry out
our obligations under our contract with you or for our legitimate
interests.6.2.We require those companies to keep your personal data confidential
and secure and to protect it in accordance with the law and our policies. They
are only permitted to process your data for the lawful purpose for which it has
been shared and in accordance with our instructions.6.3.We do not make personal
data available to third parties other than as set out in clauses 6.1 and 6.6 of
this policy.6.4.We do not send your personal data outside the European Economic
Area. If this changes you will be notified of this and the protections which are
in place to protect the security of your data will be explained.6.5.Our specific
GDPR Employee Policy sets out some of the measure used to protect employee
data.6.6.If third party organisations have access to personal data we ensure
that they have adequate policies in place to protect the data in accordance with
the GDPR requirements and principles.7.Subject access requests7.1.Persons who
would like to know what personal information we hold may make a Subject Access
Request (SAR) in relation to their own personal data. The contact person is set
out in clause 8.2 below. We are required to respond within one month unless the
request is complex or numerous in which case the period in which we must respond
can be extended by a further two months.7.2.There is normally no fee for making
a subject access request.8.Your data subject rights8.1.You have the right to
information about what personal data we process, how and on what basis as set
out in this policy.8.2.Matters arising under clauses 7.1 and 8.3 to 8.8 should
be referred in writing to privacy@langleyholdings.com8.3.You have the right to
access your own personal data by way of a subject access request (see section 7
above.).8.4.You can request that we correct any inaccuracies in your personal
data.8.5.You have the right to request that we erase your personal data where we
were not entitled under the law to process it.8.6.While you are requesting that
your personal data is corrected or erased or are contesting the lawfulness of
our processing, you can apply for its use to be restricted while the application
is made.8.7.You have the right to object to data processing where we are relying
on a legitimate interest to do so and you think that your rights and interests
outweigh our own and you wish us to stop.8.8.You have the right to object if we
process your personal data for the purposes of direct marketing. You will be
given the opportunity to unsubscribe from future direct email campaigns but we
may retain your personal data where for legitimate business reasons we consider
it appropriate to do so.8.9.You have the right to be notified of a data security
breach concerning your personal data.8.10.You have the right to lodge a
complaint with our data protection officer (see 8.2) or our data protection
supervisory authority.

Full contact details including a helpline number can be found on the Information
Commissioner’s Office website (www.ico.org.uk). This website has further
information on your rights and our obligations.

1. Google Analytics - Opt Out: https://tools.google.com/dlpage/gaoptout

2. Facebook: https://www.facebook.com/about/privacy/update

3. Twitter: https://twitter.com/en/privacy#update

4. LinkedIn: https://www.linkedin.com/legal/privacy-policy

5. Youtube/Google: https://policies.google.com/privacy?hl=en

6. dotmailer: https://www.dotmailer.com/terms/privacy-policy/

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