Privacy Policy and GDPR Compliance

Cameron Grant, Managing Director and Ben Grant, Chairman and Export Sales Director

OEM Group Ltd Website Privacy Policy

Introduction

The website secureseal.com is operated by OEM Group Limited (“we”, “us” or “OEM”) and we are a controller for the purposes of the Data Protection Act 1998 and the EU General Data Protection Regulation 2016/679. This means that we are responsible for, and control the processing of, the personal information you provide to us when using this website in accordance with this privacy policy.

We understand that customers care about the use and storage of their personal information and we value your trust in allowing us to do this in a careful and sensible manner. We have created this privacy policy statement in order to demonstrate our commitment to the privacy of our customers.

By using our website (including our mobile site), our social media pages, calling our landline or corporate mobiles, using our helpdesk functions, emailing us, or using any other OEM Group service, you are acknowledging that we are processing your personal information and, where necessary consenting to such practices, as outlined in this statement.

Personal information which we collect

We collect personal information about you (and others if their personal information is provided by you) when you:

(a) make or manage a product purchase or repair, either personally or as a representative of another client;

(b) register or alter details for your business accounts;

(d) sign up for our newsletter and other marketing emails;

(e) enquire about or apply for a Corporate Account or Business Account, Pro-forma or Distributorship; engage with us to receive helpdesk services (such as by contacting our customer services department, through the “Contact Us” form on our website or by calling our telephone helpline;

(f) post material to our website and / or social media pages;

(g) complete customer feedback or surveys;

(h) raise a complaint or dispute with us or are involved in a legally recordable incident at our premises (e.g. in relation to health and safety reporting);

(i) participate in competitions or promotions;

(j) and / or use our website and customer applications in any other way.

The personal information collected in the above manner may include the following about you (and others if their personal information is provided by you):

(a) full name;

(b) business postal address;

(d) telephone numbers;

(e) payment details;

(f) geo-location;

(g) machine identifiers (such as IP addresses);

(h) dispute resolution information;

(i) image data;

(j) website usage behavioural data (tags and cookies – see Cookies and Tracking section below);

Personal information provided by third parties

We may receive information about you from other sources (such as the Mail Preference Service), which we will add to the information we already hold about you in order to help us provide our products and services in accordance with your requirements and to ensure that the quality of data we have on your account(s) is maintained properly. We may also obtain information about you from social media providers such as Twitter and Facebook or from third party websites where you have left commentary or feedback about us.

How we use your information

We will collect personal information:

1) in order to take the necessary steps in preparation of, or to fulfil our obligations of sale:

a) Payments – provide communications about products and services being provided to you (and others if their personal information is provided by you).

b) Purchase or Account updates – send details of new, amended or cancelled products or account details and changes – usually via email.

c) Update you on matters affecting your products or purchases – contact you (and others if their personal information is provided by you) in the event of a change that affects a product or any data or personal information you have provided us with, such as changes to terms and conditions of warranty or product usage or this privacy policy.

d) Website service communication – provide notifications of any changes to our website or to our services that may affect you (and others if their personal information is provided by you);

e) Customer service communication – provide you with requested information or correspondence, such as datasheets, manuals, instruction booklets, or a response from us to an enquiry made by you.

f) To provide assistance in completing product purchase – send reminder emails to continue with a purchase which you initiated but have not completed.

g) Maintain your business account information – create a profile about you in relation to your product purchase, to update our records, create and maintain your account.

2) with your consent:

a) Simplify payment process – use saved payment details within your account OEM Group Ltd or SecureSeal Systems Ltd., so that, upon making future purchases you instruct us on, you have the convenient option of seamless ordering and payment. This information is only used / accessed when you or your agent (e.g., a trailer builder) contact us to re-order products.

b) Marketing communications – create a profile about you for marketing purposes to tailor our communications to you. We may use automated processes to do this; and we will always provide an easy opt out feature.

c) Promotional offers – inform you about promotional offers and other products or services that may be of interest (in line with Marketing communications above).

d) Maintain records indicating your consent to status – to ensure we accurately reflect your wishes when communicating to you.

3) in our legitimate interest* improve our services:

a) Market research – to contact you (and others if their personal information is provided by you) to ask about the experience using our products and services as part of a continual programme of customer service and product improvement. This is not marketing communication and is separate to Marketing communications above.

b) Website customisation – to customise our website and its content to your particular preferences in accordance with the Cookies and Tracking section below.

c) Customer support – monitor calls and help train staff in relation to our customer support and helpdesk function.

d) Product and service improvement – to improve our product and services.

e) Service analysis – to conduct research, statistical analysis and behavioural analysis on our website and social media channels. This may include providing aggregate statistical information relating to customers, sales, and traffic patterns related to website information to our in-house web management team.

4) in our legitimate interest* to protect against fraud:

a) Website improvement and fraud prevention – improve our websites, prevent or detect fraud or abuses of our websites and enable our in-house or a qualified third party to carry out technical, logistical or other functions on our behalf.

b) Security – carry out security checks when allowing you access to our services and to block fraudulent or suspected fraudulent activity.

5) in order to meet our legal obligations:

a) Taxation – ensure we meet our tax and other regulatory obligations.

b) Registration – ensure local jurisdiction regulations are complied with (where registration is necessary in such jurisdictions).

* any reliance on legitimate interest shall not prejudice your interest or fundamental rights and freedoms.

Marketing

We may periodically send promotional material to you about new products, special offers or other information which we think you may find interesting based on the profile we have created about you to the email addresses and phone numbers which you have provided.

If these are similar to products and services previously supplied by us to you, we will assume, under our legitimate interests to promote similar goods and services, that you are willing to receive this information unless you tell us otherwise. Please note that we do not want to send you information that you do not want to receive, and you can opt out at any time (please see ‘The right to ask us to stop contacting you with direct marketing’ below for further information).

We will always ask your permission before sending you email marketing information (unless your company has already received similar services or products from us as mentioned above). We do this by asking for your positive confirmation (e.g., by providing a tick or inserting your contact details in the relevant boxes) indicating that you wish to receive marketing and you can opt out at any time (please see ‘The right to ask us to stop contacting you with direct marketing’ below for further information). This ensures you only receive information that you have given us permission to send and are willing to receive.

From time to time, we may also use your information to contact you for research purposes and / or to ask about your experience using our products and services as part of a continual programme of customer service improvement. We may contact you by email, telephone, text, social media and / or mail. We may also use the information to customise the website according to your interests.

How long we will keep your personal information

We retain your information for a range of purposes which determine the period of time for which we need to keep such information. For example (list is not exclusive):

Data Retention Period For the purposes of marketing

Three (3) years from the point of last contact with you, this may include use of our website, product enquiry or purchase, or responses to communications with you

We will remove your data from our systems at the end of the applicable data retention periods, unless we are required by current or future law to retain your personal information for a longer period.

Our approach to information security

To protect your information, OEM Group Ltd. has policies and procedures in place to make sure that only authorised personnel can access the information, that information is handled and stored in a secure and sensible manner and all systems that can access the information have proportionate and reasonable security measures in place. To achieve this, employees, contractors, sub-contractors and third party suppliers have contracts, with defined roles and responsibilities.

While we take commercially reasonable measures to ensure the safety and security of your data, due to the inherent risks with the Internet, we are unable to warranty the absolute security of your data when using our services.

Transfers of your information out of the EEA

We may from time to time need to transfer your personal information to support partners which are located outside the European Economic Area, for the purpose of ensuring our websites are operating correctly or in relation to third parties to whom we share your data. Any transfer of your data will be subject to adequate levels of protection that will safeguard your privacy rights and give you remedies in the unlikely event of a security breach.

Your rights

In order to process any of the requests listed below, we may need to verify your identity for your security. In such cases your response will be necessary for you to exercise this right.

The right to access information we hold about you

At any point you can contact us to request details concerning the information we hold about you, why we have that information, and who has access to the information. In most cases you may be entitled to copies of the information we hold concerning you. Once we have received your request we will respond within 30 days.

The right to correct and update the information we hold about you

If the data we hold about you is out of date, incomplete or incorrect, please inform us and we will ensure that it is updated.

The right to have your information erased

If you feel that we should no longer be using your data or that we are illegally using your data, you can request that we erase the data we hold. When we receive your request, we will confirm whether the data has been deleted or tell you the reason why it cannot be deleted.

The right to object to processing of your data

You have the right to request that OEM Group Ltd stops processing your data. Upon receiving the request, we will contact you to tell you if we are able to comply or if we have legitimate grounds to continue. If data is no longer processed, we may continue to hold your data to comply with your other rights.

The right to ask us to stop contacting you with direct marketing

You have the right to request that we stop contacting you with direct marketing. On promotional emails we provide an ‘unsubscribe’ link at the bottom of the email which will unsubscribe you from that service. If you wish to opt out with respect to more than one email address, you must complete a separate request for each email address.

Please note it is not possible to ‘opt-out’ of receiving communication from us which relates to your products. This ensures that we can always contact you as a result of circumstances that may affect the safety or warranty of the product or service you have purchased from us, and in order for us to improve our products and services going forward.

Consent

In those cases where we need your consent to process your information, we will ask you to make a positive indication (e.g. to tick a box or insert your contact details on the relevant form or web page requiring consent). By actively providing us with your consent, you are stating that you have been informed as to the type of personal information that will be processed, the reasons for such processing, how it will be used, for how long it will be kept, who else will have access to it and what your rights are as a data subject and that you have read and understood this privacy policy.

Sharing your information

The information and data we collect is important for SecureSeal Systems and OEM Group Ltd., and we understand that you care about the use and storage of your personal information as much as we care about ours. We value your trust in allowing us to do maintain your information in our systems. We will never share this with anyone else unless we have your express consent, nor will we disclose, rent, trade or sell your personal information to any third parties for their marketing purposes.

In the event that OEM Group Ltd or any part of its business is sold to or integrated with another business, we may disclose your personal information to the new owners (and their professional advisers on the transaction) to be used by the new owners and their group of companies in the same ways as set out in this privacy policy, including to continue providing you with the same services and product information as are currently provided by OEM Group Ltd.

We may also provide aggregate statistics about our customers, sales, traffic patterns and related website information to reputable third parties in order to better understand our services, website and overall customer satisfaction which may include personally identifying information.

Use of cookies

The secureseal.com and any current or future OEM Group Ltd. websites and social media sites, make use of cookies and tags. A cookie is a small text file that can be stored by your browser on the device you use to access internet and allows the browser to pass small amounts of information about user behaviour on the given website to a web server. Tags are pieces of code that exist on web pages and collect information about usage of the web pages.

At OEM Group Ltd., we use our own cookies and tags as well as those from third party website statistical analysis companies to enable the smooth operation of the websites and to monitor visits to our website and continuously look for places to improve your website experience. We will never share any personal information about you with these third parties and the cookies and tags used maintain your anonymity.

Cookie Consent

The first time you accessed the SecureSeal.com website, you were informed about our use of cookies to improve your site experience. By continuing to browse our website you consent to our use of cookies.

Example of cookies and analytics

Google Analytics and StatCounter - These cookies may be used and may give us critical information about various pages on the websites and how our users interact with them. We use this information to improve the performance of our website and the information presented to users

How to reject and delete cookies

Should you wish to reject or block the use of cookies, you can do so at any time, usually by clicking ‘Help’ on your browser. Cookies are specific to individual browsers so if you use more than one browser, you will need to delete cookies on each browser. Please be aware though that by rejecting cookies you may not receive the optimum website experience.

Changes to this Privacy Policy

We may change this policy from time to time in accordance with legislation or other factors. You should check this policy occasionally to ensure that you are aware of the most recent version that will apply each time you access the website.

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