SALUS Controls PLC – Website Privacy Notice

SALUS Controls Plc is located in the United Kingdom (UK) and registered in England & Wales (company number: 05057362; registered address as SALUS House, Dodworth Business Park South, Whinby Road, Dodworth, Barnsley, S75 3SP).

Other affiliate companies in the EU that form SALUS include:

• SALUS Controls GmbH a company registered in Germany
• SALUS Controls Romania S.R.L a company registered in Romania
• SALUS Nordic A/S a company registered in Denmark

For the purposes of the European Union (“EU”) General Data Protection Regulation (“GDPR”), SALUS Controls Plc is the controller of all personal data processed through this Website and where you provide your personal data directly to SALUS Controls Plc for example during interaction with the sales or technical support team in the UK.

SALUS has appointed a Group Data Protection Officer (“DPO”) for you to contact if you have any questions or concerns about our personal data policies or practices. The DPO can be contacted via email at: [email protected], or by post at:

Data Protection Officer
SALUS Controls Plc
PO Box 962
Haywards Heath
RH16 9PX
United Kingdom

QL Controls Sp. Z o.o. Sp.K. (“Agent”) is a company registered in Poland and is an exclusive and sole agent appointed to sell SALUS Devices in select markets. Where you provide your details directly to our Agent then the Agent will be the Data Controller, and you will need to refer to their Privacy Notice to find out how they process your personal data and for the appropriate contact details of their data protection representative.

SALUS collects personal data from individuals when they browse or use this website, attend our sales and marketing events, and during the normal course of doing business.

SALUS will collect and process your information when we have one or more of these reasons:

• To fulfil a contract we have with you (Contract)
• When it is our legal duty (Legal)
• When it is in our legitimate interest (Legitimate Interest)
• When you consent to it (Consent)

The table below describes the personal data SALUS collects, how we will use such personal data, and the reasons or purposes we rely on to do so.

Type of Personal Data or Record	Details of Purpose and Use
Business Contact Information Business or company information of an individual, including: First and Last Name Email Address Telephone Number Company Name and Job Title Business or Home Address Area / Town / Country Bank Account Details For example, we collect this information when you: set up an account; complete a credit application form; place an order; attend our live events and fill in a form or we scan your name tag; subscribe to our newsletters or promotional news; and register for an Installer Club account. We also receive your business contact information when it is shared with us by your company (if you represent your company), obtained through public sources (e.g. Company website), or when we have purchased it from corporate email marketing companies.	Basis of Processing: CONTRACT / LEGITIMATE INTEREST We are performing a contract with you when you acquire products or services from us. This only applies when you personally are a customer. We also have a legitimate interest to use this type of information in the normal course of doing business, and includes: set up a business account; carry out credit checks; engage, supply and service our business customers; send out invoices and goods; sales and marketing; engage business prospects; and send you communications containing promotional information on Installer Club member benefits, our product range, new features, offers, events, and services. Refer to “Your Communications Choices” below for details on how to update your choices.
Technical Support Information Personal data you submit in a message through our website, contact us via phone to request technical support, or ask a question through ‘Live Chat’ or social media: First and Last Name Email Address Telephone Number Device details and Device ID Social Media Handle (name) We also keep a record of any comments, feedback, opinions, questions or complaints you raise.	Basis of Processing: CONTRACT / LEGITIMATE INTEREST We are performing a contract with you when we provide you with technical support.   This only applies when you personally are a customer. We also have a legitimate interest to use this type of data to: identify and communicate with you to provide technical support, and assist you with the installation and configuration of our products; administer or manage our products remotely; update and validate account or registration details; log, diagnose and resolve issues or faults; deal with complaints and claims, and process refunds or a product replacement; organise an onsite engineer visit; provide advice, guidance, or fixes for you to implement; send you specifications, manuals or installation guides; request feedback through a survey for research purposes (although you do not need to respond to them); support our audits and help meet our service standards, improve our service to you, or for training purposes; and investigate any suspected breach of our terms.
Warranty Information Personal data you submit online, through a form in the post, or provide over the phone to register a product for our warranty services: First and Last Name Address Email Address Telephone Number Installation Date and Supplier Device details and / or Device ID	Basis for Processing: CONTRACT / LEGITIMATE INTEREST We are performing a contract with you when we provide you with warranty services.   This only applies when you personally are a customer. We also have a legitimate interest to use this type of data to: register and maintain the warranty offered on SALUS branded products you have purchased or installed; communicate to you in relation to your warranty; and log and resolve issues or faults, deal with complaints and claims, and process refunds or a product replacement.
Survey Information Records of any non-anonymous surveys you provide feedback. First and Last Name Email Address Telephone Number Personal opinions, views, comments and feedback	Basis for Processing: LEGITIMATE INTEREST We have a legitimate interest this type of information for assessment and analysis of our market, customers, products, and services. We may use details you provide in our surveys to contact you and follow up on any comments or queries you raise.
Competition Registration Records from any competition we may run. First and Last Name Email Address Address Telephone Number	Basis for Processing: CONTRACT / LEGITIMATE INTEREST We are performing a contract with you when you participate in a competition. We also have a legitimate interest to use this type of data to: execute and fulfil the requirements of any competitions such as selecting and contacting winners; contact customers to follow up on feedback or queries raised in relation to our competitions; and send you communications containing promotional information on Installer Club member benefits, our product range, new features, offers, events, and services.
Gift Voucher or Card Offers – Claims For promotions where we offer a gift voucher or gift card on purchase of specified products: Name Email Address Telephone Number Address	Basis for Processing:  LEGITIMATE INTEREST We have a legitimate interest to use this type of data to process claims in relation to the relevant gift voucher or card promotional offer. For example we have a requirement to: Identify the purchaser of our products; Verify the purchase of our products related to a promotional offer; Send out gift voucher(s) or gift card(s); and contact you to resolve any queries, issues and provide confirmation of gift voucher/card dispatch.
WEBSITE – Automatically Collected Information When you visit our website, we will collect certain information automatically from your device: IP address, device type, unique device identification numbers, browser-type, and other technical information. information about how your device has interacted with our Website, including the pages accessed and links clicked. The IP address may provide an approximate location, but this will be no more precise than the city, state or country.	Basis for Processing: LEGITIMATE INTEREST We have a legitimate interest to use this type of information to: tailor our website to our visitors (e.g. on the basis of their geographic location); operate our website including load balancing; better understand the visitors who come to our website, where they come from, and what content is of interest to them; and enable operation of our website by enabling basic functions, for example, page navigation, access to secure areas of the website, and ability to use live chat Basis for Processing: CONSENT We will obtain your consent to process information through cookies categorised as Preference (Functionality) or Marketing that are not necessary for operating and browsing our websites, or do not capture information anonymously. Refer to section “Cookies” below for details how to change cookies settings.
E-MAIL Communications – Automatically Collected Information When we send marketing emails to you, we will also collect information automatically, as follows: Information about how an individual has interacted with emails we have sent and the time and date of such actions. Device type and IP Address when an email is opened or link in an email is clicked The IP address may provide an approximate location, but this will be no more precise than the city, state or country.	Basis for Processing: LEGITIMATE INTEREST We have a legitimate interest to use this type of information to: help us understand how individuals have interacted with an email; confirm if email communications have been read; identify invalid email addresses; improve email distribution and filtering, and help improve our email service; confirm if options or links within an email are selected; help us understand the success of an email campaign; improve design and tailoring of content for future email campaigns; and help us tailor content for subscribers in specific regions and timezones. Refer to section “Other Tracking Technology” below for further details and how to change your preferences in our marketing email communications.
Returns Information Personal data you submit through our website or contact us via phone to request a product return, such as: First and Last Name Email Address Telephone Number Address Postcode	Basis for Processing: LEGITIMATE INTEREST We have a legitimate interest to use this type of data to: Contact you in relation to the return request; Process the product return and replacement including collection and delivery; Internal administration of returns requests.

SALUS Controls Cookie Notice. We use cookies to deliver the best possible web experience. By clicking OK and continuing to browse this site, you agree that we may store and access cookies on your device. You can review and change your cookies preference below.

Cookies are small text files which are stored in the memory of your computer or other device such as mobile phones or tablet devices. Cookies are created when you visit a website using cookies. We categorise cookies as: Strictly Necessary, Preference (Functionality), Statistic (Analytical), and Marketing. Please see the cookies declaration for further details on each of these types of cookies where they are used.

You can update your cookies preferences directly using the pop up tool and selecting / deselecting the relevant check boxes, or by clicking the “Change Your Consent” link in the “Cookies” section of the Privacy Notice.
It is also possible to reject cookies manually through your computer, tablet or mobile device browser settings. Please note, however, that certain features of our website will not be available if cookies are disabled or deleted. As the means by which you can reject cookies through your browser controls vary from browser-to-browser, you should visit your browser’s help menu for more information. In addition, most advertising networks offer you a way to opt out of targeted advertising. If you would like to find out more information, please visit www.youronlinechoices.eu.

Other Tracking Technology
We use web beacons (also known as page tags) in emails we send. Web beacons are the industry standard for open tracking and is a tool to give a general overview of email subscriber engagement. This means when you receive and engage with the email messages we send you, these web beacons will track certain behaviour such as whether the email sent to you was delivered and opened. The web beacon works through a tiny invisible graphic embedded at the bottom of an email. When an email is opened with images turned on, the graphic is downloaded from our email service provider’s server and recorded as an open.
Links within our marketing emails are also tracked to show individual recipient’s clicks. If you click a link, the tracking information redirects through our email service providers’ server to the intended web address, and logged as a click.
Open tracking does not work in Plain-Text email communications or if you have chosen not to display images in an email. You can disable or activate email tracking by selecting the ‘Preference’ link within email marketing communications we may send you.

Our site may, from time to time, contain links to and from the websites of our partner networks, advertisers, affiliates, and other companies such as social media sites. If you follow a link to any of these websites, please note that these websites have their own privacy notices or policies and we do not accept any responsibility or liability for the privacy notices or policies they publish. Please check the relevant privacy notices or policies before you submit any personal data to these websites.

SALUS will only share personal data with others when we are legally permitted to do so.

SALUS is part of a global company with subsidiaries and affiliates across Asia, North America and Europe supporting our business activities including the provision of technical support to users. We also use third party data processors to process personal data on our behalf who help provide and support our products and services. Some third party data processors are based in a different country or are part of an international organisation.

As a result, personal data will be transferred, stored and accessed outside the countries where we and our data processors are located.  This includes countries outside the European Union (“EU”). The laws in some countries may not provide as much legal protection for your personal data as in the EU.

SALUS takes steps to ensure all personal data is provided with adequate protection and that transfers of personal data outside the EU are done lawfully.  Where we transfer personal data outside of the EU to a country not determined by the European Commission as providing an adequate level of protection for personal data, the transfers will be under an appropriate framework that protects the fundamental rights of anyone in the EU for transatlantic data transfers, such as the EU-US Privacy Shield or European Commission approved standard contractual clauses. If you would like more information on our transfer mechanisms please contact us via the details in section “Data Controller and Data Protection Officer”

Personal data held by us may be transferred to the following categories of recipient:

• Affiliates and subsidiaries in the same group of companies as us: for administration and operational purposes (such as Computime Limited, SALUS Controls GmbH, SALUS Nordic A/S, SALUS Controls Romania S.R.L, SALUS North America, Inc) to fulfil our contract or deploy our products and services;
• Our Agent: to provide technical support in countries they offer and sell our SALUS products and services. We may share or give access to our Agent and they shall process your personal data on our behalf.
• Third party IoT cloud providers: to provide Internet of Things (“IoT”) and Internet connection services; provide cloud-based solutions including infrastructure, servers and software; perform diagnostics and support stable operating of our apps and connected devices; provide security, back up and system availability services; and support problem management to resolve issues.
• Installers and service engineers: to book appointments with you and provide installation, device maintenance services, and any other onsite support;
• Courier and Delivery companies: for dispatch of orders, schedule and arrange pick up or delivery of warranty related returns and replacements.
• Other service providers: such as companies that support our IT and provide cloud hosting services, help develop and test our Apps, process and collect payments or debts, send communications to our customers, provide market research or marketing services, provide us with legal advice, performance of audits and generally help us deliver our services to you or support our business;
• Parties involved in corporate transactions: as part of an actual or proposed purchase, merger or transfer, or in the event of a bankruptcy; and
• Other parties: to any competent law enforcement body, regulatory, government agency, court or other third party where we believe disclosure is necessary (i) to comply with the law or to assist government or regulators; (ii) to verify or enforce compliance with policies governing our services; (iii) to exercise, establish or defend our legal rights, (iv) to protect your vital interests or those of any other person; or (v) to any other person with your consent to the disclosure.

SALUS is committed to keeping personal data secure. We endeavour to apply suitable safeguards including technical, administrative and physical measures designed to protect the privacy and security of your personal data.

SALUS also minimizes the risk to your rights and freedoms by limiting access to personal data to only those who have a business need. We require our service providers to safeguard personal data and only use your personal data for the purposes we specify.

Unfortunately, the transmission of information via the Internet is not completely secure. Although we will do our best to protect your personal data once it is received, we cannot guarantee the security of your information transmitted over the Intern

SALUS will keep your personal data for as long as is necessary for the purposes we have described. These periods vary depending on the nature of the information and your interactions with us, as required for legitimate business reasons and where permitted or required by law, regulations, litigation, accounting or reporting obligations. When your personal data is no longer necessary, we will take reasonable steps to securely destroy your information or permanently de-identify it.

The GDPR and other countries’ privacy laws provide certain rights over your personal data. If you have any questions about how we process your personal data or wish to exercise any of your rights, please contact us via the details in section “Data Controller and Data Protection Officer”.

In certain instances, and subject to certain conditions, you have the right to:

• access, update, and/or erase your personal data
• restrict and/or object to the use of your personal data
• object to marketing (see below under “Your Communications Choices”)
• withdraw consent for our use of your personal data at any time .
• request erasure of your personal data, for example where the processing does not comply with applicable data protection laws;
• when technically feasible, request personal data to be provided or transmitted directly to another controller (right to portability); and
• request a copy of the personal data we hold about you.

SALUS gives you control as to whether you receive marketing and promotional communications. We will only do so when permitted by law. If we are permitted to do so (e.g. because you are one of our customers, because you represent a company, or because you have opted-in) but you wish to stop receiving such communications, you can opt-out by updating your preference at any time by the following methods:

• Click the relevant “Unsubscribe” or “Preference” link presented in any promotional email communication we send; and
• Contacting us via the details in section “Data Controller and Data Protection Officer” and requesting removal from our mailing list.

Note – Opting out of promotional emails will not end transmission of important service-related emails that are necessary to the on-going use of our services.

SALUS hopes that you won’t ever need to, but if you do want to complain about our use of personal data, please contact our Data Protection Officer using the contact details in section “Data Controller and Data Protection Officer”.

If you do not feel we have been able to resolve your complaint satisfactorily you can lodge a complaint with the relevant data protection regulator, which for SALUS Controls Plc in the UK is the Information Commissioner’s Office (“ICO”).  For further information on how to complain to the ICO, please refer to the ICO website . Contact details of other EU data protection regulators are available here.

This Privacy Notice was last updated on: [24/04/ 2019]

We recognise that transparency is a continual responsibility, so we will keep this Privacy Notice under regular review and updated. Any changes to this notice will be posted on this page, so please check back frequently.