Privacy and Cookies Policy
1 What is the purpose of this policy?
2 Data protection principles
3 The kind of information we hold about you.
4 How is your Personal Data collected?
5 How we may use your Personal Data?
6 Website Privacy and Cookies Policy
7 Disclosures of your Personal Data
8 International data transfers
9 Data Retention
10 Data Security
11 Your data protection rights
12 How to complain
Effective Date: 31/5/2020
Last Reviewed: 31/5/2020
What is the purpose of this policy?
JohnsonBriggs Ltd is committed to protecting the privacy and security of your personal information. This policy describes how we collect and use personal information about you during and after your relationship with us. JohnsonBriggs Ltd is a “data controller” under data protection law. This means that we are responsible for deciding how we hold and use personal information. This notice does not form part of any contract to provide services. We may update this policy at any time.
Data protection principles
We will comply with data protection law. This says that the personal information we hold about you must be:
- Used lawfully, fairly and in a transparent way.
- Collected only for valid purposes that we have clearly explained to you and not used in any way that is incompatible with those purposes.
- Relevant to the purposes we have told you about and limited only to those purposes.
- Accurate and kept up to date.
- Kept only as long as necessary for the purposes we have told you about.
- Kept securely.
The kind of information we hold about you.
Personal data, or personal information, means any information about an individual from which that person can be identified. We may collect, store, use and transfer different kinds of personal information about you which we have grouped together as follows:
- Identity Data
that may include first name, last name, username or similar identifier, marital status, and title.
- Contact Data
that may include telephone numbers and email addresses.
- Marketing and Communications Data
that includes your preferences in receiving marketing from us.
- Technical Data
that includes your internet protocol (IP) address in anonymised form when accessing our website (used only to determine the location of access).
We do not collect any Special Categories of Personal Data
about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data). Nor do we collect any information about criminal convictions and offences.
How is your Personal Data collected?
We may use different methods to collect data from and about you including through:
Direct interactions.
You may give us your Identity and Contact Data by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data:
- You provide when requesting marketing to be sent to you;
- You provide when you contact us for our services;
- We obtain in the context of the use of our services;
- We collect in the context of our business relationship with customers;
- You contact us to provide services to us;
- You apply for a job with us.
Automated technologies or interactions.
As you interact with our website, we may automatically collect Technical Data using cookies, server logs and similar technologies.
Third parties or publicly available sources. We may receive personal data about you from various third parties as set out below:
- Identity and Contact Data from publicly available sources;
- Identity and Contact Data from data brokers or aggregators.
How we may use your Personal Data?
We will only use your personal information where:
- We need to perform the contract we are about to enter into or have entered into with you.
- It is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override these interests.
- We need to comply with a legal or regulatory obligation.
We use your Identity and Contact Data
primarily to enable us to establish and maintain a business relationship with you and your organisation and in the provision and development of our services.
This includes to:
- Operate, improve, and develop our services;
- Evaluate and register you as a new or prospective customer or service provider;
- Manage our relationship with you;
- Process and deliver services to your order;
- Enforce our Terms and Conditions or other legal rights where necessary;
- Perform accounting, bookkeeping auditing, billing, reconciliation activities, as well as claims management;
- Make suggestions and recommendations to you about goods or services that may be of interest;
- Anonymise Personal Data;
- Evaluate your interest in employment and contact you regarding possible employment;
- Deal with any complaints made by you.
We use your Technical Data
out of necessity:
- To ensure the security and proper functionality of our website for visitors;
- To use analytics to improve our website.
We have set out below, in table format, a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.
- We will not, without your express consent, supply your personal data to any third party for the purposes of their or any other third party’s direct marketing.
- You may instruct us at anytime not to process your personal data for marketing purposes.
Website Privacy and Cookies Policy
We are committed to safeguarding the privacy of website visitors. By using our website, you consent to our use of cookies in accordance with the terms of this policy. If you do not consent to cookies being used, you can set your browser to refuse all or some browser cookies, or alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of our website may become inaccessible or not function properly.
Details of the cookies we use and why we use them are outlined below.
Cookies are necessary and are used to ensure the security and proper functioning of our website for visitors and used in analytics to improve our website. These cookies are deleted after each browser session.
The following data is collected from website visitors and is immediately anonymised during collection:
- Referrer (i.e. previously visited website)
- Requested website or file
- Browser type and browser version
- Operating system used
- Device type used
- Time of access
- IP Address in anonymised form (used only to determine the location of access).
The data is collected out of necessity to ensure the security and proper functionality of our website for visitors.
The data detailed above is additionally determined and collected either by a pixel or log file and tracked, logged, and processed by IONOS Site Analytics, exclusively for statistical evaluation and technical optimisation of our website. The data is stored for 21 days and is not shared with other third parties.
Disclosures of your Personal Data
We may disclose your personal data to any of our employees, officers, insurers, professional advisors or external auditors, agents, suppliers (including but not limited to cloud services, archiving), or sub-contractors in so far as it is reasonably necessary for the purposes set out in this Privacy Policy.
We require our service providers by contract to only process personal data in accordance with our instructions and as necessary to perform services on our behalf of comply with legal requirements. We also require our service providers to safeguard the security and confidentiality of the personal data they process on our behalf by implementing appropriate technical and organisational security and confidentiality obligations binding employees accessing personal data.
We may disclose your personal data:
- To the extent that we are required to do so by law;
- In connection with any ongoing or prospective legal proceedings
- In order to establish, exercise or defend our legal rights;
- To third parties in the event (or contemplated event) of a sale or transfer of our business or assets.
Except as provided in this policy, we will not provide your personal data to third parties without your consent.
International data transfers
- Information that we collect may be stored and processed in and transferred between any of the countries in which we operate in order to enable us to use the information in accordance with this policy.
- Information that we collect may be transferred to countries including the United States of America which do no have data protection laws equivalent to those in force in the European Economic Area.
- You expressly agree to the transfers of personal data described in this Section 8.
Data Retention
We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting or reporting requirements.
To determine the appropriate retention period for personal data, we consider the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data.
By law we have to keep basic information about our customers (including Identity, contact, and transaction details) for six years after ceasing to be customers for tax and accounting purposes.
Data Security
- We will take reasonable technical and organisational precautions to prevent the loss, misuse or alteration of your personal data.
- In addition, we limit your access to your personal data to those employees, agents, contractors and other third parties who have a business need to know.
- 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.
- You acknowledge that transmission of information over the internet is inherently insecure and we cannot guarantee the security of data sent over the internet.
Your data protection rights
Under the data protection law, you have rights including:
- Your right of access. You have the right to ask us for copies of your personal information.
- Your right to rectification. You have the right to ask us to rectify information that you think is inaccurate. You also have the right to ask us to complete information that you think is incomplete.
- Your right to erasure. You have the right to ask us to erase your personal information in certain circumstances.
- Your right to restriction of processing. You have the right to ask us to restrict the processing of your personal data in certain circumstances.
- Your right to object to processing. You have the right to object to the processing of your personal data in certain circumstances.
- Your right to data portability. You have the right to ask that we transfer the information that you gave us to another organisation, or to you, in certain circumstances.
You are not required to pay any charge for exercising your rights. If you make a request, we have one month to respond to you.
If you wish to make a request or have a query over the treatment of personal data, please write (in the first instance) to us by email to:
or by post to:
Neil Johnson
JohnsonBriggs Ltd
29 Hare Hill Close
Pyrford
Surrey
GU22 8UH
How to complain
You can also complain to the Information Commissioner’s Office if you are unhappy with how we have used your data.
The ICO’s address is:
Information Commissioner’s Office
Wycliffe House
Water Lane
Wilmslow
Cheshire
SK9 5AF
Helpline number:
0303 123 1113
Further information is also available from the ICO: