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Welcome to Optima’s Privacy Notice.
We currently hold your Identity Data and Contact Data on a Lawful basis for processing, including on the basis of legitimate interest (see the table below for the purposes of managing our relationship with you as a representative of your business organisation on a “business to business” contact basis.

Optima respects your privacy and is committed to protecting your personal data. This privacy notice will inform you how we look after your personal data when you visit our website (regardless of where you visit it from) and tell you about your privacy rights and how the law protects you.

Please also use the Glossary to understand the meaning of some of the terms used in this privacy notice.

1. Important information and who we are
Purpose of this privacy notice
Optima is made up of several different legal entities details of which can be found below. This privacy notice is issued on behalf of these companies and us so when we mention “Optima”, “we”, “us” or “our” in this privacy notice, we are referring to the relevant company in the Optima Group. 
This privacy notice aims to give you information on how Optima collects and processes your personal data, including any data you may provide.
It is important that you read this privacy notice together with any other privacy notice or fair processing notice we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data.

Controller
Optima Contracting Limited (trading as “Optima”) based in the UK is the controller and is responsible for processing your data.
Joint Controllers
Any data which is collected by an Optima Group entity will be shared with Optima Contracting Limited in the UK. This is because Optima Contracting Limited provides support services to the Optima Group entity.
If you have any questions about this privacy notice, including any requests to exercise your legal rights, please contact the data privacy manager using the details set out in the Contact Details below.

Contact details
Full name of legal entity: Optima Contracting Limited
Email address: action@optima-group.co.uk
Postal address: Courtyard House, West End Road, High Wycombe, Bucks. HP11 2QB
Telephone number: 01494 492600

You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance (see our Contact Details above).
If you have registered with an Optima Group entity outside of the UK, you may also have a right to complain to the relevant data protection authorities in the jurisdiction of that entity. Again, we would appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance (see our Contact Details above).

Changes to the privacy notice and your duty to inform us of changes
It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.

2. The data we collect about you
Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).
We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:

Identity Data:
We may collect the following information from you:
• Title (Mr./Mrs. etc.)
• First Name,
• Last Name,
• Your job role in your organisation, – in order to provide you access to the relevant level of technical and proprietary information, which is centralised, held and operated by Optima Contracting Limited in the UK.

Contact Data includes the following, through which you will enable us from time to time to contact the business organisation which you represent in order to register your organisation for future marketing and dealings with us.
• Name of the business organisation,
• Address of your business organisation,
• Your business email address (not your personal address), as you are registering as a representative of your business organisation.
• Your business telephone number/s (not your personal numbers): as you are registering as a representative of your business.

Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences on behalf of your business organisation.  This includes your event preference data so that we can invite you to suitable or tailored events.

3. How is your personal data collected?
We use different methods to collect data from and about you including through:
• Direct interactions. You may give us your Identity and Contact Data by way of business card, or filling in forms or by corresponding with us (including one or more of our representatives) by post, phone, email or otherwise.

4. How we use your personal data
We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:
• To periodically contact you as a representative of your business organisation regarding marketing our services and goods
Where the jurisdiction of your business organisation is outside the United Kingdom or the European Economic Area, your Identity Data and Contact Data will be shared with an entity in the Optima Group which is geographically as near as possible to the jurisdiction of your business organisation to contact you. That Optima Group entity will then be a joint controller for your personal data.
• Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
• Where we need to comply with a legal or regulatory obligation.
See below to find out more about the types of lawful basis that we will rely on to process your personal data.
Generally, we do not rely on consent as a legal basis for processing your personal data other than in relation to sending third-party direct marketing communications to you via phone or email or text message as a representative of your business organisation. You have the right to withdraw consent to marketing at any time by contacting us.

Purposes for which we will use your personal data
We have set out below, in a table format, a description of all the ways we plan to use your personal data, and which of the legal basis we rely on to do so. We have also identified what our legitimate interests are where appropriate.
Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below.

Purpose/Activity Type of data Lawful basis for processing including the basis of legitimate interest
To manage our relationship with you which will include:
(a) Notifying you about changes to our terms or privacy policy
(b) Asking you to leave a review or take a survey
(a) Identity
(b) Contact
(a) Necessary to comply with a legal obligation
((b) Necessary for our legitimate interests (to keep our records updated and to study how customers use our products/services)
To deliver relevant and advertisements to you and measure or understand the effectiveness of the advertising we serve to you

(a) Identity
(b) Contact

Necessary for our legitimate interests (to study how customers use our products/services, to develop them, to grow our business and to inform our marketing strategy)
To make suggestions and recommendations to you about goods or services that may be of interest to you (a) Identity
(b) Contact
Necessary for our legitimate interests (to develop our products/services and grow our business)

 

Marketing and Promotional offers from us
We may use your Identity and Contact Data, to form a view on what we think you may want or need, or what may be of interest to your business organisation. This is how we decide which products, services, and offers may be relevant for you (we call this marketing).
You will receive marketing communications from us if, on behalf of your business organisation:
• you have registered and created an account through our website, but subject to our website policies; or
• you have requested information from us; or
• you have been a contact in respect of goods or services purchased from us by your business organisation.
and, in each case, you have not opted-out of receiving that marketing.
Third-party marketing
We will get your express opt-in consent before we share your personal data with any company outside of the Optima Group for marketing purposes.

Opting-out
You can ask us or third parties to stop sending you marketing messages at any time by contacting us.
Where you opt-out of receiving these marketing messages, this will not apply to personal data provided to us as a result of a product/service purchase, warranty registration, product/service experience or other transactions.

Change of purpose
We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.
If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.
Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

5. Disclosures of your personal data
We may have to share your personal data with other entities of the Optima Group for the purposes set out in the table in paragraph 4 above, namely where the jurisdiction of your business organisation is outside the United Kingdom or the European Economic Area, your Identity Data and Contact Data will be shared with a company which is an entity within the Optima Group (as joint controller and which is geographically as near as possible to the jurisdiction of your business organisation to contact you.
We require all entities in the Optima Group and all third parties to respect the security of your personal data and to treat it in accordance with the law.
We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.

6. International transfers
Apart from sharing your personal information with other entities in the Optima Group for the lawful purposes and legitimate interests (as set out in the table to paragraph 4 above), we do not transfer your personal data outside the European Economic Area (EEA), without your prior express written consent given by email, fax or by post.

7. Data security
We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.
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.

8. Data retention
How long will you use my personal data for?
We will only retain your personal data for as long as necessary to fulfill 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, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.
By law, we have to keep basic information about our customers (including Contact, Data, and Identity Data) for as long as you do not opt-out.
In some circumstances you can ask us to delete your data: see Request erasure below for further information.
In some circumstances, we may anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes in which case we may use this information indefinitely without further notice to you.

9. Your legal rights
Under certain circumstances, you have rights under data protection laws in relation to your personal data. Please click on the links below to find out more about these rights:
• Request access to your personal data.
• Request correction of your personal data.
• Request erasure of your personal data.
• Object to processing of your personal data.
• Request restriction of processing your personal data.
• Request transfer of your personal data.
• Right to withdraw consent.
If you wish to exercise any of the rights set out above, please contact us.

No fee usually required
You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.

What we may need from you
We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

Time limit to respond
We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.

10. Which country’s laws apply to any disputes?
If you are a consumer, please note that this policy, its subject matter, and information, are governed by English law and (where applicable) all applicable personal data protection laws of your jurisdiction. In the event of a conflict of personal data protection laws, the choice of personal data protection law shall be decided by the Optima Contracting Limited in its absolute discretion. You and we both agree that the courts of England and Wales will have exclusive jurisdiction except that if you are a resident of Northern Ireland you may also bring proceedings in Northern Ireland, and if you are resident of Scotland, you may also bring proceedings in Scotland.
If you are a business, this privacy policy, its subject matter, and formation (and any non-contractual disputes or claims) are governed by English law and (where applicable) all applicable personal data protection laws of your jurisdiction. In the event of a conflict of personal data protection laws, the choice of personal data protection law shall be decided by Contracting Limited in its absolute discretion. We both agree that Optima shall have a choice of exclusive jurisdiction of courts shall be decided by the relevant Contracting Limited in its absolute discretion.

11. Glossary
LAWFUL BASIS
Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give you the best service/product and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us

Performance of Contract means processing your data where it is necessary for the performance of a contract to which your business organisation is a party and in which you have been involved with us or to take steps at your request (on behalf of your business organisation) before entering into such a contract.
Comply with a legal or regulatory obligation means processing your personal data where it is necessary for compliance with a legal or regulatory obligation that we are subject to.

THIRD PARTIES
• Internal Third Parties
Optima Group: means companies being members in the same group of companies, primarily Optima Contracting Limited (trading as Optima) and the entity of the Optima Group with which you have registered, acting as joint controllers or processors Details of all entities in the Optima Group are as follows:

OPTIMA GROUP

Optima Contracting Ltd, OAG Ltd, Optima Products Ltd, Optima Products Asia Sdn Bhd, Optima Systems International DMCC, Optima Partitions LLC, HLS Installations Ltd.

• External Third Parties
Service providers acting as processors based [in the UK] who provide IT and system administration services.

YOUR LEGAL RIGHTS
You have the right to:
Request access to your personal data (commonly known as a “data subject access request”). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.

Object to the processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.

Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios: (a) if you want us to establish the data’s accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.

Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain information about our technical and proprietary information relating to our products or services.

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Our emails have changed so please stay in touch @OptimaSystems.com