Website Privacy and Cookies Policy

Introduction

Welcome to Zentia Limited’s privacy policy.

We respect your privacy and strive to protect your personal data. This privacy policy will inform you about how we look after your personal data when you visit our website (regardless of where you visit it from) or come into contact with us and tell you about your privacy rights and how the law protects you.

This privacy policy is provided in a layered format so you can click through to the specific areas set out below. Please also use the Glossary at the end of this privacy policy to understand the meaning of some of the terms used in it.

1. IMPORTANT INFORMATION AND WHO WE ARE
2. THE DATA WE COLLECT ABOUT YOU
3. HOW IS YOUR PERSONAL DATA COLLECTED?
4. HOW WE USE YOUR PERSONAL DATA
5. DISCLOSURES OF YOUR PERSONAL DATA
6. INTERNATIONAL TRANSFERS
7. DATA SECURITY
8. DATA RETENTION
9. YOUR LEGAL RIGHTS
10. GLOSSARY

APPENDIX 1: DATA CONTROLLERS AND CONTACT DETAILS

APPENDIX 2: COOKIE POLICY

APPENDIX 3: YOUR LEGAL RIGHTS

1. Important information and who we are

Purpose of this privacy policy

This privacy policy aims to give you information on how we collect and process your personal data through your use of this website and other interactions with us.

It is important that you read this privacy policy together with any other privacy policy 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. This privacy policy supplements other notices and privacy policies and is not intended to override them.

Controller

Zentia Limited is part of a group made up of different legal entities, details of which can be found in Appendix 1. This privacy policy is issued on behalf of the Zentia Group so when we mention “Zentia Group”, “we”, “us” or “our” in this privacy policy, we are referring to the relevant company in the Zentia Group responsible for processing your data. Appendix 1 sets out the controller/joint controllers/Internal Third Party processors responsible for this website.

Contact details

If you have any questions about this privacy policy or our privacy practices, please contact us in any of the following ways:

Full name of legal entity: Zentia Limited

Email address: marketing@zentia.com

Postal address: Kingsway South, Team Valley Trading Estate, Gateshead, Tyne & Wear NE11 0SP, UK

Telephone number: +44 (0)191 497 1000

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). However, we would appreciate the chance to deal with your concerns before you approach the ICO, so please contact us in the first instance.

Changes to the privacy policy and informing us of your changes

We keep our privacy policy under regular review – you can see the date it was last updated at the top of this policy.

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 by using the above email address.

Third-party links

This website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy policy of every website you visit.

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 doesn’t 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 includes title, first name, last name, job title and email address.
• Contact Data includes business name, business address and telephone numbers.
• Technical Data includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, and other technology on the devices you use to access this website.
• Profile Data includes your username and password for your website customer account, purchases or orders made by you, your preferences, feedback and survey responses.
• Usage Data includes information about how you use our website and products.
• Marketing and Communications Data includes your preferences in receiving marketing from us and your communication preferences.

We also collect, use and share aggregated data such as statistical or demographic data for any purpose. Aggregated data could be derived from your personal data but is not considered personal data in law as this data will not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect aggregated data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy policy.

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 filling in forms or by corresponding with us by post, phone, email, face to face, online or otherwise. This includes personal data you provide when you:
• purchase our products or request samples or product specifications;
• create a website customer account on our website;
• complete a Contact Form;
• subscribe to our publications;
• request marketing to be sent to you;
• enter a competition, promotion or survey;
• attend an event or meeting with us either in-person or virtually;
• give us feedback; or
• communicate with us in any other way, including on social media.
• Automated technologies or interactions. As you interact with our website, we will automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies, server logs and other similar technologies. We may also receive Technical Data about you if you visit other websites employing our cookies. Please see our cookie information below for further details.
• Third parties or publicly available sources. We will receive personal data about you from various third parties and public sources as set out below:

Technical Data from the following parties:

• analytics providers such as Google based outside the EU;
• advertising networks such as Google based outside the EU;
• search information providers such as Google based outside the EU; and
• online directories such as RIBA Product Selector based inside the EU.
• Identity and Contact Data from publicly available sources such as Companies House and the Electoral Register (or their equivalents) based inside and outside the EU.

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:

• Where we need to perform the contract we are about to enter into or have entered into with you;
• 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 obligation;

Generally, we do not rely on consent as a legal basis for processing your personal data although where appropriate we will get your consent before sending direct marketing communications to you via email.

Marketing opt-out

You have the right to withdraw consent to marketing at any time via the unsubscribe link in all marketing email footers. You may also email us at webmaster@armstrongceilingsolutions.co.uk and request we opt you out of future email marketing.

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 lawful bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.

Purpose/Activity	Type of data	Lawful basis for processing including basis of legitimate interest
To register you with a website customer account. The data submitted may also be used to autofill other forms you may submit	(a) Identity (mandatory) (b) Contact (voluntary) (c) Profile (d) Marketing and Communications	Necessary for our legitimate interests as without the mandatory data requested, we would not be able to create a secure password protected account
To send you targeted marketing communications by email including for example, information in relation to new product lines, product updates, details of current and future projects, quality and technical issues and a newsletter	(a) Identity (b) Contact (optional) (c) Marketing and Communications	(a) Soft opt-in under the Privacy and Electronic Communications Regulations 2003 (PECR) (b) Corporate subscriber under PECR
To respond to your queries and requests relating to our products including technical matters, including requests received through our Contact Forms and our email addresses	(a) Identity (b) Contact (c)Marketing and Communications	Necessary for our legitimate interests in order to provide a response to your request (including providing follow up information as necessary) and to retain an accurate and up to date record of customer information and requirements for relationship management purposes
To process and deliver online orders for samples and requests for technical specifications	(a) Identity (b) Contact (c)Marketing and Communications	(a) Performance of a contract with you (b) Consent
To manage our relationship with you which will include: (a) Notifying you about changes to our terms or privacy policy (b) Maintaining our customer database (c) Issuing special price approvals	(a) Identity (b) Contact (c) Profile (d) Usage (e)Marketing and Communications	(a) Performance of a contract with you (b) Necessary to comply with a legal obligation (c) Necessary for our legitimate interests (to keep our records updated and to study how customers use our products
To enable you to take part in a prize draw, competition or complete a survey	(a) Identity (b) Contact (c) Profile (d) Usage (e)Marketing and Communications	(a) Performance of a contract with you (b) Necessary for our legitimate interests (to study how customers use our products, to develop them and grow our business)
To administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)	(a) Identity (b) Contact (c) Technical	(a) Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise) (b) Necessary to comply with a legal obligation
To deliver relevant online content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you	(a) Identity (b) Contact (c) Profile (d) Usage (e)Marketing and Communications (f) Technical	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 use data analytics to improve our website, products/services, marketing, customer relationships and experiences	(a) Technical (b) Usage	Necessary for our legitimate interests (to define types of customers for our products and services, to keep our website and social media content updated and relevant, to develop our business and to inform our marketing strategy)
To make suggestions and recommendations to you about products that may be of interest to you	(a) Identity (b) Contact (c) Technical (d) Usage (e) Profile (f)Marketing and Communications	Necessary for our legitimate interests (to develop our products/services and grow our business)

Cookies

You can set your browser to refuse all or some browser cookies, or to 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. For more information about the cookies we use, please see Appendix 2 for our Cookie Policy.

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 share your personal data with the parties set out below for the purposes set out in the table “Purposes for which we will use your personal data” above.

• Internal Third Parties as set out in the Glossary.
• External Third Parties as set out in the Glossary.
• Third parties to whom we may choose to sell, transfer or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy policy.

We require 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

When the United Kingdom formally left the EU on 31 January 2020 your personal data did not physically move, but as the UK is now outside the European Union (“EU”), it was from that point that your personal data effectively “transferred” outside of the EU to Zentia Limited in the UK. It will be adequately safeguarded through EU Approved Standard Contractual Clauses between Zentia Limited and members of the Zentia Group and where necessary its other processors and any sub-processors, or in such other manner as is approved by the EU and UK government.

We do not currently transfer your personal data outside the European Economic Area (EEA). If in the future we do so, we will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data by the relevant authorities.

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.

8. Data retention

How long will you use my personal data for?

We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements relevant to us. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.

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, regulatory, tax, accounting or other requirements.

By law we have to keep basic information about our customers (including Contact, Identity, Financial and Transaction Data) for six years after they cease being customers for tax purposes.

In some circumstances you can ask us to delete your data: see “Your legal rights” below for further information.

In some circumstances we will 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.

How long will your third party processors process my personal data for?

Our Internal Third Parties and External Third Parties will process your personal data for the period during which they are processing on our behalf or as joint controllers and within those periods for such time as is applicable to your interaction with us unless legal obligations require extended retention. For example:

• Our website hosting provider retains your data on our behalf whilst you continue to access your website customer account or interact with our communications. If there is no activity after 24 months and we/you have not modified the account in any way, the data will be deleted.
• Our social media content and communications provider retains the data on our behalf for 24 months since last use unless legal obligations require extended retention.
• Our email marketing communications provider retains your data on our behalf whilst you continue to interact with our communications until either we delete your data from their email marketing tool or, we close our account with them (any remaining data is held for 90 days before deletion). We can optionally choose to expire pending contacts 30 days after our last contact attempt.

9. Your legal rights

Under certain circumstances, you have rights under data protection laws in relation to your personal data. Please see Appendix 3 to find out more about these rights:

If you wish to exercise any of the rights set out in Appendix 3, please contact us at marketing@zentia.com.

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 could 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 could 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. Glossary

Comply with a legal obligation means processing your personal data where it is necessary for compliance with a legal obligation that we are subject to.

External Third Parties means:

• Our website hosting provider which processes data on our behalf including e-mail preferences; Contact Us enquires; sample order requests; website customer account details and website access logs. Based in the UK and hosts and backs up our data in its back-up datacentre in the United Kingdom;
• Our social media content and communications provider which processes data on our behalf by forwarding enquiries and mentions of our business on social media to us to respond to. Based in the UK and hosts the data on local platforms in the UK and with Microsoft Exchange cloud service in the UK;
• Our email marketing communications provider which processes as a minimum your contact name and email address on our. Based in the UK and hosts the data on Microsoft Azure infrastructure in the Netherlands which is backed up in Ireland;
• Other service providers acting as processors based in the UK and the countries in which we operate (the countries being as set out in Appendix 1) who provide logistics services for sample order deliveries and event organisation (face-to-face and online).
• HM Revenue & Customs, regulators and other authorities acting as processors or joint controllers based in the United Kingdom and the countries in which we operate the countries being (as set out in Appendix 1) who require reporting of processing activities in certain circumstances.

Internal Third Parties means other companies in the Zentia Group acting as joint controllers and/or processors and who are based in the countries all as set out in Appendix 1. Data provided by you in our Contact Forms, sent by you to our email addresses and provided by you when you request sample orders or specification details, is forwarded via our internal mail system tool on a UK server for processing by a designated in-country business support team in order to respond to your request accordingly. CSL retains the data indefinitely.

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 you are a party or to take steps at your request before entering into such a contract.

Appendix 1

Data Controllers and contact details

For any questions relating to the website and your rights in relation to how CSL uses your personal data, please go to marketing@zentia.com and an appropriate CSL representative will be in contact as soon as possible.

Website location	Data controller or joint data controllers
Estonia	Zentia Limited
Germany	Ceiling Solutions GmbH and Zentia Limited
Ireland	Zentia Limited
Latvia	Zentia Limited
Lithuania	Zentia Limited
Portugal	Armstrong Architectural Products S.L. and Ceiling Solutions Limited
Spain	Armstrong Architectural Products S.L., Zentia Limited and Perfiles Y Techos
UK	Zentia Limited and Zentia Profiles Limited

 

Appendix 2

Cookie Policy

USE OF COOKIES

• We use the term “cookies” to refer to cookies and other similar technologies covered by the EU Directive on privacy in electronic communications.

We will not use cookies to collect personally identifiable information about you. However, should you wish to do so, you can choose to reject or block the cookies set by Shell or the websites of any third party suppliers by changing your browser settings – see the Help function within your browser for further details. Please note that most browsers automatically accept cookies so if you do not wish cookies to be used you may need to actively delete or block the cookies.

You can also visit www.allaboutcookies.org for details on how to delete or reject cookies and for further information on cookies generally. For information on the use of cookies in mobile phone browsers and for details on how to reject or delete such cookies, please refer to your handset manual.

Note, however, that if you reject the use of cookies you will still be able to visit our websites but some of the functions may not work correctly.

What is a Cookie?

A cookie is a small file of letters and numbers that website operators store on your browser or the hard drive of your computer or mobile device when you visit their websites. The cookie allows the website to record certain information such as your searches or preferences in order to make your experience more efficient during that and future visits. It also allows website operators to improve their websites.

Our use of Cookies

Our website uses different types of cookies some of which are placed by third party services that appear on our website. We are permitted to store cookies on your device that are strictly necessary for the operation of our website. For all other types of cookies, we need your consent.

You can at any time change or withdraw your consent. However, this may mean certain features on our website may not work for you.

Specifically, we use cookies:

• to understand how you navigate around our website content and thereby improve your experience. For example, some cookies will remember your language or preferences meaning you do not have to make the same choices time and again;
• for geo-localization purposes to ensure you are on the most appropriate website for your location and to remember the answer provided;
• to personalise content and ads; and
• to provide social media features.

We also share information about your use of our site with our social media, advertising and analytics partners who may combine it with other information that you’ve provided to them or that they’ve collected from your use of their services.

We and such third parties may employ the learnings of your behavior on our website(s) to serve you with targeted advertisements on third-party website(s) in an effort to “re-market” our products and services to you.

What types of Cookies do we use?

Strictly necessary cookies

These are required for the operation of our website. They include, for example, cookies that enable page navigation and access to secure areas of our website. The website cannot function properly without these cookies.

Analytical or performance cookies

These allow us to recognise and count the number of visitors and to see how visitors move around our website when they are using it. This helps us to improve the way our website works, for example, by ensuring that users are finding what they are looking for easily.

Functionality cookies

These are used to recognise you when you return to our website. This enables us to personalise our content for you, greet you by name and remember your preferences (for example, your choice of language or region).

Targeting cookies

These cookies record your visit to our website, the pages you have visited and the links you have followed. We will use this information to make our website more relevant to your interests. We may also share this information with third parties for this purpose.

First and Third Party cookies

We use both first and third-party cookies on our website.

First party cookies are issued from websites owned by us and are used for site functionality purposes including the identification of language and location preferences.

Third party cookies are issued from websites other than our websites. Please see the Third Party Cookies section below for information about these cookies.

Session cookies

Session cookies are temporary cookies used to remember/manage your time spent progressing through the various areas of our website and expire immediately you close the web browser.

Permanent cookies

Permanent cookies are used as convenience features to improve your experience when you return to our site by remembering your preferences and analyzing your behavior from previous visits to our websites. This improves the website functionality not only for you but for other users. Permanent cookies remain on your browser or mobile device even after you close your browser or restart your computer.

Third Party Cookies:

Cookies	Description	Link to Privacy Policy	Type of cookie
Magento 2 Commerce “out of the box”	The Magento 2 platform uses default cookies to understand how users arrive on our website(s) and how they engage with us on the website. The data is used to improve the user experience. Magento also uses cookies to understand the content with which you have engaged on our website(s) so they may subsequently deliver some targeted content to you.	https://docs.magento.com/m2/ce/user_guide/stores/cookie-reference.html	Strictly Necessary Functionality
GeoIP Redirect for Magento 2	We will use the GeoIP Redirect for Magento 2 extension to apply IP based re-directs or ‘GeoLocation’ functionality. The module automatically determines visitors’ location and redirects them to the correct country website.	https://amasty.com/geoip-redirect-for-magento-2.html	Strictly Necessary Functionality
Google Analytics	Google Analytics is used to understand how our media campaigns work and how you interact with our website in order to improve the user experience.	https://tools.google.com	Analytical Performance
Google Tracking Cookies	Google tracking cookies enable us to understand if you complete certain actions on our website(s) after you have seen or clicked through one of our adverts served via Google. Based on the content you have engaged with on our websites Google are able to deliver some targeted adverts across other Google partner websites.	https://support.google.com	Analytical Performance
Addthis	AddThis is a service which allows Zentia to easily share any of our pages to any of the dozens of social networks available.	www.addthis.com	Functionality
Dotdigital Engagement Cloud	Our relation marketing platform. All information contained is owned by us. Dotmailer acts as solely as service provider which is not allowed to transmit any information to 3rd parties without express written consent.	n/a	Functionality
YouTube	YouTube is a video sharing website. The platform may use cookies to optimize your viewing experience to watch videos on our websites.	www.youtube.com	Functionality

How do I reject and delete Cookies?

You can choose to reject or block all or specific types of cookies by changing your preferences for our websites and/or the websites of any third party suppliers by changing your browser settings. If you do not wish cookies to be used, you may need to actively delete or block the cookies. If you reject the use of cookies, you will still be able to visit our website, but some of the functions may not work correctly.

Appendix 3

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 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:

• If you want us to establish the data’s accuracy.
• Where our use of the data is unlawful but you do not want us to erase it.
• 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.
• 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 products or services to you. We will advise you if this is the case at the time you withdraw your consent.