Supplier Privacy Policy

Privacy Notice for Suppliers

Edition Date 25th May 2018

1. What is the purpose of this document?

MachineWorks Limited ("we", "our", "us") along with all other members of the Westec Holding Company Limited group of companies (the “Group”) are committed to protecting the privacy and security of our suppliers’ personal information. This privacy notice describes how we collect and use personal information about you/your organisation, in accordance with the General Data Protection Regulation (EU) 2016/679 – the “GDPR”, together with other UK data protection laws.

MachineWorks Limited is a "data controller". This means that we are responsible for deciding how we hold and use personal information about our suppliers (“you”, "your”). We are required under data protection legislation to notify you of the information contained in this privacy notice.

It is important that you read this notice, together with any other privacy notice we may provide on specific occasions when we are collecting or processing personal information about you, so that you are aware of how and why we are using such information. These other applicable privacy notices include our website privacy notice.

2. The kind of information we hold about you

We may collect, store, and use the following categories of personal information about you:

• Contact details such as name, title, addresses, telephone numbers and email addresses.
• Payment details for placing orders.
• Order history.
• Information about our suppliers’ use of our information and communications systems.

We typically collect personal information about you when we purchase goods and/or services from you. We may collect additional personal information throughout the period of you/your organisation supplying the goods and/or services to us for example via email, telephone or via our website.

3. How we will use information about you

We will use your personal information as follows:

• To administer or otherwise carry out our obligations arising from any contracts entered into with you/your organisation or to take steps to enter into any contracts between you/your organisation and us.
• To fulfil any requests you have made regarding our order(s) or to contact you with information relevant to your interaction with us.
• To maintain and update our Customer Relationship Management (CRM) system.
  Our lawful basis for these activities above is necessity to perform our contract of sale with you/your organisation.
• To ascertain your ability to provide us with goods and/or services.
• Fraud monitoring and prevention.
  Our lawful basis for these activities above is the pursuit of our legitimate interests of operating and expanding our business activities lawfully.

Some of the above grounds for processing will overlap and there may be several grounds which justify our use of your personal information.

If you fail to provide certain information when requested, we may not be able to perform the contract we have entered into with you or your organisation (such as purchasing the goods and/or services from you). We will only use your personal information 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 we need to use your personal information 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 information without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

We do not envisage that any decisions will be taken about you using automated means, however we will notify you in writing if this position changes.

4. Data sharing

We may have to share your data with third parties, including third-party service providers such as IT providers, Westec Holding Company Limited and Dr Johannes Heidenhain GmbH. We may sometimes be obliged to disclose your personal information by law such as by a regulator with appropriate power or court order or to otherwise comply with the law. Potential recipients include HM Revenue & Customs,

All our third-party partners/service providers are required to take appropriate security measures to protect your personal information in line with our policies. We do not allow our third-party partners/service providers to use your personal data for their own purposes. We only permit them to process your personal data for specified purposes and in accordance with our instructions.

5. Data retention

We will only retain your personal information 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, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements. In some circumstances, we may anonymise your personal information so that it can no longer be associated with you, in which case we may use such information without further notice to you. Once your organisation is no longer a supplier of ours or once we learn that you no longer work for the supplier, we will securely destroy your personal information in accordance with our data retention procedures.

6. Rights of access, correction, erasure, and restriction

It is important that the personal information we hold about you is accurate and current. Please keep us informed if your personal information changes during your working relationship with us.

Your rights in connection with personal information

Under certain circumstances, by law you have the right to:

• Request access to your personal information (commonly known as a "data subject access request"). This enables you to receive a copy of the personal information we hold about you and to check that we are lawfully processing it.
• Request correction of the personal information that we hold about you. This enables you to have any incomplete or inaccurate information we hold about you corrected.
• Request erasure of your personal information. This enables you to ask us to delete or remove personal information 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 information where you have exercised your right to object to processing (see below).
• Object to processing of your personal information 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. You also have the right to object where we are processing your personal information for direct marketing purposes (for example, email marketing or phone calls).
• Request the restriction of processing of your personal information. This enables you to ask us to suspend the processing of personal information about you, for example if you want us to establish its accuracy or the reason for processing 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.

If you want to review, verify, correct or request erasure of your personal information, object to the processing of your personal data, or request that we transfer a copy of your personal information to another party, please contact our Data Controller in writing and they will explain any conditions that may apply.

No fee usually required

You will not have to pay a fee to access your personal information (or to exercise any of the other rights). However, we may charge a reasonable fee if your request for access is clearly unfounded or excessive. Alternatively, we may refuse to comply with the request in such 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 the information (or to exercise any of your other rights). This is another appropriate security measure to ensure that personal information is not disclosed to any person who has no right to receive it.

Right to withdraw consent

In the limited circumstances where you may have provided your consent to the collection, processing and transfer of your personal information for a specific purpose, you have the right to withdraw your consent for that specific processing at any time. To withdraw your consent, please contact our Data Controller. Once we have received notification that you have withdrawn your consent, we will no longer process your information for the purpose or purposes you originally agreed to, unless we have another legitimate basis for doing so in law.

Further guidance on your rights is available from the Information Commissioner’s Office (https://.ico.org.uk/ ). You have the right to complain to the UK’s supervisory office for data protection, the Information Commissioner’s Office at https://ico.org.uk/concerns/ if you believe that your data has been processed unlawfully.

7. Changes to this Privacy Notice

Dr Fenqiang Lin has been appointed as Data Controller to oversee compliance with this privacy notice. If you have any questions about this privacy notice or how we handle your personal information, please contact the Data Controller.

We reserve the right to update this privacy notice at any time for example if the law or regulatory requirements change, if technology changes or to make the Group’s operations and procedures more efficient. We will provide you with a new privacy notice when we make any substantial updates. We may also notify you in other ways from time to time about the processing of your personal information.

This privacy notice does not override any applicable national data privacy laws and regulations in countries where the Dr. Johannes Heidenhain GmbH group operates.