Privacy Statement

Protection of your personal data is important to us. We respect and value your privacy. In this Privacy Statement, we, Delta Membrane Systems Limited will explain how we process your personal data online and offline, in your capacity as a business customer, business partner, supplier, consumer, employee, website visitor, App user or other person with a business relationship with us.

For the purposes of this Privacy Statement the personal data means any information or set of information that directly or indirectly identifies you, such as your name, email address or phone number (mobile or landlines).

Collectively, we refer to our Websites, Apps, Social Media, Emails, and Services as the “Services” that Delta Membrane Systems Limited supplies.

Information About Us

Our Data Protection Officer is Kevin Dodds. Kevin can be contacted by email at info@deltamembranes.com, by telephone on 01992 523 523, or by post at Delta House, Merlin Way, North Weald, Epping, Essex, CM16 6HR.

Our website is owned by Delta Membrane Systems Limited, a limited company registered in England under company number 3535975, whose registered address is 10 Western Road, Romford, Essex, RM1 3JT and whose head office address is Delta House, Merlin Way, North Weald, Epping, Essex, CM16 6HR.  Our website is operated by Popcorn Web Design. Our Social Media Channels and the Delta Pumps App are managed by employees of Delta Membrane Systems Limited whose roles are dedicated to the management of our business and Service(s).

Personal Data

We may process your personal data for the purposes described below and in this Privacy Statement. We may process your personal data to respond to your enquiry and to fulfil your requests, when you contact us via one of our online contact forms, via our main switchboard telephone number or otherwise (e.g. when you send us questions, suggestions, compliments or complaints, or other Services/Products. We may process your name, title, (business or private) contact details (including your email address, postal address, telephone number, name of your company, project details) and any other information that you may provide to us.

We process this information based on your consent, which can be withdrawn by you at any time.

When we are engaged to provide Service(s), we may collect personal data, including name, contact information, financial information and other information relevant to the Service(s) we provide. This information may be collected directly from you, supplied by your organisation or provided by another source. We use this information for the purposes of:

• Conducting due diligence, compliance checks (including anti-money laundering/financial) and other on-boarding processes (such as, new customers seeking customer credit accounts);
• Operating and giving you access to our technology tools;
• Managing billing, payments and financial records; and
• Responding to requests from Regulators.

We use information about our clients (and their representatives) to fulfil our contractual, legal and regulatory obligations or because we have a legitimate interest in processing the information to provide our Services and manage our business relationships.

We will retain your personal data for the period necessary to fulfil the purposes outlined in this Statement unless a longer retention period is required or permitted by applicable law. For example, to provide you with a service you have requested, to comply with applicable legal, tax, or accounting requirements or whether retention is advisable in light of our legal position (for example in regard to litigation or regulatory investigations).

When we collect personal data directly from you it is your decision whether to provide data. If you do not provide data, it may hinder your use of, or make it not possible to use, our Service(s) or Products, not allow you to remain in contact with us, to enter into contracts/agreements with us, to participate in our programmes, or to exercise your rights. If you provide information to us about another person, you must ensure that you comply with any legal obligations that may apply to your provision of the information to us.

We use personal data to process your purchase(s) and to deliver your order(s), to report the status of your order and to contact you about the transaction. For this purpose, we may process your name and address, contact details such as telephone number or email address, credit card or other payment information. Your acceptance of our Terms and Conditions of Business. We will also process information about what you have purchased from us such as your purchase history.

We process your personal data to carry out our business in selling goods and Service(s) and delivering these to you. We will process your personal data as appropriate and/or necessary:

• Under applicable law, including laws outside your country of residence and including e.g. counter-party due diligence, the reporting of whistle-blower concerns, money laundering, financing of terrorism and other crimes;
• To comply with legal obligations;
• To respond to requests from public and government authorities;
• To enforce our Terms and Conditions and other applicable policies;
• To protect our assets and/or operations;
• To protect our rights, privacy, safety or property, and/or that of yours or others; and
• To allow us to pursue available remedies or limit the damages that we may sustain. We may also process aggregated data for audits, to verify that our internal processes function as intended and are compliant with legal, regulatory or contractual requirements, for fraud and security monitoring purposes, for example, to detect and prevent cyber attacks or attempts to commit identity theft.

If so required, we may process your name, your contact information, your correspondence with Delta Membrane Systems Limited, your use of any of our Products and/or Service(s) and any other information mentioned in this Statement or otherwise provided to us by you, if such is required for one of the purposes mentioned in the above paragraph(s) and this Statement.

We may process this information to comply with a legal obligation. We may process this information for our legitimate business purposes.

If you apply for a job at Delta Membrane Systems Limited, we will process your personal data to keep you informed on the status of your application and to assess your skills, qualifications and suitability to work at Delta Membrane Systems Limited against the position you applied for and/or other open positions. We have kept the application process simple, only gathering essential information at the initial stage, such as your name, email address, phone number, work experience and relevant education. We may need data, like documents to proof your identity or qualifications, to conduct background or employment checks, when allowed by applicable laws. In certain cases, we will ask you to have video interviews with us. In that case we may process your image or other data captured by your camera. An assessment could be part of your application process. If that is the case, we will process your answers to our written assessments as well as other data originating from our assessments or questionnaires completed by you. Should you be successful and qualify for a job at Delta Membrane Systems Limited, then we require some more personal data from you to make a conditional offer of employment, such as your bank details as to process salary payments and your emergency contact details.

We process this information based on your consent, which can be withdrawn by you at any time.

If you have previously been employed by Delta Membrane Systems Limited, we may continue to process personal data that was collected before and during your working relationship with us. This data includes contact and biographical information, financial information, compensation and benefits information, employment/personnel records (including job title, contract information, training records, remuneration, performance information), photographs, webinars, recorded seminars, vlogs, blogs and podcasts. We may process this data because we have a legitimate interest in maintaining records, to provide you with references, to publicise our activities, and to conduct data analytics studies to review and better understand our workforce. We may also use this information to establish, exercise or defend legal claims and to comply with our regulatory and legal obligations (including in relation to applicable tax and employment law).

We do not share personal data with third parties following your employment, contractual relationship or partnership with us except as necessary to fulfil ongoing legal or contractual obligations.

In general, we will use the personal data we collect from you only for the purposes described in this Privacy Statement or for purposes that we explain to you at the time we collect your personal data. For the use of our Apps, a separate Privacy Statement and Terms and Conditions may apply. However, if permitted by applicable data protection laws, we may also use your personal data for other purposes, provided they are not incompatible with the purposes we have disclosed to you.

If you provide us with information about someone else, please ensure you have that person’s permission to do so for the purposes detailed in this Privacy Statement. By providing personal data relating to another person, you confirm that you have their consent to do so or are entitled to consent to the processing on their behalf (for example for children for whom you have parental or guardian responsibility).

If you are below the age of 18, we urge you to ask one of your parents or legal guardians and have their written permission before submitting any of your personal data to us. If you are a parent, we recommend you monitor your child’s use of our Services and ensure that we do not receive any personal data from your child without your written permission. If you have any question regarding your child’s personal data, please contact us.

All personal data is processed and stored securely, for no longer than is necessary (considering the reason(s)) for which it was first collected. We will comply with our obligations and safeguard your rights under GDPR always.

Our use of your personal data will always have a lawful basis, because you have consented to our use of your personal data (e.g. by subscribing to emails) or because it is in our legitimate interests.

We will not send you any unsolicited marketing or spam and will take all reasonable steps to ensure that we fully protect your rights and comply with our obligations under GDPR and the Privacy and Electronic Communications (EC Directive) Regulations 2003.

You have the right to withdraw your consent to us using your personal data at any time and to request that we delete it.

Delta’s Offices

If you visit one of our buildings, we may collect information that we need to identify you, to create a record of your visit and for visitor pass use (if issued) and to complete necessary security checks. We may also collect your image on CCTV. We use this information to maintain physical security and manage access to our offices. If you use our guest Wi-Fi, we will collect relevant information to maintain the security of the Wi-Fi service. We process information about visitors to our premises to comply with legal obligations and because we have a legitimate interest in maintaining the security of our buildings.

Delta’s Website

Our website may contain links to other websites. Please note that we have no control over how your data is collected, stored, or used by other websites and we advise you to check the privacy policies of any such website(s) before providing any personal data to them.

We do not profile Website users using Runtime Performance Tools.

Changes to Our Privacy Statement

We may change to our Privacy Statement from time to time (for example, if the law changes). We review our Privacy Statement on a yearly basis. If we do update our Privacy Statement we will post the revised version on our Website. On hard copies we will update the date on the revised Statement. You should check our Website regularly for the most up-to- date version of the Statement. All Delta Policies are available from our Head Office.

Cookies – www.deltamembranes.com

On our Websites, Apps and Social Media channels, we may use cookies and other technology for our internal analytics purposes and to improve the quality and relevance of our products and our services and to make our content and advertising more relevant to you.

Any first time user of our website will be required to accept the cookie agreement to use the Website.

For further information about the type of cookies we use, the reason why we use them, and how you can control your cookies, please refer to our Cookie Policy.

On Demand Seminar Requests

Upon your request, we can create a personal account for you to view our “On Demand” seminars. If applicable, you will be able to view and manage your viewing of our pre-recorded seminars. In this case we will process your name, email address and any other information that is required for an “On Demand” account creation. We will also process your display name and your login data.

We process this information based on your consent, which can be withdrawn by you at any time.

Apps

You can create a personal account for you to view our Services offered on our Apps. We will also process your display name and your login data. If applicable, you will be able to view and manage your personal data if you use our Apps or Services. In this instance we may process location data and device identifiers and such personal data as is included within the content generated on the App (such as pump flow and discharge rates). This may even include special category personal data (such may be determined from keyholders, if voluntarily added by you through our App). We may also process data that you provide to us via your social media accounts in relation to the App. Should you wish to share any personal data concerning other persons than yourself through our Apps (e.g. through a photo or video), you should ensure that those other persons also consent to their data being uploaded to the App for the purpose of being shared. If you share a link through the App, this link may also be visible to others.

Together with our App Terms and Conditions and any Service(s) accessible through the App we may collect and process the following data from you.

• Information you give us (submitted information): You may give us information about you by filling in forms on the App Site or in the App itself. This includes information you provide when you register to use the App Site. The information you give us may include your name, address, email address and phone number, the Delta HLA Plus Device(s) Serial Number, Product Type, Water Type, Chamber Details, Pumping Station, Delta HLA Plus Device(s) location and other registration information;
• Technical information, including a unique device identifier (for example, your Delta HLA Plus Device(s) Serial Number), date of commissioning, date of servicing;
• Information stored on your Delta HLA Plus Device(s), including log, login information or other digital content;
• Intelligent Data: We may also use technology to collect intelligent data to display the personalised activation notification features, even when the App is closed and not in use.
• If you contact us, We may keep a record of that correspondence.

We process this information based on your consent, which can be withdrawn by you at any time.

Delta Newsletters

If we send you our newsletters, we base this on your consent, which can be withdrawn at any time.

Delta Training Courses

With your consent, we can send you emails with invitations to participate in courses; attend events or interact with us as a client. If you choose to participate in these events, we need your personal date to be able to organise this.

If you participate in any of these events, we need your personal data to register you for a course and provide you with course material and to keep records of your participation and other relevant information including meal preferences, feedback and survey responses. For these purposes we may process your name, email address, business and/or private contact details. In case of training courses/events we may process your photo (such as the Delta Installer ID photo card(s)).

We process this information based on your consent, which can be withdrawn by you at any time.

Your Privacy Rights

You have the following rights in relation to your personal data:

• You have the right to access, correct, update, or request deletion of your personal data. In addition, you can object to the processing of your personal data, ask us to restrict processing of your personal data or request portability of your personal data.
• You have the right to withdraw consent (“opt-out”) of marketing communications we send you at any time. You can exercise this right by clicking the unsubscribe or opt-out link in the emails we send you.
• Similarly, if we have collected and processed your personal data with your consent, then you can withdraw your consent at any time. Withdrawing your consent will not affect the lawfulness of any processing we conducted prior to your withdrawal, nor will it affect processing of your personal data conducted in reliance on lawful processing grounds other than consent.
• Whilst we would prefer you to come to us first with any complaints, you have the right to complain to a data protection authority about our collection and use of your personal data. For more information, please contact your local data protection authority.

We respond to all requests we receive from individuals wishing to exercise their data protection rights in accordance with applicable data protection laws and free of charge. In certain cases, we may ask you to verify your identity before acting on your request. Keep in mind that there may be situations where we are entitled to deny or restrict your privacy rights, for example when we need to keep certain data to comply with legal obligations, when it is necessary to establish, exercise or defend Delta Membrane Systems Limited from legal claims or when your request is manifestly unfounded or excessive, in particular because of its repetitive character.

Contact Us Forms

The data we collect is from our “Contact Us” forms. This data allows us to

• Respond to your Brochure request;
• Respond to your Registered Installer request;
• Respond to your Call Back request;
• Respond to your Newsletter Sign-up.

Do We Share Your Data?

We will not share any of your data with any third parties for any marketing purposes.

We may sometimes contract with third parties to supply products and services to you on our behalf. These may include Registered Installers and packaged pump queries. In some cases, the third parties may require access to some or all of your data. Where any of your data is required for such a purpose, we will take all reasonable steps to ensure that your data will be handled safely, securely, and in accordance with your rights, our obligations and the obligations of the third party under the law.

Suppliers and other third parties

If you provide goods or services to us, we maintain contact information, information regarding the goods or services you provide to us and billing and financial information, including billing address, bank account and payment information. We use this information to manage our supplier relationships and to comply with our contractual and legal obligations. We may also use this information to establish, exercise or defend legal claims.

Complaints

We respect your rights and want you to be comfortable with our use of your personal data. If you have a complaint or concern about how we use your personal data, we would like to work with you to resolve it. You can report a concern or ask us a question by contacting the Data Protection Officer, Kevin Dodds. Kevin can be contacted by email at info@ deltamembranes.com, by telephone on 01992 523 523, or by post at Delta House, Merlin Way, North Weald, Epping, Essex, CM16 6HR.

How to contact us

If you have any queries regarding anything mentioned in this Privacy Statement or want to exercise any of the rights mentioned, please contact us at: info@deltamembranes.com.

This Statement is subject to review and amendment in line with prevailing legislation and best practice. Delta Membrane Systems Limited reserves the right to review and amend this policy at any time.

Kevin Dodds

Managing Director

Issued: May 2018 and reviewed annually thereafter