Information regarding the processing of personal data by Unipos (as well as ‘Information’)
The purpose of this document is to provide customers and other persons dealing with Unipos Systems Ltd, Company number 6458734, registered office Unipos Systems LTD, Unit 20, The Courtyard, Greenewable Park, Station Lane, Offord Cluny, Cambridgeshire, PE19 5ZA (as well as ‘Jansen Display’) with information on the processing of their personal data. Jansen Display, as a personal data controller, processes data of natural persons during, amongst other things:
(1) these persons’ visits to the website operated by Jansen Display,
(2) communication with customers and contractors (both current and future), and
(3) recruitment process initiated through Unipos Systems website.
The aim of this document is to inform natural persons whose personal data is processed, for what purposes and for how long Unipos Systems will, in compliance with applicable legislation, process this personal data, and what rights these natural persons have with regard to the processing of their personal data.
This Information concerns the processing of personal data of
(1) visitors of the website operated by Jansen Display,
(2) current and future customers and suppliers of Unipos Systems and, if appropriate, their representatives and contact persons,
(3) candidates for a job position at Jansen Display,
in each case to an extent corresponding to these persons’ relation to Jansen Display.
This document is effective from 25th May 2018 and is issued in accordance with Regulation (EU) 2016/679, on the protection of natural persons with regard to the processing of personal data (hereinafter the ‘Regulation’ or ‘GDPR’) in order to meet Jansen Display’s information obligation set forth for controllers in Article 13 of GDPR.
Unipos Systems may be contacted by the following means: email@example.com
- Basic terms and information
Personal data means all information on an identified or identifiable natural person (data subject). An identifiable person is a natural person who may be directly or indirectly identified, in particular by reference to an identifier (e.g. a name, surname, number, online identifier), or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.
Special categories of personal data
Special categories of personal data include ‘sensitive personal data’, i.e. data which might have the potential to harm the data subject socially, at the workplace, at school or to be a reason for discrimination. Such personal data usually concerns racial or ethnic origin, political opinions, religious or philosophical beliefs or trade union membership, and biometric data used for the purpose of uniquely identifying a natural person, data concerning health or data concerning a natural person’s sex life or sexual orientation.
Data subjects are natural persons to whom the personal data relates and who may be, directly or indirectly identified.
Personal data controller
A personal data controller is a natural person or legal entity who determines the purposes and the means of processing personal data and is liable for the processing of personal data. Unless provided otherwise in this document or in the terms of the specific service provided, Unipos Systems will be understood to be the personal data controller.
Personal data processor
A personal data processor is a natural person or a legal entity who, on the basis of a written agreement and the instructions of the controller, processes personal data on behalf of the controller.
Personal data processing
Personal data processing means any operation or set of operations which is performed on personal data or on a set of personal data, whether or not by automated means, such as collection, recording, organisation, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction.
- Categories and purposes of personal data processing
The following categories of personal data may be processed by Unipos Systems in relation to visits to Unipos Systems website including purchases made at the Unipos Systems e-shop, communication with current and possible future customers, Resellers and suppliers and their representatives and contact persons and recruitment of new employees through Unipos Systems website.
- Processing of personal data due to completed or intended purchases of goods at Unipos Systems e-shop and due to entering into contracts with customers and suppliers
When a customer purchases goods from Jansen Display, Unipos Systems is entitled to process
(1) basic personal, identification and contact data of the customer (provided directly by the customer during the purchase) or the Resellers customer (provided directly by the Reseller during the purchase) ,
(2) data concerning the contract being entered into,
(3) information relating to purchased goods,
(4) data contained in the conversation between Unipos Systems and the customer,
for the duration of the warranty period of the purchased goods and for 3 years after the warranty period expires. The purpose of such data processing is
(1) meeting Jansen Display’s obligations arising out of the contract with the customer,
(2) legitimate interests pursued by Unipos Systems consisting in ascertaining, exercising and defending its rights and claims, and
(3) legitimate interests pursued by Unipos Systems consisting in the right to inform its current customers on offers relating to goods which the customers previously purchased from Jansen Display.
Unipos Systems is entitled to process the following personal data of its suppliers relating to the purchase of goods from these suppliers
(1) basic personal, identification and contact data of the supplier,
(2) data concerning the contract being entered into,
(3) data concerning the goods,
(4) data contained in the conversation between Unipos Systems and the supplier,
for the duration of the warranty period of the purchased goods and for 3 years after the warranty period expires. The purpose of such data processing is
(1) meeting Jansen Display’s obligations from its contract with the supplier and
(2) legitimate interests pursued by Unipos Systems consisting in ascertaining, exercising and defending its rights and claims.
(3) Invoices issued by Unipos Systems are, in accordance with VAT Notice 700/21: keeping of VAT records for a period of 6 years from issue. In order to prove the legal basis for each invoice, pertaining contracts will also be archived for 6 years from the termination of the respective contract.
- Data obtained via cookies and activities which candidates pursue at Unipos Systems website
Processing this personal data will enable Unipos Systems to improve its services and focus on what is genuinely interesting to the visitors to its website, including, without limitation, its customers making purchases from the Unipos Systems e-shop and candidates for job vacancies at Jansen Display, and, as the case may be, to inform these persons on offers which are suitable to them. Such processing involves, but is not limited to:
(1) Information about the user’s device obtained from cookies if cookies are enabled in the user’s web browser and information filled in the contact forms, which is processed in order to ensure that the website is functional and the user experience improved – these data are processed on the basis of legitimate interests of Unipos Systems – to ensure that its website is functional and improved for users.
(2) In the event of any actions taking place between Unipos Systems and a potential customer on a contract which was not completed by entering into the contract, Unipos Systems will process the personal data provided for the period of 7 years from the respective communication on the basis of legitimate interests of Unipos Systems – to enable the customer to easily return to the intended purchase; such processing will be based on collecting cookies and information collected from contact forms.
(3) Records of visitor behaviour on websites administered by Jansen Display, including the e-shop, obtained from cookies if cookies are enabled in the visitor’s web browser, which are processed for the purposes of analysing visitor activity – these data are processed on the basis of legitimate interests of Unipos Systems – to monitor visitor activity on its website.
(4) Information on the user’s device obtained from cookies if cookies are enabled in the user’s web browser, which is processed for so called remarketing (or retargeting), i.e. targeting users who have visited the Unipos Systems website in the past – this data is processed on the basis of the user’s consent granted from the user’s initiative expressed by actively ticking the field ‘I agree’, following the notice in the lower part of the website saying: ‘The administrator of the website, Unipos Systems Ltd, as the controller of your personal data, processes cookies on this website required for the websites to be functional and for the purposes of analysing visitor behaviour, and in case of your consent, also for remarketing (retargeting), i.e. for targeted advertising.’ The user grants the consent for the period of 7 years and may withdraw it at any time. For withdraw user must contact Unipos Systems by email to firstname.lastname@example.org and include information about the first and last name and IP address in order to be successfully unsubscribed.
- Data processed for commercial purposes
With the consent of data subjects, we process personal data for commercial purposes.
With the consent of customers to process their personal data for commercial purposes, Unipos Systems will process personal data of its customers in order to create appropriate offers of its products and to address customers, whether by telephone, in writing, via internet advertising or by means of electronic communication using the customers’ contact details. On the basis of the consent, basic personal, identification and contact data and data concerning the contract being entered into, information on goods and data contained in the communication between Unipos Systems and the customer may be processed.
Consent to the processing of personal data for commercial purposes is voluntary and the customer may withdraw the consent at any time. This consent remains valid for 7 years, or until withdrawn by the customer. If the customer withdraws the consent, the right to process the customer’s personal data for other purposes and on the basis of other legitimate reasons in accordance with this information remains unaffected.
For commercial communications made by Unipos Systems or by third parties, Unipos Systems uses the code CA or another suitable designation from which it is clear that the communication is a commercial communication within the meaning of the term defined by the applicable legislation. Commercial communications sent by Unipos Systems will always clearly state that Unipos Systems is the sender. Commercial communications may be sent either to our customers’ contact details – based on legitimate interests of Jansen Display, and only until you express that you do not consent to the use of your contact details – or based on express consent to the processing of your personal data for marketing and commercial purposes. All commercial communications shall include a contact detail which may be used in order to stop receiving such commercial communications.
- Duration of personal data processing
Personal data processed in the course of a specific activity is processed to the extent necessary for this activity and for a period required to complete this activity or for a period required by the applicable legislation. After this term, personal data is erased or anonymized. Specific deadlines for storage of personal data for certain purposes of processing are defined individually for each such purpose.
- Manner of personal data processing
Unipos Systems carries out manual and automated processing of personal data. Unipos Systems keeps a records of all activities, both manual and automated, which involve personal data processing.
- Categories of recipients of personal data
When performing its contractual obligations, Unipos Systems uses professional and specialized services of 3rd party companies. If such suppliers process personal data transferred to them by Unipos Systems, they are in the position of personal data processors and process personal data only as instructed by Unipos Systems and cannot use them for any other purpose. Such external services include debt collection, expert analyses, legal services, auditing services, administration of IT systems, delivery and installation of goods, internet advertising or commercial representation. We carefully select each provider and enter into an agreement on personal data processing with the provider which sets out strict obligations to protect and safeguard the personal data transferred. A list of 3rd party processors is available on request:
Processors include companies located in the EU member states and in other ‘safe countries’. Personal data is transferred to countries outside the European Union and further processed always in compliance with applicable legislation.
In order to meet its statutory duties, Unipos Systems transfers personal data to public authorities as required by the applicable legislation.
- Information on rights of data in connection to personal data processing after 25th May 2018
From 25th May 2018, each data subject who is an identifiable natural person to Unipos Systems and proves its identity to Unipos Systems, will have the following rights under the Regulation.
- Right to access personal data
Under Article 15 of GDPR, the subject will have a right to access personal data, which also includes the right to obtain the following information from Jansen Display:
(1) information whether it processes personal data,
(2) information on the purposes of processing, categories of personal data concerned, recipients of personal data to whom personal data has been or will be transferred, intended duration of the processing, existence of the right to require that the controller corrects or erases personal data concerning the data subject or restricts their processing or the right to object to such personal data processing, right to file a complaint with the supervisory authority, and all available information on the source of the personal data, if such data does not come from the respective data subject,
(3) information on the fact that the controller uses automated processing, including profiling,
(4) information on suitable guarantees when transferring personal data outside the EU, if the rights and freedoms of other persons is not negatively affected,
(5) copies of personal data.
In case of a repeated request, Unipos Systems will be entitled to charge a reasonable fee for providing copies of personal data.
The rights to confirmation of personal data processing and to information may be exercised at Jansen Display’s registered office.
Right to obtain copies of the personal data processed may be exercised at Jansen Display’s registered office after the applicant’s identity has been proved.
- Right to correction of inaccurate personal data
Under Article 16 of GDPR, the data subject will have a right to correction of inaccurate data concerning the data subject processed by Jansen Display. Jansen Display’s customers will be obliged to inform Unipos Systems of any changes to their personal data and to prove such changes.
At the same time Jansen Display’s customers are obliged to cooperate with Unipos Systems if it is ascertained that the personal data which is processed about the data subject is not accurate. The data will be corrected without undue delay, however, always with regard to technical feasibility. The request for correction of personal data may be raised at Jansen Display’s registered office, after the applicant’s identity has been proved.
- Right to the erasure of personal data
Under Article 17 of GDPR, the data subject has a right to the erasure of its personal data, unless Unipos Systems proves legitimate reasons for processing of this personal data. Unipos Systems has mechanisms to ensure automated anonymization or erasure of personal data if it is no longer needed for the purpose for which it has been processed. If the data subject believes that their personal data has not been erased, it may address this in writing by sending a notice to Jansen Display’s registered office.
- Right to restriction of personal data processing
Under Article 18 of GDPR, the data subject will have the right to request, that, until its motion has been processed, the controller shall restrict processing of personal data concerning the data subject, if the data subject objects to the accuracy of the personal data processed, to the purposes of their processing or to the processing itself, in writing by sending a notice to Jansen Display’s registered office.
- Right to be informed of rectification, erasure or restriction of processing
Under Article 19 of GDPR, the data subject will have the right that Unipos Systems informs it that it will make or has corrected or erased its personal data or has restricted processing of its personal data. If personal data is rectified or erased, we will inform all recipients of the personal data concerned, unless it proves to be impossible or requires unreasonable effort. Based on the data subject’s request, we can inform the data subject about such recipients.
- Right to personal data portability
Under Article 20 of GDPR, the data subject will have the right to portability of his/her personal data which the data subject has provided to the controller in a structured commonly used machine-readable format, and the right to request that Unipos Systems shall transfer this data to another controller.
If a data subject, in connection to a service agreement or on the basis of consent, provides Unipos Systems with their personal data and the processing is automated, the data subject is entitled to obtain such data in a structured, commonly used and machine-readable format. If technically possible, this data may be directly transferred to a data controller selected by you, if a contact person acting on behalf of such controller will be identified and if it will be possible to verify such person’s identity.
Should the exercising of this right negatively impact rights and freedoms of third parties, your request will not be granted. The request may be raised at Unipos Systems stores after proving that your request is legitimate.
- Right to object to personal data processing
Under Article 21 of GDPR, the data subject will have the right to object to processing of its personal data carried out on the basis of legitimate interests of Jansen Display.
If Unipos Systems fails to prove that there is a serious legitimate reason for processing the personal data which overrides the interests or rights and freedoms of the data subject, Unipos Systems will promptly cease such processing.
A written objection may be sent to Jansen Display’s registered office.
- Right to withdraw consent with personal data processing
Consent with the processing of personal data for commercial purposes may be withdrawn at any time. Consent shall be withdrawn by an express, unambiguous and understandable expression of will, made by telephone, e-mail or at Jansen Display’s registered office.
Consent to be sent marketing communication to a specific electronic contact may be withdrawn at any time by telephone, e-mail or at Jansen Display’s registered office.
Processing of personal data from cookies may be prevented by adjusting the settings of your web browser.
- Automated individual decision-making including profiling
Data subjects have the right not to be subject to decision-making based solely on automated processing, including profiling, which produces legal effects concerning them or similarly significantly affects them. Unipos Systems confirms that it does not carry out automated decision-making without any human assessment which would produce legal effects concerning the data subjects.
- Right to address the Office for Personal Data Protection
Data subjects have the right to contact the ICO (Information Commissioner’s Office) The UK’s independent authority set up to uphold information rights in the public interest, promoting openness by public bodies and data privacy for individuals at https://ico.org.uk/.
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