LAST UPDATED: MAY 2018
At Pioneer we do all we can to respect your right to privacy and the protection of personal information.
This privacy notice applies to the Pioneer Insulation, Pioneer Decorators and Pioneer Renders, which are operated by Pioneer Wall Cladding & Building Insulation Ltd. No. 07974658, as the data controller.
When we refer to “Pioneer”, “we”, “us”, and “our”, we mean any of those data controllers, as appropriate. By “you” or “your” we mean any individual, sole trader and/or partnership that receives services from us, uses our website or otherwise interacts with Pioneer Wall Cladding & Building Insulation Ltd., C/O Brayne, Williams & Barnard Limited Rosemount House, Rosemount Avenue, West Byfleet, Surrey, England, KT14 6LB
Please read this notice carefully as it provides important information about how we handle your personal information and the steps you can take to control it. “Personal information” means information about a living individual who can be identified from that information (either by itself or when it is combined with other information).
We may update our Privacy Notice from time to time. When we do we will publish the updated Privacy Notice on our website. We would encourage you to visit our website regularly to stay informed of the purposes for which we process your information and your rights to control how we process it.
If you have any questions, comments or concerns about any aspect of this notice, please contact us using the details set out in section 8.
1. The Information we hold and how we collect it.
We, or third parties on our behalf, collect your personal information when you contact us via our website, communicate with us by phone, letter, email, social media or in person or receive our products and/or services.
We will limit the collection and processing of information to information necessary to achieve one or more legitimate purposes as identified in this notice.
We may collect the following personal information and we refer to this as “personal information” throughout this notice:
• your name;
• billing address;
• supply address;
• telephone numbers;
• e-mail addresses;
• if you are a home owner or renter;
• if we have surveyed your property: information related to number of bedrooms, type of walls, type of heating systems in use and photos of the property related to the work to be quoted for.
• if you engage with us through social media, we collect your name and store a link to your relevant social media profile, which we combine with details of your previous correspondence with us;
• if you request a quote for services with us, we create and record customer records for you and record the date of your application.
We need this personal information so we can provide services and/or products to you. If you don’t provide us with that personal information you may not be able to access certain products and/or services.
2. How we use your personal information
2.1. Legal Bases for Processing
We will only use and share your information where it is necessary for us to carry out our lawful business activities. We want to ensure that you fully understand how your information may be used. We have described the purposes for which your information may be used in detail below:
(a) Contractual necessity – we may process your information where it is necessary to enter into a contract with you for the provision of our products or services or to perform our obligations under that contract; or
(b) Legal Obligations – our use of your personal information is necessary for complying with our legal obligations; or
(c) Our Legitimate Interests as a company – to:
i. Manage, grow and develop our business;
ii. Manage the security of our network and information systems;
iii. Manage our own processes, procedures and systems;
iv. Determine the effectiveness of our promotional activities and advertising; and
v. Monitor and Improve the quality of our services, identify and develop new business opportunities and communications for the benefit of our customers.
(d) Consent – In the following specific circumstances we rely on your consent to use your personal information in a particular way:
i. To send you marketing information by email or letters.
If we rely on your consent in these ways, but you later change your mind, you may withdraw your consent by contacting us using the details in section 8 and we will stop doing so.
2.2. We collect, use and store the personal information collected about you for the below purposes:
(a) Provide, or obtain on your behalf, relevant products and/or services, benefits, and rewards;
(b) Respond to and address any enquiries or issues you have;
(c) Contact you about our services and/or products, such as sending you information when you ask us to, service announcements and administrative messages;
(d) Train our staff and improve our products and services, which may mean that we monitor and record communications that we have with you including phone conversations, emails and SMSs;
(e) Conduct, and contact you in relation to, market research e.g. through customer satisfaction surveys and questionnaires;
(f) In some cases, obtain government funding for the supply of energy efficiency measures to your property;
(g) Identify offers and advice tailored to your needs or lifestyle;
(h) Ensure the health and safety of you, our staff and contractors;
(i) Make decisions about the products and/or services and terms and conditions that we can offer to you;
(j) Respond to or resolve any enquiries or requests that you may have from social media;
(k) Enable internal reporting, business administration, adequate insurance coverage, the security of company facilities, research and development, and to identify and implement business efficiencies;
(l) Comply with any procedures, laws and regulations which apply to us – including where we reasonably consider it is in our (or others) legitimate interests to comply; and
(m) Establish, exercise or defend our legal rights – including where we reasonably consider it is in our (or others) legitimate interests.
2.3. Marketing Communications
If you opted in to receiving marketing correspondence from us, we will send you relevant marketing information (including details of other products or services provided by us which we believe may be of interest to you), by mail, phone, email, text and other forms of electronic communication. We will always give you the choice to opt out of any such further communication. If you change your mind about how you would like us to contact you or you no longer wish to receive this information, you can also tell us at any time by contacting us.
To opt out of receiving marketing messages, or to object to our use of profiling for direct marketing purposes, contact us at any time using the details in section 8.
2.4. Your sensitive personal information
We do not hold sensitive customer data, such as specific health conditions, financial situation, criminal convictions or personal circumstances of a customer.
Where government funding is made available through our partners, such as our Utility partners, local councils or their representatives, and such funding is conditioned by the existence of a vulnerability (financial, health or of other nature), we will ask you to provide any relevant personal information directly to such authorised organisations. We will not ask you for and will not store evidence of income, doctor’s certificates and any other paperwork containing sensitive personal information.
Where you qualify for such funding based on a vulnerability as assessed by an authorised organisation, we will record a ‘vulnerability flag’ in our system. This will generalise the information, ensuring no sensitive information is stored, but allowing us to act on your behalf for securing the funding from our partners.
E.g. based on health and/or financial information you provide directly to your local council, they issue a certificate of funding eligibility. Your personal circumstances are not detailed on the certificate. We add a ‘vulnerability flag’ on your account and store the certificate, then share it with the funding providers on your behalf, to secure the funding you are entitled to.
3. Information we receive from third party sources
We also receive your personal information from the following third party sources:
(a) Energy suppliers referrals – we may receive your name, address and contact details where they would like carbon-saving measures applied to your property under relevant government funding schemes;
(d) Councils, local authorities or housing associations – we may receive your name, address and contact details where they would like carbon-saving measures applied to your property under relevant government funding schemes;
(e) Letting agents, landlords, cohabitants or previous home owners – if you live into a rental property that the landlord wants us to install energy efficiency measures to, or if you purchased a property that we installed efficiency measures to, and are is covered by our warranty.
(i) Third party introducers (such as Checkatrade websites) to set up an account for you and to provide the services that you have requested;
4. Who we share your personal information with
We will share your personal information with the following categories of third parties:
(a) our third party suppliers, partners and sub-contractors that provide, review and/or receive services in relation to our services and/or products, which include: accounting processors; suppliers of technical, support and installation services; insurers; logistics providers; cloud services providers; and, if you are entitled to claim government funding for energy efficiency measures, energy performance assessors, funding providers, your local council and their designated agents.
(b) where appropriate, family members or cohabitants, landlords, or letting agents who/which may require information about you or your premises, or who introduced you to us;
(c) if we’re under a duty to disclose your information in order to comply with any legal obligation, government or law enforcement officials as may be required to meet law enforcement requirements or prevent illegal activity;
(d) regulators or other legally appointed bodies (such as the British Board of Agrement, Gas Safe, Ofgem) for legal or regulatory purposes;
(e) debt collection and tracing agents if we provide you with services and you fail to make payments;
(f) if we sell, merge, or perform any internal re-organisations in relation to any of our (or any third party’s) business or assets, the personal information will be one of the transferred assets to the relevant buyer and/or new data controller of such business or assets;
(g) any third party where required to:
i. enforce or apply our terms and conditions or any other agreement or to respond to any claims, to protect our rights or the rights of a third party, to protect the safety of any person or to prevent any illegal activity; and
ii. protect the rights, property or safety of our company, our staff, customers or others.
5. Transferring information overseas
We, or a third party who we share personal information with, may host, store and handle that personal information outside of the European Economic Area (EEA).
In the event that we transfer information to countries outside of the European Economic Area (which includes countries in the European Union as well as Iceland, Liechtenstein and Norway), we will only do so where:
(a) the European Commission has decided that the country or the organisation we are sharing your information with will protect your information adequately; or
(b) the transfer has been authorised by the relevant data protection authority; or
(c) we have entered into a contract with the organisation with which we are sharing your information (on terms approved by the European Commission) to ensure your information is adequately protected
(d) (in the case of transfers from the EEA to the USA), the recipient of the personal information has certified with the US-EU Privacy Shield Framework, as permitted by Article 46.2 of the GPDR.
6. How long do we keep your personal information
We keep your personal information for no longer than is necessary of the purposes for which the personal information is processed. The length of time we retain it for depends on the purposes for which we use it and/or as required to comply with applicable laws and to establish, exercise or defend our legal rights.
This means that some of your personal information will be kept for a short time e.g. if you contact us about a service and, after the initial discussion, we ascertain that we do not provide the service you need, we will delete your information after one year.
Other information may be kept for a longer period of time, e.g. we keep your and your property’s details (and any evidence of the work we carried out, including regular servicing) for 25 years where we are bound by the provision of our 25 years installation warranty.
7. Your rights in relation to your personal information
7.1. Access – You have a right to get access to the personal information we hold about you
If you would like a copy of the personal information we hold about you:
a) please write to: Pioneer Wall Cladding & Building Insulation Ltd., C/O Brayne, Williams & Barnard Limited Rosemount House, Rosemount Avenue, West Byfleet, Surrey, England, KT14 6LB
b) email us at email@example.com
c) Or contact us at 01932 221 209
7.2. Erasure – You have a right to request that we delete your personal information.
You may request that we delete your personal information if you believe that:
• we no longer need to process your information for the purposes for which it was provided;
• we have requested your permission to process your personal information and you wish to withdraw your consent; or
• we are not using your information in a lawful manner.
Please note that if you request us to delete your information, we may have to suspend provision of the products and services to you.
7.3. Restriction – You have a right to request us to restrict the processing of your personal information.
You may request us to restrict processing your personal information if you believe that:
• any of the information that we hold about you is inaccurate;
• we no longer need to process your information for the purposes for which it was provided, but you require the information to establish, exercise or defend legal claims; or
• we are not using your information in a lawful manner. Please note that if you request us to restrict processing your information, we may have to suspend the provision of the products and services to you.
7.4. Portability – You have a right to data portability.
Where we have requested your permission to process your personal information or you have provided us with information for the purposes of entering into a contract with us, you have a right to receive the personal information you provided to us in a portable format. You may also request us to provide it directly to a third party, if technically feasible. We’re not responsible for any such third party’s use of your account information, which will be governed by their agreement with you and any privacy statement they provide to you.
7.5. Objection – You have a right to object to the processing of your personal information.
You have a right to object to us processing your personal information (and to request us to restrict processing) for the purposes described in Section C of Schedule A – Purposes of Processing (below), unless we can demonstrate compelling and legitimate grounds for the processing, which may override your own interests, or where we need to process your information to investigate and protect us or others from legal claims. Depending on the circumstances, we may need to restrict or cease processing your personal information altogether or, where requested, delete your information. Please note that if you object to us processing your information, we may have to suspend the operation of your account and/or the products and services we provide to you.
7.6. Marketing – You have a right to object to direct marketing.
You have a right to object at any time to processing of your personal information for direct marketing purposes, including profiling you for the purposes of direct marketing.
7.7. Withdraw consent – You have to withdraw your consent.
Where we rely on your permission to process your personal information, you have a right to withdraw your consent at any time. We will always make it clear where we need your permission to undertake specific processing activities.
7.8. Lodge complaints – You have a right to lodge a complaint with the regulator.
If you wish to raise a complaint on how we have handled your personal information, you can contact our Data Protection Officer who will investigate the matter. We hope that we can address any concerns you may have, but you can always contact the Information Commissioner’s Office (ICO). For more information, visit ico.org.uk
8. How can you contact us
If you would like to contact us in relation to your rights or if you are unhappy with how we’ve handled your information, you can:
– phone us on 01932 221 209
– email us at firstname.lastname@example.org
– write to us: Pioneer Wall Cladding & Building Insulation Ltd., C/O Brayne, Williams & Barnard Limited Rosemount House, Rosemount Avenue, West Byfleet, Surrey, England, KT14 6LB
If you’re not satisfied with our response to any complaint or believe our processing of your information does not comply with data protection law, you can make a complaint to the Information Commissioner’s Office (ICO) using the following details:
Telephone number: 0303 123 1113