This is the privacy notice of GA Living Spaces Ltd. In this document, “we”, “our”, or “us” refer to GA Living Spaces Ltd. The company registered in England under company number 10968948.
This is a notice to inform you of our policy relating to all personal information that we record about you. It sets out the conditions under which we may process any information that we collect from you, or that you provide to us. In the context of the law and this notice, “process” means collect, store, transfer, use or otherwise act on information.
We take seriously the protection of your privacy and confidentiality. We understand that all visitors to our website and our showroom, and those that invite us into their property, are entitled to know that their personal data will not be used for any purpose unintended by them and will not accidentally fall into the hands of a third party.
We undertake to preserve the confidentiality of all information you provide to us and expect that you reciprocate with any personal data you receive about our employees and partners.
Our policy complies with UK law accordingly implemented, including that required by the EU General Data Protection Regulation (GDPR).
The law requires us to tell you about your rights and our obligations to you with regard to the processing and control of your personal data. We do this now, by requesting that you read the information provided at: www.knowyourprivacyrights.org
Except as set out below, we do not share, or sell, or disclose to a third party, any information collected through our website.
What is personal information?
Personal information means any information about you from which you can be identified. Examples of personal information include your name, home address, national insurance number, date of birth, telephone number and e-mail address but it also includes other pieces of information which can be used to identify you, either directly or indirectly, such as a cookie.
Who we are
GA Living Spaces Ltd is the controller and processor of data for the purposes of the GDPR.
We are not required to appoint a Data Protection Officer. However, the responsibilities of such an officer have been assumed by our Managing Director. These responsibilities include:
- handling reported data breaches and informing the ICO where necessary
- defining appropriate policies and procedures
- responding to data subject request to access the data we hold on them and correcting it where necessary.
If you have any questions about this Privacy Notice or the information we hold about you, please contact us at the address below:
GA Living Spaces Ltd, 5 Imperial Court, Laporte Way, Luton, Bedfordshire, England, LU4 8FE
Email address: firstname.lastname@example.org
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. We would however appreciate the chance to deal with your concerns before you approach the ICO, so please contact us in the first instance.
The bases on which we process information about you
The law requires us to determine under which of six defined bases we process different categories of your personal information, and to notify you of the basis for each category.
If a basis on which we process your personal information is no longer relevant, then we shall immediately stop processing your personal data.
If the basis changes then if required by law, we shall notify you of the change and of any new basis under which we have determined that we can continue to process your personal data.
1 Information we process with your consent
Through certain actions when otherwise there is no contractual relationship between us, such as when you browse our website or ask us to provide you more information about our business, including job opportunities and our services, you provide your consent to us to process information that may be personal data.
Sometimes you might give your consent implicitly, such as when you send us a message by e-mail to which you would reasonably expect us to reply.
Except where you have consented to our use of your personal data for a specific purpose, we do not use your information in any way that would identify you personally. We may aggregate it in a general way and use it to provide class information, for example to monitor the performance of a particular page on our website.
If you have given us explicit permission to do so, we may from time to time pass your name and contact information to selected associates whom we consider may provide services or products you would find useful.
We continue to process your information on this basis until you withdraw your consent, or it can be reasonably assumed that your consent no longer exists.
You may withdraw your consent at any time by instructing us at: GA Living Spaces Ltd, 5 Imperial Court, Laporte Way, Luton, Bedfordshire, England, LU4 8FE or email us at email@example.com.
However, if you do so, you may not be able to use our website or our services further.
2 Information we process because we have a contractual obligation with you
When you become a customer, by purchasing products or services from us, or otherwise agree to our terms and conditions, a contract is formed between you and us.
In order to carry out our obligations under that contract we may need to process the information you give us. Some of this information may be personal data.
We may use it in order to:
- verify your identity for security purposes
- carry out credit checks
- promote our services to you
- provide you with our services
- provide you with suggestions and advice on products and services.
We process this personal data on the basis there is a contract between us, or that you have requested we use the personal data before we enter into a legal contract.
Additionally, we may aggregate this information in a general way and use it to provide class information, for example to monitor our performance with respect to a particular service we provide. If we use it for this purpose, you as an individual will not be personally identifiable.
We shall continue to process this information under the terms of the contract.
3 Information we process because we have a legal obligation
We are subject to the law like everyone else. Sometimes, we must process your information in order to comply with a statutory obligation.
For example, we may be required to give information to legal authorities if they so request or if they have the proper authorisation such as a search warrant or court order.
This may include your personal data.
4 Information we process in order to protect your vital interests
The processing activity must be absolutely necessary and where you are unable to give your consent, e.g. life or death situations, and used as a last resort. An example would be if you collapsed in our showroom and we used your personal data to enable health professionals to access your medical records.
5 Information we process for the performance of a task carried out in the public interest
This condition allows for processing of data by public authorities and other bodies that exercise official authority and where that activity has a clear basis in. An example would be providing information on a service we are providing to you that requires liaison with a local authority, such as a planning department.
6 Information we process for the purposes of the purposes of the legitimate interests of us or our partners
We process personal information for a range of legitimate business purposes, including:
- to provide you with relevant information in relation to our products and services
- to provide you with relevant information relating to products and services you have purchased from us, including information about guarantees / warranties
- to improve our understanding on how people interact with our website
- recording calls for training and monitoring purposes
- recording CCTV images to protect our property.
Who we might share your personal information with
We engage external organisations to undertake a range of activities on our behalf, including to manage our financial accounts, to provide legal services, to carry out credit checks on our behalf, to run marketing campaigns, to provide our IT systems and to run our website.
We work in partnership with a range of third-party suppliers to assist us in delivering the products and services we have contracted to supply to you.
We only provide these business partners with the information relevant to their specific activities and they are prohibited from using it for any other purpose.
Data we collect and process
If you apply for a permanent or contract vacancy advertised by GA Living Spaces Ltd we collect information during the course of your application to join us. In order to process a job application, we require a significant range of information in relation to your identity, contact details, qualifications and work history.
We do not collect any special categories of personal data. This includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic or biometric data.
Consequences of not providing some types of information
Where we need to collect your personal information for recruitment purposes, and you fail to provide that information when requested or at application stage, we may not be able to proceed with your application. In this case we may have to withdraw your application.
How do we collect information about you?
Typically, we will collect information from you when you contact us directly or provide information in relation to career opportunities at GA Living Spaces Ltd. We collect information from and about you through direct interactions with you when you give us your personal information in discussion, by filling in forms or during correspondence with us. This includes when you:
- apply for a job from our website
- email us information
- meet with us in person
- speak with us by telephone
- provide information through online platforms
- complete questionnaires
How we will use your personal information
We obtain, use and keep personal information only where we need it for a specific purpose. We are only able to use your personal information if we have a proper legal reason or basis for doing so. These are listed below:
- to comply with our legal obligations, including the Employment Act
- where the processing is necessary for the purposes of our legitimate interests, such as assessing your suitability allocation to client projects
- where you gave given your consent for us to do so.
Most commonly we will use your information in the following ways:
- assessing your suitability for employment for the role for which you are applying, as well as future roles that may become available
- performing administrative functions (e.g. where applicable, refunding interview expenses)
- performing analysis of our applicant pool in order to better understand who is applying to positions at GA Living Spaces Ltd and how to attract top talent
- retaining your information on a database so that we can inform you in the future mailings about GA Living Spaces Ltd vacancies and events.
Who we share your information with
We may need to provide information to third parties for a variety of reasons, for example:
- previous employers
- referees provided by you
- background and financial checking agencies.
Sending your information outside of the EEA
The regulations which have been put in place to protect your privacy apply throughout the EEA. We may send your information to third parties who are based outside of the EEA, however we will only share your information with them because the following safeguards have been put in place:
- the country we send your information to is deemed to provide an adequate level of protection by the European Commission
- the information is being transferred between organisations which are engaged in the same economic enterprise, or within our corporate group, and we have an agreement in place which sets out how your privacy will be protected
- the entities we transfer your information to are based in the US and are part of the Privacy Shield which requires them to provide a similar level of protection to European standards.
Storing your information
We retain and use personal data collected during the recruitment process indefinitely in order to consider you for new positions, and, if appropriate, to refer back to an earlier application if you submit a CV or other information to us again in the future, as well as for system administration, to perform research and analysis, and to invite you to events.
CCTV in our showroom
GA Living Spaces Ltd trades from a showroom at Unit 6 Hullockpit Hill, Newnham Road, Nr Baldock, Hertfordhire, SG7 5DP.
Our landlord operates a CCTV system in the premises and uses the images gained to prevent or detect crime and to monitor the buildings and grounds in order to provide a safe and secure environment for its customers, visitors and staff.
The CCTV system comprises a number of fixed cameras which do not have sound recording capability.
CCTV collected data is undertaken in compliance with the Information Commissioner’s Office (ICO) CCTV Code of Practice to ensure that CCTV is used responsibly and safeguards both trust and confidence in its continued use. The Code of Practice is published at: https://ico.org.uk/media/1542/cctv-code-of-practice.pdf
CCTV warning signs are clearly and prominently placed at the main external entrance to the showroom, including further signage in other outdoor areas in close
Cameras are sited to ensure they only capture images relevant to the purposes for which they are installed (described above) and care is taken to ensure that reasonable privacy expectations are not violated.
Recorded data will not be retained for longer than is necessary. While retained, the integrity of the recordings will be maintained to ensure their evidential value and to protect the rights of the people whose images have been recorded.
All retained data will be stored securely at all times and permanently deleted as appropriate / required.
Access to recorded images is restricted to those staff authorised to view them, and will not be made more widely available.
Complaints regarding content on our website
We attempt to moderate user generated content, but we are not always able to do so as soon as that content is published.
If you complain about any of the content on our website, we shall investigate your complaint.
If we feel it is justified or if we believe the law requires us to do so, we shall remove the content while we investigate.
Free speech is a fundamental right, so we have to make a judgment as to whose right will be obstructed: yours, or that of the person who posted the content that offends you.
If we think your complaint is vexatious or without any basis, we shall not correspond with you about it.
When you contact us, whether by telephone, through our website or by e-mail, we collect the data you have given to us in order to reply with the information you need.
We record your request and our reply in order to increase the efficiency of our business.
We keep personally identifiable information associated with your message, such as your name and email address so as to be able to track our communications with you to provide a quality service.
When we receive a complaint, we record all the information you have given to us.
We use that information to resolve your complaint.
If your complaint reasonably requires us to contact some other person, we may decide to give to that other person some of the information contained in your complaint. We do this as infrequently as possible, but it is a matter for our sole discretion as to whether we do give information, and if we do, what that information is.
We may also compile statistics showing information obtained from this source to assess the level of service we provide, but not in a way that could identify you or any other person.
Cookies are small text files that are placed on your computer’s hard drive by your web browser when you visit any website. They allow information gathered on one web page to be stored until it is needed for use on another, allowing a website to provide you with a personalised experience and the website owner with statistics about how you use the website so that it can be improved.
Some cookies may last for a defined period of time, such as one day or until you close your browser. Others last indefinitely.
Your web browser should allow you to delete any you choose. It also should allow you to prevent or limit their use.
When you first visit our website, we inform you that continuing to use our website confirms your acceptance of cookies. Should you not wish to accept this you should prevent their use through your browser settings or leave the site.
- track how you use our website
- record whether you have seen specific messages we display on our website
- keep you signed in our site
- record your answers to surveys and questionnaires on our site while you complete them.
Personal identifiers from your browsing activity
Requests by your web browser to our servers for web pages and other content on our website are recorded. We record information such as your geographical location, your Internet service provider and your IP address. We also record information about the software you are using to browse our website, such as the type of computer or device and the screen resolution.
We use this information in aggregate to assess the popularity of the webpages on our website and how we perform in providing content to you. If combined with other information we know about you from previous visits, the data possibly could be used to identify you personally, even if you are not signed in to our website.
Information we obtain from third parties
Although we do not disclose your personal data to any third party (except as set out in this notice), we sometimes receive data that is indirectly made up from your personal information from third parties whose services we use.
Where we store your personal data
All information you provide via our website is stored on secure servers in the United Kingdom.
Access to your personal information
To obtain a copy of any personally identifiable information that we hold about you may send us a request at: GA Living Spaces Ltd, 5 Imperial Court, Laporte Way, Luton, Bedfordshire, England, LU4 8FE or email us at firstname.lastname@example.org.
After receiving the request, we will tell you when we expect to provide you with the information, and whether we require any fee for providing it to you.
Removal of your information
If you wish us to remove personally identifiable information from our website, you may contact us at GA Living Spaces Ltd, 5 Imperial Court, Laporte Way, Luton, Bedfordshire, England, LU4 8FE or email us at email@example.com.
This may limit the service we can provide to you.
Verification of your information
When we receive any request to access, edit or delete personal identifiable information we shall first take reasonable steps to verify your identity before granting you access or otherwise taking any action. This is important to safeguard your information.
Use of site by children
We do not sell provide services for purchase by children, nor do we market to children.
If you are under 18, you may use our website only with consent from a parent or guardian.
How you can complain
If a dispute is not settled, then we hope you will agree to attempt to resolve it by engaging in good faith with us in a process of mediation or arbitration.
If you are in any way dissatisfied about how we process your personal information, you have a right to lodge a complaint with the Information Commissioner’s Office. This can be done at: https://ico.org.uk/concerns/.
Retention period for personal data
Except as otherwise mentioned in this privacy notice, we keep your personal information only for as long as required by us to:
- provide you with the services you have requested;
- comply with other law, including for the period demanded by our tax authorities;
- support a claim or defence in court.
Compliance with the law
However, ultimately it is your choice as to whether you wish to use our website.
We may update this privacy notice from time to time as necessary. The terms that apply to you are those posted here on our website on the day you use our website. We advise you to print a copy for your records.
Privacy Notice – Processing of Personal Data September 2019