1. Introduction

1.1 We are committed to safeguarding the privacy of our website users and customers.

1.2 This policy applies where we are acting as a data controller with respect to
the personal data of our website users and customers; in other words, where
we determine the purposes and means of the processing of that personal data.

1.3 We use cookies on our website. Insofar as those cookies are not strictly
necessary for the provision of our website users and customers, we will ask you to
consent to our use of cookies when you first visit our website.

1.4 Our website incorporates privacy controls which affect how we will process
your personal data. By using the privacy controls, you can specify whether you
would like to receive direct marketing communications and limit the publication of
your information.

1.5 In this policy, “we”, “us” and “our” refer to MPS Glass & Window Centre Ltd.

2. How we use your personal data

2.1 In this Section 2 we have set out:

(a) the general categories of personal data that we may process;

(b) In the case of personal data that we did not obtain directly from you, the
source and specific categories of that data.

(c) the purposes for which we may process personal data; and

(d) the legal bases of the processing.

2.2 We may process data about your use of our website and services (“usage
data”). The usage data may include your IP address, geographical location, browser
type and version, operating system, referral source, length of visit, page views and
website navigation paths, as well as information about the timing, frequency and
pattern of your service use. The source of the usage data is our analytics
tracking system. This usage data may be processed for the purposes of analysing
the use of the website and services. The legal basis for this processing is
our legitimate interests, namely monitoring and improving our website
and services.

2.3 We may process your account data (“account data”). The account data may
include your name and email address. The source of the account data is you. The account data may be processed for the purposes of operating
our website, providing our services, ensuring the security of our website and
services, maintaining back-ups of our databases and communicating with you. The
legal basis for this processing is our legitimate interests, namely
the proper administration of our website and business.

2.4 We may process your information included in your personal profile on our
website (“profile data”). The profile data may include your name, address,
telephone number, email address, profile pictures, gender, date of birth,
relationship status, interests and hobbies, educational details and employment
details. The profile data may be processed for the purposes of enabling and
monitoring your use of our website and services. The legal basis for this
processing is consent OR our legitimate interests, namely the proper
administration of our website and business OR the performance of a contract
between you and us and/or taking steps, at you request, to enter into such a
contract.

2.5 We may process your personal data that are provided in the course of the use
of our services (“service data”). The service data may include name, email address and telephone number.
The source of the service data is you or your employer. The service data may be
processed for the purposes of operating our website, providing our services,
ensuring the security of our website and services, maintaining back-ups of our
databases and communicating with you. The legal basis for this processing is
consent OR our legitimate interests, namely the proper administration of our
website and business OR the performance of a contract between you and us and/or
taking steps, at your request, to enter into such a contract .

2.6 We may process information that you post for publication on our website or
through our services (“publication data”). The publication data may be processed
for the purposes of enabling such publication and administering our website and
services. The legal basis for this processing is consent OR our legitimate
interests, namely the proper administration of our website and business OR the
performance of a contract between you and us and/or taking steps, at your request,
to enter into such a contract .

2.7 We may process information contained in any enquiry you submit to us
regarding goods and/or services (“enquiry data”). The enquiry data may be processed
for the purposes of offering, marketing and selling relevant goods and/or services
to you. The legal basis for this processing is consent .

2.8 We may process information relating to our customer relationships, including
customer contact information (“customer relationship data”). The customer
relationship data may include your name, your employer, your job title or role,
your contact details, and information contained in communications between us and you
or your employer. The source of the customer relationship data is you or your
employer. The customer relationship data may be processed for the purposes of
managing our relationships with customers, communicating with customers, keeping
records of those communications and promoting our products and services to
customers. The legal basis for this processing is consent OR our legitimate
interests, namely the proper management of our customer relationships

2.10 We may process information that you provide to us for the purpose of
subscribing to our email notifications and/or newsletters (“notification data”).
The notification data may be processed for the purposes of sending you the relevant
notifications and/or newsletters. The legal basis for this processing is consent
OR the performance of a contract between you and us and/or taking steps, at your
request, to enter into such a contract.

2.11 We may process information contained in or relating to any communication that
you send to us (“correspondence data”). The correspondence data may include the
communication content and metadata associated with the communication. Our website
will generate the metadata associated with communications made using the website
contact forms. The correspondence data may be processed for the purposes of
communicating with you and record-keeping. The legal basis for this processing is
our legitimate interests, namely the proper administration of our website and
business and communications with users .

2.12 We may process identify general category of data. This data may include
list specific items of data. The source of this data is identify source. This
data may be processed for specify purposes. The legal basis for this processing is
consent OR our legitimate interests, namely specify legitimate interests OR
the performance of a contract between you and us and/or taking steps, at your
request, to enter into such a contract .

2.13 We may process any of your personal data identified in this policy where
necessary for the establishment, exercise or defence of legal claims, whether in
court proceedings or in an administrative or out-of-court procedure. The legal
basis for this processing is our legitimate interests, namely the protection and
assertion of our legal rights, your legal rights and the legal rights of others.

2.14 We may process any of your personal data identified in this policy where
necessary for the purposes of obtaining or maintaining insurance coverage, managing
risks, or obtaining professional advice. The legal basis for this processing is our
legitimate interests, namely the proper protection of our business against risks.

2.15 In addition to the specific purposes for which we may process your personal
data set out in this Section 2, we may also process any of your personal data
where such processing is necessary for compliance with a legal obligation to which
we are subject, or in order to protect your vital interests or the vital interests
of another natural person.

2.16 Please do not supply any other person’s personal data to us, unless we prompt
you to do so.

3. Providing your personal data to others

3.1 We may disclose your personal data to any member of our group of companies
(this means our subsidiaries, our ultimate holding company and all its subsidiaries)
insofar as reasonably necessary for the purposes, and on the legal bases, set out in
this policy. Information about our group of companies can be found at URL.

3.2 We may disclose your personal data to our insurers and/or professional
advisers insofar as reasonably necessary for the purposes of obtaining or
maintaining insurance coverage, managing risks, obtaining professional advice, or
the establishment, exercise or defence of legal claims, whether in court proceedings
or in an administrative or out-of-court procedure.

3.3 We may disclose specify personal data category or categories to our
suppliers or subcontractors identified at URL insofar as reasonably necessary
for specify purposes.

3.5 We may disclose your enquiry data to one or more of those selected third
party suppliers of goods and services identified on our website for the purpose of
enabling them to contact you so that they can offer, market and sell to you
relevant goods and/or services. Each such third party will act as a data
controller in relation to the enquiry data that we supply to it; and upon contacting
you, each such third party will supply to you a copy of its own privacy policy,
which will govern that third party’s use of your personal data.

3.6 In addition to the specific disclosures of personal data set out in this
Section 3, we may disclose your personal data where such disclosure is necessary for
compliance with a legal obligation to which we are subject, or in order to protect
your vital interests or the vital interests of another natural person. We may also
disclose your personal data where such disclosure is necessary for the
establishment, exercise or defence of legal claims, whether in court proceedings or
in an administrative or out-of-court procedure.

4.1 In this Section 4, we provide information about the circumstances in which
your personal data may be transferred to countries outside the European Economic
Area (EEA).

4.2 We and our other suppliers have offices and facilities in specify
countries. The European Commission has made an “adequacy decision” with respect to
the data protection laws of each of these countries. Transfers to each of these
countries will be protected by appropriate safeguards, namely the use of standard
data protection clauses adopted or approved by the European Commission, a copy of
which can be obtained from source OR the use of binding corporate rules, a copy
of which you can obtain from source OR specify appropriate safeguards and means
to obtain a copy.

4.3 The hosting facilities for our website are situated in specify countries.
The European Commission has made an “adequacy decision” with respect to the data
protection laws of each of these countries. Transfers to each of these
countries will be protected by appropriate safeguards, namely the use of standard
data protection clauses adopted or approved by the European Commission, a copy of
which you can obtain from source OR specify appropriate safeguards and means to
obtain a copy.

4.4 Specify category or categories of supplier or subcontractor is OR are
situated in specify countries. The European Commission has made an “adequacy
decision” with respect to the data protection laws of each of these countries.
Transfers to each of these countries will be protected by appropriate safeguards,
namely the use of standard data protection clauses adopted or approved by the
European Commission, a copy of which can be obtained from source OR specify
appropriate safeguards and means to obtain a copy.

4.5 You acknowledge that personal data that you submit for publication through
our website or services may be available, via the internet, around the world. We
cannot prevent the use (or misuse) of such personal data by others.

5. Retaining and deleting personal data

5.1 This Section 5 sets out our data retention policies and procedure, which are
designed to help ensure that we comply with our legal obligations in relation to the
retention and deletion of personal data.

5.2 Personal data that we process for any purpose or purposes shall not be kept
for longer than is necessary for that purpose or those purposes.

5.3 We will retain your personal data as follows:

(a) personal data category or categories will be retained for a minimum period
of period following date, and for a maximum period of period following date.

5.4 In some cases it is not possible for us to specify in advance the periods for
which your personal data will be retained. In such cases, we will determine the
period of retention based on the following criteria:

(a) the period of retention of personal data category will be determined based
on specify criteria.

5.5 Notwithstanding the other provisions of this Section 5, we may retain your
personal data where such retention is necessary for compliance with a legal
obligation to which we are subject, or in order to protect your vital interests or
the vital interests of another natural person.

6. Amendments

6.1 We may update this policy from time to time by publishing a new version on
our website.

6.2 You should check this page occasionally to ensure you are happy with any
changes to this policy.

6.3 We may OR will notify you of changes OR significant changes to this
policy by email or through the private messaging system on our website.

7. Your rights

7.1 In this Section 7, we have summarised the rights that you have under data
protection law. Some of the rights are complex, and not all of the details have been
included in our summaries. Accordingly, you should read the relevant laws and
guidance from the regulatory authorities for a full explanation of these rights.

7.2 Your principal rights under data protection law are:

(a) the right to access;

(b) the right to rectification;

(c) the right to erasure;

(d) the right to restrict processing;

(e) the right to object to processing;

(f) the right to data portability;

(g) the right to complain to a supervisory authority; and

(h) the right to withdraw consent.

7.3 You have the right to confirmation as to whether or not we process your
personal data and, where we do, access to the personal data, together with certain
additional information. That additional information includes details of the purposes
of the processing, the categories of personal data concerned and the recipients of
the personal data. Providing the rights and freedoms of others are not affected, we
will supply to you a copy of your personal data. The first copy will be provided
free of charge, but additional copies may be subject to a reasonable fee.

7.4 You have the right to have any inaccurate personal data about you rectified
and, taking into account the purposes of the processing, to have any incomplete
personal data about you completed.

7.5 In some circumstances you have the right to the erasure of your personal data
without undue delay. Those circumstances include: the personal data are no longer
necessary in relation to the purposes for which they were collected or otherwise
processed; you withdraw consent to consent-based processing; you object to the
processing under certain rules of applicable data protection law; the processing is
for direct marketing purposes; and the personal data have been unlawfully
processed. However, there are exclusions of the right to erasure. The general
exclusions include where processing is necessary: for exercising the right of
freedom of expression and information; for compliance with a legal obligation; or
for the establishment, exercise or defence of legal claims.

7.6 In some circumstances you have the right to restrict the processing of your
personal data. Those circumstances are: you contest the accuracy of the personal
data; processing is unlawful but you oppose erasure; we no longer need the personal
data for the purposes of our processing, but you require personal data for the
establishment, exercise or defence of legal claims; and you have objected to
processing, pending the verification of that objection. Where processing has been
restricted on this basis, we may continue to store your personal data. However, we
will only otherwise process it: with your consent; for the establishment, exercise
or defence of legal claims; for the protection of the rights of another natural or
legal person; or for reasons of important public interest.

7.7 You have the right to object to our processing of your personal data on
grounds relating to your particular situation, but only to the extent that the legal
basis for the processing is that the processing is necessary for: the performance of
a task carried out in the public interest or in the exercise of any official
authority vested in us; or the purposes of the legitimate interests pursued by us or
by a third party. If you make such an objection, we will cease to process the
personal information unless we can demonstrate compelling legitimate grounds for the
processing which override your interests, rights and freedoms, or the processing is
for the establishment, exercise or defence of legal claims.

7.8 You have the right to object to our processing of your personal data for
direct marketing purposes (including profiling for direct marketing purposes). If
you make such an objection, we will cease to process your personal data for this
purpose.

7.9 You have the right to object to our processing of your personal data for
scientific or historical research purposes or statistical purposes on grounds
relating to your particular situation, unless the processing is necessary for the
performance of a task carried out for reasons of public interest.

7.10 To the extent that the legal basis for our processing of your personal data is:

(a) consent; or

(b) that the processing is necessary for the performance of a contract to which
you are party or in order to take steps at your request prior to entering into a
contract,

and such processing is carried out by automated means, you have the right to
receive your personal data from us in a structured, commonly used and
machine-readable format. However, this right does not apply where it would
adversely affect the rights and freedoms of others.

7.11 If you consider that our processing of your personal information infringes
data protection laws, you have a legal right to lodge a complaint with a supervisory
authority responsible for data protection. You may do so in the EU member state of
your habitual residence, your place of work or the place of the alleged
infringement.

7.12 To the extent that the legal basis for our processing of your personal
information is consent, you have the right to withdraw that consent at any time.
Withdrawal will not affect the lawfulness of processing before the withdrawal.

7.13 You may exercise any of your rights in relation to your personal data by
written notice to us OR by methods, in addition to the other methods specified
in this Section 7.

8. About cookies

8.1 A cookie is a file containing an identifier (a string of letters and numbers)
that is sent by a web server to a web browser and is stored by the browser. The
identifier is then sent back to the server each time the browser requests a page
from the server.

8.2 Cookies may be either “persistent” cookies or “session” cookies: a persistent
cookie will be stored by a web browser and will remain valid until its set expiry
date, unless deleted by the user before the expiry date; a session cookie, on the
other hand, will expire at the end of the user session, when the web browser is
closed.

8.3 Cookies do not typically contain any information that personally identifies a
user, but personal information that we store about you may be linked to the
information stored in and obtained from cookies.

9. Cookies that we use

9.1 We use cookies for the following purposes:

(a) authentication – we use cookies to identify you when you visit our website
and as you navigate our website (cookies used for this purpose are: identify
cookies);

(b) status – we use cookies to help us to determine if you are logged into our
website (cookies used for this purpose are: identify cookies);

(c) personalisation – we use cookies to store information about your
preferences and to personalise the website for you (cookies used for this purpose
are: identify cookies);

(d) security – we use cookies as an element of the security measures used to
protect user accounts, including preventing fraudulent use of login credentials, and
to protect our website and services generally (cookies used for this purpose are:
identify cookies);

(e) advertising – we use cookies to help us to display advertisements that will
be relevant to you (cookies used for this purpose are: identify cookies);

(f) analysis – we use cookies to help us to analyse the use and performance of
our website and services (cookies used for this purpose are: identify
cookies); and

(g) cookie consent – we use cookies to store your preferences in relation to
the use of cookies more generally (cookies used for this purpose are: identify
cookies).

10. Cookies used by our service providers

10.1 Our service providers use cookies and those cookies may be stored on your
computer when you visit our website.

10.2 We use Google Analytics to analyse the use of our website. Google Analytics
gathers information about website use by means of cookies. The information gathered
relating to our website is used to create reports about the use of our website.
Google’s privacy policy is available at: https://www.google.com/policies/privacy/.

11. Managing cookies

11.1 Most browsers allow you to refuse to accept cookies and to delete cookies. The
methods for doing so vary from browser to browser, and from version to version. You
can however obtain up-to-date information about blocking and deleting cookies via
these links:

(a) https://support.google.com/chrome/answer/95647?hl=en (Chrome);

(b)
https://support.mozilla.org/en-US/kb/enable-and-disable-cookies-website-preferences
(Firefox);

(c) http://www.opera.com/help/tutorials/security/cookies/ (Opera);

(d)
https://support.microsoft.com/en-gb/help/17442/windows-internet-explorer-delete-manage-cookies
(Internet Explorer);

(e) https://support.apple.com/kb/PH21411 (Safari); and

(f) https://privacy.microsoft.com/en-us/windows-10-microsoft-edge-and-privacy
(Edge).

11.2 Blocking all cookies will have a negative impact upon the usability of many
websites.

11.3 If you block cookies, you will not be able to use all the features on our
website.

12. Our details

12.1 This website is owned and operated by MPS Glass and Window Centre Ltd

12.2 We are registered in England and Wales under registration number number,
and our registered office is at Unit 1B Swift Units, Pound Ln, Exmouth EX8 4NP.

12.3 Our principal place of business is at Unit 1B Swift Units, Pound Ln, Exmouth EX8 4NP.

12.4 You can contact us:

(a) by post, to the postal address given above;

(b) using our website contact form;

(c) by telephone, on the contact number published on our website from time to
time; or

(d) by email, using the email address published on our website from time to
time.

13. Data protection officer

13.1 Our data protection officer’s contact details are: MPS Windows

Section 1: GDPR Introduction

Section 1.2

“Personal data” is defined in Article 4(1) of the GDPR:

“(1) ‘personal data’ means any information relating to an identified or identifiable
natural person (‘data subject’); an identifiable natural person is one who can be
identified, directly or indirectly, in particular by reference to an identifier such
as a name, an identification number, location data, an online identifier or to one
or more factors specific to the physical, physiological, genetic, mental, economic,
cultural or social identity of that natural person”.

Section 1.3

The inclusion of this statement in your privacy policy will not in itself satisfy
the requirements of the Privacy and Electronic Communications (EC Directive)
Regulations 2003 as regards consent to the use of cookies. Guidance concerning
methods of obtaining such consent is included on the Information Commissioner’s
website (http://www.ico.gov.uk).

Section 2: How we use your personal data

Article 13(1) of the GDPR provides that:

“(1) Where personal data relating to a data subject are collected from the data
subject, the controller shall, at the time when personal data are obtained, provide
the data subject with all of the following information: … (c) the purposes of the
processing for which the personal data are intended as well as the legal basis for
the processing; (d) where the processing is based on point (f) of Article 6(1), the
legitimate interests pursued by the controller or by a third party”.

Article 6(1)(f) of the GDPR provides that:

“(1) Processing shall be lawful only if and to the extent that at least one of the
following applies: … (f) processing is necessary for the purposes of the
legitimate interests pursued by the controller or by a third party, except where
such interests are overridden by the interests or fundamental rights and freedoms of
the data subject which require protection of personal data, in particular where the
data subject is a child.”

Section 2.1

Article 14 of the GDPR, which applies where personal information is not obtained
from the data subject, provides that information about “the categories of personal
data concerned” must be supplied to data subjects.

Article 13 of the GDPR, which applies where personal information is obtained from
the data subject, does not include an equivalent provision.

Nonetheless, we have included references to general categories of data in this
document, because this facilitates the identification of particular purposes of
processing and the legal bases of processing – information which does need to be
provided under Article 13.

Section 3: Providing your personal data to others

Article 13(1)(e) of the GDPR requires that where personal data are collected from
the data subject, the data controller must provide the data subject with information
about “the recipients or categories of recipients of the personal data”.

Equivalent rules for data collected from someone other than the data subject are in
Article 14(1)(e).

Section 4: International transfers of your personal data

Article 13(1)(f) of the GDPR requires that data controllers disclose to data
subjects “where applicable, the fact that the controller intends to transfer
personal data to a third country or international organisation and the existence or
absence of an adequacy decision by the Commission, or in the case of transfers
referred to in Article 46 transfers subject to appropriate safeguards or 47
binding corporate rules, or the second subparagraph of Article 49(1) limited
transfers for compelling legitimate interests, reference to the appropriate or
suitable safeguards and the means by which to obtain a copy of them or where they
have been made available”.

Section 5: Retaining and deleting personal data

Article 5(1)(e) of the GDPR sets out the storage limitation, one of the fundamental
rules of the regime:

“Personal data shall be: … kept in a form which permits identification of data
subjects for no longer than is necessary for the purposes for which the personal
data are processed; personal data may be stored for longer periods insofar as the
personal data will be processed solely for archiving purposes in the public
interest, scientific or historical research purposes or statistical purposes in
accordance with Article 89(1) subject to implementation of the appropriate technical
and organisational measures required by this Regulation in order to safeguard the
rights and freedoms of the data subject … “.

Section 7: Your rights

Article 13(2) of the GDPR provides that, where personal data is collected from a
data subject, certain information about data subject rights must be provided:

“In addition to the information referred to in paragraph 1, the controller shall, at
the time when personal data are obtained, provide the data subject with the
following further information necessary to ensure fair and transparent processing:
… (b) the existence of the right to request from the controller access to and
rectification or erasure of personal data or restriction of processing concerning
the data subject or to object to processing as well as the right to data
portability; (c) where the processing is based on point (a) of Article 6(1) or point
(a) of Article 9(2), the existence of the right to withdraw consent at any time,
without affecting the lawfulness of processing based on consent before its
withdrawal; …”.

Similar provisions are set out in Article 14 in relation to personal data which is
not collected from the relevant data subject.

Section 7.3

The right to access is set out in Article 15 of the GDPR.

Section 7.4

The right to rectification is set out in Article 16 of the GDPR.

Section 7.5

The right to erasure (or right to be forgotten) is set out in Article 17 of the
GDPR, and must be notified to data subjects under Articles 13(2)(b), 14(2)(c) and
15(1)(e) of the GDPR.

Consider modifying the highlighted circumstances and exclusions, depending upon what
will be most relevant to your processing.

Section 7.6

Article 18(1) of the GDPR states:

“The data subject shall have the right to obtain from the controller restriction of
processing where one of the following applies: (a) the accuracy of the personal data
is contested by the data subject, for a period enabling the controller to verify the
accuracy of the personal data; (b) the processing is unlawful and the data subject
opposes the erasure of the personal data and requests the restriction of their use
instead; (c) the controller no longer needs the personal data for the purposes of
the processing, but they are required by the data subject for the establishment,
exercise or defence of legal claims; (d) the data subject has objected to processing
pursuant to Article 21(1) pending the verification whether the legitimate grounds of
the controller override those of the data subject.

Section 7.7

The right to object to processing is detailed in Article 21 of the GDPR, and must be
notified to data subjects under Articles 21(4), 13(2)(b) and 14(2)(c).

Article 21(3) of the GDPR states:

“Where the data subject objects to processing for direct marketing purposes, the
personal data shall no longer be processed for such purposes.”

This right is set out in Article 21(6) of the GDPR.

Section 7.10

The right to data portability is set out in full in Article 20 of the GDPR, and must
be notified to data subjects under Articles 13(2)(b) and 14(2)(c).

Section 7.11

The right to lodge a complaint with a supervisory authority is set out in Article 77
of the GDPR, and must be notified to data subjects under Articles 13(2)(d), 14(2)(e)
and 15(1)(f).

Section 7.12

Article 7(3) of the GDPR sets out the right of withdrawal. The right must be
notified to data subjects under Articles 13(2)(c) and 14(2)(d). See also Article
17(1)(b).