1.1. Direct Source is a trading division of Golding Products LTD
1.2. This policy is applicable where we are acting as a data controller of personal data pertaining to our website visitors and service users.
1.3. A ‘Data Controller’ is defined as the party which determines the means and purpose of the processing of personal data.
1.4. ‘Personal Data’ is any information pertaining to an identifiable person (‘data subject’). The personal data may, directly or indirectly, be used to identify the data subject. Examples is a name, online identifier, identification number, graphic or location data.
1.5. Direct Source is the controller responsible for your (the ‘data subject’s’) data (collectively referred to as “we”, “us” or “our” within this document).
2. How we use your personal data
2.1. Within this section we have identified:
(a) The categories of personal data which we may process;
(b) The purposes for which we may process personal data; and
(c) The legal bases allowing this processing to occur.
2.2. We may process data regarding your use of our website and services (“usage data”). The usage data may include your IP address, geographical location, browser type, browser version, operating system, referral source, length of visit, page views, website navigation paths, as well as length, timing and frequency of your visits/service use. The sources of the usage are Google Analytics and Lead Forensics. This usage data is primarily processed for the purposes of analyzing use of the website and services. Secondary processing of the data may include the use of personal data to identify your interest in our products and services; and to identify you as a potential recipient of sales and marketing material. The legal basis for this processing is our legitimate interests, namely: monitoring and improving our website and services; and the expansion of our customer base.
2.3. We may process your account data (“company account data”). This data may include your name, address, email address and telephone number. The source of the data is you or your employer. The data may be processed for the purposes of operating our website, providing you with our services, maintaining website security, backing up our databases and website and communicating with you. The legal basis for this processing is the operation of a contract between you and us or steps being taken, at your request, to enter into a contact.
2.4. We may process your personal profile data (“profile data”). The source of the data is you or your employer. The data may include your name, address, telephone number and email address. The data may be processed for the purposes of enabling and monitoring your use of our website and services; maintaining website security; and backing up our databases and website. The legal basis for this processing is our legitimate interests, namely: administration and security of our website and business.
2.5. We may process your personal data which is provided during the use of our services (“service data”). Service data may include the products and services which we have provided you, artwork and data associated with those services, the products and services which our competitors have provided you. The source of the data is you or your employer. The data may be processed in order to provide you with our services, maintaining website security, maintaining back-ups of databases and our website and to communicate with you. The legal basis for this processing is our legitimate interests, namely: administration and security of our website and business; and service fulfillment.
2.6. We may process information that you post for publication on our website or through our services (“publication data”). The source of the data is yourself or your employer. The data may be processed for the purposes of enabling publication and the administration of our website. The legal basis for this processing is consent, namely your consent to publish data provided by yourself or your employer onto our website and other marketing materials. This data may be deleted upon your request, as it your legal right.
2.7. We may process information contained in any quote or enquiry you submit to us (“enquiry data”). This data may include your name, email address, telephone number, address, and graphics. This data may be processed in order to offer, sell and provide relevant goods and/or services to you or your employer. The legal basis for this processing is consent, namely your consent to take steps toward the establishment of a contract between you and us.
2.8. We may process information relating to transactions between you and us, including the purchase of goods and services, through our website (“transaction data”). This data may include your name, address, email address, telephone number, graphics and transaction details. The source of the data is yourself or your employer. The data may be processed for the purpose of offering, selling and the provision of goods and services to you; administration of our business, and to keep proper records of those transactions. The legal basis for this processing is the performance of a contract between you and us.
2.9. We may process information provided to us for the purpose of subscribing to our mailing list and/or sales calls and/or direct mailing list (“notification data”). The data may include your name, address, email address and telephone number. The supplier of the data is you or your employer. The data may be processed for the purposes of website administration, backing up of data-bases, maintenance of website security and to send you the relevant emails/direct mail/sales calls. The legal basis for this processing is consent, namely your consent for us to process this data to send you emails and/or direct mail and/or to include you in sales calls.
2.10. We may process information contained in or relating to any communication from you to us (“correspondence data”). The data may include the communication content, attachments, graphics and metadata associated with the communication. The supplier of the data is you or your employer. For digital communications meta data is generated at point of correspondence creation by (a) your email client (b) our website (c) a sub-processor such as Tideo Chat which may be used to host communications. The data may be processed for the purposes of communicating with you; administration of our website and business; the generation of company statistics; and record keeping. The legal basis for this processing ins our legitimate interests, namely the proper administration of our website and business and for communication with yourself and/or your employer.
2.11. We may process any of your personal data identified in this policy where necessary for the establishment, exercise or defense of legal claims. 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.
2.12. We may process any of your personal date 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 protection of you, our business and others against risks.
2.13. We may process any of your personal data identified in this policy where 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 person.
3. Providing your personal data to others
3.1. We ensure that any third party with whom your data is shared has sufficient privacy and data protection measures in place. All third parties are expected to be compliant with the GDPR from the 25th May 2018. Only data reasonably necessary for the purposes, and on the legal bases, set on in this policy will be shared with third parties.
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 advices, or the establishment, exercise or defense of legal claims.
3.3. We may disclose your name, address, telephone number, email address, and service data to our suppliers or sub-processors (any other company to whom we subcontract services) insofar as reasonably necessary to supply your goods/services (fulfil our contract).
3.4. Financial transactions relating to our website and services are handled by our payment services providers HSBC. We will share transaction data with our payment service providers only to the extent necessary for the purposes of processing your payments, refunding such payments and dealing with complaints and queries relating to such payments and refunds. You can find information regarding the payment services providers’ privacy policies and practices here …
3.5. In addition to the specific disclosures of personal data set out in section 3 of this policy, 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 person.
4. International transfers of your personal data
4.1. In this section, 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 occasionally work with printers and manufacturers outside of the EEA that we may use for the purposes of fulfilling a contract with the customer. Transfers to countries outside of the EEA will be protected by appropriate safeguards, measured against those safeguards listed within the GDPR.
4.3. Where the use of a sub-processor is necessary to fulfill an order, which is outside of the EEA and does not meet appropriate safeguards, no data will be transferred by us without the full and explicit consent from the customer.
4.4. You acknowledge that personal data that you submit for publication through our website or other marketing material may be accessible for reuse and/or misuse by third parties around the globe. We cannot prevent the use or misuse of personal data made publicly available with your consent.
5. Retaining and deleting personal data
5.1. This section 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 purposes shall not be kept for any longer than is necessary for those purposes.
5.3. We will retain your personal data as follows:
(a) Customer data will be retained for a maximum period of 10 years following our last contact.
(b) Prospect/web user data will be retained for a maximum of 5 years following our last contact
(c) Data pertaining to financial transactions are bound to be retained for a minimum of 7 years.
(d) After the periods outlined in (a) through (c) sufficient data shall be retained and suppressed to identify the data subject as evidence that further data has been deleted.
5.4. Notwithstanding the previous provisions of this section, 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 any other person/s.
6. Data Security
6.1. We have put in place appropriate security measures to prevent your personal data from being accidentally lost, misused, altered, disclosed or accessed in an unauthorized way.
6.2. We limit access to your personal data those employees, agents, contractors and other third parties who have a business need to know, only sharing or disclosing information for the performance of the contract between us and the customer. They will only process your personal data on our instructions and are subject to a duty of confidentiality.
7. Your Rights
7.1. In this section we have summarized the rights 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. We are not responsible for any misunderstanding stemming from reading only the summaries included in this policy.
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 request access to your personal data, together with certain additional information. That information includes details of the purposes of processing, the categories of data concerned, the recipients of the personal data and our legal rights by which we have processed the data. Providing the rights and freedoms of others are not affected, we will supply to you a copy of your personal data within 30 days of your request. 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 certain circumstance you have the right to erasure of your personal data without undue delay. Those circumstances include: the personal data is no longer necessary for the purposes for which they were collected or 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 having been unlawfully processed. However, exclusions to the right to erasure include: exercising the right to freedom of information and expression; compliance with a legal obligation; for the establishment, exercise or defense of legal claims.
7.6. In certain 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 to erasure; we no longer need the personal data for the purposes of our processing, but you require personal data for the establishment, exercise or defense 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 defense of legal claims; for the protection of the rights of another person; or for reasons of 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 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 n us; or the purposes of 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 defense 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 immediately cease to process your personal data for this purpose.
7.9. You have a right to object to our processing if your personal data for scientific, historical 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) Legitimate interest
(c) Necessary for the fulfilment of a contract with you, 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 data infringes upon data protection laws, you have a legal right to lode a complaint with a supervisory authority responsible for data protection. In the UK this will be the Information Commissioner’s Office (ICO).
7.12. To the extent that the legal basis for our processing of your personal data is consent, you have the right to withdraw that consent at any time. Withdrawal will not affect the lawfulness of processing before the withdrawal had occurred.
7.13. You may exercise any of your rights in relation to your personal data in writing to us at our registered office address.
8. Company Details
8.1. Our website is owned and operated by Golding Products LTD.
8.2. We are registered in England and Wales under the registration number 1846022, and our registered office is at Unit 24, Hortonwood 33, Telford, Shropshire, TF1 7YQ
8.3. Our principle place of business is at:
8.4. You can contact us:
(a) By post, to the postal address given above;
(b) Using our website contact form;
(c) By telephone on 01952 607 529
(d) By email, using email@example.com
9.1. We may update this policy from time to time by publishing a new version on our website.
9.2. You should check this page occasionally to ensure you are happy with any changes to this policy.