We take your privacy very seriously. Please read this privacy policy carefully as it contains important information on who we are and how and why we collect, store, use and share your personal information. It also explains your rights in relation to your personal information and how to contact us or supervisory authorities in the event you have a complaint.
We collect, use and are responsible for certain personal information about you. When we do so we are subject to the General Data Protection Regulation, which applies across the European Union (including in the United Kingdom) and we are responsible as 'controller' or 'processor' (as applicable) of that personal information for the purposes of those laws.
This policy sets out the basis on which any personal information will be processed by us that: (i) where we are the data controller and we are entering into a contract with you that we collect from you or you have provided to us; or (ii) where we are the data processor, that is provided to us from an electrician (Electrician) to whom we provide Shine Forms software, Pirform software or a similar software app (Software) and for which we act as data processor pursuant to the terms of the Software agreement and data processing agreement with the Electrician.
It would be helpful to start by explaining some key terms used in this policy:
| We, us, our | Atlantic Business Solutions Ltd (CRN 09103764) whose registered office is at Building 2, 30 Friern Park, North Finchley, London N12 9DA |
| Personal information | Any information relating to an identified or identifiable individual |
| Special category personal information | Personal information revealing racial or ethnic origin, political opinions, religious beliefs, philosophical beliefs or trade union membership Genetic and biometric data Data concerning health, sex life or sexual orientation |
We may collect and use the following personal information about you:
your name and contact information, including email address and telephone number and company details
Information to enable us to check and verify your identity
your billing information
This personal information is required to provide services to you. If you do not provide personal information we ask for, it may delay or prevent us from providing services to you.
We collect most of this personal information directly from you in person, by telephone, text or email and/or via our website and Software.
However, we may also collect information:
from publicly accessible sources, e.g. Companies House.
from cookies on our website. For more information on our use of cookies, please see our cookie policy
Electricians enter customer data which may include personal information into the Software (to generate various certificates and forms (Forms)). This data is processed automatically within the Software to generate the Forms to enable the Electrician to perform the Electrician's obligations for customers. We have a data processing agreement in place with Electricians that use the Software. The Electrician is the data controller and we are the data processor and act only in accordance with the Electrician's instructions.
Under data protection law, we can only use your personal information if we have a proper reason for doing so, eg:
to comply with our legal and regulatory obligations;
for the performance of our contract with you or to take steps at your request before entering into a contract;
for our legitimate interests or those of a third party; or
where you have given consent.
A legitimate interest is when we have a business or commercial reason to use your information, so long as this is not overridden by your own rights and interests.
The table below explains what we use (process) your personal information for and our reasons for doing so:
| What we use your personal information for in the case of Electricians | Our reasons |
| to provide the Software. | For the performance of our obligations pursuant to the Software licence agreement |
| To prevent and detect fraud against you | For our legitimate interests or those of a third party, ie to minimise fraud that could be damaging for us and for you |
| Ensuring business policies are adhered to, e.g. policies covering security and internet use | For our legitimate interests or those of a third party, ie to make sure we are following our own internal procedures so we can deliver the best service to you |
| Operational reasons, such as improving efficiency, training and quality control | For our legitimate interests or those of a third party, ie to be as efficient as we can so we can deliver the best service for you at the best price |
| Ensuring the confidentiality of commercially sensitive information | For our legitimate interests or those of a third party, ie to protect trade secrets and other commercially valuable information To comply with our legal and regulatory obligations |
| Statistical analysis to help us manage our business, e.g. in relation to our financial performance, customer base, product range or other efficiency measures | For our legitimate interests or those of a third party, ie to be as efficient as we can so we can deliver the best service for you at the best price |
| Preventing unauthorised access and modifications to systems | For our legitimate interests or those of a third party, ie to prevent and detect criminal activity that could be damaging for us and for you To comply with our legal and regulatory obligations |
| Updating and enhancing customer records | For the performance of our contract with you or to take steps at your request before entering into a contract To comply with our legal and regulatory obligations For our legitimate interests or those of a third party, eg making sure that we can keep in touch with our customers about existing orders and new products |
| Statutory returns | To comply with our legal and regulatory obligations |
| Ensuring safe working practices, staff administration and assessments | To comply with our legal and regulatory obligations For our legitimate interests or those of a third party, e.g. to make sure we are following our own internal procedures and working efficiently so we can deliver the best service to you |
Marketing our services to:
| For our legitimate interests or those of a third party, ie to promote our business to existing and former customers |
| Credit reference checks via external credit reference agencies | For our legitimate interests or those of a third party, ie to ensure our customers are likely to be able to pay for our products and services |
| External audits and quality checks, e.g. for ISO or Investors in People accreditation and the audit of our accounts | For our legitimate interests or a those of a third party, ie to maintain our accreditations so we can demonstrate we operate at the highest standards To comply with our legal and regulatory obligations |
| What we use your information for in the case of customers of Electricians | Our reasons |
| Processing within our Software | For the performance of our obligations as data processor under the Software licence and data processing agreement with the Electrician. The information is processed within the Software which is situated on sub-contracted servers (see "where your personal information is held" below) to generate the Forms. |
The above table does not apply to special category personal information, which we will only process with your explicit consent.
Where we are the data controller (i.e. not in relation to customers of Electricians), we may use your personal information to send you updates (by email, text message, telephone or post) about our services, including exclusive offers, promotions or new services.
We have a legitimate interest in processing your personal information for promotional purposes (see above ' How and why we use your personal information '). This means we do not usually need your consent to send you promotional communications. However, where consent is needed, we will ask for this consent separately and clearly.
We will always treat your personal information with the utmost respect and never sell OR share it with other organisations for marketing purposes.
You have the right to opt out of receiving promotional communications at any time by:
contacting us at support@shineforms.co.uk
using the 'unsubscribe' link in emails
We may ask you to confirm or update your marketing preferences if you instruct us to provide further services in the future, or if there are changes in the law, regulation, or the structure of our business.
We share personal information with:
sub-contractors/suppliers (in relation to information provided to us by the Electricians we currently use Microsoft Azure platform for storage of our Software and Forms including the information captured within the Forms);
our insurers and brokers;
our banks;
We only allow our service providers to handle your personal information if we are satisfied they take appropriate measures to protect your personal information and it is necessary. We also impose contractual obligations on service providers relating to ensure they can only use your personal information to provide services to us and to you. We may also share personal information with external auditors, e.g. in relation to ISO or Investors in People accreditation and the audit of our accounts.
We may disclose and exchange information with law enforcement agencies and regulatory bodies to comply with our legal and regulatory obligations.
We may also need to share some personal information with other parties, such as potential buyers of some or all of our business or during a re-structuring. Usually, information will be anonymised but this may not always be possible. The recipient of the information will be bound by confidentiality obligations.
We will not share your personal information with any other third party.
Information may be held at our office and by our platform service providers, described above (see above: ' Who we share your personal information with ').
None of these third parties are based outside the European Economic Area.
In the case of Electricians:
We will keep your personal information while you have an account with us or we are providing services to you. Thereafter, we will keep your personal information for as long as is necessary:
to respond to any questions, complaints or claims made by you or on your behalf;
to show that we treated you fairly;
to keep records required by law.
We will not retain your personal information for longer than necessary for the purposes set out in this policy.
When it is no longer necessary to retain your personal information, we will delete or anonymise it.
In the case of customers of Electricians:
We will store data that we receive from Electricians in relation to individuals within the Forms for as long as is necessary for the performance of the contract in the capacity of data processor with the respective Electrician and as directed by the Electrician as the relevant Data Controller.
Electricians have the following rights, which you can exercise free of charge:
| Access | The right to be provided with a copy of your personal information (the right of access) |
| Rectification | The right to require us to correct any mistakes in your personal information |
| To be forgotten | The right to require us to delete your personal information---in certain situations |
| Restriction of processing | The right to require us to restrict processing of your personal information---in certain circumstances, e.g. if you contest the accuracy of the data |
| Data portability | The right to receive the personal information you provided to us, in a structured, commonly used and machine-readable format and/or transmit that data to a third party in certain situations |
| To object | The right to object:
|
| Not to be subject to automated individual decision making | The right not to be subject to a decision based solely on automated processing (including profiling) that produces legal effects concerning you or similarly significantly affects you |
For further information on each of those rights, including the circumstances in which they apply, please contact us or see the Guidance from the UK Information Commissioner's Office (ICO) on individuals' rights under the General Data Protection Regulation.
Please note that if we hold your personal information as the result of an Electrician inputting the personal information to generate Forms then we are a data processor and you should contact the Electrician as data controller, not us because we can only act on the instructions of the Electrician.
If you would like to exercise any of those rights, please:
email us (see below: 'How to contact us'); and
let us have enough information to identify you.
let us have proof of your identity and address (a copy of your driving licence or passport and a recent utility or credit card bill); and
let us know what right you want to exercise and the information to which your request relates.
We have appropriate security measures to prevent personal information from being accidentally lost, or used or accessed unlawfully. We limit access to your personal information to those who have a genuine business need to access it. Those processing your information will do so only in an authorised manner and are subject to a duty of confidentiality. We continually test our systems and are ISO 27001 certified, which means we follow top industry standards for information security.
We also have procedures in place to deal with any suspected data security breach. We will notify you and any applicable regulator of a suspected data security breach where we are legally required to do so.
If you want detailed information from Get Safe Online on how to protect your information and your computers and devices against fraud, identity theft, viruses and many other online problems, please visit www.getsafeonline.org. Get Safe Online is supported by HM Government and leading businesses.
We hope that we can resolve any query or concern you may raise about our use of your information.
The General Data Protection Regulation also gives you right to lodge a complaint with a supervisory authority, in particular in the European Union (or European Economic Area) state where you work, normally live or where any alleged infringement of data protection laws occurred. The supervisory authority in the UK is the Information Commissioner who may be contacted at https://ico.org.uk/concerns or telephone: 0303 123 1113.
This privacy notice was published on 01 August 2020.
We may change this privacy notice from time to time, when we do we will inform you via our website.
Please contact us at support@shineforms.co.uk if you have any questions about this privacy policy or the information we hold about you.