STEMM Commercial Limited ('STEMM') is committed to protecting and respecting your privacy.
This policy sets out the basis on which any personal data we collect from you, or that you provide to us, will be processed by us. Please read the following carefully to understand our views and practices regarding your personal data and how we will treat it. By visiting www.stemmcommercial.com and by providing personal data to us, you are accepting and consenting to the practices described in this policy.
For the purpose of the Data Protection Act 2018 and the General Data Protection Regulation (together ‘Data protection regulations’), the data controller is STEMM Commercial Limited.
We collect personal data about you to provide our services to you and develop our business in accordance with this policy (your ‘Personal Information’).
1. Personal Information we collect about you
The information you give us may include your names, company details, e-mail address and phone number. With regard to each of your visits to our site, we may also collect the following information:
We do not collect any ‘sensitive data’ (like racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership, genetic data, biometric data etc.) except when we have to comply with the law.
2. Where we collect your Personal Information
We principally collect information through your input, by filling in forms on our site www.stemmcommercial.com (our site), through face to face meetings or events or by corresponding with us by phone, social media or e-mail. We may also receive information related to you from other sources:
We do not sell your Personal Information or use it for any other purposes than those stated below.
3. How we use your Personal Information
We process your Personal Information to effectively run our business, for the following purposes:
Cookies may be used by us to provide you with customised information from our website. A cookie is an element of data that a website can send on your browser, which may then store it on your system. Cookies allow us to understand how you interact with our website and help us improve your user experience.
5. How we protect your Personal Information
We endeavour to take all reasonable steps to protect your Personal Information. We have implemented appropriate technical and organisational measures to ensure appropriate security of processing. Any shared files or folders are password controlled and agreed with clients in advance of sharing. Computer systems are protected by up-to-date anti-virus software (Bullguard) and encrypted. Access to your Personal Information by staff is protected by unique passwords. Our staff and associates are under strict obligations of confidentiality and only relevant staff has access to your data. We also have put in place a procedure to respond to data breaches and we will report it to you or to relevant authorities when required.
6. Where we store your Personal Information
Data collected by us is stored on secure hosted facilities at Microsoft (using Office365 and OneDrive). Links to Microsoft's services and privacy agreements can be found here. We also store information our customer relationship management system (CRM), Really Simple Systems. We may also use DropBox (DropBox Privacy Statement) to share files with you or work on current work.
We will only keep your Data for as long as is necessary for the purposes outlined in this policy, unless a longer retention period is required by legal, regulatory and accounting requirements. We have strict review and retention policies in place to meet these obligations and your Personal Information is kept for the length of a sales cycle (4 years).
7. Transfers and disclosures of your Personal Information
We may share your information with the following third parties:
When we share your Personal Information with third parties, we always ensure that we have appropriate safeguards in place to protect your privacy and that we share Personal Information in accordance with this policy and Data protection regulations.
We may disclose your Personal Information to third parties:
Where we have given you (or where you have chosen) a password which enables you to access certain relevant data, you are responsible for keeping this password confidential and we ask you to not share it with anyone.
Unfortunately, the transmission of information via the internet and electronically is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted to our website or electronically; any transmission is at your own risk. Once we have received your information, we will use strict procedures to prevent unauthorised access.
8. Your rights
You have the right to ask us not to process your personal data for marketing purposes. We will usually inform you (before collecting your data) if we intend to use your data for such purposes or if we intend to disclose your information to any third party for such purposes. You can exercise your right to prevent such processing by checking certain boxes on the forms we use to collect your data. You can also exercise the right at any time by contacting us at The Data Protection Manager, Sandford Gate, Eastpoint Business Park, Oxford OX4 6LB.
You have the right to access personal data we hold about you. This includes the right to ask us supplementary information about:
We will provide you with the data within one month of your request, unless doing so would adversely affect the rights and freedoms of others. We will tell you if we can’t meet your request for that reason.
You have the right to make us correct any inaccurate personal data about you. If you believe that any information we are holding on you is incorrect or incomplete, please write to email@example.com write to the address at the end of this policy. We will promptly correct any information found to be incorrect.
Our site may, from time to time, contain links to and from the websites of our partner networks, advertisers and affiliates. If you follow a link to any of these websites, please note that these websites have their own privacy policies and that we do not accept any responsibility or liability for these policies.
If, at any time, you want to verify, update, amend your personal data or exercise any other rights related to your personal data, please email us at firstname.lastname@example.org write to us at
The Data Protection Manager, STEMM Commercial, Sandford Gate, Eastpoint Business Park, Oxford OX4 6LB.
Last updated: 15th November 2018