Privacy

Privacy Policy

TORRIDON CPM PRIVACY POLICY

Last updated 21.05.18

Introduction
 

Torridon CPM is an independent Service provider whose business is in the provision of Project Management, Cost Consultancy and CDM Principal Designer Services to the Property and Construction Industry in the UK and Ireland.

Under the General Data Protection Regulation (GDPR) individuals have the right to be informed about how their Personal Data is being processed. The Regulation clearly stipulates that this must be done in a concise, transparent, intelligible and easily accessible form, using clear and plain language. You can find out more about GDPR at the ICOs website.

Torridon CPM are committed to safeguarding the privacy of our website visitors and service users.

This policy applies where we are acting as a data controller with respect to the personal data of all Torridon websites, and also for all customers and enquiries, in other words, where we determine the purposes and means of the processing of that personal data.

By using any of our websites and agreeing to this policy, you consent to our use of cookies in accordance with the terms of our separate Cookie Policy.

How we use your personal data
 

In this Section we have set out:

How we collect personal data

the general categories of personal data that we may process;

any data collected by cookies;

the purposes for which we may process personal data; and

the legal bases of the processing (for more details see our Terms and Conditions).

We collect and store personal data by carrying out our services and give examples of such collection activities as:

Providing a quote or tender for Works

Purchasing products or Services

You commission a service or are nominated as a contact point for a service we provide

You give us your details through networking, business card hand outs or via electronic communications via our website or social media platforms

Your Company or Project is targeted by us as a Potential Client via our Marketing Campaigns via publicly available information/printed or digital media sources

We may process data about your use of our website and services ("usage data"). This could be from cookies as you browse our websites without telling us who you are. 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 Google Analytics. This usage data may be processed for the purposes of analysing and improving the use of the website and services.

We collect personal data from potential, current and former clients/suppliers and other individuals with an interest in the property and construction industry to fulfil our stated purposes. The data routinely collected usually includes some or all of the following: Contact Name, Company Name, Office Address, Job Title, Telephone Number(s) and Email Address.

The legal basis for this processing under GDPR is our legitimate interests, namely work associated with cost planning, tendering, procurement, project management, cost management and CDM in relation to construction and renovations works. We do not collect any personal data from third party data vendors and do not sell any data to these organisations.

We may process your personal data ("personal data"). The personal data may include your name, email address and contact number. The source of the personal data is you. The personal data may be processed for the purposes of operating our website, providing our services such as Tendering, Cost Management, Project Management, ensuring the security of our website and services, maintaining back-ups of our databases and communicating with you. It is also used in a way we believe you should reasonably expect us to use the data which does not materially impact your rights, freedom or interests

The legal basis for this processing is our legitimate interests, namely the proper administration of our website and business.

We may process your information held in our database ("profile data"). The profile data may include your name, address, telephone number, email address and any additional information you provide, which may include details about your budget, project, area and your opinions, or your profession and employment details. The profile data may be processed for the purposes of enabling and monitoring your use of our website and services, for direct marketing purposes, where agreed to, and also may be aggregated to provide statistics about the sector and the process of Project Management, in which case all data will also be anonymized.

The legal basis for this processing is our legitimate interests, namely direct marketing for the benefit of the sector and people wishing to carry out property or construction works. The source of the profile data is you.

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 our legitimate interests, namely the proper administration of our website and business.

Providing your personal data to others

We may disclose your personal data to any member of our group of companies insofar as reasonably necessary for the purposes, and on the legal bases, set out in this policy.

In addition to the specific disclosures of personal data set out in this Section 4, 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.

Retaining and deleting personal data
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.

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.

We will retain the data you give us, for differing periods of time, dependent on the reason you have supplied it to us, whether there is a need to retain the data and in accordance with our data retention policy. All such time frames are guided by industry best practice and other relevant legislation.

Notwithstanding the other provisions of this Section5, 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.

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

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

Your rights
You may instruct us to provide you with any personal information we hold about you; provision of such information will be subject to:

(a)    the payment of a fee (currently fixed at GBP 15); and

(b)    the supply of appropriate evidence of your identity (for this purpose, we will usually accept a photocopy of your passport certified by a solicitor or bank plus an original copy of a utility bill showing your current address).

We may withhold personal information that you request to the extent permitted by law.

You may instruct us at any time not to process your personal information for marketing purposes. You can do this by emailing kenny@torridoncpm.co.uk

In practice, you will usually either expressly agree in advance to our use of your personal information for marketing purposes, or we will provide you with an opportunity to opt out of the use of your personal information for marketing purposes.

Cookies

In common with many other companies, we use standard technology called 'cookies' on our website. Cookies are small pieces of information that are stored by your browser on your computer's hard drive. They help us to collect statistical data about our users' browsing actions and patterns but they do not identify any individual. They enable us to:

Manage and develop our website e.g. to improve usability or measure the popularity of a given web page

Speed up your searches during subsequent visits

Most browsers are initially set to accept cookies; you do not need to use cookies to visit our website, but parts of the site may not work as intended if you don't. You may refuse to accept cookies by activating the appropriate setting on your browser (Note: turning cookies off at the browser level could disable cookies on ALL sites you visit, and therefore disable the functionality you rely on when visiting those sites).

Links to other websites

The Websites may contain links to other websites that are outside our control and are not covered by this privacy policy. If you access other sites using the links provided, the operators of these sites may collect information from you that will be used by them in accordance with their privacy policy, which may differ from ours.

Is any personal data stored or processed outside the European Economic Area (EEA)?

We use secure cloud-based services for hosting the data but none of this infrastructure is knowingly based outside the EEA. Like many small businesses we hold data on cloud servers and drives in various environments. We always select to work with reputable companies like Microsoft and Google who run those servers and we take every reasonable precaution to ensure that your data is kept safely and securely in as far as it would be reasonable for us to check the extent of the policies of those service providers.

Mail Fulfilment

To help us communicate with you, we use a web-based marketing automation platform called MailChimp to manage our communications, so by opting in to either Torridon CPM or Third-party contact at the point of registering with us you are agreeing to us:

Transferring your contact information to MailChimp

Storing your contact information in our MailChimp account

Sending marketing emails from our MailChimp account

Tracking interactions for email marketing and ad placement purposes

And, in the case of third party emails, sharing aggregated data (without personal contact information) for the purposes of monitoring and improving communications from a marketing perspective.

Our details

Our websites are owned and operated by Torridon CPM.

Torridon CPM (registered number SC557714) is registered in Scotland, whose registered office is at 81 Rhodes Park, North Berwick, EH39 5NA.

You can contact us:

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

(b)       by telephone, on 07763 910673; or

(c)       by email, using kenny@torridoncpm.co.uk

Data protection contact

To get in touch about data protection please contact kenny@torridoncpm.co.uk