Privacy Notice

Introduction

Atmos International Limited (ICO registration 3044274)(“ATMOS”) takes your privacy very seriously. This Privacy Notice is intended to set out your rights and answer any queries you may have about your personal data. If you need more information, please contact: GDPR@Atmosi.com.

If you have entered into a contract with one of our subsidiaries or group companies, the controller of your data will be the Atmos company or companies stated in your contract and any additional consent you give us. In all other circumstances, the controller of your data will be Atmos International Limited (UK).

Our personal information handling policy and procedures have been developed in line with the requirements of the 1995 European Union Data Protection Directive (Directive 95/46/EC) and the General Data Protection Regulation (in force from 25 May 2018) and applicable national law.

1. What information do we collect?

We collect and process personal data about you when you interact with us and our products and when you purchase goods and services from us. The personal data we process includes:

  • your name;
  • your username and password;
  • your work address, email address and/or phone number;
  • your job title;
  • your payment and delivery details, including billing and delivery addresses and credit card details, where you make purchases from us;
  • information related to the browser or device you use to access our website;
  • internet browser and operating system;
  • recordings of calls you make to our customer service team;
  • and/or any other information you provide
  • Your name, job title, email, phone number, company and address, (“Contact Information”);
  • Pages and products viewed, emails from us that you opened, browser type, operating system ("OS"), Internet Protocol ("IP") address and device information (collectively, “Analytical Information”);

We may collect your Personal Information or usage data from third parties, including without limitation:

  • Your email address and other collected Personal Information about you may be forwarded to Atmos by a third-party website when you request for Atmos to contact you through such third-party website;
  • Your Personal Information may be forwarded to Atmos when you choose to participate in a third-party application or feature, such as live chat, one of our social media pages or a similar application or feature on a third-party website;
  • Additional Personal Information may be forwarded to Atmos from third parties to combine with the Personal Information we collect through your use of the Services in order to enhance our ability to serve you, to focus content we provide to you and to offer you opportunities to purchase products or services that we believe may be of interest to you based upon the information we have collected.

We will apply the terms of our Privacy Policy to any Personal Information received from a third party unless we have disclosed to you otherwise.  Atmos is not responsible for these third parties' dissemination of your Personal Information.

2. How do we use this information and what is the legal basis for this use?

We process the personal data listed in paragraph 1 above for the following purposes:

  • as required to establish and fulfil a contract with you, for example, if you make a purchase from us or enter into an agreement to provide or receive services. This may include verifying your identity, taking payments, communicating with you, providing customer services and arranging the delivery or other provision of products or services. We require this information in order to enter into a contract with you and are unable to do so without it;
  • to comply with applicable law and regulation;
  • in accordance with our legitimate interests in protecting Atmos’s legitimate business interests and legal rights, including but not limited to, use in connection with legal claims, compliance, regulatory and investigative purposes (including disclosure of such information in connection with legal process or litigation);
  • with your express consent to respond to any comments or complaints we may receive from you, and/or in accordance with our legitimate interests including to investigate any complaints received from you or from others, about our website or our products or services;
  • we may use information you provide to personalise (i) our communications to you; (ii) our website; and (iii) products or services for you, in accordance with our legitimate interests;
  • to monitor use of our websites and online services. We may use your information to help us check, improve and protect our products, content, services and websites, both online and offline, in accordance with our legitimate interests;
  • if you provide a credit or debit card, we may also use third parties (such as POS payment providers) to check the validity of the sort code, account number and card number you submit in order to prevent fraud, in accordance with our legitimate interests and those of third parties;
  • we may monitor any customer account to prevent, investigate and/or report fraud, terrorism, misrepresentation, security incidents or crime, in accordance with applicable law and our legitimate interests;
  • in circumstances where you contact us by telephone, calls may be recorded for quality, training and security purposes, in accordance with our legitimate interests; and 
  • we may use your information to invite you to take part in market research or surveys. 
  • Analytics: When you use the Services, we automatically collect and use non-identifying Analytical Information in order for us to continually improve user experience with our Services.
  • Marketing: We may use your Personal Information to determine what products may be of interest to you, provide you with marketing communications (if you have opted-in of such communications) and to conduct market research. We may also use information you provide us, including your industry, whether you own our product, experience with our products, and user-generated content, for these marketing purposes.

Internet cookies

We use cookies on this website to provide you with a better user experience. We do this by placing a small text file on your device / computer hard drive to track how you use the website, to record or log whether you have seen particular messages that we display, to keep you logged into the website where applicable, to display relevant adverts or content, referred you to a third-party website.

Some cookies are required to enjoy and use the full functionality of this website.

We use a cookie control system which allows you to accept the use of cookies, and control which cookies are saved to your device / computer. Some cookies will be saved for specific time periods, where others may last indefinitely. Your web browser should provide you with the controls to manage and delete cookies from your device, please see your web browser options.

Cookies that we use are;

  • Website cache to make the website load faster
  • Various non-identifying analytics cookies

Webchat platform

We may also send you direct marketing in relation to relevant products and services. Electronic direct marketing will only be sent where you have given your consent to receive it, or (where this is allowed) you have been given an opportunity to opt-out. You will continue to be able to opt-out of electronic direct marketing at any time by following the instructions in the relevant communication.

Email marketing messages & subscription

Under the GDPR we use the consent lawful basis for anyone subscribing to our newsletter or marketing mailing list. We only collect certain data about you, as detailed in the "Processing of your personal date" above. Any email marketing messages we send are done so through an EMS, email marketing service provider. An EMS is a third-party service provider of software / applications that allows marketers to send out email marketing campaigns to a list of users.

Email marketing messages that we send may contain tracking beacons / tracked clickable links or similar server technologies in order to track subscriber activity within email marketing messages. Where used, such marketing messages may record a range of data such as; times, dates, I.P addresses, opens, clicks, forwards, geographic and demographic data. Such data, within its limitations will show the activity each subscriber made for that email campaign.

Any email marketing messages we send are in accordance with the GDPR and the Privacy & Electronic Communications Regulation (PECR). We provide you with an easy method to withdraw your consent (unsubscribe) or manage your preferences / the information we hold about you at any time. See any marketing messages for instructions on how to unsubscribe or manage your preferences, you can also unsubscribe from all MailChimp lists, by following this link, otherwise contact the EMS provider.

Our EMS provider is MailChimp. We hold the following information about you within our EMS system;

  • Email address
  • I.P address
  • Subscription time & date
  • Company
  • Country

3. With whom and where will we share your personal data?

We may share your personal data with our subsidiaries to process it for the purposes of inter-group administration and to deliver products or services where elements of these are provided by group companies other than those with which you have directly contracted.

We may also share your personal data with the below third parties:

  • our professional advisors such as our auditors and external legal and financial advisors;
  • marketing and communications agencies where they have agreed to process your personal data in line with this Privacy Notice;
  • market research companies;
  • our suppliers, business partners and sub-contractors; and/or
  • search engine and web analytics.

Personal data may be shared with government authorities and/or law enforcement officials if required for the purposes above, if mandated by law or if needed for the legal protection of our legitimate interests in compliance with applicable laws. Personal data may also be shared with third party service providers who will process it on behalf of ATMOS for the purposes above. Such third parties include, but are not limited to, providers of website hosting, maintenance, call centre operation and identity checking.

In the event that our business or any part of it is sold or integrated with another business, your details will be disclosed to our advisers and those of any prospective purchaser and will be passed to the new owners of the business.

4. How long will you keep my personal data?

We will not keep your personal information for any purpose for longer than is necessary and will only retain the personal information that is necessary in relation to the purpose. We are also required to retain certain information as required by law or for as long as is reasonably necessary to meet regulatory requirements, resolve disputes, prevent fraud and abuse, or enforce our terms and conditions.

Where you are a customer, we will keep your information for the length of any contractual relationship you have with us plus 12 months after.

Where you are a prospective customer and you have expressly consented to us contacting you, we will only retain your data (a) until you unsubscribe from our communications; or, if you have not unsubscribed, (b) while you interact with us and our content; or (c) for 36 months from when you last interacted with us or our content.

In the case of any contact you may have with our customer services team, we will retain those details for as long as is necessary to resolve your query and for two weeks after the query is closed.

We will retain your data for a short time beyond the specified retention period, to allow for information to be reviewed and any deletion to take place. In some instances, laws may require ATMOS to hold certain information for specific periods other than those listed above.

5. Where is my data stored?

The personal data that we collect from you may be transferred to, and stored outside the European Economic Area (“EEA”).  It may also be processed by staff operating outside the EEA who work for us or for one of our suppliers, in which case the third country's data protection laws will have been approved as adequate by the European Commission or other applicable safeguards are in place. Further information may be obtained from our GDPR Team.

6. What are my rights in relation to my personal data?

You have the right to ask us not to process your personal data for marketing purposes. You can exercise your right to prevent such processing by checking certain boxes on the forms we use to collect your data, clicking the unsubscribe button on any communication we have sent to you or by contacting us.

Where you have consented to us using your personal data, you can withdraw that consent at any time.

If the information we hold about you is inaccurate or incomplete, you can notify us and ask us to correct or supplement it.

You also have the right, with some exceptions and qualifications, to ask us to provide a copy of any personal data we hold about you.

Where you have provided your data to us and it is processed by automated means, you may be able to request that we provide it to you in a structured, machine readable format.

If you have a complaint about how we have handled your personal data, you may be able to ask us to restrict how we use your personal data while your complaint is resolved. In some circumstances you can ask us to erase your personal data (a) by withdrawing your consent for us to use it; (b) if it is no longer necessary for us to use your personal data; (c) if you object to the use of your personal data and we don't have a good reason to continue to use it; or (d) if we haven't handled your personal data in accordance with our obligations.

7. Where can I find more information about Atmos’s handling of my data?

Should you have any queries regarding this Privacy Notice, about Atmos’s processing of your personal data or wish to exercise your rights you can contact Atmos’s GDPR Team using this email address: GDPR@Atmosi.com. If you wish to make a request for personal information under the General Data Protection Regulation (EU GDPR 2016/679), please click here. If you are not happy with our response, you can contact the Information Commissioner's Office:https://ico.org.uk/

Resources & further information

Issue Date: May 2018

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