Holophane Europe Limited.

GDPR

Published October 2021


General

This Privacy Notice (“Notice”) addresses the processing of data of Holophane’s customers (“Customer Data”) by Holophane or a third party on behalf of Holophane. This Notice applies to the processing of Customer Data by electronic means. To fully understand your rights, we encourage you to read this Notice. This Notice may be changed without Customer consent, even though an amendment may relate to a benefit conferred on the customer. Any amendment shall enter into force after it has been approved and published. Holophane with its registered office at Bond Ave, Milton Keynes, MK1 1JG is responsible for processing of Customer Data as stated in this Notice.

If you have any questions about this notice, or wish to request a copy of the Data Subject Rights Request Form to have data removed then please contact the Privacy Officer: privacyofficer@holophane.co.uk


01 What categories of personal data do we process?

Below you will find an overview of the categories of personal data we process, what lawful ground the Company has to do this and for what purpose the data serves.

Category
Purpose
General company records
We need this information for our legitimate interest and the execution of the agreement with the customer.

E.g. Credit management, IT purposes (back-up & recovery)
Legal files / contracts and agreements
We need this information to comply with a legal obligation. It is also used for business process execution, internal management and management reporting.

E.g. IT purposes (back-up & recovery), litigations
Other records
We need this information for safety and security purposes.

E.g. CCTV recording
Payroll and salary records
We need this information to comply with a legal obligation.

E.g. IT purposes (back-up & recovery), litigations
Purchasing and sales records
We need this information for our legitimate interest and the execution of the agreement with the customer. E.g. Credit management, IT purposes (back-up & recovery)


02 How long do we retain your data

Holophane retains your data for no longer than is necessary for the purposes for which the data is processed. Other retention periods can be found in our Personal Data Retention Charter, by contacting
the Privacy Officer: privacyofficer@holophane.co.uk


03 Do we disclose your data to third parties?

Holophane discloses your data to third parties, please see the following list of third party categories used. Only the respective and relevant data is shared between each specific third party:

Category
Location
Internal accounts, HR & projects (parent company)
United States of America
Wage/Salary payments
EU
Pension management company
EU
Marketing/Trade show mailer company
EU
Distribution wholesale partners
EU
Contracted logistics delivery company
EU
Pension management company
EU
Selected recruitment agencies (when hiring)
EU
Agent partners (during sales process)
EU
Visitor ID badge entry system/company
EU
Lighting dashboard management company
EU
IT Support & Maintenance company
EU
Expense reporting company
EU


04 How do we secure your data?

Holophane handles your personal data with the greatest care. We have taken various technical and organisational measures to protect your personal data against misuse, loss, unauthorized access, undesirable disclosure and unauthorized modification. For more information, contact the privacy officer via email.


05 What are your rights?

You have the right to access, rectify or erase the personal data we processed about you. In addition, you have the right to restrict or object to the processing of your data and the right to data portability. This means that you can submit a request to us to send your personal data as a computer file to you or to another organization.

Holophane would also like to point out, that you have the right to lodge a complaint with the supervisory authority, the ICO.org. You can do this via the following link: www.ico.org.uk.