Agua Via Ltd (“AVL”) respects your privacy and is determined to protect your personal data. The purpose of this privacy notice is to inform you as to how we look after your personal data when you visit our website (regardless of where you visit it from). We’ll also tell you about your privacy rights and how the data protection law protects you.

1. WHO WE ARE AND IMPORTANT INFORMATION

What is the purpose of this privacy notice?

This privacy notice aims to give you information on how we collect and process your personal data through your use of this website.

This website is not intended for children and we do not knowingly collect data relating to children.

You must read this privacy notice together with any other privacy notice we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. This privacy notice supplements any other notices and is not intended to override them.

Controller

Agua Via Ltd (collectively referred to as " AVL " "we", "us" or "our" in this privacy notice) is the controller and responsible for your personal data collected & processed by us via this website. Our contact details are Agua Via Ltd, Garden Cottage, Hascombe Road, Godalming GU8 4AE, UK. Our Data Administrator can be contacted at this address or by email GDPR@aguavia.com

Third-party links outside of our control

This website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements.

When you leave our website, we encourage you to read the privacy notice of every website you visit.

2. THE PERSONAL DATA WE COLLECT ABOUT YOU

Personal data, or personal information, means any information about an individual from which that person can be identified. You can find out more about personal data from the Information Commissioners Office.

We may collect, use, store and transfer different kinds of personal data about you, as follows:

  • Identity Data includes your First Name, Last Name and the Company or business that

    you work for or represent.

  • Contact Data includes your Postal Address, Email Address and Telephone Number.

    We do not collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data). Nor do we collect any information about criminal convictions and offences.

    If you fail to provide personal data

    Where we need to collect your personal data by law, or in order to perform or enter into a contract with you and you fail to provide that data when requested, we may not be able to perform the contract or enter into it (for example, to provide you with goods or services). In this case, we may have to cancel a contract for a product or service you have with us but we will notify you if this is the case at the time.

3. HOW WE COLLECT YOUR PERSONAL DATA

We use different methods to collect data from and about you. You may give us your Identity and Contact data by filling in forms or by corresponding with us by post, phone, email, our website or otherwise. This includes personal data you provide when you:

  • Contact us to discuss our products and services

  • Send an inquiry via our website

3. HOW WE USE YOUR PERSONAL DATA

We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:

  • Performance of Contract this means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.

  • Legitimate Interest this means where necessary for the purposes of our legitimate interests in conducting and managing our business to enable us to give you the best service/product and the most secure online experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law

Comply with a legal or regulatory obligation this means processing your personal data where it is necessary for compliance with a legal or regulatory obligation that we are subject to.

PURPOSES FOR WHICH WE WILL USE YOUR PERSONAL DATA

We have set out below, in a table format, a description of all the ways we plan to use your personal data, with the legal bases we rely on to do so.
Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data.

To register your business as a (a) Identity Necessary for our legitimate
new customer (b) Contact interests (to be able to contact you)

Purpose/Activity

Type of data

Lawful basis for processing including basis of legitimate interest

To perform any contractual obligations we have with your company or you

(a) Identity (b) Contact

Necessary for our legitimate interest to be able to carry out business transactions with your company

To manage our relationship with you which will include:

(a) Notifying you about changes to our terms or privacy policy

(b) Asking you to leave a review or take a survey

(a) Identity (b) Contact

(a) Necessary to comply with a legal obligation

(b) Necessary for our legitimate interests (to keep our records updated and to study how customers use our products/services)

To make suggestions and recommendations to you about goods or services that may be of interest to you

(a) Identity (b) Contact

Necessary for our legitimate interests (to develop our products/services and grow our business)

In connection with a prospective sale of all or part of our business, company or assets or in connection with a corporate restructuring

(a) Identity (b) Contact

Necessary for our legitimate interests in ensuring continuity of business or the interests of the purchaser

Marketing

Individuals have a right to object to direct marketing at any time either by clicking on the unsubscribe link in the email or by contacting the Data Administrator at Garden Cottage, Hascombe Road, Godalming GU8 4AE, UK, or by emailing GDPR@aguavia.com

We have established the following personal data control mechanisms:

Promotional offers from us

We may use information about you or your company to form a view on what we think your company may want or need, or what will be of interest to your company. This is how we decide which products, services and offers may be relevant to your company. Inevitably such information is likely to contain personal details of contacts within your company.
Your business will receive marketing communications from us, via the contact details we have been provided, if you have requested information from us or purchased goods or services from us or if you provided us with your details when you entered a competition or registered for a promotion and, in each case, you have not objected to receiving such marketing.

Third-party marketing

We will get your express opt-in consent before we share your personal data with any company outside of AVL for marketing purposes.

Opting out

You can ask us to stop sending you marketing messages at any time by following the opt-out links on any marketing message sent to you or by emailing GDPR@aguavia.com at any time. Where you opt out of receiving these marketing messages, this will not prevent you from receiving relevant service-related communications in connection with a product/service purchase, warranty registration, product or service experience or other transactions.

Change of purpose

We will only use your personal data for purposes compatible with those for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose.

If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.

Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

4. WHO WE SHARE YOUR PERSONAL DATA WITH

We may have to share your personal data with the parties set out below for the purposes set out in the table in paragraph 4 above.

• External Third Parties Service, for example:

  • Suppliers which manufacture products or provide services to you on our behalf.

  • Professional advisers acting as controllers including lawyers, bankers, auditors and insurers based in the UK who provide consultancy, banking, legal, insurance and accounting services.

  • HM Revenue & Customs, regulators and other authorities acting as processors or controllers based in the United Kingdom who require reporting of processing activities in certain circumstances.

  • Third parties to whom we may choose to sell, transfer, or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy notice.

    We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.

5. INTERNATIONAL TRANSFERS

If you are located outside of the European Economic Area (EEA) then we will use your personal data as necessary in order to communicate with you and to conduct business with you or your company; this will involve a transfer of your personal data to your location. Apart from this, currently we do not share your personal data with any entity outside the European Economic Area (EEA). However, if that position changes, we will ensure that safeguards are put in place as required by data protection law.

7. DATA RETENTION

We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.
To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.

8. YOUR LEGAL RIGHTS

Unless subject to an exemption, under the data protection laws you have the following rights with respect to your personal data:

  • The right to request a copy of the personal data which we hold about you;

  • The right to request that we correct any personal data if it is found to be inaccurate or out of

    date;

  • The right to request your personal data is erased where it is no longer necessary to retain

    such data;

  • The right to withdraw your consent to the processing at any time, where consent was the

    lawful basis for processing your data;

  • The right to request that we provide you with your personal data and where possible, to

    transmit that data directly to another data controller, (known as the right to data portability), where applicable (i.e., where our

    processing is based on consent or is necessary for the performance of our contract with you or where we process your data by

    automated means);

  • The right, where there is a dispute in relation to the accuracy or processing of your personal

    data, to request a restriction is placed on further processing;

  • The right to object to our processing of personal data, where applicable, i.e. where

    processing is based on our legitimate interests (or in performance of a task in the public interest/exercise of official authority); direct marketing or processing for the purposes of scientific/historical research and statistics).

    If you wish to exercise any of the rights set out above, please contact our Data Administrator at Agua Via Ltd Garden Cottage, Hascombe Road, Godalming GU8 4AE, UK, or by emailing GDPR@aguavia.com

  • No fee required – with some exceptions

    You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable administration fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.

    What we may need from you

    We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

    Time limit to respond

    We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.

9. CHANGES TO THIS NOTICE AND YOUR DUTY TO INFORM US OF CHANGES

This version is the first version and is dated May 29, 2020
Please keep us informed if your personal data changes during your relationship with us. It is important that the personal data we hold about you is accurate and current.

10. QUERIES, REQUESTS OR CONCERNS

To exercise all relevant rights, queries or complaints in relation to this policy or any other data protection matter between you and us, please in the first instance contact our Data Administrator at Garden Cottage, Hascombe Road, Godalming GU8 4AE, UK, or by emailing GDPR@aguavia.com

If this does not resolve your complaint to your satisfaction, you have the right to lodge a complaint with the Information Commissioners Office on 03031231113 or via email https://ico.org.uk/global/contact-us/email/ or at the Information Commissioner's Office, Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF, England, UK.