Please also see the section entitled “Glossary” below for further information on the meaning of some of the terms used in this policy.
Important Information & Who We Are
This policy provides you with information on how Everest 2020 Limited collects and makes use of or “processes” your Personal Data in the following circumstances:
- When you submit an enquiry through our website;
- When you submit an enquiry through the chatbot function on our website;
- When you submit an enquiry via SMS text;
- When you submit an enquiry to any of our social media profiles;
- When you complete and submit feedback forms on our website;
This website is not intended for children, and we do not knowingly collect Personal Data relating to children.
Everest 2020 Limited is, for the purposes of data protection legislation, the Data Controller in relation to any and all Personal Data which you may provide to us.
If you have any questions about this policy, including any requests to exercise your legal rights as a Data Subject, please contact our Data Protection Team using the details set out below.
If you have any questions about this policy or our privacy practices, please contact our Data Protection Team in the following ways:
Full name of legal entity: Everest 2020 Limited - Registered Company Number 12534543
Email address: firstname.lastname@example.org
Postal address: Data Protection, Building 1, Albany Place, Welwyn Garden City, AL7 3BT
You have the right to make a complaint at any time to the Information Commissioner's Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO, so please do contact our DPO in the first instance.
Changes to this policy and your duty to inform us of any changes to your Personal Data
We keep this policy under regular review. This version was last updated on 27 May 2021.
It is important that the Personal Data we hold about you is accurate and current. Please keep us informed if your Personal Data changes during your relationship with us.
We ask that you provide us in return with some information about you to enable us to meet the above purposes. We may ask you for more such information from time to time, and we will store this information with information we already keep about you. You may change, update or remove it at any time in accordance with this policy.
Personal Data which we may collect about you, and how we use it
“Personal Data”, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous 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:
- Where we need to perform the contract we are about to enter into or have entered into with you.
- Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
- Where we need to comply with a legal obligation.
We may collect, use, store and transfer different kinds of Personal Data from and about you through a number of different methods, as set out below:
|Source of data||Categories of personal data||Lawful basis|
|Customer||Website enquiry||Name, address, telephone number(s), email address, enquiry details||Legitimate interest: to respond to your enquiry, e.g. for a quote|
|Customer||Webchat enquiry||Name, other information needed to identify you as a customer, record of webchat conversation||Legitimate interest: to assist you on the chat, quality assurance, legal and compliance, and for training and monitoring|
|Customer||Text enquiry||Mobile number, other information needed to identify you as a customer, record of text conversation||Legitimate interest: to assist you via text, quality assurance, legal and compliance, and for training and monitoring|
|Customer||Website visit||Technical information such as IP address, location data (see Cookies Policy)||Consent or legitimate interest (please see our Cookies Policy)|
|Customer||Social media enquiry||Profile information, preferences, interactions via social media (e.g. Facebook. Instagram, Twitter etc)||Legitimate interest: to respond to your enquiry|
|Customer||Feedback form on the website||Name, address, telephone number(s), email address, feedback form content||Legitimate interest: to help us improve our products and services|
Please see above to find out more about the types of lawful basis upon which we rely to process your Personal Data. We will usually get your consent before sending direct marketing communications to you when purchasing goods and services from us, and otherwise will rely upon legitimate interest when you book an appointment with our contact centre. We will in any event provide you with further information in relation to how we use your personal data as and when you book an appointment via a telephone call to our contact centre. You have the right to withdraw any consent to marketing provided when purchasing our goods and services at any time by contacting us.
Please 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. Please contact us if you need details about the specific legal ground we are relying on to process your Personal Data where more than one ground has been set out in the table above.
Other than through direct interactions, we may also collect Personal Data about you from:
- Third parties or publicly available sources. We will receive Personal Data about you from various third parties and public sources as set out below.
We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data could be derived from your Personal Data but is not considered Personal Data in law as this data will not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect Aggregated Data with your Personal Data so that it can directly or indirectly identify you, we treat the combined data as Personal Data which will be used in accordance with this policy.
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.
Where we need to collect Personal Data by law, or under the terms of a contract we have with you, and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with goods or services). In this case, we may have to cancel a product or service you have with us but we will notify you if this is the case at the time.
We will only use your Personal Data for the purposes for which we collected it as referred to above, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.
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.
We strive to provide you with choices regarding certain Personal Data uses, particularly around marketing and advertising. We may use your Personal Data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which products, services and offers may be relevant for you.
You will receive marketing communications from us if you have requested information from us, purchased goods or services from us and you have not opted out of receiving that marketing.
We will never sell or provide your Personal Data to third parties for marketing purposes.
You can ask us or to stop sending you marketing messages at any time by following the opt-out links on any marketing message sent to you or by contacting us; either by telephone, post or by e-mail at email@example.com and insert "unsubscribe" or "stop" as the appropriate subject heading.
Where you opt out of receiving these marketing messages, this will not apply to Personal Data provided to us as a result of a product/service purchase, warranty registration, product/service experience or other transactions.
Who we may share your Personal Data with
We may share your Personal Data with external organisations solely to carry out services on our behalf and for the purposes described above. We and they are legally obliged to process your Personal Data in accordance with our instructions and data protection obligations, and to put in place contractual and other security measures that protect your Personal Data. They cannot use any of your Personal Data for their own purposes, including marketing.
The main functions that are or may be carried out by external organisations are as follows:
- Sales and installation of our products
- Payment processing
- IT and database management
- Web hosting, online content services and data storage
- Data analytics and data cleansing
- Legal and compliance-related services
We may also share your Personal Data with 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 policy.
Your Personal Data may leave the UK and European Economic Area to facilitate the above functions. Where this happens, we ensure that your Personal Data is protected using standard contractual clauses, which are standardised contracts that guarantee that your Personal Data is protected to the same standard that it is in the UK.
If you wish to see a copy of these contracts, please contact us using the contact information contained within this policy.
How long we will use your Personal Data for
Whenever we collect or process your Personal Data, we'll only keep it for as long as is reasonably necessary for the purpose for which it was collected, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your Personal Data for a longer period in the event of a complaint, or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.
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, regulatory, tax, accounting or other requirements.
At the end of that retention period, your data will either be deleted completely or anonymised, for example by aggregation with other data, so that it can be used in a non-identifiable way for the purposes of statistical analysis and business planning.
By law, we have to keep basic information about our customers for [six] years after they cease being customers for [tax] purposes.
In some circumstances you can ask us to delete your data: see your legal rights below for further information.
In some circumstances, we will anonymise your Personal Data (so that it can no longer be associated with you) for research or statistical purposes, in which case we may use this information indefinitely without further notice to you.
How we protect your Personal Data
We have put in place appropriate security measures to prevent your Personal Data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your Personal Data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your Personal Data on our instructions and they are subject to a duty of confidentiality.
We have put in place procedures to deal with any suspected Personal Data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.
We always hold your Personal Data securely and to prevent unauthorised disclosure or access to your Personal Data, we have implemented strong security safeguards including operating our website over the https protocol. We also follow stringent procedures to ensure we work with all Personal Data in line with current data protection legislation.
Your legal rights
It is important that the Personal Data we hold about you is accurate and current. Please keep us informed if your Personal Data changes during your relationship with us.
Your rights over your Personal Data
Under certain circumstances, you have rights under data protection laws in relation to your personal data.
You have the right to:
- Request access to your personal data (commonly known as a "data subject access request"). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
- Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
- Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
- Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
- Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios:
- If you want us to establish the data's accuracy.
- Where our use of the data is unlawful but you do not want us to erase it.
- Where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims.
- You have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
- Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
- Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent in relation to our use of personal data to provide our services, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.
If you wish to exercise any of the rights set out above, please contact our Data Protection Team using the contact details above.
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 fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we could refuse to comply with your request in these circumstances.
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.
We try to respond to all legitimate requests within one month. Occasionally it could 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.
“Legitimate Interest” means the interest of our business in conducting and managing our business to enable us to give you the best service/product and the best and most secure 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). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us.
“Performance of Contract” 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.
“Comply with a legal obligation” means processing your personal data where it is necessary for compliance with a legal obligation that we are subject to.