Privacy Policy

Welcome to the ECI Group privacy notice.

ECI Group comprises Engineers and Constructors International, Inc. (ECI), Simon Carves Engineering Ltd (SCEL) and International Technical Excellence Centers LLC (ITEC), collectively referred to as ECI Group.

ECI Group (“we”, “us” or “our”) respects your privacy and is committed to protecting your personal data. This privacy notice will inform you as to how we look after your personal data, including when you visit our website www.ecigrouponline.com (“our Site”), (regardless of where you visit it from), provide it by other means, apply for a job with us or make an enquiry, as well as informing you about your privacy rights and how the law protects you.

1. IMPORTANT INFORMATION AND WHO WE ARE

Purpose of this privacy notice

This privacy notice aims to give you information on how ECI Group collects and processes your personal data.  This will include any data you may provide to us when you purchasing our products and/or services, submit an enquiry with us or when you share this information to us by email, telephone, mail, in person or otherwise. For clients, this will include employee contact details for the purpose of providing our services to you.

Our site is not intended for children and we do not knowingly collect data relating to children.

It is important that you read this privacy notice together with any other privacy notice or fair processing 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 the other notices and is not intended to override them.

If you are an employee of ours, then we may have a separate privacy notice explaining how we process your data, which is available from the HR Department on request.

Controller

Simon Carves Engineering Ltd is the controller and responsible for your personal data.

We have appointed a data privacy manager (DPM) who is responsible for overseeing questions in relation to this privacy notice. If you have any questions about this privacy notice, including any requests to exercise your legal rights, please contact the DPM using the details set out below.

Contact details

Our full details are:

Full name of legal entity:           Simon Carves Engineering Ltd

Email address:                           info@ecigrouponline.com; subject “Data Privacy”

Postal address:                          Simon Carves Engineering Ltd, 2nd Floor, M.I.O.C, Styal Road, Manchester, M22 5WB, United Kingdom

Telephone number:                   +44 (0)161 718 4400

Should you have any concerns, we would appreciate the chance to deal with them in the first instance. If you would like to speak to us in relation to any concerns you have, please contact us.

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 (http://www.ico.org.uk).

Changes to the privacy notice and your duty to inform us of changes

This version was last updated on 10^th March 2020 and historic version can be obtained by contacting us.

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.

Third-party links

This site 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 DATA WE COLLECT ABOUT YOU

Personal data, or personal information, 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 may collect, use, store and transfer different kinds of personal data that you give us through our site or by using our applications, corresponding with us by phone, e-mail or otherwise about you which we have grouped together as follows:

• Identity Data includes first name, middle name, maiden name, last name, username or similar identifier.
• Contact Data includes billing address, delivery address, email address and telephone numbers.
• Financial Data includes bank account and payment card details.
• Transaction Data includes details about payments to and from you and other details of products and/or services you have purchased from us.
• Technical Data includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system, referral source and platform and other technology on the devices you use to access this website.
• Profile Data includes your CV and work experience, business development and networking information, your interests, preferences, feedback and survey responses, employment history, salary, references and referees, benefits package, professional development, training, professional memberships, business plan, disciplinary details and proceedings, skills and attributes, education details, qualifications and other similar information.
• Usage Data includes information about how you use our site and products and services including but not limited to length of visit, page views, website navigation paths as well as information about the timing, frequency and pattern of service use.
• Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.

We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data may be derived from your personal data but is not considered personal data in law as this data does 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 privacy notice.

Special Category we do not usually 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 usually collect any information about criminal convictions and offences.  In the event we are required, or believe we need to process this data, we will obtain your consent in advance.

If you fail to provide personal data

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 products). In this case, we may be unable to process an order for a product and/or service or we may have to cancel a product and/or service you have ordered with us but we will notify you if this is the case at the time.

3. HOW IS YOUR PERSONAL DATA COLLECTED?

We use different methods to collect data from and about you including through:

Direct interactions. You may give us your Identity, Contact and Financial Data by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you;

• place an order for our products;
• subscribe to our newsletters;
• interact with us and our social media;
• submit an enquiry to us regarding our products and/or services;
• request marketing to be sent to you;
• apply for a job; or
• give us some feedback.

Automated technologies or interactions. As you interact with our website, we may automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies and other similar technologies. We may also receive Technical Data about you if you visit other websites employing our cookies. Please see below for further details on cookies.

Third parties or publicly available sources. We may receive personal data about you from various third parties as set out below:

• Technical Data from the following parties:
  • analytics providers such as Google; and
  • search information providers.
• Contact, Financial and Transaction Data from providers of technical, payment and delivery services, including PayPal, Visa, Mastercard and Banks.
• Identity and Contact Data from publicly availably sources.

4. 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:

• 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 or regulatory obligation; and
• to the purchaser (or prospective purchaser) of any business or asset that we are (or are contemplating) selling.

Generally, we do not rely on consent as a legal basis for processing your personal data.

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, and which of the legal bases we rely on to do so.  We have also identified what our legitimate interests are where appropriate (please see paragraph 11 (Glossary) for a definition of legitimate interest).

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 below.

Marketing

We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising.

Promotional offers from us

We may use your Identity, Contact, Technical, Usage and Profile 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 (we call this marketing).

You will receive marketing communications from us if you have requested information from us, purchased products from us or you work at a Company and/or business we believe may be interested in our products, and, in each case, you have not opted out of receiving that marketing.

Third-party marketing

We do not share your personal data with any company outside of ECI Group companies for marketing purposes.

Opting out

You can ask us or third parties to stop sending you marketing messages at any time by contacting us.

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 and/or service purchase, warranty registration, product experience or other transactions with us.

Client Communications

We do not collect client personal data for our clients, beyond business emails and telephone number of you or your employees, as well as recording a history of contact.

We rely on legitimate interest to store and use this information, because we need to communicate with you in order to provide services and perform our functions, as well as responding to requests for information and placing orders.  We believe it is within your reasonable expectations that we will process this minimal contract information and this will not impact the legal rights and freedoms of your and/or your employees. We also provide the opportunity for you to opt out of any communications and you may exercise your data rights (set out below)

5. COOKIES AND INTEGRATED SOFTWARE

We do not actively initiate any collection of a website user’s individual information. We passively receive information that is automatically sent to us by your web browser. This information typically includes your domain name (the site after the @ in your e-mail address). It may also contain your user name (the name before the @ in your e-mail address). The amount of information sent depends on the settings you have on your web browser; please refer to your browser if you want to learn what information it sends. We however do not actively seek to identify any individual visitor, with the exception of investigating security breaches or cooperating with authorities pursuant to a legal matter.

You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of this website may become inaccessible or not function properly.

Our website uses cookies to distinguish you from other users of our website. This helps us to provide you with a good experience when you browse our website and also allows us to improve our site. By continuing to browse the site, you are agreeing to our use of cookies.

A cookie is a small file of letters and numbers that we store on your browser or the hard drive of your computer if you agree. Cookies contain information that is transferred to your computer’s hard drive.

We use the following cookies:

• Strictly necessary cookies. These are cookies that are required for the operation of our website. They include, for example, cookies that enable you to log into secure areas of our website.
• Analytical/performance cookies. They allow us to recognise and count the number of visitors and to see how visitors move around our website when they are using it. This helps us to improve the way our website works, for example, by ensuring that users are finding what they are looking for easily.
• Functionality cookies. These are used to recognise you when you return to our website. This enables us to personalise our content for you, greet you by name and remember your preferences (for example, your choice of language or region).
• Targeting cookies. These cookies record your visit to our website, the pages you have visited and the links you have followed. We will use this information to make our website and the advertising displayed on it more relevant to your interests. We may also share this information with third parties for this purpose.

You can find more information about the individual cookies we use and the purposes for which we use them in the table below:

The following Cookies are active on our websites:

Please note that third parties (including, for example, advertising networks and providers of external services like web traffic analysis services) may also use cookies, over which we have no control. These cookies are likely to be analytical/performance cookies or targeting cookies.

You block cookies by activating the setting on your browser that allows you to refuse the setting of all or some cookies. However, if you use your browser settings to block all cookies (including essential cookies) you may not be able to access all or parts of our site.

Change of purpose

We will only use your personal data for the purposes 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 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.

6. DISCLOSURES OF YOUR PERSONAL DATA

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.

Internal third parties such as our employees or officers who are based in the United Kingdom and provide IT and system administration services and undertake leadership reporting.

External third parties including:

• specialist IT support, suppliers and sub-contractors for the performance of this site;
• payment service providers, including Barclays and Visa and delivery companies to process and deliver your order;
• professional advisers including lawyers, bankers, marketing agencies, auditors and insurers who provide consultancy, banking, legal, insurance and accounting services including AON, Heatons, SM&G, Barclays and Westfield Health;
• credit reference agencies, law enforcement and fraud prevention agencies to help us prevent and deal with fraud;
• outsourced service providers, including ADP Ltd, Boab Plc, BUPA, Computershare Ltd, Chase Templeton Ltd, Deltek GB Ltd, Egencia UK Ltd and Review Travel Ltd.
• HM Revenue & Customs, regulators and other authorities who require reporting or 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.

7. INTERNATIONAL TRANSFERS

We do not usually transfer your personal data to third parties outside the European Economic Area (EEA). If we intend to do this we will request your consent and keep you informed.

We may transfer and share data within ECI Group companies. In addition, our employees and officers will be able to access emails and our IT systems whilst outside the EEA, in the course of their employment.  This does mean that your personal data is accessible whilst outside the EU, however, we have assessed the risk and ensured adequate safeguards are in place, including the following:

• Secure email with password
• Password protected and encrypted IT systems
• IT security measures
• Training of our employees on data protection
• Robust policies and procedures
• Obligations in our contracts with employees

8. DATA SECURITY

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.

9. DATA RETENTION

How long will you use my personal data for?

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.

Your personal data will, usually, be stored for no longer than 7 years following you, or your employer, ceasing to be a customer of ours.

If you have registered to receive communications from us as part of our mailing list, then we will keep your personal data for 7 years.

If you have sent us your CV in response to a job posting and you were unsuccessful in your application, we will keep your data for 6 months from the end of the closure of the job posting. If you have sent us your CV speculatively, we will keep your data for up to 1 year before deletion.

In some circumstances you can ask us to delete your data: see Request erasure below for further information.

In some circumstances we may 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.

10. YOUR LEGAL RIGHTS

Under certain circumstances, you have rights under data protection laws in relation to your personal data as detailed below. If you wish to exercise any of the rights set out below, please contact us.

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 may 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 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.

Correction of information

If you notify us that the personal data we hold is complete or inaccurate we will correct or complete the information as soon as possible.

Deletion of information

You have the right to request that your personal data be deleted; including if we no longer need it for the purpose we collected it, or you withdraw your consent.

Following such a request we will erase your personal data without undue delay unless continued retention is necessary and permitted by law. If we made the personal data public, we will take reasonable steps to inform other data controllers processing about your erasure request.

Object to processing

You have the right to object to us processing 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.

Restriction on processing

You have the right to request that we suspend processing your personal data, but hold it for you, in the event the personal data we hold is inaccurate, the processing is unlawful or we no longer need the personal data. Once the processing is restricted, we will only continue to process your personal data if you consent or we have another legal basis for doing so.

Access to information

You have the right to access information held about you and any access request will usually be free of charge. We will endeavour to provide information in a format requested, but we may charge you a reasonable fee for additional copies.

Data Portability

You have the right to receive a copy of your personal data which you gave to us. The copy will be provided in a commonly used and machine-readable format.  You can also have it transmitted directly from us to another data controller, where technically possible.

If you wish to exercise any of the rights set out above, please contact us.

No fee usually required

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 may refuse to comply with your request in these circumstances.

Withdraw consent at any time

You may withdraw your 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, 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.

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.

11. GLOSSARY

LAWFUL BASIS

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