SHORT BROTHERS PLC PRIVACY STATEMENT
Last revision on June 24th 2020
1. About this privacy statement
Short Brothers Plc and all its business segments, divisions and subsidiaries (collectively “Shorts”, “we” or “our”) are committed to conducting business in a way that complies with applicable data protection laws and regulations in every country in which Shorts operates.
This privacy statement sets out how we collect, store, use and safeguard your personal data. It applies when you visit our website, customer portals, (collectively, our “Sites”), as well as our offline interaction, such as when you attend one of our events (e.g. marketing event, trade show or sales meeting).
Generally, the Shorts entity that operates the Site you visit or the entity that you interact with offline is the entity that acts as controller of any personal data collected through your interaction and is the entity that is primarily responsible for how that personal data is used. Shorts also acts as data controller in respect of certain centralized data processing activities.
For your information and convenience, our Sites may contain links to other websites or apps run by other organizations, which we do not control. This privacy statement does not apply to those other websites and apps‚ so we encourage you to read their privacy statements to stay informed of how they use your personal data.
2. Which personal data we collect
The personal data we collect depends on the ways in which you interact with Shorts and it may include the following:
We do not knowingly collect personal data from anyone under the age of 16.
3. How we collect your personal data
Shorts collects your personal data from you, from third parties and through cookies.
4. Why we collect your personal data and our lawful bases for processing it
Shorts processes your personal data for different purposes, during and after the end of your relationship with us. These purposes include:
We will only use your personal data where we have lawful bases for doing so. Lawful bases include, among others, each one of the following:
Where we rely on your consent to use your personal data, you have the right to withdraw or decline your consent at any time. Please see the ‘Your rights regarding your personal data’ section for further details on how you can do this.
If you have any questions about, or objections to, the lawful bases upon which we use your personal data, please contact our data privacy officer in any of the ways described at the end of this privacy statement.
5. Marketing and advertising
We use your personal data to send you marketing information directly from us by post or email where you gave your consent to such use (unless there is another lawful bases for using your personal data for marketing and advertising purposes in your jurisdiction, which does not require your consent). We also use your personal data and information inferred from your personal data to tailor ads to your interests and preferences. This allows us to improve the relevance of our ads to you.
You have the right to object to our use of your personal data for marketing and advertising purposes, or – where we rely on your consent to use your personal data for marketing and advertising purposes – to withdraw your consent. Please see the ‘Your rights regarding your personal data’ section for further details.
6. How we store, process, transfer and protect your personal data
The personal data we collect about you will be stored in a range of different places, including on our servers and in our information management systems and databases (e.g. Shorts’ marketing databases and customer support systems).
Because we are a global business, we may process your personal data in different geographical locations (including outside the European Economic Area).
We only share your personal data on a need-to-know basis as follows:
To ensure that your personal data is adequately protected no matter where it is processed, we have internal policies and controls in place to prevent your personal data from being lost, accidentally destroyed, misused, unintentionally disclosed, or accessed other than by our employees or third parties hired by Shorts.
For example, we request that Shorts employees familiarise themselves with our IT policies governing data security. When we engage third parties to process personal data on our behalf, we require that they do so on the basis of Shorts’ written instructions, under a duty of confidentiality, and in accordance with technical and organisational measures that are appropriate to ensure the security of your personal data.
7. Your rights regarding your personal data
You have a number of rights regarding your personal data. You may also have additional rights depending on your jurisdiction.
If you would like to exercise any of these rights, please advise Shorts by sending us an email at: email@example.com. You can also raise a complaint about our data processing practices with the data protection regulator in your jurisdiction. Please see the ‘How you can contact us about this privacy statement or make a complaint section below.
8. How long we keep your personal data
The period for which your personal data is held is determined by a number of factors including the purpose for which we use that personal data and our legal obligations. We do not generally retain personal data in an identifiable form for longer than is necessary, though in some cases we may choose to retain certain personal data in a depersonalized or aggregated form.
9. How we make changes to this privacy statement
Should we elect to change this privacy statement, we will post the changes here, so please check this page from time to time to ensure that you are informed of any changes.
10. How you can contact us about this privacy statement or make a complaint
If you have any questions or suggestions about this privacy statement or about how we use your personal data, please contact our data privacy officer:
Anne Bell, Data Privacy Manager
Tel: +44 28 90733657
Please let us know if you are unhappy with how we use your personal data. Our data privacy officer will respond to your complaint within 30 days.
If you are not satisfied with the way we handled your complaint, you may refer your complaint to your local data protection regulator. For a complete list of data protection regulators within the European Union, please visit http://ec.europa.eu/newsroom/article29/item-detail.cfm?item_id=612080.