Stanley Electric (U.K.) Company Limited Privacy Notice for the EEA
Last Updated March 2019
We respect the privacy of every person who visits or registers with or submits personal information through our website at https://www.stanley.co.jp/e/ (the “Site”) and who uses the products and services that we offer, including from the Site (our “Services”).
1. Purpose of this privacy notice
This privacy notice (“Privacy Notice”) explains our approach to any personal information that we might collect from you or which we have obtained about you from a third party and the purposes for which we process your personal information. This Privacy Notice also sets out your rights in respect of our processing of your personal information.
For more information click here.
This Privacy Notice will inform you of the nature of the personal information about you that is processed by us and how you can request that we delete it, update it, transfer it and/or provide you with access to it.
This Privacy Notice is intended to assist you in making informed decisions when using the Site and our products and services. Please take a moment to read and understand it. Please note that it should be read in conjunction with our Website Terms and Conditions and Cookie Policy.
Please also note that this Privacy Notice only applies to the use of your personal information obtained by us, it does not apply to your personal information collected during your communications with third parties or your use of their products or services (for example where you follow links to third party websites over which we have no control or purchase goods or services from those third parties).
2. About us
The Site and our Services are operated by Stanley Electric Company Limited Japan (“we”, “us”, “our” or “Stanley”).
For more information click here.
Stanley Electric (U.K.) Company Limited is Stanley Electric Company Limited Japan’s subsidiary in the UK. Stanley Electric (U.K.) Company Limited is the data controller responsible for your personal information and is a private limited company registered in England under company registration number 04071741 with its registered office address located at Suite 3c, Part 3rd Floor, The Columbia Centre, Station Road, Bracknell, Berkshire, England, RG12 1LP.
Please note that depending on with which Stanley Group entity you contract in relation to the Services the following entities may also be data controllers responsible for your personal information processed in relation to the Services:
• Stanley Electric (U.K.) Company Limited: a private limited company registered in England under company registration number 04071741 with its registered office address located at Suite 3c, Part 3rd Floor, The Columbia Centre, Station Road, Bracknell, Berkshire, England, RG12 1LP.
• Stanley Electric Co., Ltd. Japan;Stanley Electric GmbH; STANLEY-IDESS S.A.S.; Stanley Electric Hungary kft.; Tianjin Stanley Electric Co., Ltd.; Suzhou Stanley LED Lighting Technology Co., Ltd.; Shanghai Stanley Electric Co., Ltd.; Stanley Electric (China)Investment Co., Ltd.; Guangzhou Stanley Electric Co., Ltd.; Shenzhen Stanley Electric Co., Ltd.; Stanley Electric Trading (Shenzhen) Co., Ltd.; Wuhan Stanley Electric Co.,Ltd.; Stanley Electric Korea Co., Ltd.; Stanley Electric (Asia Pacific) Ltd.; Vietnam Stanley Electric Co., Ltd.; PT. Indonesia Stanley Electric; Stanley Electric Holding Asia-Pacific Pte. Ltd.; Thai Stanley Electric Public Co., Ltd.; Asian Stanley International Co., Ltd.; Stanley Electric Sales of India Pvt. Ltd.; Lumax Industries Ltd.; Hella-Stanley Holding Pty Ltd; Stanley Electric U.S. Co., Inc.; I I Stanley Co., Inc.; Stanley Electric Sales of America, Inc.; Stanley Electric Manufacturing Mexico S.A. DE C.V.; Stanley Electric do Brasil Ltda.
3. How to contact us
Stanley Electric (U.K.) Company Limited is Stanley Electric Company Limited Japan’s representative in the UK. If you have any questions about this Privacy Notice or want to exercise your rights set out in this Privacy Notice, please contact us by calling us on: +44 (0)1344 830450
4. Personal information we collect and how we use it
Our primary goal in collecting personal information from you is to: (i) provide our products and services to you; (ii) verify your identity (where applicable); (iii) help us improve our Site and our products and services and develop and market new products and services; (iv) carry out requests made by you on the Site; (v) investigate or settle inquiries or disputes; (vi) comply with any applicable law, court order, other judicial process, or the requirements of a regulator; (vii) enforce our agreements with you; (viii) protect the rights, property or safety of us or third parties, including our other customers and users of the Site; (ix) provide support for the provision of our products and services; (x) carry out recruitment activities; and (xi) use as otherwise required or permitted by law.
To undertake these goals, we may process the following personal information:
If you are a visitor to the Site:
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Name and job title.
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Contact information including email address.
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Demographic information such as postcode, preferences and interests.
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Other information relevant to provision of Services.
Primarily Stanley Electric is engaged by corporate customers (i.e. other corporate entities) and as such those customers are not data subjects. However as part of such instructions personal information about other persons may be provided to us (e.g. personal information relating, without limitation, to any of our corporate clients’ or prospective clients’ workers or subscribers.)
If you are an individual whose personal information may be processed by us as a result of providing the Services to others (including corporate clients) , we will process a variety of different personal information depending on the Services provided in question.
The following is a non-exhaustive list which is reflective of the varied nature of the personal information processed as part of our business.
For instance, if we are providing technical support to a corporate customer for the benefit of a subscriber we may be provided with, and then process, personal information about that subscriber including but not limited to the subscriber’s name and contact details.
We might also need to process personal information in relation to corporate customers’ workers who use a Stanley Electric product in the course of their work for our corporate customer.
We will process a variety of different personal information depending on the Services provided in question.
If you are a potential recruit to a Stanley Electric office:
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Name and job title.
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Contact information including email address.
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Curriculum vitae, your education, employment history and similar matters and similar information that you may provide to us.
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Other information relevant to potential recruitment to Stanley Electric.
In particular, we may use your personal information for the following purposes:
Fulfilment of our Services. For more information click here.
Our website does not operate a registration process where we collect and maintain personal information; there is no function for you to voluntarily submit to us during your use of the Site.
Customer services and enquiries. For more information click here.
Our Site uses various user interfaces to allow you to request information about our products and services. Our enquiry services are accessible by email and telephone. When making an enquiry, the enquirer’s name and contact information (email address, postal address, telephone number) may be requested, together with details of other personal information that is relevant to the enquiry. This information is used in order to enable us to manage and respond to your enquiries and requests.
What is our legal basis?
It is in our legitimate interest to use your personal information in such a way to ensure that we provide the very best customer service we can to you.
Your feedback about our products and services. For more information click here.
From time to time, we may invite you to provide feedback about our products and services in the form of online, postal or via surveys. We will collect your name and contact details (email address, postal address, telephone number) and any other personal information you choose to volunteer in your feedback
We also provide an online form which you can use to report technical issues with our Site. This form allows you to submit your name, email address and details of the issue you wish to report.
We use this information to help us improve the quality of customer service provided by our staff. We also use your feedback to monitor the quality of our products and services and to assist with the selection of future product and service lines.
What is our legal basis?
It is in our legitimate interest to use the personal information provided by you in your feedback for the purposes described above.
Customer insight and analysis. For more information click here.
We analyse your contact details with other personal information that we observe about you from your interactions with our Site, with our email communications to you and/or with our products and services, such as the products and services you have purchased or viewed, or from your use of our wifi.
Where you have given your consent (where lawfully required), we use cookies, log files and other technologies to collect personal information from the computer hardware and software you use to access the Site, or from your mobile device. This includes the following:
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an IP address to monitor Site traffic and volume;
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a session ID to track usage statistics on our Site; and
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information regarding your personal or professional interests, demographics, experiences with our products and contact preferences.
Our web pages contain cookies, web beacons or pixel tags (“Tags”). Tags allow us to track receipt of an email to you, count users who have visited a web and collect other types of aggregate information. Once you click on an email that contains a Tag, your contact information may subsequently be cross-referenced to the source email and the relevant Tag.
In some of our email messages, we use a “click-through URL” linked to certain websites administered by us or on our behalf. We may track click-through data to assist in determining interest in particular topics and measure the effectiveness of these communications.
Please see our Cookie Policy for further information.
This information is used to create insights about our visitors’ browsing habits on our Site. Where we have your consent to do so, we will also use your location data for customer insight and analysis purposes.
By using this information, we are able to measure the effectiveness of our content and how visitors use our Site and our products and services. This allows us to learn what pages of our Site are most attractive to our visitors, which parts of our Site are the most interesting and what kind of features and functionalities our visitors and clients like to see.
We also use this information to help us with the selection of future product and service lines and website design and to remember your preferences.
We also use this information for marketing purposes (see the “Marketing Communications” section below for further details).
What is our legal basis?
Where your personal information is completely anonymised, we do not require a legal basis to use it as the information will no longer constitute personal information that is regulated under data protection laws. However, our collection and use of such anonymised personal information may be subject to other laws where your consent is required. Please see our Cookie Policy for further details.
Where your personal information is not in an anonymous form, it is in our legitimate interest to use your personal information in such a way to ensure that we provide the very best products and services to you and our other visitors and clients.
We will only use your location data for insight and analysis purposes where we have your consent to do so.
Marketing communications.
We carry out the following marketing activities using your personal information:
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Postal and email marketing. For more information click here.
We use information that we observe about you from your interactions with our Site, with our email communications to you and/or with our products and services in order to decide what sort of marketing communications to send you. Please see the “Customer Insight and Analysis” section above for more details about the personal information collected and how it is collected.
We use your name and address to send you marketing communications by post.
What is our legal basis?
Where your personal information is not in an anonymous form, it is in our legitimate interest to use your personal information for marketing purposes.
We will only send you marketing communications by email where you have consented to receive such communications, or where we have a lawful right to do so. (e.g. if you are a corporate subscriber, based on a legitimate interest).
Recruitment. For more information click here.
We use your personal information for recruitment purposes, in particular, to assess your suitability for any position for which you may apply for with us, whether such application has been received by us online, by email or by hard copy and whether submitted directly by you or by a third party recruitment agency on your behalf. We also use your personal information to communicate with you about the recruitment process, to keep records about our recruitment process and to comply with our legal and regulatory obligations in relation to recruitment.
We may process any personal information about you that you volunteer when you apply for a job with us. We may also process your personal information obtained from any third parties we work with in relation to our recruitment activities, including without limitation, recruitment agencies, background check providers, credit reference agencies, your referees and the Disclosure and Barring Service (if applicable).
The personal information we process may include your name and contact information (e.g. email address, postal address, telephone number), personal information concerning your education, qualifications and employment history and any other personal information which appears in your curriculum vitae and covering letter, which you volunteer in an application form or during an interview or which is contained in any reference we receive about you. Such information may also include special categories of personal information (such as information about your health, any medical conditions and your health and sickness records) and information relating to criminal convictions and offences if that information is relevant to the role you are applying for.
We also use your personal information for the purposes of reviewing our equal opportunity profile in accordance with applicable legislation. We do not discriminate on the grounds of gender, race, ethnic origin, age, religion, sexual orientation, disability or any other basis covered by local legislation. All employment-related decisions are made entirely on merit.
What is our legal basis?
Where we use your personal information in connection with recruitment, it will be in connection with us taking steps at your request to enter into a contract we may have with you or it is in our legitimate interest to use personal information in such a way to ensure that we can make appropriate and informed recruitment decisions.
We will not process any special (or sensitive) categories of personal information or personal information relating to criminal convictions or offences except where we are able to do so under applicable legislation or with your explicit consent.
Receipt of services from suppliers. For more information click here.
If we have engaged you or the organisation you represent to provide us with products or services (for example, if you or the organisation you represent provide us with services such as IT support or financial advice), we may collect and process your personal information in order to manage our relationship with you or the organisation you represent, to receive products and services from you or the organisation you represent and, where relevant, to provide products and services to our customers.
The personal information we collect from you may include your name, job title, contact information (including email address, telephone number and postal address), bank account or other payment details and any other personal information you volunteer which is relevant to our relationship with you or the organisation you represent.
What is our legal basis?
It is necessary for us to use your personal information to perform our obligations in accordance with any contract that we may have with you or it is in our legitimate interest to use personal information in such a way to ensure that we have an effective working relationship and are able to provide our products and services to our customers in an effective way.
Business administration and legal compliance. For more information click here.
We use your personal information for the following business administration and legal compliance purposes:
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to comply with our legal obligations;
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to enforce our legal rights;
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to protect the rights of third parties; and
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in connection with a business transition such as a merger, acquisition by another company, or sale of all or a portion of our assets.
What is our legal basis?
Where we use your personal information in connection with a business transition, to enforce our legal rights or to protect the rights of third parties, it is in our legitimate interest to do so. For all other purposes described in this section, it is our legal obligation to use your personal information to comply with any legal obligations imposed upon us such as a court order.
We will not process any special (or sensitive) categories of personal information or personal information relating to criminal convictions or offences except where we are able to do so under applicable legislation or with your explicit consent.
Any other purposes for which we wish to use your personal information that are not listed above, or any other changes we propose to make to the existing purposes, will be notified to you using your contact details.
5. What if you fail to provide your personal information?
Where we are required by law to collect your personal information, or we need to collect your personal information under the terms of a contract we have with you, and you fail to provide that personal information when we request it, we may not be able to perform the contract we have or are trying to enter into with you. This may apply where you do not provide the personal information we require in connection with an application for employment with us. In this case, we may have to cancel your job application or the provision of the relevant products or services to you, in which case we will notify you.
6. How do we obtain your consent?
Where our use of your personal information requires your consent, you can provide such consent:
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at the time we collect your personal information following the instructions provided; or
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by informing us by post or phone using the contact details set out in this Privacy Notice.
7. Our use of cookies and similar technologies
Our Site uses certain cookies, web beacons, pixel tags, log files and other technologies of which you should be aware. Please see our Cookie Policy to find out more about the cookies and other similar technologies we use, the purposes for which we use them and how to manage, block or delete them.
8. Sharing Data
We will only share personal information with others when we are legally permitted to do so. When we share personal information with others, we put contractual arrangements and security mechanisms in place to protect the personal information and to comply with our data protection, confidentiality and security standards.
For more information click here.
When processing your personal information we may need to share it with third parties as follows:
Other organisations within our group of companies: We may share personal information with other organisations within our group of companies where necessary for administrative purposes or where those organisations assist us in the provision of our products and services.
Third-party organisations that provide applications/functionality, data processing or IT services: We use third parties to support us in providing our products and Services and to help provide, run and manage our internal IT systems. Such third parties may include, for example, providers of information technology, cloud based software as a service providers, identity management, website hosting and management, data analysis, data back-up, security and storage services. The servers powering and facilitating that cloud infrastructure are located in secure data centres around the world, and personal information may be stored in any one of them. We also share your personal information with third-party service providers to assist us with insight analytics. These providers are described in our Cookie Policy.
Payment providers: We may share personal information with third parties who assist us with the processing of payments and refunds.
Delivery and courier companies: We use third-party delivery companies and couriers to help deliver any products that our customers order from our Website, as well as our postal marketing.
Auditors, lawyers, accountants and other professional advisers: We share personal information with professional services firms who advise and assist us in relation to the lawful and effective management of our organisation and in relation to any disputes we become involved in.
Law enforcement or other government and regulatory agencies: We may share personal information with law enforcement or other government and regulatory agencies or other third parties as required by, and in accordance with, applicable law or regulation.
Other third parties: Occasionally, we may receive requests from third parties with authority to obtain disclosure of personal information, such as to check that we are complying with applicable law and regulation, to investigate an alleged crime, to establish, exercise or defend legal rights. We will only fulfil requests for personal information where we are permitted to do so in accordance with applicable law or regulation.
This list is non-exhaustive and there may be circumstances where we need to share personal information with other third parties in order to provide our products and services and carry out our regulatory duties as effectively as we can.
9. Transfers outside the EEA
Where necessary in order to administer this Site and to deliver our Services, we will transfer personal information to countries outside the European Economic Area. Non-EEA countries do not have the same data protection laws as the United Kingdom and the EEA. However, when transferring your personal information outside the EEA, we will comply with our legal and regulatory obligations in relation to the personal information including having a lawful basis for transferring personal information and putting appropriate safeguards in place to ensure an adequate level of protection for the personal information. We will take reasonable steps to ensure the security of your personal information in accordance with applicable data protection laws.
For more information click here.
When transferring your personal information outside the EEA, we will ensure that at least one of the following safeguards is implemented:
Consent: By using this Site and using our Services you consent to us transferring your personal data outside of the EEA.
Adequacy decisions: We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data by the European Commission. For further details, see https://ec.europa.eu/info/law/law-topic/data-protection/data-transfers-outside-eu/adequacy-protection-personal-data-non-eu-countries_en.
Model clauses: Where we use certain service providers, we may use specific contracts approved by the European Commission which give personal data the same protection it has in Europe. For further details, see https://ec.europa.eu/info/law/law-topic/data-protection/data-transfers-outside-eu/model-contracts-transfer-personal-data-third-countries_en.
EU-U.S. Privacy Shield: Where we use providers based in the US, we may transfer data to them if they are part of the Privacy Shield which requires them to provide similar protection to personal data shared between Europe and the US. For further details, see https://ec.europa.eu/info/law/law-topic/data-protection/data-transfers-outside-eu/eu-us-privacy-shield_en.
Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the EEA.
10. Personal information of children under 18
Our Website and the commercial products and Services that we offer are not targeted at those under 18. If you are under 18, we ask that you obtain your parent’s or guardian’s consent before submitting personal information to us or requesting any products or services from us.
If you are a parent or guardian of a child under 18, please ensure that you supervise your child’s use of our Website and our products and Services and ensure they obtain your consent before submitting any personal information to us or requesting any products or Services from us.
For the purpose of safeguarding the rights, interests and freedoms of children, we may ask you to verify your age in order to continue using our Website and/or any of our products and Services you may have requested.
11. How long we keep your personal information
Regarding personal information we have processed in connection with the supply of our products and services to any person or organisation, we will retain personal information relevant to that supply of products or services for seven years from the date of supply and in compliance with our obligations under the EU General Data Protection Regulation (or similar legislation around the world). We may then destroy such files without further notice or liability.
Regarding any other personal information we have processed, we will retain relevant personal information for seven years from the date of our last interaction with the relevant person or organisation and in compliance with our obligations under the EU General Data Protection Regulation (or similar legislation around the world). We may then destroy such files without further notice or liability.
If any personal information is only useful for a short period (e.g. for a specific marketing campaign), we may delete it at the end of that period.
If you have opted out of receiving marketing communications from us, we will need to retain certain personal information indefinitely so we know not to send you further marketing communications in the future.
12. Confidentiality and security of your personal information
We are committed to keeping the personal information you provide to us secure and we will take reasonable precautions to protect your personal information from loss, misuse or alteration.
For more information click here.
We have implemented information security policies, rules and technical measures to protect the personal information that we have under our control from:
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unauthorised access;
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improper use or disclosure;
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unauthorised modification; and
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unlawful destruction or accidental loss.
All our employees and data processors (i.e. those who process your personal information on our behalf, for the purposes listed above) who have access to and are associated with the processing of personal information are obliged to respect the confidentiality of the personal information of all users of our Site and our Services.
13. How to access your information and your other rights
You have the following rights in relation to the personal information we hold about you:
Your right of access. For more information click here.
If you ask us, we will confirm whether we are processing your personal information and, if so, provide you with a copy of that personal information (along with certain other details). If you require additional copies, we may charge a reasonable fee for producing those additional copies.
Your right to rectification. For more information click here.
If the personal information we hold about you is inaccurate or incomplete, you are entitled to have it rectified. If we have shared your personal information with others, we’ll let them know about the rectification where possible. If you ask us, where possible and lawful to do so, we will also tell you who we’ve shared your personal information with so that you can contact them directly.
Your right to erasure. For more information click here.
You can ask us to delete or remove your personal information in some circumstances, such as where we no longer need it or where you withdraw your consent (where applicable). If we have shared your personal information with others, we will let them know about the erasure where possible. If you ask us, where it is possible and lawful for us to do so, we will also tell you who we have shared your personal information with so that you can contact them directly.
Your right to restrict processing. For more information click here.
You can ask us to block or suppress the processing of your personal information in certain circumstances, such as where you contest the accuracy of that personal information or you object to us processing it. It won’t stop us from storing your personal information, though. We will tell you before we lift any restriction. If we have shared your personal information with others, we will let them know about the restriction where it is possible for us to do so. If you ask us, where it is possible and lawful for us to do so, we will also tell you who we have shared your personal information with so that you can contact them directly.
Your right to data portability. For more information click here.
You have the right, in certain circumstances, to obtain personal information you have provided to us (in a structured, commonly used and machine readable format) and to reuse it elsewhere or to ask us to transfer it to a third party of your choice.
Your right to object. For more information click here.
You can ask us to stop processing your personal information, and we will do so, if we are:
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relying on our own or someone else’s legitimate interest to process your personal information, except if we can demonstrate compelling legal grounds for the processing; or
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processing your personal information for the purposes of direct marketing.
Your rights in relation to automated decision-making and profiling. For more information click here.
You have the right not to be subject to a decision when it is based on automatic processing, including profiling, if it produces a legal effect or similarly significantly affects you, unless such profiling is necessary for the entering into, or the performance of, a contract between you and us.
Your right to withdraw consent. For more information click here.
If we rely on your consent (or explicit consent) as our legal basis for processing your personal information, you have the right to withdraw that consent at any time. You can exercise your right of withdrawal by contacting us using our contact details in the “How to Contact Us” section above or by using any other opt-out mechanism we may provide, such as an unsubscribe link in an email.
Your right to lodge a complaint with the supervisory authority. For more information click here.
If you have a concern about any aspect of our privacy practices in the UK, including the way we have handled your personal information, you can report it to the Information Commissioner’s Office (ICO). You can find details about how to report a concern on the ICO website at https://ico.org.uk/concerns/ or by calling their helpline on 0303 123 1113.
14. Collection of information by third-party sites and sponsors
The Site contains links to other sites whose information practices may be different than ours. Visitors should consult the other sites' privacy notices as Stanley Electric (U.K.) Company Limited has no control over information that is submitted to, or collected by, these third parties.
15. Changes to this Privacy Notice
We may make changes to this Privacy Notice from time to time.
For more information click here.
To ensure that you are always aware of how we use your personal information we will update this Privacy Notice from time to time to reflect any changes to our use of your personal information. We may also make changes as required to comply with changes in applicable law or regulatory requirements. We will notify you by email, if we have your email address, of any significant changes. However, we encourage you to review this Privacy Notice periodically to be informed of how we use your personal information.