1.        Scope

All data subjects whose personal data is collected, in line with the requirements of the GDPR.

2.        Responsibilities

2.1 Business Systems Manager is responsible for ensuring that this notice is made available to data subjects prior to ASM Technologies Limited collecting/processing their personal data.

2.2 All Employees/Staff of ASM Technologies Limited who interact with data subjects are responsible for ensuring that this notice is drawn to the data subject’s attention and their consent to the processing of their data is secured.

3.        Privacy notice 

3.1 Who are we?

ASM Technologies Limited provides IT related spares, hardware and software to IT Service organisations and maintainers across the globe

Our Data Protection Officer / Business Systems Manager and data protection representatives can be contacted directly here:

• ([email protected])
• (01606 863707)
• The personal data we would like to process on you is:

Personal data type:	Source (where ASM Technologies Limited obtained the personal data from if it has not been collected directly from you, the data subject. Note if the personal data has been accessed from publicly accessible sources):
Name	ASM Technologies Limited: Customer
E-mail Address	ASM Technologies Limited: Customer
Telephone Number	ASM Technologies Limited: Customer
Address	ASM Technologies Limited: Customer

The personal data we collect will be used for the following purposes:

• Provide IT-related spares, hardware and software to IT service organisations and maintainers across the globe.
• Our legal basis for processing for the personal data:
• Contractual necessity
• Any legitimate interests pursued by us, or third parties we use, are as follows:
• None
• The special categories of personal data concerned are:
• None

3.2      Consent

By consenting to this privacy notice you are giving us permission to process your personal data specifically for the purposes identified.

Consent is required for ASM Technologies Limited to process both types of personal data, but it must be explicitly given. Where we are asking you for sensitive personal data we will always tell you why and how the information will be used.

You may withdraw consent at any time by completing and sending back the Withdrawal of Consent Procedure.

3.3      Disclosure

ASM Technologies Limited will pass your personal data to third parties as part of the processing activities.

Third country (nonEU)/international organisation	Safeguards in place to protect your personal data	Retrieve a copy of the safeguards in place here:
United States of America
Thailand
China
Australia
Ukraine
Hong Kong
Singapore
India
South Africa
Mauritius
Japan
South Korea
Russia
Egypt
Moldova
Taiwan

3.4      Retention period

ASM Technologies Limited will process personal data for the purpose of providing the service and will store the personal data for 7 years in line with the ASM Technologies Limited Data Retention Policy.

3.5      Your rights as a data subject

At any point while we are in possession of or processing your personal data, you, the data subject, have the following rights:

• Right of access – you have the right to request a copy of the information that we hold about you.
• Right of rectification – you have a right to correct data that we hold about you that is inaccurate or incomplete.
• Right to be forgotten – in certain circumstances you can ask for the data we hold about you to be erased from our records.
• Right to restriction of processing – where certain conditions apply to have a right to restrict the processing.
• Right of portability – you have the right to have the data we hold about you transferred to another organisation.
• Right to object – you have the right to object to certain types of processing such as direct marketing.
• Right to object to automated processing, including profiling – you also have the right to be subject to the legal effects of automated processing or profiling.
• Right to judicial review: in the event that ASM Technologies Limited refuses your request under rights of access, we will provide you with a reason as to why. You have the right to complain as outlined in clause 3.6 below.
• All of the above requests will be forwarded on should there be a third party involved (as stated in 3.4 above) in the processing of your personal data.

3.6      Complaints

In the event that you wish to make a complaint about how your personal data is being processed by ASM Technologies Limited (or third parties as described in 3.4 above), or how your complaint has been handled, you have the right to lodge a complaint directly with the supervisory authority and ASM Technologies Limited’s data protection representatives Business Systems Manager.

The details for each of these contacts are:

	Supervisory authority contact details	Business Systems Manager contact details
Contact Name:	Information Commissioners Office (ICO)	Business Systems Manager
Address line 1:	Wycliffe House	Meridian House
Address line 2:	Water Lane	Windsor House, Gadbrook Business Centre
Address line 3:	Wilmslow	Northwich
Address line 4:	Cheshire	Cheshire
Address line 5:	SK9 5AF	CW9 7TN
Email:		[email protected]
Telephone:	0303 123 1113	01606863707

3.7 Privacy statement

Read more about how and why we use your data at asmtech.com

4.        Online privacy statement

Personal data

Under the EU’s General Data Protection Regulation (GDPR) personal data is defined as:

“any information relating to an identified or identifiable natural person (‘data subject’); an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person”.

How we use your information

This privacy notice tells you how we, ASM Technologies Limited, will collect and use your personal data to provide IT related spares, hardware and software.

Why does ASM Technologies Limited need to collect and store personal data?

In order for us to provide you with the service we need to collect personal data for the provision of IT related spares, hardware and software to IT service organisations. In any event, we are committed to ensuring that the information we collect and use is appropriate for this purpose and does not constitute an invasion of your privacy. In terms of being contacted for marketing purposes ASM Technologies Limited would contact you for additional consent.

Will ASM Technologies Limited share my personal data with anyone else?

We may pass your personal data on to third-party service providers contracted to ASM Technologies Limited in the course of dealing with you. Any third parties that we may share your data with are obliged to keep your details securely, and to use them only to fulfill the service they provide on your behalf. When they no longer need your data to fulfil this service, they will dispose of the details in line with ASM Technologies Limited’s procedures. If we wish to pass your sensitive personal data onto a third party we will only do so once we have obtained your consent, unless we are legally required to do otherwise.

How will ASM Technologies Limited use the personal data it collects about me? ASM Technologies Limited will process (collect, store and use) the information you provide in a manner compatible with the EU’s General Data Protection Regulation (GDPR). We will endeavor to keep your information accurate and up to date, and not keep it for longer than is necessary. ASM Technologies Limited is required to retain information in accordance with the law, such as information needed for income tax and audit purposes. How long certain kinds of personal data should be kept may also be governed by specific business-sector requirements and agreed practices. Personal data may be held in addition to these periods depending on individual business needs.

Under what circumstances will ASM Technologies Limited contact me?

Our aim is not to be intrusive, and we undertake not to ask irrelevant or unnecessary questions. Moreover, the information you provide will be subject to rigorous measures and procedures to minimise the risk of unauthorised access or disclosure.

Can I find out the personal data that the organisation holds about me? ASM Technologies Limited at your request, can confirm what information we hold about you and how it is processed. If ASM Technologies Limited does hold personal data about you, you can request the following information:

• Identity and the contact details of the person or organisation that has determined how and why to process your data. In some cases, this will be a representative in the EU.
• Contact details of the data protection officer, where applicable.
• The purpose of the processing as well as the legal basis for processing.
• If the processing is based on the legitimate interests of ASM Technologies Limited or a third party, information about those interests.
• The categories of personal data collected, stored and processed.
• Recipient(s) or categories of recipients that the data is/will be disclosed to.
• If we intend to transfer the personal data to a third country or international organisation, information about how we ensure this is done securely. The EU has approved sending personal data to some countries because they meet a minimum standard of data protection. In other cases, we will ensure there are specific measures in place to secure your information.
• How long the data will be stored.
• Details of your rights to correct, erase, restrict or object to such processing.
• Information about your right to withdraw consent at any time.
• How to lodge a complaint with the supervisory authority.
• Whether the provision of personal data is a statutory or contractual requirement, or a requirement necessary to enter into a contract, as well as whether you are obliged to provide the personal data and the possible consequences of failing to provide such data.
• The source of personal data if it wasn’t collected directly from you.
• Any details and information of automated decision making, such as profiling, and any meaningful information about the logic involved, as well as the significance and expected consequences of such processing.ASM Technologies Limited accepts the following forms of ID when information on your personal data is requested: [Passport, Driving Licence and Utility Bill dated within the last 3 months]
• Contact details of the Business Systems Manager:
• What forms of ID will I need to provide in order to access this?

	Data Protection Officer / Business Systems Manager contact details
Contact Name:	Business Systems Manager
Address line 1:	Meridian House
Address line 2:	Road One Winsford Industrial Estate
Address line 3:	Winsford
Address line 4:	Cheshire
Address line 5:	CW7 3QG
Email:	[email protected]
Telephone:	01606863707

Document Owner and Approval

Business Systems Manager is the owner of this document and is responsible for ensuring that this record is reviewed in line with the review requirements of the GDPR.

A current version of this document is available to specified members of staff on the distribution list determined by the Business Systems Manager and is published

04/07/2018

Signature:                                                             Date:

Change History Record

Issue	Description of Change	Approval	Date of Issue
1	Initial issue	Business Systems Manager	04/07/2018