Privacy Policy

This privacy policy sets out how Volex plc (“Volex”, “we”, “us”, or “our”) use and protect any personal data that you provide to us or that we collect about you when you use our website.

We are committed to ensuring that your privacy is protected.  Should we ask you to provide certain information by which you can be identified when using this website or through communication channels outside of this website, then you can be assured that it will only be used in accordance with this privacy policy.

The Volex entity responsible for your personal information will be the member of the Volex group of companies that originally collects information from or about you. This will be explained at the point at which your personal information is first collected by that Volex entity, for example where you or the business you work for engages us to provide a products and services or where we engage you to provide a service to us.

You can find out more about Volex at www.volex.com or by contacting us using the information in the “Our Contact Details” section below.

We may change this policy from time to time by updating this page; the “LAST UPDATED” legend at the top of this policy indicates when it was last revised.  In the case of certain material changes we may reach out to you by email or via your customer account.  You should check this page from time to time to ensure that you are happy with any changes; any changes will become effective when we post the revised privacy policy on the website.

You might find external links to third party websites on our website. This privacy notice does not apply to your use of a third party site.

 

WHAT PERSONAL DATA WE COLLECT, AND WHEN AND WHY WE USE IT

“Personal data” or “personal information” means any information that identifies you as an individual or relates to an identifiable individual.  It does not include data where the identity has been removed (anonymous data).

Whose information do we collect

We collect information about you if you:

• use one of our website(s) or online services;
• purchase or receive one of our services; or
• you are identified as a potential customer,
• you inquire about employment through our Career portal which contains its own employee privacy notice.

When you use our website

On our website, personal information (such as your name, address, telephone number, or email address) is collected when you voluntarily submit it through a website form, such as during a request for information about our services.

If you are raising an enquiry with us in connection with your business, we will collect the name and country of operation of your business along with details of your product interest and the nature of your enquiry.

Other information that may also constitute personal information (such as your browser type, operating system, IP address, domain name, number of times you visited the website, dates you visited the website, and the amount of time you spent viewing the website) may be collected via cookies and other tracking technologies. Aggregate Information (such as how many times visitors log onto the website) may also be collected. Further details on our use of cookies can be found below and within our Cookies Policy.

How we use your information	What is the legal basis for our use of your information
To respond to queries you raise through the website.	Our use of your personal information is in our legitimate interest as a commercial organisation.
To manage our relationship with you, which may include notifying you of changes to our privacy policy or terms of use/service and asking you to take part in surveys.	(a)            In order to take steps at your request prior to entering into a contract or for the performance of a contract to which you are a party; (b)            In order comply with legal obligations to which we are subject; and (c)            Necessary for our legitimate interests (to keep our records updated).
To provide, maintain and improve our services, including developing new features and customer offerings.	(a)            In order to take steps at your request prior to entering into a contract or for the performance of a contract to which you are a party; and Necessary for our legitimate interests (to define types of customers for our products and services, to keep our website updated and relevant).
To market to you about our products and services, and otherwise to identify goods and services which we believe may be of interest to you.	Our use of your personal information is in our legitimate interest as a commercial organisation.
To monitor your use of our websites in order to make improvements to the site and the user experience.	Where we have your consent to do so.
To perform internal operations and for internal record keeping purposes, including preventing fraud or abuse of our services, troubleshooting software bugs and operational problems, conducting data analysis, testing and research, and monitoring and analysing usage and activity trends.	(a)            Necessary to comply with a legal obligation to which we are subject; and (b)            Necessary for our legitimate interests (to define types of customers for our products and services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy).

We do not collect (and we ask that you do not send us) any special categories of personal data (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) about you in connection with our operation of our website, nor do we seek to collect any information about criminal convictions and offences.

When you purchase one of our products or services

Where you purchase or receive our products or services, we may collect:

• basic identification and contact information (such as your name, address, telephone number, gender, national ID number or driving licence information and email address) in order to fulfil your order, provide our products and services and manage your account;
• demographic information such as your age and information about your occupation;
• financial information (such as bank account information, tax registration information, billing and details) in order to manage and process payments you make to us;

• information held by credit references agencies and fraud prevention agencies, in order to assess your application for the use of our products and services; and
• information about your use of our products and services and your satisfaction with them, in order to continuously improve the products and services that we provide to you.

We will use this information in the following ways and where we are satisfied that we have an appropriate legal basis to do so:-

How we use your information	What is the legal basis for our use of your information
Setting up and ongoing management of your account with us.	(a)            Our use of your personal information is necessary to perform a contract with you. (b)            It is also necessary to use your personal information in our legitimate interest as a commercial organisation.
For credit control purposes and to analyse payments made against your account.	(a)            Our use of your personal information is necessary to perform a contract with you. (b)            It is also necessary to use your personal information in our legitimate interest as a commercial organisation.
For credit vetting purposes, to assess your application to receive our services.	Our use of your personal information is in our legitimate interest as a commercial organisation.
To provide general customer services and to respond to your queries and complaints in relation to our services.	(a)            Our use of your personal information is necessary to perform a contract with you. (b)            It is also necessary to use your personal information in our legitimate interest as a commercial organisation.
To deliver our goods and services to you as you request.	Our use of your personal information is necessary to perform a contract with you.
To evaluate your use of our products and services in order to assist with our development of new products and services, and to make improvements to our existing products and services.	Our use of your personal information is in our legitimate interest as a commercial organisation.
For our internal budgeting purposes, maintain financial records, undertake internal financial reporting and make payments to contractors and other third parties	Our use of your personal information is in our legitimate interest as a commercial organisation.
For fraud prevention purposes and to monitor our customers’ use of our services into to detect fraud.	Our use of your personal information is in our legitimate interest as a commercial organisation.
To market to you about our products and services, and otherwise to identify goods and services which we believe may be of interest to you.	Our use of your personal information is in our legitimate interest as a commercial organisation.
Conducting focus groups and undertaking customer relationship management activities and customer satisfaction surveys in order to make improvements to our products and services.	Our use of your personal information is in our legitimate interest as a commercial organisation.
For our employee training purposes.	Our use of your personal information is in our legitimate interest as a commercial organisation.
In order to enable us to comply with any legal or regulatory requirements.	Our use of your personal information is necessary to comply with a relevant legal or regulatory obligation that we have.

When You are identified as a potential customer

We collect information directly, from other members of the Volex group, and from publicly available sources about organisations who feel might like to hear from us or receive our products and services. In those circumstances, we may collect basic identification and contact information (such as your name, address, telephone number, and email address) in order to market our goods and services to you. We will only do so in accordance with your preferences and as described in this privacy notice.

Specifically we may collect:

• basic identification and contact information (such as your name, address, telephone number, gender, national ID number and email address) in order to fulfil any order, provide our services and manage your account;
• demographic information such as your age and information about your occupation; and
• information and feedback you provide to us about our products and services in order to continuously improve the products and services that we provide to you.

We will use this information in the following ways and where we are satisfied that we have an appropriate legal basis to do so:-

How we use your information	What is the legal basis for our use of your information
To provide general customer services and to respond to your queries and complaints in relation to our services.	Our use of your personal information is necessary to perform a contract with you. It is also necessary to use your personal information in our legitimate interest as a commercial organisation.
To evaluate your use of our products and services in order to assist with our development of new products and services, and to make improvements to our existing products and services.	Our use of your personal information is in our legitimate interest as a commercial organisation.
For our internal budgeting purposes, maintain financial records, undertake internal financial reporting and make payments to contractors and other third parties	Our use of your personal information is in our legitimate interest as a commercial organisation.
To market to you about our products and services, and otherwise to identify goods and services which we believe may be of interest to you.	Our use of your personal information is in our legitimate interest as a commercial organisation, or, where necessary, we have your express consent to do so.
Conducting focus groups and undertaking customer relationship management activities and customer satisfaction surveys in order to make improvements to our products and services.	Our use of your personal information is in our legitimate interest as a commercial organisation.
In order to enable us to comply with any legal or regulatory requirements.	Our use of your personal information is necessary to comply with a relevant legal or regulatory obligation that we have.

 

SHARING YOUR PERSONAL DATA

We share your data with certain third parties set out below for the purposes set out in the table above:

• Service providers (acting as processors, such as contact management providers) who provide IT and system administration services in connection with your use of the website.
• Professional advisers including lawyers, bankers, auditors and insurers who provide consultancy, banking, legal, insurance and accounting services.
• Fraud prevention agencies in order to detect and prevent fraud.
• Public and government authorities, including authorities outside your country of residence, where we receive requests from them.
• Third parties to whom we 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 policy.

We also use and disclose personal information, as necessary or appropriate: (a) to comply with applicable law, including laws outside your country of residence; (b) to comply with legal process; (c) to protect our operations; (d) to protect our rights, property or safety, and/or that of our users, you, our or others; and (e) to allow us to pursue available remedies or limit the damages that we may sustain.

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.

TRANSFERS OF YOUR PERSONAL DATA TO LOCATIONS OUTSIDE THE UNITED KINGDOM/THE EUROPEAN ECONOMIC AREA

Our sharing of your personal data with the third parties identified above will result in the transfer of your personal data to locations outside of the UK or the European Economic Area (“EEA”), which may have data protection rules that are different from those in the UK or the EEA (as applicable).  Whenever we transfer your personal data out of the UK or the EEA, we ensure at least one of the following safeguards is implemented:

• We transfer your personal data to countries that have been deemed by the UK government or the European Commission (as applicable) to provide an adequate level of protection for personal data. This applies in respect of any transfer of your personal data (i) from the UK to the EEA and (ii) from the EEA to certain approved non-EEA countries.
• For transfers from the UK or the EEA to countries not considered adequate (such as when we share personal data with third parties), we rely on adequate measures, such as standard contractual clauses, which give personal data the same protection it has in the UK and the EEA. You may obtain a copy of these measures by using the information in the “Our Contact Details” section below.

SECURITY

We strive to keep your information as secure as possible.  In order to prevent unauthorised access or disclosure we have put in place suitable physical, electronic, and managerial procedures to safeguard and secure the information we collect online. Measures we take include placing confidentiality requirements on our staff members and service providers and destroying or permanently anonymising personal information if it is no longer needed for the purposes for which it was collected.  As the security of information depends in part on the security of the computer you use to communicate with us and the security you use to protect any usernames and passwords necessary to make use of our website, please take appropriate measures to protect this information.

STORING YOUR PERSONAL INFORMATION

We will store your personal information for as long as is reasonably necessary for the purposes for which it was collected, as explained in this privacy policy.  In some circumstances we store your personal information for longer periods of time according to the following criteria:

• While we have an ongoing relationship with you and provide our services to you (for example, for as long as you have an account with us or keep using our services);
• Where we are required to do so in accordance with legal, regulatory, tax, accounting requirements (for example, certain laws require us to keep records of your transactions for a certain period of time before we can delete them); and
• Where we need to have an accurate record of your dealings with us in the event of any complaints or challenges, or if we reasonably believe there is a prospect of litigation relating to your personal information or dealings (such as in regard to applicable statutes of limitations, litigation or regulatory investigations).

YOUR LEGAL RIGHTS

Under certain circumstances and subject to certain exemptions, you have rights under data protection laws, to request to access, update, correct, suppress, restrict or delete your personal data provided to us, object to the processing of your personal data (for example, you may object to our use of your information for direct marketing purposes), or request to receive an electronic copy of your personal data for purposes of transmitting it to another company (where the right to data portability is provided to you by applicable law).

We may ask you for additional information to confirm your identity and for security purposes, before responding to a request you raise.  We reserve the right to charge a fee where permitted by law, for instance if your request is manifestly unfounded or excessive.

You can exercise your rights by contacting us using the details below in the “Our Contact Details” section.  Subject to legal and other permissible considerations, we will make every reasonable effort to honour your request promptly or inform you if we require further information in order to fulfil your request.

OUR CONTACT DETAILS

Volex plc is the entity responsible for collection, use, and disclosure of your personal information under this privacy policy.

If you have any questions, concerns or complaints regarding our compliance with this privacy policy and the data protection laws, or if you wish to exercise your rights, we encourage you to first contact us using the details set out below.  We will investigate and attempt to resolve complaints and disputes and will make every reasonable effort to honour your wish to exercise your rights as quickly as possible and in any event, within the timescales provided by applicable data protection laws.

Email – Volex Legal Team

How to contact regulatory authorities

You also have the right to report your concern to an appropriate regulatory authority, depending on where you have your habitual residence or place of work, or where an alleged infringement of applicable data protection law occurs.  For the UK, this is the Information Commissioner’s Office (“ICO”), the UK supervisory authority for data protection issues (www.ico.org.uk).  For the EEA, a list of data protection authorities is available here.