Privacy and Cookie Policy

This privacy policy sets out how TMT First Ltd (we, our, us ) uses and protects any information that you provide to us when you use this website.

TMT First Ltd is committed to ensuring that your privacy is protected. TMT are registered with the Information Commissioner’s Office with Registration Number Z3505486. Should we ask you to provide certain information by which you can be identified when using this website, then you can be assured that it will only be used in accordance with this privacy statement and our registration.

TMT First Ltd may change this policy from time to time by updating this page. You should check this page from time to time to ensure that you are happy with any changes.

Our role when using your personal data

For the personal data described in this Privacy Policy, TMT First Ltd generally acts as the data controller. This means that we determine why and how your personal data is processed, including where you use our website, contact us, request a quotation, place an order or otherwise interact directly with TMT First.

Where we share personal data with payment or finance providers, those organisations may act as independent data controllers for the personal data they process for their own purposes, for example to provide payment or finance services, carry out eligibility or fraud checks, or meet their legal and regulatory obligations. Their processing is subject to their own privacy information.

In some circumstances, TMT First processes personal data on behalf of our business customers, for example when providing contracted repair, logistics, IT asset disposition or other services. In those circumstances, TMT First may act as a data processor, and the relevant business customer remains responsible for determining the purposes and means of that processing.

Where TMT First and another organisation jointly determine the purposes and means of processing personal data, the parties may act as joint controllers. Where this applies, we will provide appropriate information about the arrangement and the respective responsibilities of the parties.

What we collect

We may collect the following information:

• Name and job title
• Contact information including email address
• Demographic information such as address and postcode
• Other information relevant to the quote or fulfilment of your order

Sources of personal data

We collect most personal data directly from you when you:

• submit an enquiry;
• request a quote;
• place an order;
• sign up for updates or marketing;
• correspond with us by email, phone or post; or
• otherwise interact with our website or services.

We may also collect personal data from other sources, including:

• your employer or the organisation you represent, where they engage us for business services;
• payment providers and finance providers, where relevant to payment processing or fraud checks;
• website technologies such as cookies, analytics tools and server logs, which may collect technical information such as IP address, browser details and website activity;
• manufacturers, service partners or distributors where they refer work to us or support warranty / service activity;
• recruitment websites or agencies, where you apply for a role through those channels; and
• publicly available business information, where this is used for proportionate B2B sales and marketing activity.

If we receive your personal data from a source other than you, we will process it only where permitted by law and provide privacy information in accordance with UK data protection requirements.

What we do with the information we gather

We require this information to understand your needs and provide you with a better service, and in particular for the following reasons:

• Internal record keeping.
• Payment Processing
• We may use the information to improve our products and services.
• We may also use your information to contact you about your order. We may contact you by email, phone or mail.
• From time to time, we may periodically send promotional emails about new products, special offers or other information which we think you may find interesting using the email address which you have provided.

Our lawful basis for this processing will depend on the context: contract for orders and service delivery, legitimate interests for responding to business enquiries and proportionate B2B communications, consent for certain consumer marketing, and legal obligation where processing is required by law.

Where you choose to use a finance option or request a finance referral, we may share information necessary to facilitate that application or referral with the relevant finance provider. This may include your name, address and postcode, email address, telephone number, and relevant quotation, order or finance information. We only share information that is necessary for the finance provider to process the referral or provide the requested finance service.

TMT First does not require special category personal data for finance referrals and does not intentionally share special category personal data with finance providers for this purpose.

Personal data collected or shared for payment, finance application or finance referral purposes will only be used for those purposes unless there is a separate lawful basis for another use. We do not treat a request for finance or a finance referral as consent to receive marketing. Any use of personal data by TMT First for marketing or analytics is considered separately and will only take place where we have an appropriate lawful basis and, where required, your consent.

Lawful bases for processing

We only process personal data where we have a valid lawful basis under UK data protection law. Depending on how you interact with us, these lawful bases may include:

• Contract – where processing is necessary to take steps at your request or to perform a contract with you, for example to process an order, arrange payment, facilitate a finance application or referral requested by you, provide repair or other service communications, fulfil an order, manage returns, warranties or customer support.
• Legitimate interests – where processing is necessary for our legitimate interests and those interests are not overridden by your rights and freedoms, for example for internal administration, record keeping, improving our services, responding to business enquiries, maintaining website security, preventing fraud, and sending relevant B2B marketing communications to business contacts.
• Consent – where we rely on your consent, for example for certain marketing communications to consumers and for non-essential cookies or similar technologies where required. Where we rely on consent, you can withdraw it at any time.
• Legal obligation – where we need to process personal data to comply with a legal or regulatory obligation.

Where we rely on legitimate interests, those interests generally include operating and improving our business, responding to enquiries, maintaining customer relationships, ensuring website and information security, and promoting relevant products and services in a proportionate way.

International transfers

Some of the organisations that provide services to us may process or store personal data outside the United Kingdom.

Where personal data is transferred outside the UK, we ensure that an appropriate mechanism is in place to protect your personal data in accordance with UK data protection law. Depending on the country and organisation involved, this may include:

• transferring personal data to a country or organisation covered by UK adequacy regulations;
• using the UK International Data Transfer Agreement (IDTA);
• using the EU Standard Contractual Clauses together with the UK International Data Transfer Addendum; or
• another lawful transfer mechanism permitted under UK data protection law.
  Where required, we also assess the risks associated with the transfer and implement additional safeguards where appropriate.

Security

We are committed to ensuring that your information is secure. 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.

Your Data Protection Rights

Under data protection law, you may have the following rights depending on the circumstances and the lawful basis on which we process your personal data:

• Right to be informed – you have the right to be informed about how we collect and use your personal data. This Privacy Policy is intended to provide that information.
• Right of access – you can ask us for a copy of the personal data we hold about you.
• Right to rectification – you can ask us to correct personal data that you believe is inaccurate or complete information that you believe is incomplete.
• Right to erasure – you can ask us to delete your personal data in certain circumstances.
• Right to restrict processing – you can ask us to restrict the way we use your personal data in certain circumstances.
• Right to data portability – in certain circumstances, you can ask us to provide personal data you have given us in a structured, commonly used and machine-readable format, or ask us to transfer it to another organisation where technically feasible.
• Right to object – you can object to certain types of processing, including processing based on our legitimate interests. You have an absolute right to object to the use of your personal data for direct marketing.
• Rights relating to automated decision-making and profiling – you have rights in relation to decisions made solely using automated processing, including profiling, where those decisions have legal or similarly significant effects on you.

Where we rely on your consent, you can withdraw that consent at any time. Withdrawal of consent does not affect the lawfulness of processing carried out before consent was withdrawn.

To exercise any of these rights, please contact us at [email protected]. You do not normally have to pay a fee to exercise your rights. We may need to ask you for information to confirm your identity before responding to your request.

You also have the right to complain to the Information Commissioner’s Office (ICO) if you are unhappy with how we have used your personal data.

How long we keep your personal data

We retain personal data only for as long as necessary for the purpose for which it was collected, and to meet legal, regulatory, tax, accounting, warranty, contractual and evidential requirements.

As a guide:

Enquiry and correspondence records are retained for as long as necessary to deal with your enquiry and for a reasonable period afterwards to manage follow-up, defend legal claims and maintain business records.
Customer order, service and repair records are retained in line with our service, finance, tax, consumer law and warranty obligations. Depending on the service, this may be up to 3 years after repair or up to 7 years where required for contractual, finance or compliance purposes.
Marketing records are retained while you remain subscribed or while we are actively marketing to you on a lawful basis. If you opt out, we will keep limited suppression details so that we can honour your preference and avoid contacting you again.
Cookie, analytics and security log data is retained for only as long as necessary for website operation, security monitoring, troubleshooting and analytics, and is typically retained for up to 12 months, unless we need to keep it longer to investigate an incident or comply with legal obligations.
Subject access request and other privacy rights records are retained for up to 3 years after closure.

Retention periods may vary where a longer or shorter period is required by law, regulation, contract, warranty arrangements, dispute handling or an active investigation. When the applicable retention period ends, we securely delete or anonymise the personal data.

Your right to complain to the ICO

You have the right to lodge a complaint with the Information Commissioner’s Office (ICO) using the details below if you are unhappy with how we use your personal data. We would appreciate the chance to deal with your concerns first, so please contact us in the first instance.

Information Commissioner’s Office (ICO)
Wycliffe House
Water Lane
Wilmslow
Cheshire
SK9 5AF
Helpline: 0303 123 1113
Website: www.ico.org.uk

Contact us about data protection

If you have any questions about this policy or how we handle your personal data, please contact:

TMT First Ltd
Holditch House
Holditch Road
Newcastle-under-Lyme
Staffordshire
ST5 9JQ

Email: [email protected]
Telephone: 01782 576920