Privacy Policy

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 This Privacy Notice (the “Notice”) sets out how Waste to Watts Ltd ("W2W") collects and processes information about you when you visit this website or when you otherwise provide your personal information us, as described in this Notice.

References in this Notice to “we”, “us” or “our” are references to W2W.

If you have any questions or concerns about our use of your personal information then please contact us using the contact details provided on this Website.

1. Information collected

The personal information that we may collect about you broadly falls into the following categories:

Information that you provide voluntarily

Certain parts of our Website may ask you to provide personal information voluntarily. Further examples of this are set out below; however as a general point, the personal information that you are asked to provide, and the reasons why you are asked to provide it, will be made clear to you at the point we ask you to provide your personal information.

• General:  You may give us information, including information that can identify you (“personal information”), when you make enquiries about the Website, our products or services or about career opportunities with us or when you otherwise communicate with us (whether via the Website or otherwise).  For example, we may ask you to provide specific information set out in an online inquiry form.  You may choose to provide additional information to us when you communicate with us or otherwise interact with us, including in any free text box contained in an online inquiry form.
• Personal Information that we collect when you do business with us: 
  We may process your personal information when you conduct business with us (whether through the Website or otherwise) as, or on behalf of, a customer or prospective customer, or as, or on behalf of, a vendor, supplier, consultant, professional adviser or other third party.  In this context, we process:
  • business contact information that is necessary to understand your role within your organization and to communicate with you;
  • financial information that is necessary to take payment or fulfil contractual obligations or for related purposes;
  • personal opinions/insights included in any feedback necessary to evaluate our performance and that of our suppliers or other business partners; and
  • personal information necessary to conduct business effectively with you or the organization that you represent.
• Personal Information that you provide about another person:  If you provide us with information about another person, for example, if you refer someone to us via the Website who you think would be interested in joining our team, you confirm that you have informed them of our identity and the purposes (as set out in this Notice) for which their personal information will be processed and that you have obtained any necessary consents to the processing of their personal data. When we first contact them, we may tell them where we got the information from.

Information we collect automatically

When you visit our Websites, we may also collect certain information by automated means from your device.  In some countries, including countries in the European Economic Area (EEA), this information may be considered personal information under applicable data protection laws.

Specifically, the type of information we collect automatically may include information such as your IP address, device type, unique device identification numbers, browser type, broad geographic location (e.g. country or city-level location) and operating system, referring URLs, information about your visit including the URL clickstream to, through and from our Websites, download errors, number of Website visits, average time spent on the Website, length of visits to certain pages and page interaction. We collect this information automatically through the use of various technologies including through “cookies”.

A cookie is a data file containing small amounts of information that a website can send to your browser (and many websites do), which may then be stored on your computer as a tag that distinguishes your computer but does not name you.  

Information that we obtain from third party sources

From time to time, we may receive personal information about you from third party sources, including our group companies, business partners and other third party sources and add it to the information we already hold about you.  We will only do so where we have checked that these third parties either have your consent or are otherwise legally permitted or required to disclose your personal information to us.  The types of information we collect from third parties include: 

• updated business address information;
• purchase history;
• demographic information;
• credit information from credit reference agencies about customers or business partners;
• information obtained from employment and recruitment agencies to whom you provide your information in connection with a career opportunity with us.

Personal Information for which we act as a data processor:  We may process personal information on behalf of our customers in the context of supporting our products.  We do so in accordance with the instructions of our customers.  While our customers are in control of what personal information is processed by our products it will typically include personal information about individuals who are involved with the sale or support of our products or services.  For further information about how such information is handled by our customers, please refer to the privacy policies of those customers.

2. Use of personal information

We process your personal information for the following purposes:

• To deal with your inquiries and requests;
•  To create and administer records about any online account that you register with us, or to allow you to register an account with us;
• To maintain and improve the accuracy of the records that we hold about you;
• To provide you with information, and access to resources that you have requested from us;
• To provide our products and services;
• To otherwise maintain our relationship with you, including requesting/processing your feedback;
• Research and development and to improve our products and services (subject to your prior consent, which will be obtained separately from this Notice);
• Website and system administration and security;
• For internal analytics, in particular too better understand the visitors who come to our Websites, where they come from and what content on our Website is of interest to them  and to improve the navigation and content of the Website for information about opting out of the cookies that are used for this purpose);
• To assess financial, credit or insurance risks arising from any relationship or prospective relationship with a customer, supplier, distributor or other business partner;
• To alert you to updates to the Website, and any to any news and events in which we think you may be interested (should you opt in to receiving such updates) and/or to allow you to submit enquiries to us;

3. Information we share

We will only disclose personal information to other companies within our group of companies. We may also share your information with third parties when:

(1) it is necessary to involve third party service providers such as software product/support providers on a “need-to-know” basis in order to support the provision of our products and services and business operations; (2) we have your consent or have otherwise been requested by you (e.g. with social media networks or with other employers); (3) required by a court order or any by any competent legal, regulatory, government agency, court or other third party where we believe disclosure is necessary: (i) as a matter of applicable law or regulation, (ii) to exercise, establish or defend our legal rights or the rights of our customers, website users or other third parties (e.g. with debt collection and tracing agencies or to enforce our Terms of Use), or (iii) to protect your vital interests or those of any other person; (4) in connection with the actual or potential sale or transfer of a business, provided that we inform the buyer (or potential buyer) it must use your personal information only for the purposes disclosed in this Notice and (5) to credit reference agencies (name only) to establish creditworthiness, to the extent permitted by applicable law.

4. Your choices in relation to direct marketing

We may use the information that you give to us to contact you by mail, telephone, fax email or electronic messaging service to alert you to updates to the Website, and any news and events in which we think you may be interested (should you opt in to receiving such updates).  We will also offer you the opportunity to unsubscribe in every communication sent.

5. Legal basis for processing personal information (if EEA data protection law applies)

If EEA data protection law applies, our legal basis for collecting and using the personal information described above will depend on the personal information concerned and the specific context in which we collect it.  

However, we will normally collect personal information from you only (i) where we need the personal information to perform a contract with you, (ii) where the processing is in our legitimate interests and not overridden by your rights, or (iii) where we have your consent to do so.  In some cases, we may also have a legal obligation to collect personal information from you or may otherwise need the personal information to protect your vital interests or those of another person.

If we collect and use your personal information in reliance on our legitimate interests (or those of any third party), this interest will normally be to operate our Website(s) and to communicate with you as necessary to provide our services to you and for our legitimate commercial interest, for instance, when responding to your queries, improving our Website(s), undertaking marketing, or for the purposes of detecting or preventing illegal activities. 

Given the business-to-business context in which we undertake the processing of your personal information, and the safeguards we take to protect your personal information, our legitimate interests are not outweighed by an prejudice to your individual rights and freedoms.  We may have other legitimate interests and if appropriate we will make clear to you at the relevant time what those legitimate interests are.

You can choose not to provide personal information to us.  However, unless otherwise indicated, the information that we request is necessary for the purposes of entering into and performing a contract with you or your organization and/or providing services/website facilities to you or your organization and failure to provide it will impede the contracting process and/or the provision of the relevant services or facilities.

6. Links to Other Websites and social media

The Website may contain links to other websites which are outside our control and are not covered by this Notice. While we try to link only to websites that share our high standards and respect for privacy, we are not responsible for the content, security or privacy practices employed by other websites.   If you access other websites using the links provided, the operators of these websites may collect information from you which will be used by them in accordance with their privacy notice, which may differ from ours.

On some Website pages, third parties that provide content, applications or plug-ins through our Websites may track your use of content, applications and plug-ins or customize content, applications and plug-ins for you.  For example, when you share a webpage using a social media sharing button on our Websites (e.g., Facebook, Twitter, or Google Plus), the social network that has created the button will record that you have done this. For more information on social media plug-ins on our Websites, see our Cookies Notice.

7. Data Retention

We retain personal information that we collect from you where we have an ongoing legitimate business need to do so.  If you are a client or vendor (or a representative of a client for vendor, your personal  information will be retained for a period of time to allow us to provide or receive the relevant services (as the case may be) and to comply with applicable legal, tax or accounting requirements.  We will not retain your information for longer than is necessary for our business purposes or for legal requirements. 

When we have no ongoing legitimate business need to process your personal information, we will either delete or anonymize it or, if this is not possible (for example, because your personal information has been stored in backup archives), then we will securely store your personal information and isolate it form any further processing until deletion is possible.

8. Security

We maintain reasonable and appropriate technical and organizational security measures to protect the personal information you provide to us through a Website against unauthorized disclosure, use, alteration, or destruction. These measures are designed to provide a level of security appropriate to the risk of processing your personal information. Please note, however, that perfect security does not exist on the Internet. Therefore, while we endeavor to protect your personal information, when data is transferred over the Internet it may potentially be accessed and used by unauthorized parties.

Where you have a password, which enables you to access a Website, you are responsible for keeping this password secure and confidential.

9. Your rights

If you are from certain territories (such as Switzerland or the EEA), you may have the right to access the personal information that we hold about you, or to correct, amend or delete such information pursuant to the EU-U.S. or Swiss-U.S. Privacy Shield Frameworks (as applicable).  If EEA data protection law applies to the processing of your personal information, you have the following data protection rights: 

• If you wish to access, correct, update or request deletion of your personal information, you can do so at any time by contacting us.  
• In addition, you can object to processing of your personal information, ask us to restrict processing of your personal information or request portability of your personal information.
• You have the right to opt-out of marketing communications we send you at any time. You can exercise this right by clicking on the “unsubscribe” or “opt-out” link in the marketing e-mails we send you.  To opt-out of other forms of marketing (such as postal marketing or telemarketing), then please contact us using the contact details provided herein.
• Similarly, if we have collected and process your personal information with your consent, then you can withdraw your consent at any time.  Withdrawing your consent will not affect the lawfulness of any processing we conducted prior to your withdrawal, nor will it affect processing of your personal information conducted in reliance on lawful processing grounds other than consent.
• You have the right to complain to a data protection authority about our collection and use of your personal information.  For more information, please contact your local data protection authority.
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If you wish to make such a request, please contact us. Before responding to your request, we may ask you to verify your identity and to provide further details about your request. We willendeavor to respond within an appropriate timeframe and, in any event, within any timescales required by law or, where applicable, within the timescales required by law.

10. International transfers

We belong to an international group of companies.  Consequently, we may transfer your personal information outside your country of residence to countries or jurisdictions where we have facilities or engage third parties to provide services to us for the purposes outlined in this Notice.  The countries to which we may transfer your personal information are in Europe. Such countries may not have the same level of data protection as within your country. If we do make such a transfer, we will, take steps in accordance with applicable laws to protect your personal information and will obtain your prior consent separately from this Notice, if required to do so by applicable law.