1. Introduction
As one of our customers, suppliers or someone else with whom we engage in business activities with, you understand and agree that we collect, use and disclose your personal information in accordance with this Privacy Policy (this “Policy”).
We use your personal information in order to fulfil our commitment to providing our products to you and with added services to improve your experience in connection with all of your interactions with CHG GROUP (the “Purpose”). As part of that undertaking, we are committed to safeguarding the privacy of the personal information that we gather.
2. The application of this policy
This policy applies to personal information regarding Companies, Suppliers and all other individuals with whom we engage in business activities with and to the use of that personal information in any form - whether oral, electronic or written. This policy gives effect to our commitment to protect your personal information and has been adopted by all of the separate and distinct legal entities that manage, operate, franchise, license, own and/or provide services to the CHG GROUP.
Those entities include the separate and distinct legal entities which provide services to you under the CHG GROUP brand. References to “CHG GROUP”, “we” and “our” throughout this Policy, depending upon the context, collectively refer to those separate and distinct legal entities.
While this Policy is intended to describe the broadest range of our personal information processing activities globally, those processing activities may be more limited in some jurisdictions based on the
restrictions of their laws. For example, the laws of a particular country may limit the types of personal information we can collect or the manner in which we process that personal information. In those instances, we adjust our internal policies and/or practices to reflect the requirements of local law.
3. Types of personal information we collect
The term “personal information” in this policy refers to information that does or is capable of identifying you as an individual. The types of personal information that we process (which may vary by jurisdiction based on applicable law) include:
• your name, gender, personal and work contact details, date and place of birth, image/photos, nationality;
• your bank account details, and your account details such as customer reference number or customer ID and credentials;
• information, feedback or content you provide regarding your marketing preferences, or to our websites or apps and those of third parties;
• information collected whilst you access a website (we describe this in more detail in Sections 6 and 7 below).
Much of the personal information we process is information that you or someone acting on your behalf knowingly provides to us. However, in other instances, we process personal information that we are able to infer about you based on other information you provide to us or during our interactions with you, or personal information about you that we receive from a third party. This policy also applies to the personal information about you that we receive from a third party, unless specifically covered by such third party’s privacy policy.
There may be very rare instances in which the personal information that you provide to us or that
we collect is considered Sensitive Personal Information under the privacy laws of some countries.
Those laws define “Sensitive Personal Information” to mean personal information from which we
can determine or infer an individual’s racial or ethnic origin, political opinions, religious beliefs or
other beliefs of a similar nature, membership in a trade union or professional association, physical or
mental health or condition, medical treatment, genetic data, sexual life or judicial data (including
information concerning the commission or alleged commission of a criminal offence). In some very
rare instances, financial records may form part of Sensitive Personal Information where you are
located. We only process Sensitive Personal Information in your jurisdiction if and to the extent
permitted or required by applicable law.
When you agree to this policy you are, to the extent required under your local law, you are granting
your express and written consent to the processing of any personal information that you provide to
CHG GROUP. that is considered to be Sensitive Personal Information or financial information. Save to
the extent required by law, you are not obliged to provide CHG GROUP with any of your Sensitive
Personal Information, and should you chose not to, this will not prevent you from purchasing any
products or services from CHG GROUP .
4. How we use personal information
Subject to applicable laws, we may collect, use and disclose relevant portions of your personal
information in order to:
• provide and charge for products and related services;
• provide you with a better or more personalised level of product, service, and/or experience including information and services from a third party (such as other products, or offers related to your preference for a given product);
• respond to requests for information and services, including services from a third party (such as a
companies who make and transport products, provide services, and research product buyers);
• administer the CHG GROUP Marketing News and Product/Services Updates;
• fulfil contractual obligations to you, anyone involved in the process of making your access to
products the best possible;
• conduct market research, customer satisfaction and quality assurance surveys, and direct
marketing and sales promotions;
• provide for the safety and security of staff, or others;
• administer general record keeping;
• meet legal and regulatory requirements;
• test and evaluate new products and services.
CHG GROUP . uses and retains your personal information for as long as is necessary to fulfil the
purpose, however we will delete all data held where no business activity has taken place for 5-years.
5. Disclosures of your personal information
From time to time, we may disclose your personal information. We would always make that disclosure in agreement with applicable law. In some jurisdictions, data privacy laws may require us to obtain your consent before we transfer your information from your originating country to other countries. When you agree to this policy, you are, to the extent required and permitted under your local law, granting your consent to the transfer of your personal information to such other countries for the Purpose and to the extent stated in this section and as described in Section 4 above.
Circumstances where we might make such disclosure (in addition to those described in Section 4
above) include:
5.1 Our agents, service providers and suppliers
Like most Businesses, we may outsource the processing of certain functions and/or information to
third parties. When we do outsource the processing of your personal information to third parties or
provide your personal information to third-party service providers, we oblige those third parties to
protect your personal information in accordance with the terms and conditions of this policy, with
appropriate security measures.
5.2 Consumer insights
Where we hold personal information about you, we may disclose this personal information to other
companies that also hold information about you. These companies may combine the information in
order to better understand your preferences and interests, thereby enabling them and us to serve
you better. If your personal information is used for direct marketing purposes, you have the right to
object to that by contacting us using the contact information provided under Section 11 below.
5.3 Business transfers
In the unlikely event that we, or substantially all of our assets, are acquired, personal information
collected about you, or control of such information, may be one of the transferred assets.
5.4 Legal requirements
We reserve the right to disclose any personal information we have concerning you if we are
compelled to do so by a court of law or lawfully requested to do so by a governmental entity or if we
determine it is necessary or desirable to comply with the law or to protect or defend our rights or
property in accordance with applicable laws. We also reserve the right to retain personal
information collected and to process such personal information to comply with accounting and tax
rules and regulations and any specific record retention laws.
6. Information we collect when you visit us online
If you access the CHG GROUP . website, you may wish to know the following:
6.1 You can browse without revealing who you are
You can always visit our websites without logging in or otherwise revealing who you are.
6.2 Usage information
When you visit our websites, we collect information about how you use those websites. Examples of
such information include the Internet Protocol address automatically assigned to your computer
each time you browse the Internet, the date and time of your visit, the pages you access and the
amount of time you spend on each page, the type of Internet browser you use, your device’s
operating system and the URL of any websites that you visited before and after visiting our website.
That information is not linked to you as an individual unless you create a user profile, but we may
keep records of the device being used.
6.3 Cookies and other similar technology
We may use cookie technology on our websites to allow us to evaluate and improve the
functionality of our websites. Cookies by themselves cannot be used to reveal your identity. They
identify your browser, but not you, to our servers when you visit our websites.
If you do not want to accept cookies, you can block them by adjusting the settings on your Internet
browser. However, if you block them, you may not be able to use all of the features of our websites.
6.4 Social media
Our websites may also contain plug-ins and other features that integrate third party social media
platforms into our websites. You will be able to activate them manually. If you do so, the third
parties who operate these platforms may be able to identify you, they may be able to determine
how you use this website and they may link and store this information with your social media
profile. Please consult the data protection policies of these social media platforms to understand
what they will be doing with your personal data. If you activate these plug-ins and other features,
you will be doing so at your own risk.
6.5 Security
Because the security of your personal information is important to us, the personal information we
collect from you online is stored by us and/or our service providers on databases protected through
a combination of physical and electronic access controls, firewall technology and other reasonable
security measures. Nevertheless, such security measures cannot prevent all loss, misuse or
alteration of personal information and we are not responsible for any damages or liabilities relating
to any such incidents to the fullest extent permitted by law. Where required under law, we will
notify you of any such loss, misuse or alteration of personal information that may affect you so that
you can take the appropriate actions for the due protection of your rights.
6.6 Minor children
We do not sell products or services for purchase by children and we do not knowingly solicit or
collect personal information from children. If you are under the age of 18 (or a minor in the
jurisdiction in which you are accessing our websites), you may only use our websites with the
involvement of a parent or guardian.
6.7 Targeted advertising
This may include advertisements displayed on our own websites or apps, or advertisements from us
displayed on other companies' websites. The advertisements you see may be based on information
collected by us or third parties and/or may be based on your activities on our websites or third-party
websites.
7. Apps
When you download or register to use one of our apps or digital product, you may submit personal
information to us such as your name, address, email address, phone number, date of birth,
username, password and other registration information, financial and credit card information,
personal description and/or image.
Further, when you use our apps, we may collect certain information automatically, including
technical information related to your mobile device, your device’s unique identifier, your mobile
network information, the type of mobile browser you use and information about the way you use
the app.
Depending on the particular app you use and only after you have agreed to such collection, we may
also collect information stored on your device, including contact information, friends lists, login
information (where necessary to allow us to communicate with other apps at your request), photos,
videos, location information or other digital content. Further details of the kinds of information we
collect is set out in the privacy notice for each individual app.
8. Choice
You may always choose what personal information (if any) you wish to provide to us. However, if
you choose not to provide certain details, some of your experiences with us may be affected (for
example, we cannot deliver a product without an address).
If you provide us with your contact details (e.g. postal address, email address, telephone number or
fax number), we may contact you to let you know about the products, services, promotions and
events offered that we think you may be interested in. We may also share your personal information
with carefully-selected third parties, who may communicate directly with you. In some jurisdictions,
data privacy laws may require us to obtain a separate consent before we do so. You can always
choose whether or not to receive any or all of these communications by contacting us as described
in Section 11 below or following the “unsubscribe” instructions contained in the communications.
If you have an account with CHG GROUP Limited. We ask you to indicate your communication
preferences at the time you apply for the account. We may also ask you to indicate how you would
like to receive any offers, marketing and promotional information (e.g. via email or regular mail) and
whether you would be willing to participate in surveys. Once you have indicated your preferences,
you can always change them.
In some jurisdictions, in addition to you agreeing to this Policy, data privacy laws may require us to
obtain a separate consent before we send you information that you have not specifically requested.
In certain circumstances, your consent may be implied (e.g. where communications are required in
order to fulfil your requests and/or where you have volunteered information for use by us). In other
cases, we may seek your consent expressly in accordance with applicable laws (e.g. where the
information collected is regarded to be Sensitive Personal Information under local regulations).
We will abide by any request from you not to send you direct marketing materials. When such a
request is received, your contact details will be “suppressed” rather than deleted. This will ensure
that your request is recorded and retained unless you provide a later consent that overrides it.
9. Updating or Accessing Your Personal Information
With some limited exceptions, you have rights to access and update personal information held about
you. If you want to inquire about any personal information we may have about you, you can do so
by sending us a written request by letter or email to the addresses set out in Section 11 below.
Please be sure to include your full name, address, and/or email address and phone number so we
can ascertain your identity and whether we have any personal information regarding you, or in case
we need to contact you to obtain any additional information we may require to make that
determination.
You may request that we correct, cancel, and/or stop processing or using personal information that
we hold about you. If we agree that the personal information is incorrect, or that the processing
should be stopped, we will delete or correct the personal information. If we do not agree that the
personal information is incorrect we will tell you that we do not agree, explain our refusal to you and
record the fact that you consider that personal information to be incorrect in the relevant file(s).
10. Changes to this policy
Just as our business changes constantly, this policy may also change. To assist you, this Policy has an
effective date set out at the end of this document.
11. Request for access to personal information/questions or complaints
According to applicable law, you have a right of access to a copy of the information comprised in
your personal data; a right to object to processing that is likely to cause or is causing damage or
distress;
A right to prevent processing for direct marketing; a right to object to decisions being taken by
automated means; a right in certain circumstances to have inaccurate personal data rectified,
blocked, erased or destroyed; and a right to claim compensation for damages caused by a breach of
the Data Protection Act.
If you have any questions about this Policy, about the processing of your data described, or any
concerns or complaints with regard to the administration of the Policy, or if you would like to submit
a request (in the manner described in Section 9 above) for access to or deletion of the personal
information that we maintain about you, please contact us by any of the following means:
• by mail CHG GROUP , 2 Wortley Road, Deepcar, Sheffield, S36 2UZ
• by contacting the front desk at CHG GROUP on 0114 2180470
If you are not satisfied with the response that you receive, you can escalate your concern to
management who are responsible for Data Protection Compliance by sending an email to
You may request that we correct, cancel, and/or stop processing or using personal information that
we hold about you. If we agree that the personal information is incorrect, or that the processing
should be stopped, we will delete or correct the personal information. If we do not agree that the
personal information is incorrect we will tell you that we do not agree, explain our refusal to you and
record the fact that you consider that personal information to be incorrect in the relevant file(s).
All requests for access to your personal information must be submitted in writing by letter to Senior
Management (Data Compliance), CHG GROUP, 2 Wortley Road, Sheffield, S36 2UZ. We may respond
to your request by letter, email, telephone or any other suitable method.
Effective date: May 1, 2019
Signed by: Peter D. Clarke, Managing Director
Review Date: 01/03/2024
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