Sinomine Specialty Fluids understands that your privacy is important to you and that you care about how your personal data is used. We respect and value the privacy of everyone who visits this website, formatebrines.com mystagingwebsite.com (Our Site), and will only collect and use personal data in ways that are described here and in a way that is consistent with our obligations and your rights under the law.
In this policy the following terms shall have the following meanings:
|‘Cookie’||means a small text file placed on your computer or device by Our Site when you visit certain parts of Our Site and/or when you use certain features of Our Site. Details of the cookies used by Our Site are set out in parts 14 to 16 below|
|‘Cookie law’||means the relevant parts of the Privacy and Electronic Communications (EC Directive) Regulations 2003|
Our Site is owned and operated by Sinomine Specialty Fluids with registered offices at Ocean House, Hareness Circle, Altens Industrial Estate, Aberdeen, AB12 3LY, Scotland.
Data Protection Officer: Joan Gover
Email address: firstname.lastname@example.org
Telephone number: (44) 1224 897229
Postal address: Sinomine Specialty Fluids, Ocean House, Hareness Circle, Altens Industrial Estate, Aberdeen, AB12 3LY, Scotland.
Personal data is defined by the General Data Protection Regulation (EU Regulation 2016/679) (GDPR) and the Data Protection Act 2018 (collectively, ‘the data protection legislation’) as ‘any information relating to an identifiable person who can be directly or indirectly identified in particular by reference to an identifier’.
Personal data is, in simpler terms, any information about you that enables you to be identified. Personal data covers obvious information such as your name and contact details, but it also covers less obvious information such as identification numbers, electronic location data and other online identifiers.
Under the data protection legislation, you have the following rights, which we will always work to uphold:
The right to access the personal data we hold about you. Part 13 will tell you how to do this.
The right to have your personal data rectified if any of your personal data held by us is inaccurate or incomplete. Please contact us using the details in part 17 to find out more.
The right to be forgotten, i.e. the right to ask us to delete or otherwise dispose of any of your personal data that we hold. Please contact us using the details in part 17 to find out more.
The right to restrict (i.e. prevent) the processing of your personal data.
The right to object to us using your personal data for a particular purpose or purposes.
The right to withdraw consent. This means that, if we are relying on your consent as the legal basis for using your personal data, you are free to withdraw that consent at any time.
The right to data portability. This means that, if you have provided personal data to us directly, we are using it with your consent or for the performance of a contract, and that data is processed using automated means, you can ask us for a copy of that personal data to re-use with another service or business in many cases.
Rights relating to automated decision-making and profiling. We do not use your personal data in this way.
For more information about our use of your personal data or exercising your rights as outlined above, please contact us using the details provided in part 17.
It is important that your personal data is kept accurate and up-to-date. If any of the personal data we hold about you changes, please keep us informed as long as we have that data.
Further information about your rights can also be obtained from the Information Commissioner’s Office or your local Citizens Advice Bureau in the United Kingdom or equivalent organisations in other countries within the European Economic Area (EEA), which consists of all EU member states, plus Norway, Iceland and Liechtenstein.
If you have any cause for complaint about our use of your personal data, you have the right to lodge a complaint with the Information Commissioner’s Office in the United Kingdom. We would welcome the opportunity to resolve your concerns ourselves however, so please contact us first, using the details in part 17.
|Data collected||How we collect the data|
|Identity information, i.e. your name and title||Registration form when downloading materials and registering to receive other information|
|Contact information, i.e. your email address||Registration form when downloading materials and registering to receive other information|
|Business information, i.e. your company name and job title||Registration form when downloading materials and registering to receive other information|
|Profile information, including your preferences, interests and login details||On accessing our site, when sending communication to us and through the registration process named above|
|Technical information, including your IP address, browser type, browser versions and operating system||On accessing our site, when sending communication to us and through the registration process named above|
Under the data protection legislation, we must always have a lawful basis for using personal data. The following table describes how we may use your personal data and our lawful bases for doing so:
|What we do||What data we use||Our lawful basis|
|Registering you on Our Site||Personal contact details; name, title, company name, email address, etc.||Legitimate business interests and day-to-day running of Our Site|
|Providing and managing your account||Identity information, contact information, business, information, profile information and technical information||Legitimate business interests and day-to-day running of Our Site|
|Providing and managing your access to our downloads||Profile information, business information and technical information||Legitimate business interests and day-to-day running of Our Site|
|Personalising and tailoring your experience on Our Site||Profile information, business information and technical information||Legitimate business interests and day-to-day running of Our Site|
|Administering Our Site||Technical information, business information and profile information||Legitimate business interests and day-to-day running of Our Site|
|Administering our business||Identity information, contact information, business information, profile information and technical information||Legitimate business interests and day-to-day running of Our Site|
|Supplying our products to you||Identity information, contact information, business information, profile information and technical information||Legitimate business interests and day-to-day running of Our Site|
|Communicating with you||Identity information and contact information||Legitimate business interests and day-to-day running of Our Site|
|Supplying you with information that you have opted-in-to (you may opt-out at any time)||Identity information and contact information||Legitimate business interests and day-to-day running of Our Site|
With your permission and/or where permitted by law, we may also use your personal data for marketing purposes, which may include contacting you by email with information, announcements, news and event invitations, etc. You will not be sent any unlawful marketing or spam. We will always work to fully protect your rights and comply with our obligations under the data protection legislation and the Privacy and Electronic Communications (EC Directive) Regulations 2003, and you will always have the opportunity to opt-out. We will always obtain your express opt-in consent before sharing your personal data with third parties for marketing purposes and you will be able to opt-out at any time.
Third parties whose content appears on Our Site may use third-party cookies, as detailed below in part 14. Please refer to parts 14 to 16 for more information on controlling cookies. Please note that we do not control the activities of such third parties, nor the data that they collect and use themselves, and we advise you to check the privacy policies of any such third parties.
We will only use your personal data for the purpose(s) for which it was originally collected unless we reasonably believe that another purpose is compatible with that or those original purpose(s) and need to use your personal data for that purpose. If we do use your personal data in this way and you wish us to explain how the new purpose is compatible with the original, please contact us using the details in part 17.
If we need to use your personal data for a purpose that is unrelated to, or incompatible with, the purpose(s) for which it was originally collected, we will inform you and explain the legal basis, which allows us to do so. In some circumstances, where permitted or required by law, we may process your personal data without your knowledge or consent. This will only be done within the bounds of the data protection legislation and your legal rights.
We will not keep your personal data for any longer than is necessary in light of the reason(s) for which it was first collected. Your personal data will therefore be kept for the following periods (or, where there is no fixed period, the following factors will be used to determine how long it is kept):
|Type of data||How long we keep it|
|Identity information, i.e. your name and title||Until you ask us to remove your registration or until we no longer offer the information for which you have registered|
|Contact information, i.e. your email address||Until you ask us to remove your registration or until we no longer offer the information for which you have registered|
|Business information, i.e. your company and job title||Until you ask us to remove your registration or until we no longer offer the information for which you have registered|
|Technical information, including your IP address, browser type, browser versions and operating system||Until you ask us to remove your registration, or if you have not visited our site for a period of 48 months|
We will store or transfer your personal data within the European Economic Area (EEA). This means that your personal data will be fully protected under the data protection legislation, GDPR and/or to equivalent standards by law.
We may store or transfer some or all of your personal data in countries that are not part of the European Economic Area (the EEA consists of all EU member states, plus Norway, Iceland and Liechtenstein). These are known as ‘third countries’ and may not have data protection laws that are as strong as those in the UK and/or the EEA. This means that we will take additional steps to ensure that your personal data is treated just as safely and securely as it would be within the UK and under the data protection legislation as follows:
We share your data within the group of companies of which we are a part. Where this involves the transfer of personal data outside the EEA, our group ensures that personal data is protected by requiring all companies within the group to follow the same rules with respect to personal data usage. These are known as ‘binding corporate rules’. More information on binding corporate rules is available from the European Commission.
We share your data with external third parties, as detailed below in part 10, that are based outside of the EEA. The following safeguards are applied to such transfers:
We will only transfer your personal data to third countries whose levels of data protection are deemed ‘adequate’ by the European Commission. More information is available from the European Commission.
We use specific contracts with external third parties that are approved by the European Commission for the transfer of personal data to third countries. These contracts require the same levels of personal data protection that would apply under the data protection legislation. More information is available from the European Commission.
Where we transfer your data to a third party based in the US, the data may be protected if they are part of the EU-US Privacy Shield. This requires that third party to provide data protection to standards similar to those in Europe. More information is available from the European Commission.
Please contact us using the details below in part 17 for further information about the particular data protection mechanisms used by us when transferring your personal data to a third country.
The security of your personal data is essential to us and to protect your data, we take a number of important measures, including the following:
limiting access to your personal data to those employees, agents, contractors and other third parties with a legitimate need to know and ensuring that they are subject to duties of confidentiality;
procedures for dealing with data breaches (the accidental or unlawful destruction, loss, alteration, unauthorised disclosure of, or access to, your personal data) including notifying you and/or the United Kingdom’s Information Commissioner’s Office where we are legally required to do so.
We will not share any of your personal data with any third parties for any purposes, subject to the following exceptions.
In some limited circumstances, we may be legally required to share certain personal data, which might include yours, if we are involved in legal proceedings or complying with legal obligations, a court order, or the instructions of a government authority.
In addition to your rights under the data protection legislation, set out in part 5, when you submit personal data via Our Site, you may be given options to restrict our use of your personal data. In particular, we aim to give you strong controls on our use of your data for direct marketing purposes (including the ability to opt-out of receiving emails from us, which you may do by unsubscribing using the links provided in our emails at the point of providing your details).
You may also wish to sign up to one or more of the preference services operating in the UK: The Telephone Preference Service (TPS), the Corporate Telephone Preference Service (CTPS) and the Mailing Preference Service (MPS). These may help to prevent you receiving unsolicited marketing. Please note, however, that these services will not prevent you from receiving marketing communications that you have consented to receiving.
You may access Our Site without providing any personal data at all.
If you want to know what personal data we have about you, you can ask us for details of that personal data and for a copy of it (where any such personal data is held). This is known as a ‘subject access request’.
All subject access requests should be made in writing and sent to the email or postal addresses shown in part 17.
There is not normally any charge for a subject access request. If your request is ‘manifestly unfounded or excessive’ (for example, if you make repetitive requests) a fee may be charged to cover our administrative costs in responding.
We will respond to your subject access request within one month of receiving it. Normally, we aim to provide a complete response, including a copy of your personal data within that time. In some cases, however, particularly if your request is more complex, more time may be required up to a maximum of three months from the date we receive your request. You will be kept fully informed of our progress.
By using Our Site, you may also receive certain third-party cookies on your computer or device. Third-party cookies are those placed by websites, services and/or parties other than us. Third-party cookies are used on Our Site for monitoring use of our website and activities conducted on it. For more details, please refer to section 4 below.
All cookies used by and on Our Site are used in accordance with current cookie law. We may use some or all of the following types of cookie:
Strictly necessary cookies:
A cookie falls into this category if it is essential to the operation of Our Site, supporting functions such as logging in, your shopping basket and payment transactions.
It is important for us to understand how you use Our Site, for example, how efficiently you are able to navigate around it and what features you use. Analytics cookies enable us to gather this information, helping us to improve Our Site and your experience of it.
Functionality cookies enable us to provide additional functions to you on Our Site such as personalisation and remembering your saved preferences. Some functionality cookies may also be strictly necessary cookies, but not all necessarily fall into that category.
It is important for us to know when and how often you visit Our Site and which parts of it you have used (including which pages you have visited and which links you have visited). As with analytics cookies, this information helps us to better understand you and, in turn, to make Our Site and advertising more relevant to your interests. Some information gathered by targeting cookies may also be shared with third parties.
Third-party cookies are not placed by us; instead, they are placed by third parties that provide services to us and/or to you. Third-party cookies may be used by advertising services to serve up tailored advertising to you on Our Site, or by third parties providing analytics services to us (these cookies will work in the same way as analytics cookies described above).
Any of the above types of cookie may be a persistent cookie. Persistent cookies are those that remain on your computer or device for a predetermined period and are activated each time you visit Our Site.
Any of the above types of cookie may be a session cookie. Session cookies are temporary and only remain on your computer or device from the point at which you visit Our Site until you close your browser. Session cookies are deleted when you close your browser.
Cookies on Our Site are not permanent and will expire.
For more specific details of the cookies that we use, please refer to the table below.
The following first-party cookies may be placed on your computer or device:
|Name of cookie||Purpose and type||Strictly necessary|
|Manual form download||For functioning of manual downloads||Yes|
|Software form download||For functioning of software downloads||Yes|
|MSDS form download||For functioning of MSDS downloads||Yes|
|WordPress cookies||For functioning of user sessions||Yes|
Our Site uses analytics services provided by third-party analytics providers. Website analytics refers to a set of tools used to collect and analyse anonymous usage information, enabling us to better understand how Our Site is used. This, in turn, enables us to improve Our Site. You do not have to allow us to use these cookies, however whilst our use of them does not pose any risk to your privacy or your safe use of Our Site, it does enable us to continually improve Our Site, making it a better and more useful experience for you.
The analytics service(s) used by Our Site use(s) analytics cookies to gather the required information.
The analytics service(s) used by Our Site use(s) the following analytics cookies:
|Name of cookie||Purpose and type||Provider||Strictly necessary|
|_ga||Used to distinguish users||Google Analytics||Yes|
|_gid||Used to distinguish users||Google Analytics||Yes|
|_gat||Used to throttle request rate. If Google Analytics is deployed via Google Tag Manager, this cookie will be named _dc_gtm_||Google Analytics||Yes|
Before cookies are placed on your computer or device, you will be shown a prompt requesting your consent to set those cookies. By giving your consent to the placing of cookies you are enabling us to provide the best possible experience and service to you. You may, if you wish, deny consent to the placing of cookies unless those cookies are strictly necessary; however certain features of Our Site may not function fully or as intended. You can return to your cookie preferences to review and/or change them at any time.
In addition to the controls that we provide, you can choose to enable or disable cookies in your internet browser. Most internet browsers also enable you to choose whether you wish to disable all cookies or only third-party cookies. By default, most internet browsers accept cookies, but this can be changed. For further details, please consult the help menu in your internet browser or the documentation that came with your device.
The links below provide instructions on how to control cookies in all mainstream browsers:
Google Chrome: https://support.google.com/chrome/answer/95647?hl=en-GB
Microsoft Internet Explorer: https://support.microsoft.com/en-us/kb/278835
Microsoft Edge: https://support.microsoft.com/en-us/microsoft-edge/delete-cookies-in-microsoft-edge-63947406-40ac-c3b8-57b9-2a946a29ae09
Safari (macOS): https://support.apple.com/en-gb/guide/safari/sfri11471/mac
Safari (iOS): https://support.apple.com/en-gb/HT201265
Mozilla Firefox: https://support.mozilla.org/en-US/kb/enable-and-disable-Cookies-website-preferences
Android: https://support.google.com/chrome/answer/95647?co=GENIE.Platform%3DAndroid&hl=en (Please refer to your device’s documentation for manufacturers’ own browsers.)
To contact us about anything to do with your personal data and data protection, including to make a subject access request, please use the following details:
Email address: email@example.com
Telephone number: (44) 1224 897229
Postal address: Sinomine Specialty Fluids, Ocean House, Hareness Circle, Altens Industrial Estate, Aberdeen, AB12 3LY, Scotland.
We may change this privacy notice from time to time. This may be necessary, for example, if the law changes, or if we change our business in a way that affects personal data protection.