Ultima Business Solutions Limited (“we”, “us”, “our” in this privacy policy) respects your privacy and is committed to protecting your personal data.  This privacy policy will inform you as to how we look after your personal data when you visit our website (regardless of where you visit it from) and tell you about your privacy rights and how the law protects you.

Purpose of this privacy policy

This privacy policy aims to give you information on how we collect and process your personal data through your use of this website https://www.ultima.com/, including any data you may provide through this website when you sign up to our newsletter, use our online services or portals.

This website is not intended for children and we do not knowingly collect data relating to children.

It is important that you read this privacy policy together with any other privacy policy or fair processing policy we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data.  This privacy policy supplements other notices and privacy policies and is not intended to override them.

Controller

We are the controller and are responsible for your personal data

We are made up of different legal entities.  This privacy policy is issued on behalf of our group so when we mention “we”, “us” or “our” in this privacy policy, we are referring to the relevant company in our Group responsible for processing your data. we are the controller and responsible for this website.

We have a Data Protection Team who are responsible for overseeing questions in relation to this privacy policy. If you have any questions about this privacy policy, including any requests to exercise your legal rights, please contact the Data Protection Team using the details set out below.

Full name of legal entity: Ultima Business Solutions Limited

Email address: dataprotection@Ultima.com

Postal address: Ultima Business Solutions Limited, Gainsborough House, Manor Park, Basingstoke Road, Reading, Berkshire, RG2 0NA

You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK regulator for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.

Changes to the privacy policy and your duty to inform us of changes

We keep our privacy policy under regular review and may amend this from time to time, so please be sure to check back periodically.

It is important that the personal data we hold about you is accurate and current.  Please keep us informed if your personal data changes during your relationship with us.

Third-party links

This website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you.  We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy policy of every website you visit.

The data we collect about you

Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).

We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:

• Identity Data includes first name, maiden name, last name, username, job title, occupation. employer, or similar identifier.
• Contact Data includes email address and telephone numbers, generally business mobile numbers or other business telephone numbers provided.
• Technical Data includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, and other technology on the devices you use to access this website.
• Profile Data includes your username and password, preferences, feedback and survey responses (particularly if you access one of our portal sites).
• Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.

We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data could be derived from your personal data but is not considered personal data in law as this data will not directly or indirectly reveal your identity.  For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature.  However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy policy.

We do not collect any Special Categories of Personal Data about you (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).  Nor do we collect any information about criminal convictions and offences.

If you fail to provide personal data

Where we need to collect personal data by law, or under the terms of a contract we have with you, and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with our services).  In this case, we may have to cancel a service you have with us but we will notify you if this is the case at the time.

How is your personal data collected?

We use different methods to collect data from and about you including through:

• Direct interactions. You may give us your Identity, Contact and Profile Data by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you
• apply for our products or services;
• create an account on our website or portals;
• subscribe to our service or publications;
• request marketing to be sent to you;
• enter a competition, promotion or survey; or
• give us feedback or contact us.
• Automated technologies or interactions. As you interact with our website or portals, we will automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies and other similar technologies. Please see our cookie policy for further details.
• Third parties or publicly available sources. We will receive personal data about you from various third parties as set out below
• Technical Data from the following parties:
  • analytics providers such as Google, LinkedIn and Cyfe, based outside the UK;
  • advertising networks such as Google Search and Display network as well as LinkedIn, based outside the UK; and
  • search information providers such as Google and Bing, based outside the UK.
• Identity and Contact Data from data brokers or aggregators such as Cognism based inside the UK. We occasionally purchase lists of IT contacts from an approved data supplier.  The data supplier only passes on the details of recipients who have consented to their details being passed on to technology service businesses, such as us.
• Identity and Contact Data from publicly available sources such as Companies House.

Where we store your personal data

We may process and store personal data, that you provide to us, on our internal and external third party hosted systems.  Personal data that you provide to us shall be stored on systems in accordance with our internal Information Security Management System and applicable law.

How we use your personal data

We will only use your personal data when the law allows us to.  Most commonly, we will use your personal data in the following circumstances:

• Where we need to perform the contract we are about to enter into or have entered into with you;
• Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests;
• Where we need to comply with a legal obligation;
• Where we need to manage our relationship with you, as our customer;
• Where we need to provide general customer services;
• To provide information about the services we offer, including invitations to events we hold periodically;
• To ensure that content from our site is presented in the most effective manner for you and for your computer;
• To provide you with information, products or services that you request from us or which we feel may interest you, where you have consented to be contacted for such purposes or where we have a legitimate interest for contacting you;
• To allow us to tailor our website to the needs of our clients;
• For marketing purposes;
• To allow you to participate in interactive features of our service, when you choose to do so; and
• To notify you about changes to our service.

Marketing

We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising.

If you are not our customer your details will be included on our database for one of the following reasons:

• You have enquired about a specific product via a manufacturer and they have passed your details to us in order that your enquiry may be followed up.
• Event registration/attendance.  You have provided your details when registering for one of our seminars, or you have provided your details when visiting us at a conference/exhibition.

If you do not wish to continue to receive emails from us please let us know by emailing marketingteam@ultima.com or visit our communication preferences page.  We do not knowingly get involved in “spamming” activities of any kind and we work only with business partners who we believe have similar anti-spamming policies.

You can update your email communication preferences at any time.  Please visit our Update Email Preferences page.

Third-party marketing

We will get your express opt-in consent before we share your personal data with any third party for marketing purposes.  Opting out You can ask us or third parties to stop sending you marketing messages at any time by logging into the website and checking or unchecking relevant boxes to adjust your marketing preferences.  Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of a product/service purchase, warranty registration, product/service experience or other transactions.

Cookies

Cookies are files with a small amount of data, which may include an anonymous unique identifier. Cookies are sent to your browser from a web site and stored on your computer’s hard drive.  You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies.  If you disable or refuse cookies, please note that some parts of this website may become inaccessible or not function properly.  For more information about the cookies we use, please see our Cookie Policy.

Change of purpose

We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose.  If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.

If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.

Please note that we may process your personal data without your knowledge or consent, where this is required or permitted by law.

Disclosures of your personal data

We may share your personal data with the parties set out below for the purposes set out above.

• Internal Third Parties
• Third parties to whom we may 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.
• if we are under a duty to disclose or share your personal data in order to comply with any legal obligation, or in order to enforce or apply our website terms of use and other agreements; or
• to protect the rights, property, or safety of us, our clients, or others. This includes exchanging information with other companies and organisations for the purposes of fraud protection and credit risk reduction.

In addition, in order to provide products / services to our customers, it is sometimes necessary for us to work with a third party or parties (the Partner) that may operate within the UK or on a global basis and provide them with Identity and Contact Data.  Under the terms of the data protection laws of both you, the Customer, and your agents together with those of our employees and agents, such information will be restricted to the minimum amount necessary to provide the products and/or services.

Any information or access to such information will be provided as part of the goods and services being procured.

The third party or parties may use the Identity and Contact Data for the delivery/promotion/marketing of the products / services supplied.  They may hold the information in their databases located outside the UK and the Identity and Contact Data may be used, processed and/or transferred to the United States or other countries located outside of the UK.

By providing us with Identity and Contact Data, you, shall indemnify us against any claims, actions, liabilities, losses, fines, penalties, costs and expenses arising out of the provision of such Identity and Contact Data and any other personal data you provide for the purposes.

If we are acting as a Data Processor to your organisation as part of a services agreement, matters in relation to Data Protection shall be set out in the Data Processing Agreement.

If the information that you provide to us is for purposes of our business partners providing a service to you (where we act as an intermediary and do not provide the services directly), then you consent to us providing the relevant business partner with that information.  The use of that information may be set out in the relevant business partner’s Privacy Statement, as described in the General Terms & Conditions, or relevant Product Terms. 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.

International Transfers

Whenever we transfer your personal data out of the UK, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:

• We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data.
• Where we use certain service providers, we may use specific contracts approved for use in the UK which give personal data the same protection it has in the UK.

Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the UK.

Data security

We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know.  They will only process your personal data on our instructions and they are subject to a duty of confidentiality.  We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

How long will you use my personal data for?

We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements.  We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.

To determine the appropriate retention period for personal data, we consider the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements.

Your legal rights

You have the right to ask us not to process your personal data for marketing purposes.  We will usually inform you (before collecting your data) if we intend to disclose your information to any third party for such purposes. You can exercise your right to prevent such processing by checking certain boxes on the forms we use to collect your data.  You can also exercise the right at any time by contacting us at marketingteam@ultima.com.

You also have the following rights in relation to your personal data, the right:

• to access – You have the right to ask us for copies of your personal information.
• to rectification – You have the right to ask us to rectify personal information you think is inaccurate. You also have the right to ask us to complete information you think is incomplete.
• to erasure – You have the right to ask us to erase your personal information in certain circumstances.
• to restriction of processing – You have the right to ask us to restrict the processing of your personal information in certain circumstances.
• to object to processing – You have the right to object to the processing of your personal information in certain circumstances.
• to data portability – You have the right to ask that we transfer the personal information you gave us to another organisation, or to you, in certain circumstances.

Under certain circumstances, you have rights under data protection laws in relation to your personal data.  Please see ICO contact information to request information on these rights.

No fee usually required

You will not have to pay a fee to access your personal data (or to exercise any of the other rights).  However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we could refuse to comply with your request in these circumstances.

What we may need from you

We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights).  This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it.  We may also contact you to ask you for further information in relation to your request to speed up our response.

Time limit to respond

We try to respond to all legitimate requests within one month. Occasionally it could take us longer than a month if your request is particularly complex or you have made a number of requests.  In this case, we will notify you and keep you updated.

Last updated: September 2022.