Evergen Systems Ltd and its division Evergen Air values the privacy of those who provide Personal Data to it and recognises the importance of protecting Confidential Information. This privacy and confidentiality policy (the “Policy”) describes how and why we collect, store and use Personal Data and Confidential Information, and provides information about individuals’ rights.
This Policy applies to both Personal Data supplied to Evergen Air either by an individual or by others and to Confidential Information supplied by clients or prospective clients. We may use Personal Data and Confidential Information supplied to us for any of the purposes as set out in this Policy, or as otherwise disclosed at the point of collection.
This Policy is an important document. We recommend that you read it carefully and retain a copy for your future reference.
In this Policy, we use the terms:
“Confidential Information” refers to information supplied to an Evergen Air by a customer or prospective customer, which is identified as being confidential at the time of disclosure or would be regarded as confidential by a reasonable person or is protected by a regulatory obligation of confidentiality.
“Personal Data” has the meaning set out in EU Regulation 2016/679 (the “GDPR”). This includes any information about an individual from which that person can be identified.
“we”, “us”, and “our” (and other similar terms) refer to – as the relevant context dictates – When dealing with Personal Data, Evergen Systems will be the data controller as prescribed (the “Data Controller”);
“you” and “your” (and other similar terms) refer to – as the relevant context dictates – our clients, individuals associated with our clients, contacts, suppliers, job applicants, staff and visitors to the Evergen Air website, www.evergenair.com
Your rights in relation to Personal Data and how to exercise them
Under certain circumstances you have the following rights:
- the right to ask us to provide you, or a third party, with copies of the Personal Data we hold about you at any time and to be informed of the contents and origin, verify its accuracy, or else request that such information be supplemented, updated or rectified according to the provisions of local law;
- the right to request erasure, anonymisation or blocking of your Personal Data that is processed in breach of the law;
- the right to object on legitimate grounds to the processing of your Personal Data. In certain circumstances we may not be able to stop using your Personal Data. If that is the case, we’ll let you know and explain why; and
- withdrawal of consent – when Personal Data are processed on the basis of consent an individual may withdraw consent at any time (this may apply to processing of special categories of Personal Data where you have instructed us to act on your behalf and includes the following: racial/ethnic origin, political opinions, religious or philosophical beliefs and trade union membership). In the event that you no longer want to receive any marketing material from us, please use the unsubscribe option (which is in all of our marketing emails to you),or contact the Data Controller as set out below.
To exercise such rights and if you have any questions about how we collect, store and use Personal Data, then please contact us using the details as set out in the “Data Controller contact information” section below.
What basis do we have for processing your Personal Information?
We will only process Personal Data where we have a lawful reason for doing so. The lawful basis for processing Personal Data by us will be one of the following:
- the processing is necessary for the performance of a contract you are party to or in order to take steps at your request prior to you entering into a contract;
- the processing is necessary in order for us to comply with our legal or regulatory obligations (such as compliance with anti-money laundering legislation and for conflict checking purposes);
- the processing is necessary for the pursuit of our legitimate business interests (including that of the delivery and the promotion of our services);
- the data subject has given consent to the processing of his or her Personal Data for one or more specific purposes.
What Personal Data do we collect and process?
We aim to be transparent about why and how we collect and process Personal Data. For further information on our processing activities please review the relevant section below:
Evergen Systems of which Evergen Air is a division process Personal Data about contacts using client relationship management tools (we currently use “Salesforce” ‘Mailchimp’ amongst others). Personal Data that is collected, added to and processed includes: name, email address, job title, telephone number, area of business, job role, jurisdiction, language, seniority, other business contact information, and information relating to the strength of your business relationship with our people. The Personal Data may also be collected via staff, via your communications with us, or by virtue of us providing our services to you or at a networking event. In addition Personal Data may also be collected via the Evergen Air www.evergenair.com We may cross-reference our marketing records against publicly available information, including LinkedIn and professional profiles published on your organisation’s website, to ensure that the records we hold remain accurate and up to date.
- For contact and communication purposes: we may use your contact information to send you updated information that we may circulate from time to time, news about any events we are organising or participating in, and/or other information about us and the services provided by Evergen Systems that we believe may be of interest to you. You can specify your contact preferences when registering online to receive communications from us (for example, through the Evergen Air website, www.evergenair.com)
- or by subsequently advising us of your contact preferences using options provided on all of our marketing emails or the contact details as set out in the “Data Controller contact information” section below.
- Making contact details available to Evergen staff, including information relating to the strength of our professional relationships between us and you or your organisation. This information will be established using automated means (this is a form of profiling).
- Performing analytics – such as trends, sales intelligence, marketing effectiveness (such as click and open rates) uptake and progress.
- Utilising artificial intelligence to research news feeds, sites, posts etc and performing analytics to assist us in contacting you with relevant information.
Personal Data is retained on Salesforce for as long as it is necessary for the purposes set out above (being the length of the business relationship). If a business contact requests to be forgotten their contact details will be deleted from Salesforce. If a business contact opts out of receiving marketing materials or otherwise objects to any processing carried out for marketing purposes their details will be deleted and marketing materials will no longer be sent, the processing that is subject to the objection will cease.
Customers and end-users
We request that our customers only provide Personal Data which is necessary for us to carry out our services.
If we need Personal Data in respect of individuals associated with customers in order to provide air cleaning services we ask our clients to provide this Policy to the data subjects.
In the majority of circumstances we will collect Personal Data from our clients or from third parties acting on behalf of our clients.
- Managing client relationships: providing clients with information on our services and updates that we consider may be relevant to them; arranging and hosting events; and identifying where we may make improvements in service delivery..
Please refer to information made available when applying online for further details as to how Personal Data is collected, processed and how long it is retained for.
Personal Data, including name, email address, telephone number and other business contact information, may be collected from PR agencies or from databases that we subscribe to.
- Press releases and joint press releases from our clients/organisations that we are working with.
- Invitations to meet Evergen company staff.
- Press party.
- To highlight any spokespeople who may be of interest on a specific industry theme or topic relevant to the journalist.
- Business trips may require the use of the Personal Data to assist us with travel arrangements.
- Internal communications.
Personal Data will be retained for as long as it is necessary for the purposes of the above, or if you advise us you no longer wish to be contacted your Personal Data will be removed from our contact lists.
Suppliers (including individual contractors)
Personal Data, including name, email address, telephone number and other business contact information, is collected to receive services from suppliers, to manage the relationship with the supplier, and for the provision of services to our clients.
- To receive services from our suppliers: please note that we will use and disclose their Personal Data in such manner as we believe is reasonably necessary to receive and to review the provision of those services from suppliers.
- Services to clients: if a supplier is assisting us in delivering services to our clients we will process Personal Data to manage that relationship.
- Administration: to agree payment arrangements with our suppliers, and to make payments to them.
A general retention period of 13 years will be applied unless there are any legal and or regulatory exceptions which may require documentation to be held for shorter or longer periods. If you require further information please contact us using the details as set out in the “Data Controller contact information” section below.
Personal Data in relation to staff will be held on various internal systems and applications. A privacy notice which sets out the purposes for which Personal Data will be processed and contains information on data subject rights is provided to staff at the commencement of employment. If further information is required please contact Human Resources / Mr Ricky Singh
Visitors to the Evergen Air website
We do not routinely monitor IP addresses for visitors to our website.Personal Data will be collected if you sign up to attend any of our events and/or to receive our marketing literature.
- Business contacts: if you have signed up to attend one of our events or to receive our marketing literature please see the paragraph above headed ‘Business contacts’.
Who else may have access to your Personal Data?
On occasion, we may need to share your Personal Data with third parties. We will only share Personal Data where we are legally permitted to do so.
Where you supply us with Personal Data as a client, we will assume, unless you instruct us otherwise in writing, that we can disclose your Personal Data in such manner as we believe is reasonably necessary to provide our services (including as described in this Policy), or as is required under applicable law. This might be because, for example, we may pass your Personal Data to third parties such as:
- Companies associated in the air review of your premises
- Installation or maintenance of equipment at your premises
- events: we may need to pass on your Personal Data (e.g. name, company, occupation) to a third party in connection with management of an event, in which case the details will only be used by the third party for that specific purpose;
- business partners, service providers and other affiliated third parties: to enable us to provide our services to you, our business partners. Our arrangements with external service providers currently cover the provision of support services including IT (including but not limited to our cloud technology providers), events management, document production, business and legal research, secretarial services, marketing and business development and facilities management
How we look after your Personal Data and Confidential Information
We have in place appropriate technical and organisational security measures to protect your Personal Data against unauthorised or unlawful use, and against accidental loss, damage or destruction.
Links to other websites
The Evergen Air website, www.evergenair.com may link to other, unaffiliated third-party websites. Please note that Evergen Systems and its division Evergen Air is not, and cannot, control or be responsible for the content or privacy and confidentiality practices of any third-party websites.
This Policy was last updated in September2021. Please check back regularly to keep informed of updates to this Policy.
While we hope that you will not need to, if you want to complain about our use of Personal Data please send an email detailing your complaint to the Evergen Data Office, Mr Ricky Singh at email@example.com if you prefer to write to us, please do so at Evergen Air, Unit 3, Business Park, 48 Bell St, Maidenhead SL6 IBR