Tech Connect Privacy Policy
This page contains all requirements communicated by Legal that must be accounted for in the product.
INTRODUCTION
Coats is committed to protecting your privacy and providing you with a positive experience while using our products and services. This Privacy Notice (the “Notice”) applies to the Coats Tech Connect Application (the “App”) and describes:
- the types of personal data we may collect or that you may provide when you download, install, register with, access or use the App; and
- our practices for collecting, using, maintaining, protecting and disclosing that personal data.
This Notice only applies to the personal data we collect in this App and other electronic communications sent through, or in connection with, the App.
Please read this Notice carefully to understand our policies and practices regarding your personal data and how we will treat it. If you do not agree with our policies and practices, do not download, register with, or use this App. By downloading, registering with, or using this App, you agree to this Notice. This Notice may change from time to time (see the section titled: Changes to our Privacy Notice). Your continued use of the App after we revise this Notice means you accept those changes, so please check the Notice periodically for updates .
THE DATA WE COLLECT ABOUT YOU
We may collect, use, store, or otherwise process and transfer different kinds of personal data about you as follows:
- Communication Data: voice and audio recording information when you use audio features, including automatic transcripts prepared of the same;
- Contact Data: email address and telephone number(s);
- Content Data: includes information stored on your device, including login information;
- Device Data: includes the type of mobile device you use, a unique device identifier (for example, your Device’s IMEI number, the MAC address of the Device’s wireless network interface, or the mobile phone number used by the Device), type of mobile browser you use, time zone setting;
- Identity Data: first name, last name, username or similar identifier, title, date of birth and gender;
- Location Data: includes your current location disclosed by GPS technology;
- Profile Data: includes your username and password, in-App history, your disclosed interests, preferences, feedback and survey responses; and
- Usage Data: includes details of your use of the App including, but not limited to, traffic data and other communication data and the resources that you access.
We may also collect, use and share aggregated data such as statistical 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 App 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 notice.
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.
HOW IS YOUR PERSONAL DATA COLLECTED?
We will collect and process the following data about you:
- Information you give us. This is information (including Identity, Contact and Communications Data) you consent to giving us about you by filling in forms on the App, or by corresponding with us (for example, by email, telephone or instant message). It includes information you provide when you download or register to use the App, subscribe to any of our services, share data via the App and when you report a problem with the App or our services. If you contact us, we will keep a record of that correspondence.
- Information we collect about you and your device. Each time you use the App we will automatically collect personal data including Device, Content and usage Data. we collect this data using cookies and other similar technologies. Please see our cookie policy here for further details.
HOW WE USE YOUR PERSONAL DATA
We will only use your personal data when the law allows us to do so. Most commonly we will use your personal data in the following circumstances:
- Where you have consented before the processing.
- Where we need to perform a contract we are about to enter or have entered 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 or regulatory obligation.
We have provided more information on the types of lawful basis that we will rely on to process your personal data below.
PURPOSES FOR WHICH WE WILL USE YOUR PERSONAL DATA
| Purpose/activity | Type of data | Lawful basis for processing |
|---|---|---|
| To install the App and register you as a new user | Identity Contact Device |
Your consent |
| To manage our relationship with you including notifying you of changes to the App or any of our products/ services | Identity Contact Profile |
Your consent Performance of a contract with you Necessary for our legitimate interests (to keep records updated and to analyse how customers use our products/ Services) Necessary to comply with legal obligations (to inform you of any changes to our terms and conditions) |
| To administer and protect our business and the App including troubleshooting, data analysis and system testing | Identity Contact Device |
Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security) |
| To monitor trends so that we can improve the App and the products/ services we offer | Communication Contact Content Device Identity Location Profile usage |
Consent Necessary for our legitimate interests (to develop our products/services/ the App and grow our business) |
| To use data analytics to improve the App, our products/ services, customer relationships and experiences | Communication Contact Content Device Identity Location Profile usage |
Consent Necessary for our legitimate interests (to develop our products/services/ the App and grow our business) |
LAWFUL BASIS
We will only use your personal data when the law allows us to. Most commonly, we will use your personal data where we have/ it is necessary:
- Consent which means processing your personal data where you have signified your agreement by a statement or clear opt-in to processing for a specific purpose. Consent will only be valid if it is a freely given, specific, informed and unambiguous indication of what you want. You can withdraw your consent at any time by contacting us.
- A legitimate Interest which means the interest of our business in conducting and managing our business to enable us to give you the best service/product and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us.
- In the performance of contract which means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.
- To comply with a legal obligation which means processing your personal data where it is necessary for compliance with a legal obligation that we are subject to.
INTERNATIONAL TRANSFER
We may transfer your personal data to another company within our group of companies outside of the jurisdiction you reside. We ensure your personal data is protected by requiring all our group companies to follow the same rules when processing your personal data.
TRANSFER OF DATA OUT OF THE EEA
Some of our external third parties are based outside the EEA so their processing of your personal data will involve a transfer of data outside the EEA.
Whenever we transfer personal data out of the EEA, 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 personal data to countries that have been deemed to provide an adequate level of protection for personal data by the European Commission.
- Where we use certain service providers, we may use specific contracts approved by the European Commission which give personal data the same protection it has in Europe.
Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the EEA.
DATA SECURITY
All information you provide to us is stored on secure servers. Where we have given you (or where you have chosen) a password that enables you to access the App or our services, you are responsible for keeping the password confidential. We ask you not to share a password with anyone.
Once we have received your information, we will use reasonable security measures and security features to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, including:
- We review our information collection, storage and processing practices, including physical security measures, to prevent unauthorised access to our systems.
- We restrict access to personal information to employees, contractors and agents who need that information in order to process it. Anyone with this access is subject to strict contractual confidentiality obligations and may be disciplined or terminated if they fail to meet these obligations.
We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator when we are legally required to do so.
YOUR LEGAL RIGHTS
Depending on your location and under certain circumstances you have the following rights under data protection laws in relation to your personal data. You have the right to:
- Request access to your personal data. This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
- Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
- Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
- Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
- Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios:
a) if you want us to establish the data's accuracy;
b) where our use of the data is unlawful but you do not want us to erase it;
c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or
d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
- Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
- Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. we will advise you if this is the case at the time you withdraw your consent.
CHANGES TO OUR PRIVACY NOTICE
We may update this Notice from time to time. If we make material changes to how we treat your information, we will post the new privacy Notice on this page [and notify you by an in-App alert the first time you use the App after we make the change.
CONTACT INFORMATION
To ask questions or comment on the contents of this Notice and our privacy practices, contact us at:
- Full name of legal entity: J. & P. Coats, Limited
- Postal address: 4 Longwalk Road, Stockley Park, Uxbridge, England, UB11 1FE
- Email: privacy@coats.com
You have the right to make a complaint at any time to the Information Commissioner's Office (ICO), the UK supervisory authority for data protection issues, or other competent supervisory authority if the App is downloaded outside the United Kingdom.