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Privacy Notice
Version 1 02/2023
This Privacy Notice (“Policy”) is directed to any and all business partners, customers, suppliers and the like. Please read this privacy notice carefully as it sets out how we collect and process your personal information.
1.Purpose and Scope
It is one of the fundamental principles of Kingspan Insulation Limited. and its subsidiaries (together “Kingspan” or “the Company”) to strictly observe all national and international laws and regulations under which Kingspan is operating and to maintain high ethical standards in conducting its business.
It is the strong belief of Kingspan’s management that not only the interest of Kingspan, its employees and various stakeholders, but also the interest of society, is best served by a conduct in adherence with a policy which ensures protection of personal data. Therefore, it is the policy of Kingspan to strictly comply in all respects with the General Data Protection Regulation, including all national Data laws and regulations which strive to protect the individual’s personal data which in any way are controlled, owned or processed by Kingspan.
2.Personal Data Protection
2.1.1 Data Protection Officer - Contact Information
Kingspan is both considered Data Controller and Data Processor, and in that regard responsible for ensuring that personal data is processed in accordance with the applicable laws and regulations. Kingspan has internally appointed a Data Protection Officer (DPO), who is globally responsible for ensuring and supporting locally that rules and procedures regarding processing of personal data are observed in the daily business.
Any questions in relation to the processing of personal data within the Company, can be directed at the Data Protection Officer. Contact information of the Data Protection Officer is available here.
2.2 Processing of personal data
Kingspan is solely processing personal data in a business-to-business setup, and does not in any way process consumer data.
Kingspan process two categories of data subjects, (1) any and all business partners, customers, suppliers and the like for which this Policy is applicable, (2) employees for which an internal policy is applicable.
2.2.1 Types of personal data
As described above this Policy concerns the processing of personal data of data subject category (1).
In this regard Kingspan will process personal data, which include amongst other:
• Name
• Password
• Contact information
• Email address
• Telephone numbers
• Company where employed
• Job title
• Certification of skills
2.2.2 Purpose of processing personal data
Kingspan collect, store, process and delete personal data for legitimate business purposes in general. For example, when we need to:
• Register in CRM or other similar systems
• Register a new Tools user
• Keep record of certification of skills
• Send newsletters
• Have correspondence in relation to projects
• Distribute technical information / updates / email
• In order to identify and comply with our obligations
• In order to determine to sue or defend Kingspan against legal requirements
• Handle claims
2.2.3 The extent of data
Kingspan ensures that only personal data necessary for particular purposes are processed. Therefore, only the amount of data needed for each specific purpose is collected. It is ensured that the amount of processed data is not unnecessarily large, the storage time is not too long and only the relevant and necessary employees has access hereto.
Kingspan will before the processing of personal data, investigate whether it is possible to minimize the amount of personal data. Kingspan also investigate whether some of the data types we use may be used in anonymous or pseudonymized form. This will be done for all processing, unless Kingspan obligations to public authorities or to daily business operations does not allow it.
Kingspan will only collect, process and store the personal data needed to meet the intended purpose. In addition, it may be decided by law what type of data it is necessary to collect and store for our business operations. The type and extent of the personal data Kingspan process may also be required to fulfill a contract or other legal obligation.
2.2.4 Control
Kingspan verify that the personal data we control, own or process are to the best of our knowledge not incorrect or misleading. Kingspan also make sure to update the personal data continuously.
Kingspan’s administration of personal data is dependent on the personal date being correct and up to date, why it is important that business contacts, customers, suppliers or the like notifies when personal data in these relations should be edited, updated or deleted.
3. Rights of the registered
Anyone whose personal data Kingspan process (the “Registered”) have a right of access to the personal data.
Furthermore, the Registered have the right to object to the collection and further processing of personal data. Moreover, the Registered have the right to rectification of personal data, or to require Kingspan to restrict the processing of the personal data.
If requested, Kingspan will delete the personal data which we store and process without undue delay, unless we may continue the processing on another legal basis, e.g. if the processing is necessary to defend a legal claim or to comply with a request from the registered.
Under certain circumstances, the Registered may also request that Kingspan provide an overview of the personal data in a structured, commonly used and machine-readable format and request to transmit such data to another data controller.
If the Registered wishes to exercise the rights as described above, please contact the DPO. Contact details can be found at here.
If the Registered disagree with how Kingspan process personal data or the purposes for which we process personal data, the Registered may either contact us, take legal actions at the ordinary courts or lodge a complaint with the local Data Authorities.
4. Security
To protect the access to personal data by unauthorized persons, Kingspan uses IT solutions that automatically ensure that data is only available to relevant employees. There is also embedded protection against unlimited access to data.
Kingspan have also adopted internal rules on information security in our IT Policy that contain instructions and measures which protect your data against being destroyed, lost or modified, from unauthorized disclosure, and against unauthorized access or knowledge hereof.
5. Transfer
5.1 Transfer to third parties
As part of Kingspan’s business, we may disclose your personal information to third parties located in your country and in countries other than your own, in due compliance with applicable laws.
The disclosure of personal data must be substantively justified and, moreover, necessary for the provision of a legitimate interest of the employee, business partner, customer, supplier or the Company. Processing of personal data incompatible with the purposes which is the basis of the Company's processing must not occur.
Regardless of whether Kingspan transfer personal data to partners’ resident in countries inside or outside the EU or EEA, we must always ensure that our level of privacy protection will comply with the requirements we have set in this policy and under applicable laws and regulations. Amongst other we ask for data processing agreements, information security and documentation of fulfilment of rights.
Kingspan is aware of the requirements for the content of data processing agreements and we always ensure that the necessary agreements are in place to secure personal data rights.
5.2 Transfer intercompany
As part of Kingspan’s business, the disclosure of personal data between the Kingspan affiliates is a necessity for running the daily business.
In order to ensure to highest level of security possible, intercompany data processing agreements are made between all Kingspan affiliates. Each legal entity being both data controller and data processor means that the agreements are mutual in the obligations of both roles, ensuring that the General Data Protection Regulation and all national data laws and regulations are complied with.
6. Retention
Kingspan only retain your personal information for as long as is necessary for us to use your personal information for the purposes described above or to comply with our legal obligations.
7. Storage and deletion records of personal data
7.1. Storage
Kingspan’s records of personal data is stored in a safe, secure and accessible manner. Any documents and financial files that are essential to our business operations during an emergency is duplicated and/or backed up at least once a day and maintained off site.
7.2 Deletion
Kingspan is responsible for the continuing process of identifying the records that have met their required retention period and supervising their deletion. The deletion of personal data, confidential, financial and personnel-related records is conducted by shredding. The deletion of electronic records is coordinated with the IT Department / Manager.
8. Implementation and Compliance
Where a Kingspan company is a participant in any joint venture or commercial sharing arrangement, Kingspan seeks, as far as practicable, to ensure that the combined vehicle complies with our Policies.
In order to ensure that all relevant Employees are trained in the content of this Policy, hereunder measures to ensure compliance with this Policy, Kingspan have implemented various training initiatives, including an e-learning program. Kingspan will continuously strive to optimize its efforts in this regard.
If you become aware of any suspected or actual breaches of our Policy, please inform the Data Protection Officer or Legal Department. All reports are treated confidentially and investigated properly and promptly.
In case of any questions about this Policy, or the applicable legislation you should contact the Data Protection Officer.
The Policy can be provided in hard copy upon request to the Data Protection Officer. Disregard or breach of the Group Policy by an employee may result in disciplinary action.
9. Cookies
When you use the Kingspan website we record information about you through our own or third-party cookies. The information is collected for functional, statistical or marketing purposes.
Information on what a cookie is, how we use them on our website and how you can de-activate certain cookies can be found in our Cookie Policy and Settings on www.kingspan.com.
10. Amendments
Kingspan reserve the right to amend this Policy based on substantial changes in the legislation, new technical solutions, new or improved functions or changes to our website.
