1. GENERAL

NXSF International together with any group companies (“we” “us” “our”) are committed to protecting and respecting your privacy. For the purposes of data protection legislation, we are the data controller and we will process your personal data in accordance with the Data Protection Act 2018, the UK General Data Protection Regulation, the Privacy and Electronic Communications Regulations, and other applicable legislation which relates to the processing of personal data. Please read the following carefully to understand our views and practices regarding your personal data and how we will treat it.

2. VISITORS TO OUR WEBSITE

2.1 We may collect and process personal data about you in the following circumstances:

2.1.1 when you complete forms on our website (“Site”). This includes your name, address, email and telephone number, which is provided at the time of registering to use our Site, where you ask us to contact you about our goods or services, subscribe to our mailing list, or subscribe/request our goods and services.

2.1.2 whenever you provide information to us when reporting a problem with our Site, making a complaint, making an enquiry, or contacting us for any other reason. If you contact us, we may keep a record of that correspondence.

2.1.3 details of your visits to our Site including, but not limited to, traffic data, location data, weblogs and other communication data, whether this is required for our own billing purposes or otherwise, and the resources that you access (see section 2.2.2 on Cookies below); and

2.1.4 whenever you disclose your information to us, or we collect information from you in any other way, through our Site.

2.2 We may also collect data in the following ways:

IP Address

2.2.1 We may collect information about your device, including where available your Internet Protocol address, for reasons of fraud protection. We may also collect information about your device’s operating system and browser type, for system administration and to report aggregate information to our advertisers. This is statistical data about our users' browsing actions and patterns and does not identify any individual.

Cookies

2.2.2 Our Site uses cookies and similar technology to distinguish you from other users of our Site. This helps us to provide you with a good experience when you browse our Site and allows us to improve our Site. For detailed information on the cookies we use and the purposes for which we use them see our Cookie Policy.

2.3 We may use your personal data for our legitimate interests in order to:

2.3.1 provide you with information, or services that you requested from us.

2.3.2 allow you to participate in interactive features of our Site, when you choose to do so.

2.3.3 ensure that content from our Site is presented in the most effective manner for you and for your device.

2.3.4 improve our Site and services.

2.3.5 process and deal with any complaints or enquiries made by you; and

2.3.6 contact you for marketing purposes where you have signed up for these where permitted by applicable law.

Website Links

Our Site may, from time to time, contain links to and from the websites of third parties. Please note that if you follow a link to any of these websites, such websites will apply different terms to the collection and privacy of your personal data and we do not accept any responsibility or liability for these policies. When you leave our Site, we encourage you to read the privacy notice/policy of every website you visit.

3. CUSTOMERS

3.1 We will collect details such as your name, address, phone number and email address when you order goods or services from us either via our Site or linked social media sites / other third-party partner sites. We will use this information to process your order and comply with our contractual obligations.

3.2 In order to perform our contract with you, we may also need to share personal data with third parties such as payment providers and postal service organisations to assist in the delivery of goods or services you have ordered; this could include EDI partners, third party couriers, or warranty providers.

3.3 We may also advertise your feedback on our website and marketing materials (subject to obtaining your prior consent where necessary).

3.4 We will retain your information as long as we require this to provide you with the goods or services ordered from us and for a period of 6 years afterwards. Where you have subscribed to receive marketing correspondence from us we will keep your personal data for the period of time described in section 6 below.

4. SUPPLIERS

We will collect details such as your employee names, telephone numbers and email addresses in order to contact you about goods or services ordered with you, to place further orders and to pay you for the goods and/or services supplied. We will keep the personal data for 6 years further to being provided with the goods/services.

5. 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 the 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 goods or services). In this case, we may have to cancel a product or service you have with us but we will notify you if this is the case at the time.

6. MARKETING

6.1 In addition to the uses described in sections 2-4 above, where you indicate you would like to receive marketing correspondence from us, subscribe to our mailing lists or newsletters, enter into any of our competitions or provide us with your details at networking events, we may use your personal data for our legitimate interests in order to provide you with details about our goods, services, business updates and events, which we think may be of interest.

6.2 You have the right to opt-out of receiving the information detailed in section 6.1 at any time. To opt-out of receiving such information you can:

6.2.1 tick the relevant box situated in the form on which we collect your information;

6.2.2 clicking the unsubscribe button contained in any such communication received; or

6.2.3 email us at info@uk.nxsfi.com providing us with your name and contact details.

6.3 Where you have subscribed to receive marketing correspondence from us we will keep personal data 6 years from when you last interacted with us, subject to our legal obligations.

6.4 From time to time we may market on behalf of other companies, for example by adding banners to our website pages. Clicking on these links will direct you to a third-party site, where you should consult their privacy policy. We will not share your personal data with any third parties without your prior consent.

7. MONITORING AND RECORDING

We may monitor and record communications with you (such as telephone communications and emails) for the purpose of training, fraud prevention and compliance. We also have CCTV cameras installed in our premises for the purpose of crime prevention and for health and safety reasons. Please contact info@uk.nxsfi.com for details on how long we store this information for.

8. AUTOMATED PROCESSING

8.1 We may occasionally consult with third party marketing organisations who use automated processing of anonymised personal data to make recommendations on economic or predictable consumer purchasing behaviours. We do not make decisions which affect an individual based purely on automated processing activities.

8.2 We occasionally carry out a credit checks on customers:

8.2.1 so that we can make credit decisions about you; and

8.2.2 to prevent fraud and money laundering.

8.3 Our search may be recorded on the files of the credit reference agency.

8.4 If further to undertaking a credit check you receive a low credit score, we reserve the right not to supply you with goods or services on credit and/or require upfront payment for the goods or services you wish to purchase. In this case a member of our team will notify you.

8.5 If you provide false or inaccurate information and we suspect fraud, we will record this. if you want to see your credit file, please contact our Customer Services team who will provide you with contact details for the Credit Agency used.

9. LEGAL BASIS FOR PROCESSING YOUR PERSONAL DATA

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

9.1.1 for performance of a contract we enter into with you;

9.1.2 where necessary for compliance with a legal or regulatory obligation we are subject to;

9.1.3 where you have given us consent;

9.1.4 where necessary to protect your vital interests; and

9.1.5 for our legitimate interests (as described within this policy) and your interests and fundamental rights do not override these interests.

9.2 NXSF International explicitly rely on a basis of legitimate interests when processing data in the following ways. This basis is balanced against your rights and interests and does not override your right to object.

9.2.1 NXSF International may supply email addresses to fulfilment partners and couriers in order to improve the service of package delivery.

9.2.2 NXSF International may monitor opening of marketing emails in order to improve the service of supplying marketing communications when you have consented to the use of cookies.

9.3 NXSF International may contact customers with details of goods that the customer prepared for purchase where the purchase did not complete successfully in order to improve the service of purchasing.

10. DISCLOSURE OF PERSONAL DATA TO THIRD PARTIES

10.1 In addition to the third parties mentioned above, we may disclose your information to third parties for our legitimate interests as follows:

10.1.1 to staff members in order to facilitate the provision of goods or services to you.

10.1.2 to our affiliated entities to support internal administration.

10.1.3 IT software providers that host our website and store data on our behalf.

10.1.4 professional advisers including consultants, lawyers, bankers and insurers who provide us with consultancy, banking, legal, insurance and accounting services.

10.1.5 HM Revenue and Customs, regulators and other authorities who require reporting of processing activities in certain circumstances; and

10.1.6 third parties who we may choose to sell, transfer or merge parts of our business or assets. Alternatively, we may seek to acquire other business or merge with them. If a change happens to our business then the new owners my use your personal data in the same way as set out in this privacy policy.

10.2 We may disclose personal data to the police, regulatory bodies, legal advisors or similar third parties where we are under a legal duty to disclose or share personal data in order to comply with any legal obligation, or in order to enforce or apply our website terms and conditions and other agreements; or to protect our rights, property, or safety of our customers, or others. This includes exchanging information with other companies and organisations for the purposes of fraud protection and credit risk reduction.

10.3 We will not sell or distribute personal data to other organisations without your approval.

10.4 In order to be able to offer you Klarna’s payment options, we will pass to Klarna certain aspects of your personal information, such as contact and order details, in order for Klarna to assess whether you qualify for their payment options and to tailor the payment options for you.

General information on Klarna you can find here. Your personal data is handled in accordance with applicable data protection law and in accordance with the information in Klarna’s privacy policy.

11. TRANSFERRING YOUR PERSONAL DATA OUT OF THE UNITED KINGDOM

It is sometimes necessary for us to transfer your personal data to countries outside the UK. In those cases we will comply with applicable laws designed to ensure the privacy of your personal data.

Under data protection laws, we can only transfer your personal data to a country outside the UK where:

• the UK government has decided the particular country ensures an adequate level of protection of personal data (known as an ‘adequacy regulation’) further to Article 45 of the UK GDPR. A list of countries the UK currently has adequacy regulations in relation to is available here.
• there are appropriate safeguards in place, together with enforceable rights and effective legal remedies for you; or
• a specific exception applies under relevant data protection law.

Where we transfer your personal data outside the UK, we do so on the basis of an adequacy regulation or, where this is not available, legally approved standard data protection clauses recognised or issued further to Article 46(2) of the UK GDPR. In the event we cannot or choose not to continue to rely on either of those mechanisms at any time, we will not transfer your personal data outside the UK unless we can do so on the basis of an alternative mechanism or exception provided by UK data protection law and reflected in an update to this policy.

Any changes to the destinations to which we send personal data or in the transfer mechanisms we rely on to transfer personal data internationally will be notified to you in accordance with the section on ‘Changes to this privacy policy’ below.

12. DATA SECURITY

12.1 Where we have given you (or where you have chosen) a password which enables you to access certain parts of our Site, you are responsible for keeping this password confidential. We ask you not to share a password with anyone.

12.2 Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your information transmitted to our Site; any transmission is at your own risk.

12.3 Information you provide to us is shared on our secure servers. We have implemented appropriate physical, technical, and organisational measures designed to secure your information against accidental loss and unauthorised access, use, alteration or disclosure. In addition, we limit access to personal data to those employees, agents, contractors and other third parties that have a legitimate business need for such access.

13. YOUR RIGHTS

13.1 Under data protection law, you have the right:

13.1.1 to be provided with a copy of your personal data.

13.1.2 to ask us to correct any mistakes in your personal data.

13.1.3 to require us to delete your personal data (in certain situations).

13.1.4 to require us to restrict processing of your personal data in certain circumstances.

13.1.5 to receive the personal data you provided to us, in a structured, commonly used and machine-readable format and/or transmit that data to a third party – in certain situations.

13.1.6 to object:

13.1.6.1 at any time to your personal data being processed for direct marketing (including profiling); and

13.1.6.2 in certain other situations to our continued processing of your personal data.

13.1.7 not to be subject to a decision based solely on automated processing that produces legal effect concerning you or similarly significantly affects you.

13.1.8 to withdraw consent at any time if you have provided us with consent to use your personal data.

13.2 We may request specific information from you to help us confirm your identity and your right to access, and to provide you with the personal data that we hold about you or make your requested changes. Data protection legislation may allow or require us to refuse to provide you with access to some or all the personal data that we hold about you or to comply with any requests made in accordance with your rights referred to above. If we cannot provide you with access to your personal data, or process any other request we receive, we will inform you of the reasons why, subject to any legal or regulatory restrictions.

13.3 Please send any requests relating to the above to our Data Protection Officer at info@uk.nxsfi.com specifying your name and the action you would like us to undertake.

14. CHANGES TO OUR PRIVACY POLICY

We reserve the right to update this privacy policy at any time, and any changes we make to our privacy policy will be posted on this page. We will notify you if there are any changes to this policy that materially affect how we collect, store or process your personal data. If we would like to use your previously collected personal data for different purposes than those, we notified you about at the time of collection, we will provide you with notice and, where required by law, seek your consent, before using your personal data for a new or unrelated purpose. We may process your personal without your knowledge or consent where required by applicable law or regulation.

15. CONTACT US

We have appointed a Data Protection Officer to oversee compliance with this privacy policy. If you have any questions, comments or requests regarding this policy or how we use your personal data please contact our Data Protection Officer at  info@uk.nxsfi.com. This is in addition to your right to contact the Information Commissioners Office if you are unsatisfied with our response to any issues you raise at https://ico.org.uk/global/contact-us/

Last updated: 2nd April 2024