The privacy and security of your
how and why we use your personal data, to make sure you stay informed and can
be confident about giving us your information.
We’ll keep this page updated to show you all the things
we do with your personal data. This policy applies if you’re a customer of
First Trace Heating Direct Ltd. or its subsidiary brands or use any of our
services, visit our website, use our mobile app, email, call or write to us. In
certain circumstances we may also provide an extra privacy notice, which will
always refer to this page.
We’ll never sell your personal data and will only share
it with organisations we work with when it’s necessary and the privacy and
security of your data is assured.
By continuing to use the website you accept these terms
We may need to disclose your personal data where we are
under a legal duty to comply with any legal obligation.
Who are ‘we’?
First Trace Heating Direct Ltd. is a company registered
in England under company number 3492441. Our registered office is 9 Winckley
Square, Preston, Lancashire, PR1 3HP. We are committed to ensuring that your
privacy is protected. This policy sets out the basis on which any personal data
we collect from you, or that you provide to us will be processed by us.
Information we collect & how
we’ll use it
When you use any online form on our website, respond to a
survey, or enter a competition or promotion, we need to know your name and
other information such as your postal address, email address, telephone number
(which are your personal data), as well as your purchase history for our
warranty application form.
By submitting this information you consent to our use of
time. We gather this information to allow us to process your request.
We may also use aggregate information and statistics for
the purposes of monitoring website usage in order to help us develop the
website and our service and may provide such aggregate information to third
parties. These statistics will not include information that can be used to
identify any individual.
We may also wish to provide you with information about
special features of our website or any special service or products which we
think may be of interest to you. You can unsubscribe to these materials by contacting
us via email at email@example.com or calling us on 01772 761333.
We’ll only use your personal data on relevant lawful
grounds as permitted by the EU General Data Protection Regulation (from 25 May
2018)/UK Data Protection Act and Privacy of Electronic Communication
Personal data provided to us will be used for the purpose
or purposes outlined in any fair processing notice in a transparent manner at
the time of collection or registration where appropriate, in accordance with
any preferences you express. If asked by the police, or any other regulatory or
government authority investigating suspected illegal activities, we may need to
provide your personal data.
We will retain your data in line with the lifespan of the
business needs. Warranty information and information relating to invoices will
be retained for 50 years and quotations which are not followed through to sales
will be retained for 5 years. We will delete your data during the following
Below are the main uses of your data which depend on the
nature of our relationship with you and how you interact with our various
services, websites and activities.
protocol (ip) addresses and other information gathering technologies
Please note that the information
we gather from the following technologies does not specify any specific
individual and is used by us as statistical data only about our users browsing
actions and patterns.
information, including the Internet protocol (IP) address used to connect your
computer to the Internet, your login information, browser type and version,
time zone setting, browser plug-in types and versions, operating system and
platform and if you access our website via your mobile device we will collect
your unique phone identifier.
your visit, including, but not limited to the full Uniform Resource Locators
(URL) and query string, clickstream to, through and from our website (including
date and time), products you viewed or searched for, page response times,
download errors, length of visits to certain pages, page interaction
information (such as but not limited to, scrolling, clicks, and mouse-overs),
and methods used to browse away from the page.
The terms that you
use to search our website.
You can choose to refuse to accept the above by
activating the setting on your browser which allows you to refuse the setting
of cookies. However, if you select this setting you will be unable to access
certain parts of our site. Unless you have adjusted your browser setting so
our site. Modern browsers provide the ability to navigate the web privately by
using “private browsing mode” or you can use a proxy server, which allows web
users to see pages via a third party web server.
Your privacy is important to us, so we’ll always keep
your details secure. We’d like to use your details to keep in touch about
things that may matter to you.
If you choose to hear from us we may send you information
based on what is most relevant to you. This might be about new products,
services or promotions.
We’ll only send these to you if you agree to receive them
and we will never share your information with companies outside First Trace
Heating Direct Ltd, or its subsidiaries, for inclusion in their marketing. (We
may however share cookie data with third parties to help with our own
advertising targeting). If you agree to receive marketing information from us
you can change your mind at a later date.
Personal data provided to us may also be profiled to help
us with advertising targeting. For example, we may use your personal data to
find online users with a similar profile to yourself who may be interested in
our products or services.
We may sometimes use third parties to capture some of our
data on our behalf, but only where we are confident that the third party will
treat your data securely, in accordance with our terms and inline with the
requirements set out in the GDPR.
Use of the
SnugStat app data
The data provided by the SnugStat app user account holder
are only used for the handling of your app usage requests and functions, and
access to the SnugStat app for registration purposes, including:
How the user uses SnugStat Thermostat products: We will
collect information about how the user, and where the user share’s access,
others are using SnugStat Thermostat products and services in their property
and their performance, what devices are connected to them and how those devices
are being used with the SnugStat products. For example, this includes
information about the smart devices connected to your SnugStat Thermostat,
collect about rooms’ temperatures, temperature settings and heating schedules.
In addition, we will collect information about the pages users visit in the
SnugStat app and how they use them.
Location information: We will collect information about
a user’s exact location when they choose to share that with us. For example,
the user may set up their SnugStat app to lower the temperature of the heating
as they get further away from their property. To do this, the user will need to
opt in, switch on their location settings and set their desired heating
distance-based rules. We will also collect location information of the SnugStat
Thermostat, as part of the SnugStat app set-up process, but this is only used
for when the distance-based rules are activated, as detailed above.
Users are not required to provide any of the personal
information described above to us, however, if you do not do so, you may not be
able to use our products and services, or the functionality of our products may
We are committed to taking appropriate technical and organisational
measures to protect your personal data against unauthorised or unlawful
processing and against accidental loss, destruction or damage to personal data.
When you provide your personal data through the SnugStat app, this information
is held and stored in an encrypted file. The information that you provide to us
will be held in our systems, which are located on our premises or those of an
appointed third party. We may also allow access to your information by other
third parties who act for us for the purposes of providing and maintaining the
SnugStat app. Your personal data may be accessed by and processed outside the
European Economic Area (the European Economic Area being the European Union and
Iceland, Liechtenstein and Norway, also referred to as the “EEA”) - including
by staff operating outside the EEA who work for us or for one of our suppliers.
Where your personal data are transferred outside of the EEA, we ensure that
appropriate safeguards are in place.
Personal data created by your involvement with us
Your interaction and involvement with us will result in personal data
being created. This could include details of how and when the following takes
place: products purchased, enquiries, quotations, sales calls and visits to our
stands at exhibitions.
Call recording and monitoring
We monitor and record calls, emails, SMS messages or other
communications including those on social media platforms for:
- Business purposes such as quality control and training
- Processing necessary information for entering into or performance of a contract
- Meeting any legal obligation
- To investigate and analyse any queries or concerns you raise with us
- For the legitimate interests of the data controller
We are the controller and we are
also the processor of this information. This data has been gathered with your
consent from your giving of this information over the telephone and your
continued use of the telephone system following notification that your call
will be recorded. It is also gathered in the legitimate interests of retaining
vital information that may be required in the event of a claim for breach of
contract or professional negligence.
In order to comply with our contractual, statutory, and
management obligations and responsibilities, we process personal data,
including ‘sensitive’ personal data, from job applicants and employees.
Such data can include, but isn’t limited to, information
relating to health, racial or ethnic origin, and criminal convictions. In
certain circumstances, we may process personal data or sensitive personal data,
without explicit consent. Further information on what data is collected and why
it’s processed is given below.
- Contractual responsibilities: Our contractual responsibilities include
those arising from the contract of employment. The data processed to meet
contractual responsibilities includes, but is not limited to, data relating to:
payroll, bank account, postal address, sick pay; leave, maternity pay, pension
and emergency contacts.
- Statutory responsibilities: Our statutory responsibilities are those
imposed through law on the organisation as an employer. The data processed to
meet statutory responsibilities includes, but is not limited to, data relating
to: tax, national insurance, statutory sick pay, statutory maternity pay,
family leave, work permits, equal opportunities monitoring.
- Management responsibilities: Our management responsibilities are those
necessary for the organisational functioning of the organisation. The data
processed to meet management responsibilities includes, but is not limited to,
data relating to: recruitment and employment, customer service calls, training
and development, absence, disciplinary matters, e-mail address and telephone
Sensitive personal data
The Act defines ‘sensitive personal data’ as information
about racial or ethnic origin, political opinions, religious beliefs or other
similar beliefs, trade union membership, physical or mental health, sexual
life, and criminal allegations, proceedings or convictions.
In certain limited circumstances, we may legally collect
and process sensitive personal data without requiring the explicit consent of
(a) We will process data about an employee’s health where
it is necessary, for example, to record absence from work due to sickness, to
pay statutory sick pay, and to make any necessary arrangements or adjustments
to the workplace in the case of disability. This processing will not normally
happen without the employee’s knowledge and, where necessary, consent.
(b) We will process data about, but not limited to, an
employee’s racial and ethnic origin, their sexual orientation or their
religious beliefs only where they have volunteered such data and only for the
purpose of monitoring and upholding our equal opportunities stance and related
(c) Data about an employee’s criminal convictions will be
held as necessary.
personal data to other bodies
In order to carry out our contractual and management
responsibilities, we may, from time to time, need to share an employee’s
personal data with one or more third party supplier.
To meet the employment contract, we are required to
transfer an employee’s personal data to third parties, for example, to pension
providers and HM Revenue & Customs.
In order to fulfil our statutory responsibilities, we’re
required to give some of an employee’s personal data to government departments
or agencies e.g. provision of salary and tax data to HM Revenue & Customs.
First Trace Group Ltd. will notify all members of any
are always aware of how First Trace Group Ltd. uses your personal data.
How to contact First Trace
Heating Direct Ltd.
We welcome your views about our website and our Privacy
Policy. If you would like to contact us with any queries or comments please send
an email to firstname.lastname@example.org or telephone 01772 761 333. Should you feel
that your data is not being handled properly, you can complain to the ICO
(Information Commissioners Office).
How can I change my marketing and contact preferences?
We'd love to stay in touch, but we don't want to out-stay
We’ll always act upon your choice of how you want to receive
communications (for example, by email, post or phone). However, there are some
communications that we need to send. These are essential to fulfil our promises
to you as a customer. Examples are:
- Transaction messaging, such as
invoices or purchase confirmations. warranty information or app updates.
- Product related messaging, such
as warranty information or app updates.
If, at any time, you want to update or amend your
personal data or marketing preferences please contact us in one of the
following ways either by email to email@example.com or by calling 01772 761 333.
purposes such as quality control and training
necessary information for entering into or performance of a contract
any legal obligation
investigate and analyse any queries or concerns you raise with us
the legitimate interests of the data controller