Romax Marketing & Distribution Ltd is the data controller and we are responsible for your personal data (referred to as “we”, “us” or “our” in this privacy notice).

Our email address is: hello@romax.co.uk

Our postal address is: Unit 8, Halo Business Park, Cray Avenue, Orpington BR5 3FQ

If you are not happy with any aspect of how we collect and use your data, you have the right to complain to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues

(www.ico.org.uk). We should be grateful if you would contact us first if you do have a complaint so that we can try to resolve it for you.

It is very important that the information we hold about you is accurate and up to date. Please let us know if at any time your personal information changes by emailing us at hello@romax.co.uk

Sensitive Data

We do not collect any Sensitive Data about you. Sensitive data refers to data that 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. We do not collect any information about criminal convictions and offences.

We require your explicit consent for processing sensitive data and we will request your signature for this consent.

HOW WE USE YOUR PERSONAL DATA

We will only use your personal data when legally permitted. The most common uses of your personal data are:

• Where we need to perform the contract between us.
• 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.

Generally, we do not rely on consent as a legal ground for processing your personal data, other than in relation to sending marketing communications to you via email or text message. You have the right to withdraw consent to marketing at any time by emailing us at  hello@romax.co.uk

Purposes for processing your personal data

Set out below is a description of the ways we intend to use your personal data and the legal grounds on which we will process such data. We have also explained what our legitimate interests are where relevant. We may process your personal data for more than one lawful ground, depending on the specific purpose for which we are using your data. Please email us at hello@romax.co.uk  if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below.

Marketing communications 

You will receive marketing communications from us if you have:

• requested information from us or purchased goods or services from us; or
• if you provided us with your details and ticked the box at the point of entry of your details for us to send you marketing communications; and
• in each case, you have not opted out of receiving that marketing. 

We will get your express opt-in consent before we share your personal data with any third party for marketing purposes. You can ask us or third parties to stop sending you marketing messages at any time by emailing us at hello@romax.co.uk at any time.  Where you opt out of receiving our marketing communications, this will not apply to personal data provided to us as a result of a product/service purchase, warranty registration, product/service experience or other transactions.

DISCLOSURES OF YOUR PERSONAL DATA

We may have to share your personal data with the parties set out below for the purposes set out in the table in paragraph 2 above:

• Service providers who provide IT and system administration services.
• Professional advisers including lawyers, bankers, auditors and insurers who provide consultancy, banking, legal, insurance and accounting services.
• HM Revenue & Customs, regulators and other authorities based in the United Kingdom and other relevant jurisdictions who require reporting of processing activities in certain circumstances.
• Third parties to whom we sell, transfer, or merge parts of our business or our assets.

We require all third parties to whom we transfer your data to respect the security of your personal data and to treat it in accordance with the law. We only allow such third parties to process your personal data for specified purposes and in accordance with our instructions.

INTERNATIONAL TRANSFERS

We do not share your personal data within our group of companies which involves transferring your data outside the UK/European Economic Area (EEA).

Countries outside of the European Economic Area (EEA) do not always offer the same levels of protection to your personal data, so UK/European law has prohibited transfers of personal data outside of the UK/EEA unless the transfer meets certain criteria.

If none of the above safeguards is available, we may request your explicit consent to the specific transfer. You will have the right to withdraw this consent at any time.

Please email us at hello@romax.co.uk if you want further information on the specific mechanism used by us when transferring your personal data out of the EEA.

DATA SECURITY

We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know such data. They will only process your personal data on our instructions and they are subject to a duty of confidentiality. We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

DATA RETENTION

We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.

To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.

By law we have to keep basic information about our customers (including Contact, Identity, Financial and Transaction Data) for six years after they cease being customers for tax purposes.

In some circumstances you can ask us to delete your data: see below for further information.

In some circumstances we may anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes in which case we may use this information indefinitely without further notice to you.

YOUR LEGAL RIGHTS

Under certain circumstances, you have rights under data protection laws in relation to your personal data. These include the right to:

• Request access to your personal data.
• Request correction of your personal data.
• Request erasure of your personal data.
• Object to processing of your personal data.
• Request restriction of processing your personal data.
• Request transfer of your personal data.
• Right to withdraw consent.

You can see more about these rights at: https://ico.org.uk/for-organisations/guide-to-the-general-data-protection-regulation-gdpr/individual-rights/ If you wish to exercise any of the rights set out above, please email us at hello@romax.co.uk.

You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.

We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.

Cookies

A cookie is a small data file with text stored in your browser. The information is used to distinguish you as a unique visitor. These Cookies do not contain any information about you as a person.

Most browsers are initially set to allow cookies. The feature can be turned off. If you do not know how to turn off cookies on your browser, try using the browser’s help function or visit for more information on cookies http://www.allaboutcookies.org/.

We use the following cookies:

Real Cookie Banner

To manage the cookies and similar technologies used (tracking pixels, web beacons, etc.) and related consents, we use the consent tool “Real Cookie Banner”. Details on how “Real Cookie Banner” works can be found at https://devowl.io/rcb/data-processing/.

The legal basis for the processing of personal data in this context are Art. 6 (1) lit. c GDPR and Art. 6 (1) lit. f GDPR. Our legitimate interest is the management of the cookies and similar technologies used and the related consents.

The provision of personal data is neither contractually required nor necessary for the conclusion of a contract. You are not obliged to provide the personal data. If you do not provide the personal data, we will not be able to manage your consents.

Google Analytics Cookies

This website uses Google Analytics to collect information about how people use this site. We do this to make sure it’s meeting its users’ needs and to understand how we could do it better.

Google Analytics stores information about what pages you visit, how long you are on the site, how you got here and what you click on. We do not collect or store your personal information (e.g. your name or address) so this information cannot be used to identify who you are. We do not allow Google to use or share our analytics data.

The following cookies are set by Google Analytics:

Cookie Name                                            Purpose

Used by Google Analytics. Each unique browser that visits a page on our site is provided with a unique ID via the __utma cookie. In this way, subsequent visits to our website via the same browser are recorded as belonging to the same (unique) visitor. Thus, if a person interacted with our website using both Firefox and Internet Explorer, the Google

Analytics reports would track this activity under two unique visitors.

__utma

Similarly if the same browser were used by two different visitors, but with a separate computer account for each, the activity would be recorded under two unique visitor IDs. On the other hand, if the browser happens to be used by two different people sharing the same computer account, one unique visitor ID is recorded, even though two unique individuals accessed the site.

When visitors reach our site via a search engine result, a direct link, or an ad that links to your page, Google Analytics stores the type of referral information in a cookie. The parameters in the cookie value

__utmz                                                       string are parsed and sent in the GIF Request (in the utmcc variable).

The expiration date for the cookie is set as 6 months into the future. This cookie gets updated with each subsequent page view to our site; thus it is used to determine visitor navigation within your site.

This cookie is used to establish and continue a user session with our site. When a user views a page on your site, the Google Analytics code

attempts to update this cookie. If it does not find the cookie, a new one

__utmb is written and a new session is established. Each time a user visits a __utmc        different page on our site, this cookie is updated to expire in 30

minutes, thus continuing a single session for as long as user activity continues within 30-minute intervals. This cookie expires when a user pauses on a page on our site for longer than 30 minutes.

Social bookmarking and sharing Cookie Name            Purpose

These are used by AddThis social bookmarking service, they enable us to allow you to share our pages and take advantage of social bookmarking. You can view Addthis’s

uid, uvc, uit, psc, di, dt, uid, uit, psc, siteaud, cookie policy here

ana_svc

< http://www.addthis.com/privacy/privacy- policy#publisher-visitors>

These are placed by the LinkedIn share button, they enable us to allow you to share our pages within your

__qca, bcookie, X-LI-IDC, visit,                                          LinkedIn network.

NSC_MC_WT_FU_IUUQ                                                     You can view LinkedIn’s privacy and cookie policy

here http://www.linkedin.com/static?key=privacy_policy

Last Updated December 2021