For privacy notices relating to Luxfer Group Retirement Savings Plan please refer to either of the
following, depending on the circumstances:
· Cullen Wealth (financial advice)
· Aviva (personal pension provider)
1. Purposes of this Privacy Policy
This privacy policy aims to give you information about how your personal data is collected and processed when you use this website, including any data you may provide through this website when you sign up to our newsletter.
This website is not intended for children and we do not knowingly collect data relating to children.
This privacy policy supplements other notices and privacy policies and is not intended to override them. It is important that you read any other privacy policy or fair processing policy we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data.
2. What personal data will we collect?
Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data). We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows;
• "Identity Data" includes first name, maiden name, last name, username or similar identifier.
• "Contact Data" includes address, company address, email address and telephone numbers.
• "Technical Data" includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, and other technology on the devices you use to access this website.
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.
3. Where we get personal information from
Some of the information the Trustees have comes directly from you. In addition, the Plan Administrator may have obtained information from you.
The Trustees may then in turn pass information about you to the Plan Actuary or may instruct the administrator to do so.
The Trustees and the Plan Administrator are the source of the personal information which the Plan Actuary has about you.
Sometimes the Trustees get information from other sources: for example, from your Plan employer (for information such as your salary and length of service); from another scheme if you have transferred benefits from that scheme; from government departments such as HMRC and DWP; and from publicly accessible sources (e.g. the electoral roll) if the Trustees have lost touch with you and are trying to find you. Again, the Trustees may in turn pass this to the Plan Actuary.
If the Trustees ask you for other information in the future (for example, about your health), they will explain whether you have a choice about providing it and the consequences for you if you do not do so.
4. What will we use your personal information for?
Pursuant to the General Data Protection Regulation (EU) 2016/679 (“GDPR”) we must have a "legal ground" to use your personal data in each case. We set out below further information about each legal ground that we may rely on;
Legitimate Interest: 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.
Performance of Contract: 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.
Comply with a legal obligation: means processing your personal data where it is necessary for compliance with a legal obligation that we are subject to.
Grounds for Processing
We have set out below a description of the ways we plan to use your personal data, and which of the legal grounds we rely on to do so. We have also identified what our legitimate interests are where appropriate.
Please note that 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 contact us 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.
Purpose/Activity
To respond to your general enquiries about our company, services or products and to direct your enquiry to the appropriate Luxfer group company
Type of data
(a) Identity
(b) Contact
Legal grounds for processing including basis of legitimate interest
Necessary for our legitimate interests (e.g. to facilitate sales of our services/products and improving our products and services)
Purpose/Activity
To manage our relationship with you which will include any communication with you (e.g. to inform you of changes to this policy)
Type of data
(a) Identity
(b) Contact
Legal grounds for processing including basis of legitimate interest
(a) Performance of a contract with you
(b) Necessary for our legitimate interests (to keep our records updated and to study how customers use products/services)
(c) Necessary to comply with a legal obligation
Purpose/Activity
To use data analytics to improve our website and to develop new services.
Type of data
(a) Technical
Legal grounds for processing including basis of legitimate interest
Necessary for our legitimate interests (to define types of customers for our products and services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy)
Purpose/Activity
To keep you informed by email about new information that is published on the Luxfer website
Type of data
(a) Identity
(b) Contact
Legal grounds for processing including basis of legitimate interest
Necessary for our legitimate interests (to develop our products/services and grow our business)
Marketing
We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising.
You will receive such marketing communications from us if you have requested information directly form us.
Cookies
You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of this website may become inaccessible or not function properly. For more information about the cookies we use, please see details of our Cookie Policy at the bottom of the page.
5. Keeping your information safe
When we pass your information to a third party, we seek to ensure that they have appropriate security measures in place to keep your information safe and to comply with general principles in relation to data protection.
Some of the people we share your information with may process it overseas. This means that your personal information may on occasion be transferred outside the UK and the European Economic Area. Some countries already provide adequate legal protection for your personal information, but in other countries, additional steps will need to be taken to protect it.
You can contact us for more information about the safeguards we use to ensure that your personal information is adequately protected in these circumstances (including how to obtain copies of this information).
Queries and further information
If you want more information about what we do with your information and what your rights are, please contact the Trustees via the Plan Secretary at: David Mead, Luxfer Group Limited, Lumns Lane, Manchester, M27 8LN or david.mead@luxfer.com.
If you have concerns about the way we handle your personal information, you can contact the Information Commissioner´s Office or raise a complaint at www.ico.org.uk/concerns, or call its helpline on 0303 123 1113.