Be Cool Group UK Ltd Refrigeration and Air Conditioning
Privacy Policy

At Be Cool Group, data protection and data security when using our website and services are very important to us. We would therefore like to inform you at this point which of your Personal Data we collect when you visit our website and for what purposes it is used.

Background
This Privacy Policy describes our privacy practices in plain language, keeping legal and technical jargon to a minimum, to make sure you understand the information provided. However, to achieve this objective we would like to explain you the following concepts.

a) What is Personal Data?
Personal Data is any information that relates to an identified or identifiable living individual. Different pieces of information, which collected together can lead to the identification of a particular person, also constitute Personal Data.

b) What is Processing?
“Processing” means and covers virtually any handling of data.

c) What law applies?
In principle, we will only use your Personal Data in accordance with the applicable data protection laws, in particular the UK`s Data Protection Act (“DPA”) and the General Data Protection Regulation (“GDPR”).

d) Who is responsible for data processing?
The responsible party within the meaning of the DPA and the GDPR is Be Cool Group UK Ltd of Office 7, 35/37 Ludgate Hill, London, EC4M 7JN (“Be Cool Group”, “we”, “us”, or “our”). If you have any questions or if you wish to exercise your rights under the DPA or GDPR, please contact us using info@becoolrefrigeration.co.uk or call 0203 488 1889 or write to us at the above address.

General Principles
a) Purpose and legal basis of processing
In accordance with the DPA and GDPR we need to have both a purpose and a legal basis to process Personal Data. The purposes are:

• providing the website and its functions and contents,
• responding to contact requests and communicating with our customers,
• providing our services, and
• security measures.

Of course, we can only do that if we have at least one of the following legal bases or in other words lawful reasons to do so. Unless specifically described below, we typically link the above purposes to one of the following:

• consent,
• to fulfil our services and carry out contractual obligations,
• to fulfil our legal obligations, and
• to protect our legitimate interests.

b) Categories of data subjects and types of data processed
During the course of using our website and services, we process the following types of data from visitors and users:

• inventory data,
• contact data,
• content data,
• contract data,
• usage data, and
• meta/communication data.

c) Security
Our website uses SSL or TLS encryption to ensure the security of data processing and to protect the transmission of confidential content, login data or contact requests that you send to us. We have also implemented numerous security measures (“technical and organisational measures”) for example encryption or need to know access, to ensure the most complete protection of Personal Data processed through this website.

Nevertheless, internet-based data transmissions can always have security gaps, so that absolute protection cannot be guaranteed. And databases or data sets that include Personal Data may be breached inadvertently or through wrongful intrusion.

Upon becoming aware of a data breach, we will notify all affected individuals whose Personal Data may have been compromised as expeditiously as possible after which the breach was discovered.

d) Retention and Storage
We retain your Personal Data as necessary in connection with the purposes described in this Privacy Policy, and in accordance with the UK’s Statutory Retention Periods and other applicable laws for up to 6 years.

e) Minors
We do not request Personal Data from minors and children and do not knowingly collect such data or pass it on to third parties.

f) Automated decision-making
Automated decision-making including profiling does not take place.

g) Do Not Sell
We do not sell your Personal Data.

h) Special Category Data
Unless specifically required and consent is obtained, for a particular service, we do not process special category data.

Data we collect automatically
a) Log files
When you visit our website, we collect the Personal Data that your browser automatically transmits to our server. This information is temporarily stored in a so-called log file. This includes:

· IP address of the requesting computer,
· Date and time of access,
· name and URL of the file accessed,
· website from which the access was made (referrer URL),
· browser used and, if applicable, the operating system of your computer as well as the name of your access provider.

The processing of the aforementioned data is necessary for the provision of a website and thus serves to protect our legitimate interest.

b) Cookies
i) Why do we use cookies?
We use cookies and similar technologies to collect certain information about visitors. In this Cookie Policy we explain how we and third parties use cookies while you are browsing our website, including subpages, or other features (generally referred to in this policy as the “website”).

We also have a presence on social media networks such as LinkedIn in the form of social media pages. Please visit their websites to find out about their privacy policies and the privacy and marketing controls for their community, as we have no control over the operation of these social media platforms.

ii) What are cookies?
Like most websites you visit, our website uses cookies and other similar technologies (commonly referred to as “cookies”). Cookies are text files embedded in a website that contain small amounts of information that is downloaded to your device or embedded in a website when you visit it. Cookies can then be sent back to the original website or to another website that recognises that cookie on each subsequent visit.

Cookies are useful because they allow a website to recognise a user’s device and remember your actions and settings (such as login details, language, font size and other display settings) over a period of time.

Where possible, security measures are taken to prevent unauthorised access to our cookies and similar technologies. A unique identifier ensures that only we and/or our authorised service providers have access to cookie data.

iii) How we use cookies?
We use different types of cookies on our website for different purposes as set out below. Some of these cookies are placed by us and others by third parties (e.g., social media platform and analytics providers etc.).

Necessary cookies – These cookies are required for the operation of our website to enable core website functions, ensure website security, and enable network management. They are sometimes referred to as “strictly necessary” or “essential” cookies. Without these cookies, a website cannot function properly. These include, for example, cookies that allow us to remember your preferences for agreeing to cookies and to balance network load. You can log in to secure areas of our website and access user accounts or online forms.

Functional and Analytical Cookies – These cookies are either functional or analytical. They are used to improve functionality, enhance and personalise the browsing experience and analyse website traffic and usage.

• Analytical cookies allow us to recognise and count the number of visitors and see how visitors use our website. They help us understand and measure how you interact with our website, allow us to collect statistics about our website visitors to better understand them and improve the way our website works, for example by ensuring that users can easily find what they are looking for. Analytical cookies also allow us to test new website content, features or interactions to improve the website experience and appearance for everyone.

• Functional cookies are used to improve what you can do on our website. Examples of this include helping us to deliver a better and more personalised user experience for you, testing and delivering the best website design, layout and content, and remembering the choices you make between sessions. This allows us to improve and personalise our content for you, greet you by name and remember your preferences.

• In addition, certain third-party cookies are required to enable some functionality embedded on the website. These third-party cookies are only placed when you interact with certain functionality on the website.

iv) How can you manage cookies?
Browser control
Most browsers allow you to control cookies through the cookie settings, which you can customise to consent to the use of cookies. You can also check and delete cookies with most browsers. To do so, please refer to your browser manufacturer’s documentation by following the link relevant to you Google Chrome, Mozilla Firefox, Microsoft Edge, Opera, Safari.

Pop-up consent tool
When you visit our website for the first time, you will be presented with a pop-up cookie setting window. This pop-up is a consent tool and allows you to indicate your preferences regarding cookies. You can accept or reject them or view this Cookie Policy before giving your consent to cookies or rejecting them. This allows you to make an informed decision about the cookies we use. You are free to accept or reject cookies but note that browsing our website may be less user-friendly and relevant content may be affected after you reject them.

Regardless of your initial decision, you may from time to time withdraw your consent or adjust your preferences through browser control settings, clearing your cookie folder, or by changing your preferences in our Pop-Up Consent Tool.

vi) What cookies does Be Cool Group use?
First party and third-party cookies commonly used on the Sites are listed in the table below. We strive to keep this list current and will update it accordingly. In any case, you can always manage all cookies and other tracking technologies used on the website.

• _gcl_au
o .becoolrefrigeration.co.uk
o Provided by Google Tag Manager to experiment advertisement efficiency of websites using their services.
o 3 months
o Analytics

• _ga
o .becoolrefrigeration.co.uk
o The _ga cookie, installed by Google Analytics, calculates visitor, session and campaign data and also keeps track of site usage for the site’s analytics report. The cookie stores information anonymously and assigns a randomly generated number to recognize unique visitors.
o 2 years
o Analytics

• CLID
o www.clarity.ms
o Microsoft Clarity set this cookie to store information about how visitors interact with the website. The cookie helps to provide an analysis report. The data collection includes the number of visitors, where they visit the website, and the pages visited.
o 1 year
o Analytics

• _gid
o .becoolrefrigeration.co.uk
o Installed by Google Analytics, _gid cookie stores information on how visitors use a website, while also creating an analytics report of the website’s performance. Some of the data that are collected include the number of visitors, their source, and the pages they visit anonymously.
o 1 day
o Analytics

• _gat_UA-97591622-1
o .becoolrefrigeration.co.uk
o A variation of the _gat cookie set by Google Analytics and Google Tag Manager to allow website owners to track visitor behaviour and measure site performance. The pattern element in the name contains the unique identity number of the account or website it relates to.
o 1 minute
o Analytics

• _clck
o .becoolrefrigeration.co.uk
o Microsoft Clarity sets this cookie to retain the browser’s Clarity User ID and settings exclusive to that website. This guarantees that actions taken during subsequent visits to the same website will be linked to the same user ID.
o 1 year
o Analytics

• _ga_5C8GD7S0FH
o .becoolrefrigeration.co.uk
o This cookie is installed by Google Analytics.
o 2 years
o Analytics

• _uetsid
o .becoolrefrigeration.co.uk
o Bing Ads sets this cookie to engage with a user that has previously visited the website.
o 1 day
o Performance

• _uetvid
o .becoolrefrigeration.co.uk
o Bing Ads sets this cookie to engage with a user that has previously visited the website.
o 1 year 24 days
o Performance

• MUID
o .bing.com
o Bing sets this cookie to recognize unique web browsers visiting Microsoft sites. This cookie is used for advertising, site analytics, and other operations.
o 1 year 24 days
o Advertisement

• _clsk
o .becoolrefrigeration.co.uk
o Microsoft Clarity sets this cookie to store and consolidate a user’s pageviews into a single session recording.
o 1 day
o Analytics

• SM
o c.clarity.ms
o Microsoft Clarity cookie set this cookie for synchronizing the MUID across Microsoft domains.
o session
o Analytics

• MUID
o .clarity.ms
o Bing sets this cookie to recognize unique web browsers visiting Microsoft sites. This cookie is used for advertising, site analytics, and other operations.
o 1 year 24 days
o Advertisement

Google Analytics
We use Google Analytics based on our legitimate interest and your consent, a web analytics service provided by Google LLC, on our website. Google Analytics also uses cookies to enable our website to analyse how users use our website across multiple devices. The information generated by the cookies about your use of our website is transmitted to and stored by Google, including transmission to the United States. The following data is processed through the use of Google Analytics:

• 3 bytes of the IP address of the called system of the website visitor (anonymised IP address),
• the website called up,
• the website from which the user reached the accessed page of my website (referrer),
• the subpages accessed from the website,
• the time spent on the website, and
• the frequency with which the website is accessed.

Google states that it will not associate your IP address with any other data held by Google.

You can disable tracking by Google Analytics with future effect by downloading and installing the Google Analytics Opt-out Browser Add-on for your current web browser following this link http://tools.google.com/dlpage/gaoptout?hl=en.

Microsoft Clarity
We use the “Clarity” service provided by Microsoft Corporation, One Microsoft Way, Redmond, WA 98052-6399, USA. Clarity enables an analysis of the use of our website. This creates a log of mouse movements and clicks with the intention of deriving potential improvements for the website. The information collected is transmitted to Clarity and stored there. According to Microsoft, this information can also be used for advertising purposes. Opt-out option: https://choice.microsoft.com/opt-out The legal basis for this processing is our legitimate interest and your consent.

c) Hosting
To provide our website, we use the services of Cloudflare, who process all data to be processed in connection with the operation of our website on our behalf. The legal basis for the data processing is our legitimate interest in providing our website.

d) Content Management System (CMS)
We also use the Content Management System (CMS) of WordPress a service provided by Automattic Inc, to publish and maintain the created and edited Content and texts on our website and to provide the forms used. This means that all content and texts submitted to us by users for publication is transferred to WordPress. In addition to texts, this also includes, for example your data in our forms. The legal basis for this processing is our legitimate interest.

Data we collect directly
We may ask you for Personal Data when you:
• use our website,
• request services, support, or information,
• participate online or otherwise in marketing activities,
• interact with us on third-party social networking sites (subject to the terms of use and privacy policies of said third parties), or
• contact us.

Categories of Personal Data we collect may include your name, email address, phone number and IP addresses. We may also collect data about your Business such as Business name and contact details as well as demographic data such your interests, and preferences.

In the context of a contact request on our website, in addition to your enquiry you may also disclose your name, e-mail, telephone number and the type of services required.

We are also present on social media and if you contact us via social media platforms, we and the relevant platform are jointly responsible for the processing of your data and enter into a so-called joint controller agreement.

We process the data of our service users in order to be able to provide our contractual services as well as to ensure the security of our services and to be able to develop it further. This includes in particular our support, correspondence with you, invoicing, fulfilment of our accounting and tax obligations. Accordingly, the data is processed on the basis of fulfilling our contractual obligations as well as to fulfil our legal obligations.

Where any Personal Data relates to a third party, you represent and warrant that the Personal Data is up-to-date, complete, and accurate and that you have obtained the third party’s prior consent for our collection, use and disclosure of their Personal Data for the Purposes. You agree that you shall promptly provide us with written evidence of such consent upon demand by us.

Unless otherwise specified the purposes of processing are contractual performance and service, contact requests and communication, office and organisational procedures, administration, and response to requests, visit action evaluation.

The legal basis for the data processing is the fulfilment of our contractual obligations and, in individual cases, the fulfilment of our legal obligations as well as your consent. You may withdraw your consent and request us to stop using and/or disclosing your Personal Data by submitting your request to us using info@becoolrefrigeration.co.uk or call 0203 488 1889 or write to us at the above address.

Data from third party sources
We may obtain data about you from third-party sources, such as our marketing partners, social networks, and other third parties. We may use this data to better analyse your user behaviour to improve our ability to provide you with relevant marketing information and services, and to prevent and combat fraud. The legal basis for the data processing is our legitimate interest.

Disclosure, Sharing and Transfer
a) Cooperation with processors and third parties
If, in the course of our processing, we disclose data to other persons and companies (processors or third parties), transmit it to them or otherwise grant them access to the data, this will only be done on the basis of a legal permission (e.g., if a transmission of the data to third parties, such as to payment service providers, is necessary for the performance of the contract), you have consented, a legal obligation provides for this or on the basis of our legitimate interests (e.g., when using agents, web hosts, etc.). If we commission third parties to process data on the basis of a so-called “processing agreement.

b) Marketing
Insofar as you have also given us your consent to process your Personal Data for marketing and advertising purposes, we are entitled to contact you for these purposes via the communication channels you have given your consent to. You may withdraw your consent and request us to stop by submitting your request to us using info@becoolrefrigeration.co.uk or call 0203 488 1889 or write to us at the above address.

c) International Transfer
In the course of our website operation, we process data. We usually do not transfer Personal Data to countries outside the UK and the EEA. However, if we do, we ensure that processing of your Personal Data is governed by Processing Agreements that include Standard Contractual Clauses to ensure a high level of data protection.

d) Disclosure
We will not disclose or otherwise distribute your Personal Data to third parties unless this is a) necessary for the performance of our services, b) you have consented to the disclosure, c) or if we are legally obliged to do so e.g., by court order or if this is necessary to support criminal or legal investigations or other legal investigations or other legal proceedings; as required by law or regulation; if Be Cool Group (or a part of Be Cool Group) is sold to or merged with another company; or proceedings at home or abroad or to fulfil our legitimate interests.

Your Rights and Privileges
a) Privacy rights
Under the DPA and GDPR, you can exercise the following rights:
• Right to information
• Right to rectification
• Right to object to processing
• Right to deletion
• Right to data portability
• Right of objection
• Right to withdraw consent
• Right to complain to a supervisory authority
• Right not to be subject to a decision based solely on automated processing.

If you have any questions about the nature of the Personal Data we hold about you, or if you wish to request the erasure or rectification of Personal Data we hold about you, or to exercise any of your other rights as a data subject, please contact us.

b) Updating your information
If you believe that the information, we hold about you is inaccurate or that we are no longer entitled to use it and want to request its rectification, deletion, or object to its processing, please do so by contacting us.

c) Withdrawing your consent
You can revoke consents you have given at any time by contacting us. The legality of the data processing carried out until the revocation remains unaffected by the revocation.

d) Access Request
In the event that you wish to make a Data Subject Access Request, you may inform us in writing of the same. We will respond to requests regarding access and correction as soon as reasonably possible. Should we not be able to respond to your request within thirty (30) days after receiving your request, we will let you know in writing within thirty (30). If we are unable to comply with your request, we will tell you why (except where we are not required to do so under the respective legal regulations mentioned above).

e) Complaint to a supervisory authority
You have the right to complain about our processing of Personal Data to a supervisory authority responsible for data protection. The supervisory authority in the UK is: The Information Commissioner`s Office (ICO) is located at Wycliffe House, Water Ln, Wilmslow SK9 5AF, UK www.ico.org.uk

Changes and Updates
Since changes in the law or in our internal company processes may make it necessary to adapt this Privacy Policy from time to time, we ask you to read this Privacy Policy regularly.

Concerns and Contact
If you have any concerns about a possible compromise of your privacy or misuse of your Personal Data on our part, or any other questions or comments, you can contact us using info@becoolrefrigeration.co.uk or call 0203 488 1889 or write to us at the above address.

This Privacy Policy was last updated on Tuesday, 21 February 2023.