Privacy Policy

1. Introduction

Heat & Power Services (HPS) is committed to respecting the appropriate standards on privacy and data protection in all areas where it operates.

This Policy complies with the Does of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data.

This Policy has the following objectives: -

a. Lay down the rules relating to the protection of natural persons with regard to the processing of personal data and rules relating to the free movement of personal data.

b. Protect the fundamental rights and freedoms of natural persons and in particular their right to the protection of personal data.

HPS will ensure that all existing and newly hired employees are made aware of this Policy and are provided with appropriate training on a regular basis.

This Policy does not substitute any applicable national data protection and privacy laws and regulations in countries where HPS operates. Local laws must be always followed and will take precedence over the Policy where they provide for stricter standards on privacy and data protection.

2. Scope

This Policy sets out a framework for Personal Data processing activities including the collection, use and disclosure of Personal Data carried out by or on behalf of HPS.

The purpose of the Policy is to provide for rules to be followed by all HPS employees when handling and/or transferring the following Personal Data for the following purposes:

a) Human resources Personal Data, including Personal Data of HPS current and former employees, temporary workers, trainees and job applicants (identity information, professional contact and organization information, contract information, salary and benefits related information, job qualifications and performance information, information for management and eligibility to share holdings, emergency contact information);

b) Personal Data of HPS business contacts within customers, prospects and suppliers (identity information, contact information, billing information, information provided as part of satisfaction surveys);

c) Health Personal Data concerning individuals to whom HPS may provide specific services to address health issues (in particular respiratory issues) and medical devices (identity information, contact information and pathology, prescription and treatment).

3. Definitions

Personal Data:

Any information relating to an identified or identifiable Natural Person.

Natural Person:

A person who can be identified, directly or indirectly, in particular by reference to an identification number or to one or more factors specific to their physical, physiological, mental, economic, cultural or social identity.

Data Subject:

A Natural Person whose Personal Data is being Processed.

Processing

Any operation or set of operations which is performed on Personal Data or on sets of Personal Data.

HPS:

Heat & Power Services limited.

Child:

A Natural Person under 16 Years of Age

4.Data Protection Principles

Data Protection Principles to be followed by HPS for the collection, use and disclosure of Personal Data:

Personal Data shall be processed lawfully, fairly and in a transparent manner in relation to the data subject;
Personal Data collected must be for specific, explicit and for legitimate purposes;
Only adequate, relevant and limited Personal Data to what is necessary in relation to the purposes for which they are processed
Personal Data shall be accurate and, where necessary, kept up to date; every reasonable step shall be taken to ensure that personal data that are inaccurate, having regard to the purposes for which they are processed, are erased or rectified without delay;
Personal Data will be kept in a form which permits identification of data subjects for no longer than is necessary for the purposes for which the personal data are processed;
Personal data shall be processed in a manner that ensures appropriate security of the personal data, including protection against unauthorised or unlawful processing and against accidental loss, destruction or damage, using appropriate technical or organisational measures;
Uphold the Rights of the Data Subject.

5. Rights of the Data Subject

The Data Subject has the following Rights:

1. Right to information:
You have the right to know whether your Personal Data is being processed; what data is gathered, from where it is obtained and why and by whom it is processed.

2. Right to access:
You have the right to access the data collected from/about you. This includes your right to request and obtain a copy of your Personal Data gathered.

3. Right to rectification:
You have the right without undue delay to request rectification of inaccurate personal data. Considering the purposes of the processing, the data subject shall have the right to have incomplete personal data completed, including by means of providing a supplementary statement.

4. Right to erasure:
You have the right for erasure of personal data without undue delay on grounds detailed in ‘Regulation (EU) 2016/679 Article 17’.

5. Right to restrict processing:
You have the right to restrict the Processing of your Personal Data where conditions detailed in ‘Regulation (EU) 2016/679 Article 17’ apply,

6. Right to data portability:
You have the right to obtain your Personal Data in a machine-readable format or if it is feasible, as a direct transfer from one Processor to another.

7. Right to object to processing:

In certain cases, you have the right to object to Processing of your Personal Data, for example in the case of direct marketing

8. Right to object to automated Processing:
You have the right to object to automated Processing, including profiling; and not to be subject to a decision based solely on automated Processing. This right you can exercise whenever there is an outcome of the profiling that produces legal effects concerning or significantly affecting you.

9. Right to lodge a complaint:
In the event that we refuse your request under the Rights of Access, we will provide you with a reason as to why. If you are not satisfied with the way your request has been handled please contact us.

10. Right for the help of supervisory authority:
You have the right for the help of a supervisory authority and the right for other legal remedies such as claiming damages.

11. Right to withdraw consent
You have the right withdraw any given consent for Processing of your Personal Data.

6. Data we gather

We save information you have provided us with, such as your e-mail address, name, billing address, home address etc that is necessary for delivering you a product/service or to enhance your customer experience with us.

7. How we use your Personal Data We use your personal data to:

Provide our service to you. This includes for example registering your account; providing you with other products and services that you have requested; providing you with promotional items at your request and communicating with you in relation to those products and services; communicating and interacting with you; and notifying you of changes to any service;
Develop and enhance your customer experience;
Fulfil and obligation under law or contract.

We use your Personal Data on legitimate grounds and/or with your Consent: On the grounds of entering into a contract or fulfilling contractual obligations, we Process your Personal Data for the following purposes:

Identification;
Provision of a service or to send/offer you a product;
Sales/Invoicing Communication.

On the ground of legitimate interest, we Process your Personal Data for the following purposes:

Administration and analysis of our client base, contractors & supplier chain in order to improve the quality, variety, and availability of products/services offered/provided
Conduct client satisfaction surveys, contractor competence & supplier quality

We process your Personal Data in order to fulfil obligation rising from law and/or use for options provided by law. We save your billing information and other information gathered about you for as long as needed for accounting purposes or other obligations deriving from law, but not longer than but not longer than is necessary to fulfil our business obligations to you.

8. Data Security

We do our best to keep your Personal Data safe. We use safe protocols for communication and transferring data (such as HTTPS). We use anonymising and pseudonymising where suitable. We monitor our systems for possible vulnerabilities and attacks.

Even though we try our best we can not guarantee the security of information. However, we promise to notify suitable authorities of data breaches. We will also notify you if there is a threat to your rights or interests. We will do everything we reasonably can to prevent security breaches and to assist authorities should any breaches occur.

9. Children

HPS shall not collect or knowingly collect information from Children.