Phasix Privacy Policy

1. PURPOSE OF THIS POLICY

This policy describes how we collect and use personal data about you, in accordance with the General Data Protection Regulation (GDPR), the Data Protection Act 1998 and any other national implementing laws, regulations and secondary legislation, as amended or updated from time to time, in the UK ('Data Protection Legislation').

Please read the following carefully to understand our practices regarding your personal data and how we will treat it.

2. ABOUT US

Hi Gain Limited T/A Phasix ESD ("Hi Gain Ltd", "Phasix", "Phasix ESD", "we", "us", "our" and "ours") is a company supplying services primarily into the semiconductor industry. We are registered in England and Wales as a limited liability company under number: 06763602 and our registered office is at 19 Clifftown Road, Southend-on-Sea, SS1 1AB.

For the purpose of the Data Protection Legislation and this policy, we are the 'data controller'. This means that we are responsible for deciding how we hold and use personal data about you. We are required under the Data Protection Legislation to notify you of the information contained in this privacy policy.

We have appointed a Data Protection Point of Contact who is responsible for assisting with enquiries in relation to this privacy policy or our treatment of your personal data. Should you wish to contact our Data Protection Point of Contact you can do so using the contact details noted at paragraph 12 (Contact Us), below.

3. HOW WE MAY COLLECT YOUR PERSONAL DATA

We obtain personal data about you, for example:

• when you request a proposal from us in respect of the goods and/or services we provide;
• when you, or your employer engages us to provide our goods and/or services and also during the provision of those goods and/or services;
• when you contact us by email, telephone, post, website or social media (for example when you have a query about our goods and services);
• from third parties and/or publicly available resources (for example, from your employer, from Companies House, from LinkedIn or from HMRC); or
• when you visit our website at www.phasix.co.uk.

Website - IP Addresses and Cookies

We may collect information about your computer, including where available your IP address, operating system and browser type, for system administration and internal marketing.

This is statistical data about our website users' browsing actions and patterns and does not identify any individual. For the same reason, we may obtain information about your general internet usage by using a cookie file which is stored on the hard drive of your computer. Cookies contain information that is transferred to your computer's hard drive. They help us to improve our website and to deliver a better and more personalised service.

They enable us:

• To estimate our audience size and usage pattern.
• To store information about your preferences, and so allow us to customise our website according to your individual interests.
• To speed up your searches.
• To recognise you when you return to our website.

Website - Where we store your data

You may refuse to accept cookies by activating the setting on your browser which allows you to refuse the setting of cookies. However, if you select this setting you may be unable to access certain parts of our website. Unless you have adjusted your browser setting so that it will refuse cookies, our system will issue cookies when you log on to our website.

4. THE KIND OF INFORMATION WE HOLD ABOUT YOU

The information we hold about you may include the following:

• your personal details (such as your name, business email, business telephone number);
• details of contact we have had with you in relation to the provision, or the proposed provision, of our services;
• details of any services you have received from us;
• our correspondence and communications with you;
• information about any complaints and enquiries you make to us;
• information from research, surveys, and marketing activities;
• Information we receive from other sources, such as publicly available information, information provided by your employer or our clients or information from our suppliers;
• Details of any goods or services you may provide to us.

5. HOW WE USE PERSONAL DATA WE HOLD ABOUT YOU

We may process your personal data for purposes necessary for the performance of our contract with you or your employer or our clients and to comply with our legal obligations.

We may process your personal data for the purposes necessary for the performance of our contract with our clients. This may include processing your personal data where you are an employee, subcontractor, supplier or customer of our client.

We may process your personal data for the purposes of our own legitimate interests provided that those interests do not override any of your own interests, rights and freedoms which require the protection of personal data. This includes processing for marketing, business development, statistical and management purposes.

We may process your personal data for certain additional purposes with your consent, and in these limited circumstances where your consent is required for the processing of your personal data then you have the right to withdraw your consent to processing for such specific purposes.

Please note that we may process your personal data for more than one lawful basis depending on the specific purpose for which we are using your data.

Situations in which we will use your personal data.

We may use your personal data in order to:

• carry out our obligations arising from any agreements entered into between you or your employer and us (which will most usually be for the provision of our goods and services);
• carry out our obligations arising from any agreements entered into between our clients and us (which will most usually be for the provision of our goods and services) where you may be a subcontractor, supplier or customer of our client;
• provide you with information related to our goods, services and our events and activities that you request from us or which we feel may interest you;
• seek your thoughts and opinions on the goods and services we provide;
• notify you about any changes to our services; and,
• record details of goods and services provided by you.

In some circumstances we may anonymise or pseudonymise the personal data so that it can no longer be associated with you, in which case we may use it without further notice to you.

If you refuse to provide us with certain information when requested, we may not be able to perform the contract we have entered into with you. Alternatively, we may be unable to comply with our legal or regulatory obligations.

We may also process your personal data without your knowledge or consent, in accordance with this notice, where we are legally required or permitted to do so.

Data retention

We will retain your personal data for as long as is necessary to fulfil the purposes for which it is collected, for example, while you remain an existing customer of our business or legitimate potential customer for our specialised products and services.

When assessing what retention period is appropriate for your personal data, we take into consideration:

• The requirements of our business and the goods or services provided;
• Any statutory or legal obligations;
• The purposes for which we originally collected the personal data;
• The lawful grounds on which we based our processing;
• The types of personal data we have collected;
• The amount and categories of your personal data; and,
• Whether the purpose of the processing could reasonably be fulfilled by other means.

However, we will not know the exact date when you may move to another company, or your company is merged with, or acquired by another company, or ceases trading.

Change of purpose

Where we need to use your personal data for another reason, other than for the purpose for which we collected it, we will only use your personal data where that reason is compatible with the original purpose.

Should it be necessary to use your personal data for a new purpose, we will notify you and communicate the legal basis which allows us to do so before starting any new processing.

6. DATA SHARING

Why might you share my personal data with third parties?

We will share your personal data with third parties where we are required by law, where it is necessary to administer the relationship between us, when obtaining product information or support from our suppliers on your behalf, when providing goods and/or services in accordance with your request, or where we have another legitimate interest in doing so.

We will not sell or pass on your personal data to any commercial or charitable organisation.

Which third-party service providers process my personal data?

"Third parties" includes our suppliers and third-party service providers. The following activities are carried out by third-party service providers: IT and cloud services, professional advisory services, marketing services and banking services.

All of our third-party service providers are required to take commercially reasonable and appropriate security measures to protect your personal data. We only share your personal data with our third-party service providers for a specified purpose, and in accordance with a reasonable business need.

What about other third parties?

We may need to share your personal data with a regulator or to otherwise comply with the law. We will not share your personal data with other third parties without your consent.

7. DATA SECURITY

We have put in place commercially reasonable and 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. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.

8. RIGHTS OF ACCESS, CORRECTION, ERASURE, AND RESTRICTION

Your duty to inform us of changes

It is important that the personal data we hold about you is accurate and current. Should your personal information change, please notify us of any changes of which we need to be made aware by contacting us, using the contact details below.

Your rights in connection with personal data

Under certain circumstances, by law you have the right to:

• Request access to your personal data. This enables you to receive details of the personal data we hold about you and to check that we are processing it lawfully.
• Request correction of the personal data that we hold about you.
• Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have exercised your right to object to processing (see below).
• Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this basis. You also have the right to object where we are processing your personal information for direct marketing purposes.
• Request the restriction of processing of your personal data. This enables you to ask us to suspend the processing of personal data about you, for example if you want us to establish its accuracy or the reason for processing it.
• Request the transfer of your personal data to you or another data controller if the processing is based on consent, carried out by automated means and this is technically feasible.

If you want to exercise any of the above rights, please email our data protection point of contact sales@phasix.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 for access is clearly unfounded or excessive. Alternatively, we may refuse to comply with the request in such circumstances.

We may need to request specific information from you to help us confirm your identity and ensure your right to access the information (or to exercise any of your other rights). This is another appropriate security measure to ensure that personal information is not disclosed to any person who has no right to receive it.

9. RIGHT TO WITHDRAW CONSENT

In the limited circumstances where you may have provided your consent to the collection, processing and transfer of your personal data for a specific purpose (for example, in relation to direct marketing that you have indicated you would like to receive from us), you have the right to withdraw your consent for that specific processing at any time. To withdraw your consent, please email our data protection point of contact sales@phasix.co.uk.

Once we have received notification that you have withdrawn your consent, we will no longer process your personal information (personal data) for the purpose or purposes you originally agreed to, unless we have another legitimate basis for doing so in law.

10. CHANGES TO THIS NOTICE

Any changes we may make to our privacy notice in the future will be updated on our website at https://phasix.co.uk/privacy-policy.

This privacy notice was last updated June 2019.

11. CONTACT US

If you have any questions regarding this notice or if you would like to speak to us about the manner in which we process your personal data, please email or write to:

Data Protection Point of Contact
Phasix ESD
Unit 17
Focus 303 Business Centre
Focus Way
Andover, Hampshire SP10 5NY

sales@phasix.co.uk

Telephone: +44 (0) 1264 361622

You also have the right to make a complaint to the Information Commissioner's Office (ICO), the UK supervisory authority for data protection issues, at any time. The ICO's contact details are as follows:

Information Commissioner's Office
Wycliffe House,
Water Lane,
Wilmslow,
Cheshire,
SK9 5AF

Telephone - 0303 123 1113 (local rate) or 01625 545 745