Privacy Policy

Who we are?

Complete Refreshment Solutions Ltd is an independent vending operator and supplier of all types of free standing, desktop, snack and can/bottle vending machines. Our contact number 01527 388230. The data controller at Complete Refreshment Solutions is Jackie Carrington and is available on the main contact number.

What information do we collect?

Here at Complete Refreshment Solutions we take privacy very seriously and we only take the personal data from you that require in order to fulfil contractual agreements. The types of information we collect are names, addresses, email addresses and phone numbers. We collect this data directly from the customer when they confirm that they wish to do business with Complete Vending Services, whether this is by supply of machine, wholesale products and or service cover. We collect the data directly from the data subjects. Most customers complete a Service Level Agreement in which they agree for us to hold this data to fulfil the terms of the contract, those that chose not to sign a Service Contract are asked to consent to Complete Refreshment Solutions holding this data. The only data provided to third party companies is names, addresses and telephone numbers when we are asked to cover a service call or filter change on a subcontracting basis.

We do not hold bank details for customers or other sensitive data or financial information. We hold financial details of suppliers in order to make required payments. This information is stored on our secure banking system and our secure accounting software.

How do we use personal information?

• personalisation of content, business information or user experience
• account set up and administration
• delivering marketing communications
• Sending marketing communications
• providing customer service communication
• carrying out surveys • internal research and development purposes
• providing goods and services • legal obligations (eg prevention of fraud)
• meeting internal audit requirements

Spam

We never send bulk unsolicited emails (Spam) to email addresses. All emails sent by us will be clearly marked as originating from us.

What legal basis do we have for processing your personal data?

The legal processing of your personal data described in this policy is based on your consent or on the contractual necessity (which means that the processing of your Personal Data is required for Complete Refreshment Solutions to provide services to you). Legitimate interests, to provide existing clients with relevant and beneficial announcements regarding a service we provide e.g industry-wide notices such as changes to currency used with our machines. This requires us to process clients’ email address only and so has minimal privacy impact.

When do we share personal data?

We always treat personal data confidentially and we only share or disclose personal data in order to fulfil our contractual obligations and in order to provide a service that the customer – for example requesting a third party contractor or machine manufacturer to attend a service call on behalf on Complete Refreshment Solutions. In these circumstances we share your data directly with the service coordinator via email to that individual who will then in turn only share the data with the engineer attending site. We have a data processing agreement in place with those companies that we use for subcontracting purposes to safeguard your data. If we need to share data with any other companies we will contact you by email to gain your consent.

Where do we store and process personal data?

We store and process your data onsite at Complete Refreshment Solutions Head Office, all data is stored on a secured file server on our network, on our secured service call logging, order processing and accounts software and in address books & email (on local computers). We do not store process data out of the country.

How do we secure personal data?

To ensure our data security we work to ensure the following measures are in place:
• to protect data against accidental loss
• to prevent unauthorised access, use, destruction or disclosure
• to ensure business continuity and disaster recovery
• to restrict access to personal information
• to conduct privacy impact assessments
• to train staff on data security
• to manage third party risks, through use of contracts and agreements

How long do we keep your personal data for?

We keep personal data for customers and suppliers for the duration of the contract with us and 6 years following this for tax purposes. After this point the details will be removed from our system and destroyed.

Information kept for marketing communication will be held until you notify us that that you no longer wish to receive this information.

Your rights in relation to personal data

If at any point you believe retained information is incorrect you can request to see this information and have it corrected or possibly deleted. Providing you with this information will not cost anything but charges may be applied if requests become excessive.

If you wish to raise a complaint on how we have handled your personal data you can contact us at info@completerefreshmentsolutions.co.uk and jackie@completerefreshmentsolutions.co.uk and the team will investigate this matter.

You have the right to withdraw consent at any time and this means that we cannot process your data provided without consent. If you are not satisfied with our response or believe we are processing your personal data not in accordance with the law you can complain to the information commission’s office.

You can contact Data protection officer at jackie@completerefreshmentsolutions.co.uk

Use of cookies and other technologies

You can find further details of our Cookie Policy at www.completerefreshmentsolutions.co.uk