Privacy and Cookie Policy

This Privacy Notice (the “notice”) sets out how we, TI Fluid Systems plc, registered company number 09402231, 4650 Kingsgate Cascade Way, Oxford Business Park South, Oxford, Oxfordshire, OX4 2SU and our affiliates and associated offices (collectively “Group”, “we”, “us”, “our”) process the personal data of individuals (each a “User”, “you”, “your”) who contact us or who use our websites, services, programs, content and related features (collectively, the “Website”).

If you have any questions about this notice, please contact us by email.

This notice sets out our views and practices regarding your personal data and how we will treat it. Please read this document carefully. By visiting or using our Website, you acknowledge the processing described in this notice.

We will let you know, by posting on our Website or otherwise, if we make any changes to this notice from time to time. Your continued use of the Website after notifying such changes will amount to your acknowledgement of the amended notice.

This version of our privacy notice was published in May 2018.

What is personal data?

“Personal data” means any information relating to an identified or identifiable natural person, known as ‘data subject’, who can be identified directly or indirectly; it may include name, address, email address, phone number, IP address, location data, cookies, call recording and similar information. It may also include “special categories of personal data” such as racial or ethnic origin, political opinions, religious or philosophical beliefs, or trade union membership, and the processing of genetic data, biometric data for the purpose of uniquely identifying a data subject, data concerning health or data concerning a natural person’s sex life or sexual orientation.

What personal data do we process?

We may process the following personal data:

Information provided by you. You may give us information about you by filling in forms such as the contact form on our website, subscribing to services, ordering a product, making applications in respect of job postings, uploading information, corresponding with us by e-mail, phone or otherwise. This information may include your name, email address, billing address, shipping address, phone number, position and place of employment, payment information, the content of any email you send to us and similar information.

Information about others. You may also provide to us personal data relating to third parties, such as people who you work with, your job contacts for reference and other individuals.

Information about your device. With regard to each of your visits to our website we may collect technical information about your device such as IP address, operating system, browser, time zone setting, the Internet address of the website from which you linked directly to our website, URL clickstream data, page interaction information (such as scrolling, clicks, and mouse-overs), and methods used to browse away from the page.

Information from third party sources. This may include information received from credit reference agencies, shipping companies, our service providers and other third parties.

Generally, you are under no obligation to provide this information, but without it, we may be unable to provide you with some of our Website features or content. We may require credit reference agency information before entering into a service agreement with you. Some personal data will be mandatory in order for us to comply with mandatory client due diligence processes before we are able to provide the Website.

Information about third parties should only be provided if you have demonstrable permission to do so or if the information is available in the public domain.

We will rely on the information provided by you as accurate, complete and up to date and you agree to ensure that this will be the case.

How do we use your personal data?

We will only process personal data, in accordance with applicable law, for the following purposes:

1. responding to your queries, requests and other communications;
2. providing the Website and related features, subscriptions and other Website;
3. enabling suppliers and service providers to carry out certain functions on our behalf in order to provide the Website, including webhosting, data storage, identity verification, technical, logistical and other functions, as applicable;
4. allowing you to use features on our website, when you choose to do so;
5. serving personalised advertising to your devices, based on your interests in accordance with our Cookie Statement below. You have the right to disable cookies as set out below;
6. ensuring the security of our business and preventing and detecting fraud;
7. administering our business, including complaints resolution, troubleshooting of our website, data analysis, quality control, staff training, testing of new features, research, statistical and survey purposes;
8. developing and improving our Website, products and services;
9. administering investor relations; and
10. complying with applicable law, including in response to a lawful request from a court or regulatory body.

The legal basis for our processing of personal data for the purposes described above will typically include:

• processing necessary to fulfil a contract that we have in place with you or other data subjects, such as processing for the purposes set out in paragraphs (a), (b), (c) and (d);
• your consent, such as processing for the purposes set out in paragraph (e);
• processing necessary for our or a third party’s legitimate interests, such as processing for the purposes set out in paragraphs (a), (b), (c), (d), (f), (g) and (h), which is carried out on the basis of our legitimate interests to ensure that Website, products and services are properly provided, ensure the security of our business and our Users and for the proper administration of our business;
• processing necessary for compliance with a legal obligation to which we are subject, such as processing for the purposes set out in paragraph (j); and
• other applicable legal grounds.

Cookie Statement

What exactly are cookies? In order to collect the information including personal data as described in this Notice, we may use cookies and similar technology on our website. A cookie is a small piece of information which is sent to your browser and stored on your computer’s hard drive, mobile phone or other device. Cookies can be first party, i.e. cookies that the website you are visiting places on your device, or third party cookies, i.e. cookies placed on your device through the website but by third parties, such as, Google. For more information please visit www.allaboutcookies.org.

The cookies placed on our Website. For example, we may use the following cookies on our website:

• Strictly necessary cookies. These cookies are essential in order to enable you to move around our website and use its features. Without these cookies, the content you have asked for cannot be provided. They are deleted when you close the browser. These are first party cookies.
• Performance cookies. These cookies collect information in an anonymous form about how visitors use our website. They allow us to recognise and count the number of visitors and to see how visitors move around the website when they are using it and the approximate regions that they are visiting from. These are first party cookies. For example, this website uses Google Analytics to help analyse how Users use the website. The information generated by the cookie about your use of the website (including IP address) is transmitted to Google. This information is then used to evaluate Users’ use of the website and to compile statistical reports on website activity for the Group.
• Functionality cookies. These cookies allow our website to remember choices you make (such as your user name, language or the region you are in, if applicable) and provide enhanced, more personal features. The information these cookies collect may be anonymised and they cannot track your browsing activity on other websites. These are first party cookies.
• Social Media cookies. These cookies allow you to connect with social media networks such as Facebook, Twitter, LinkedIn and Google+. These are persistent cookies which will be kept on your device until their expiration or earlier manual deletion.
• Other cookies and similar technologies from time to time.

We may combine information from these types of cookies and technologies with information about you from other sources.

Cookie Audit:

Cookie	Type	Duration	Description
__utma	First Party	2 years from set/update	Used to distinguish users and sessions. The cookie is created when the javascript library executes and no existing __utma cookies exists. The cookie is updated every time data is sent to Google Analytics.
__utmt	First Party	10 minutes	Used to throttle request rate.
__utmb	First Party	30 mins from set/update	Used to determine new sessions/visits. The cookie is created when the javascript library executes and no existing __utmb cookies exists. The cookie is updated every time data is sent to Google Analytics.
__utmc	First Party	End of browser session	Not used in ga.js. Set for interoperability with urchin.js. Historically, this cookie operated in conjunction with the __utmb cookie to determine whether the user was in a new session/visit.
__utmz	First Party	6 months from set/update	Stores the traffic source or campaign that explains how the user reached your site. The cookie is created when the javascript library executes and is updated every time data is sent to Google Analytics.
__utmv	First Party	2 years from set/update	Used to store visitor-level custom variable data. This cookie is created when a developer uses the _setCustomVar method with a visitor level custom variable. This cookie was also used for the deprecated _setVar method. The cookie is updated every time data is sent to Google Analytics.

Cookie consent and opting out. By using our Website, we assume that you are happy for us to place cookies on your device. Most internet browsers automatically accept cookies. However, if you, or another user of your device, wish to withdraw your consent at any time, you have the ability to accept or decline cookies by modifying your browser setting. Learn how to disable cookies for your browser here. If you choose to decline cookies, you may not be able to fully experience the interactive features of our website, our platforms and Website.

If you are based in Europe, when you arrive on our website a pop-up message will appear asking for your consent to place advertising cookies on your device.  In order to provide your consent, please click ‘Accept’. Once your consent has been provided, this message will not appear again when you revisit.  If you, or another user of your device, wish to withdraw your consent at any time, you can do so by altering your browser settings.

You may also opt-out from third party cookies by selecting appropriate options on http://www.youronlinechoices.com/uk.

Disclosure of personal data

There are circumstances where we may wish to disclose or are compelled to disclose your personal data to third parties. These scenarios include disclosure to:

• our affiliates or associated offices;
• our suppliers and service providers to facilitate the provision of the Website, products and services including webhosting providers, identity verification partners (in order to verify your identity against public databases), analytics providers, consultants, for example, in order to protect the security or integrity of our business, including our databases and systems and for business continuity reasons;
• successor or partner legal entities, on a temporary or permanent basis, for the purposes of a joint venture, collaboration, financing, sale, merger, reorganisation, change of legal form, dissolution or similar event relating to our business. In the case of a merger or sale, your personal data will be permanently transferred to a successor company;
• public authorities where we are required by law to do so; and
• other third parties where you have provided your consent.

International transfer of your personal data

We may transfer your personal data to a third party in countries outside the country in which the personal data were originally collected for further processing in accordance with the purposes set out above. In particular, your personal data may be transferred across our group of companies to the US and other countries or to private organisations abroad such as our suppliers and service providers. Where this is the case, we will ensure that appropriate transfer mechanisms, such as standard contractual clauses, are in place to ensure an adequate level of data protection. You may contact us for a copy of such safeguards in these circumstances.

Retention of personal data

We retain personal data for as long as is necessary for the purposes listed above or longer as may be required by the law. Please contact us for further details of applicable retention periods.

We may keep an anonymized form of your personal data, which will no longer refer to you, for statistical purposes without time limits, to the extent that we have a legitimate and lawful interest in doing so.

Security of personal data

We will use appropriate technical and organisational information security measures to try to prevent unauthorised access to your personal data. However, please be aware that the transmission of information via the internet is never completely secure. Whilst we can do our best to keep our own systems secure, we cannot control the whole of the internet and we cannot therefore guarantee the security of your information as it is transmitted to and from our website.

Where you have created or received a password or verification link which enables you to access certain parts of our website or content, you are responsible for keeping such information confidential. We ask you not to share such information with anyone.

Data subject rights

Data subjects may ask us for a copy of their information, to correct it, erase it or to transfer it to other organisations at their request. Data subjects also have the right to object to some processing including profiling and, where we have asked for their consent to process the data subject’s data, to withdraw this consent. In particular, data subjects have the right to object to direct marketing at any time. Where a data subject withdraws their consent, this will not affect the legitimacy of the processing conducted prior to your request.  Where we process data because we have a legitimate interest in doing so (as explained above), the data subject has a right to object to this.

Please email us for further information. We will aim to acknowledge your enquiries within 72 hours and respond within one month, unless otherwise required by law. Please note that these rights may be limited in some situations, for example, where we can demonstrate that we have a compelling ground or are required by law to process your data.

We hope that we can satisfy queries you may have about the way we process your data. However, if you have unresolved concerns you also have the right to complain to the relevant data protection authority.

Third party sites

Third party policies for related Websites, if available, and offerings linked to or from this website have their own privacy statements that can be viewed by clicking on the corresponding links within each respective website. Since we do not have control over the policies or practices of participating merchants and other third parties, we are not responsible for the privacy practices or contents of those sites. We recommend you review their policies before you provide any personal data or complete any transaction with them.