Privacy policy for personal data and surveys

The protection of your personal data is important to us. The following document provides you with information about how we handle and protect your personal data.

I. Important information about data protection at the MEWA group of companies (customers)

The following document provides important information about how the companies of the MEWA group of companies (MEWA) located in Germany and across Europe process your personal data. The corporate purpose of MEWA is the development, preparation and care of reusable textile systems. MEWA also provides services in the textile service field for companies in manufacturing, business, handicrafts, trade and the catering business.

We, as the MEWA company, the contractual partner of your company (hereinafter referred to as we, us or our), hereby provide the following essential and further information on data processing (Privacy Policy) in order to give you an overview of our procedures regarding the collection, storage, use, disclosure or deletion (hereinafter referred to collectively as process or processing) of any kind of personal information about you (e.g. name or contact information; hereinafter referred to collectively as personal data) within the framework of our customer relationship. Further information about data protection is outlined below in Section II. 

1. Information about the data controller and contact information of data protection officer

We, as the contractual partner of your company, are the data controller in charge of processing your personal data. Our contact details can be found on the respective contract documents and also on our business correspondence (e.g. letters, emails, etc.). You can contact our data protection officer by addressing mail to the following postal address: MEWA UK Textile Services Limited, Data Protection Officer, Unit 44 Elmdon Trading Estate, Bickenhill Lane, Birmingham, B37 7HE, or by email at data.protection@mewa.co.uk.

2. Type and provenance of the personal data we process

Our clients are businesses. As a result, the personal data we process about you includes your business address and contact details, as they are required to process the customer relationship with your company. We generally receive all personal data which we process directly from you. In some cases, however, third parties also provide us with such data, for example, data which was provided to your employer or collected from publicly available sources. Detailed information about this topic can be found below in Section II.1.

3. Purposes of processing and legal bases

We process your personal data for the following purposes:

To execute and fulfil contracts concluded with our corporate customers; to implement measures for the improvement of our products/services and for strengthening our customer relationship; to carry out surveys, for example, for market research or customer satisfaction (customer feedback); for customer retention/direct marketing, providing that you have not objected to the processing of your personal data for this purpose.

In general, we apply the following legal bases:
Processing is necessary for (i) the protection of a legitimate interest (Art. 6 (1) (f) General Data Protection Regulation, GDPR; ‘Protection of the legitimate interest’), (ii) compliance with a legal obligation (Art. 6 (1) (c) GDPR ‘Compliance with a legal obligation’) or, (iii) is carried out in individual cases based on consent (Art. 6 (1) (a) GDPR; ‘Consent’). Detailed information about this topic can be found below in Section II.2 and Section II.3. 

4. Recipients of your data and legal bases

We transfer your personal data to other MEWA companies and third parties as well as our service providers. In accorance with currently valid legal provisions, we transfer data to government authorities, courts, external consultants and similar third parties. Some of the aforementioned recipients are located in countries outside the European Union (EU). Detailed information about this topic can be found below in Section II.4 and Section II.5.

5. Storage and retention periods

Your personal data shall be deleted as soon as it is no longer necessary to achieve the purpose for which it was originally collected, or if deletion is necessary in accordance with applicable legal provisions. Data shall also be deleted if this is necessary pursuant to applicable legal provisions. Detailed information about this topic can be found below in Section II.6.

6. Your legal rights

Pursuant to applicable law, you have certain rights with regard to the processing of your personal data. These apply in accordance with the applicable legal provisions. You have, for example, the right of access to your data, as well as the right to have data rectified, erased or handed over to you. Detailed information about this topic can be found below in Section II.7.

7. Service and contact

For all enquiries, our Customer Service can be contacted at any time using the regular contact options available. Would you like to exercise your rights as a data subject? Or do you have any other questions regarding this information? Simply contact the MEWA company that is your company’s contractual partner. The contact details can be found on the respective contract documents and also on our business correspondence (e.g. letters, emails, etc.).  

II. Further Privacy Policy information for MEWA customers

1. Type and provenance of the personal data we process

We process personal data in the context of business relationships with legal entities. Personal data processed by us includes:

  • your business addresses and contact information such as name, address, telephone number, email address, function and department as the contact for our clients, your employer, etc;
  • data, which we need for correct invoicing, such as bank details, tax reference numbers, etc. (provided this is related to the data of a legal entity). 

We generally receive all personal data which we process directlyfrom our customer relationships. Sometimes we alsoreceive personal data from other MEWA companies, for example, when several MEWA companies are involved in looking after a customer. We also process personal data which we have received by other means in compliance with the respectively applicable data protection laws, for example, from publicly accessible sources, such as business and company registers, trade fairs, exhibitions, Internet sources, newspapers and classified directories, etc; from third parties not affiliated with MEWA, for example, business/trade associations, credit agencies, insurance companies,
etc.

2. Purposes of processing and legal bases

We process your personal data previously described in Section II.1 on the basis of the respective legal bases. This applies to the purposes set forth below, and described in detail, and to carry out surveys (see Section II.3).

Processing purpose
Art. 6 (f) GDPR
Pursual of our legitimate interests, for example:

  • Execution and fulfilment of contracts concluded with our corporate customers;
  • Implementation of measures for the improvement of our products/services and for strengthening our customer relationship, such as market research measures or customer satisfaction surveys (customer feedback);
  • Customer retention/direct marketing by telephone or post, providing that you have not objected to the processing of your personal data for this purpose;
  • Internal administrative purposes, for example, coordinating the provision of services to our customers, measures to ensure IT security and IT operations;
  • Anonymisation and pseudonymisation of personal data in connection with the analysis and evaluation of key figures of the services provided by us or other MEWA companies;
  • Consultation and exchange of data with credit agencies (e.g. SCHUFA, IHD) to determine creditworthiness and default risks.

Art. 6 (1) (c) GDPR 
Compliance with our legal obligations, for example:

  • In connection with communicating certain tax-relevant information or applicable legal sanctions;
  • To comply with commercial, tax or other legal requirements for the retention/storage of certain personal data.

Art. 6 (1) (a) GDPR
For specific purposes to which you have given consent, for example,

  • Distribution of advertising/electronic newsletters;
  • Invitation to participate in surveys and the execution of surveys.   

Should we process your personal data at some stage for any other purpose than originally intended, we shall inform you about such new purpose to the extent to which we are legally permitted. You may withdraw a consent granted to us at any time. However, please be aware that data processing remains permissible up until the time that the consent is withdrawn.

3. Execution of surveys

We also process personal data for the purpose of improving MEWA products/services and strengthening our customer relationships. The processing of personal data in connection with surveys is carried out based in accordance with Art. 6 (1) (a) or Art. 6 (1) (f) GDPR.

3.1 Invitation to participate in surveys:

To address potential participants by email or telephone, we process (as far as is necessary) information such as your name and/or your business contact details (address, email, telephone). In addressing you, we will only do so in compliance with the legal requirements for existing customer advertising or based on the consent you have given us. You may contact data.protection@mewa.co.uk at any time to object to the use of your contact information with effect for the future. You will not incur any costs other than the transmission costs according to basic rates (see Section II 7.6Exercising your right to object). You may also withdraw your consent (see Section II.2).

3.2 Data-efficient implementation:

We or our commissioned service providers, ensure that we collect as little personal data as possible, or none at all, in our surveys. After all, we want to receive open and honest feedback. In specific cases, we expressly carry out personal surveys or, at your request, create an explicit personal reference. For example, we conduct personal feedback interviews to ensure your satisfaction with our services following a customer/sales contact. That way we can take any adjustment or implementation requests into consideration for the future. The survey results, in particular on market research, are presented to us in an aggregated form so that we have no direct way of analysing these results on a personrelated basis. 

3.3 Online surveys:

With online surveys, the technical access data transmitted by your browser will be automatically stored. This data includes, for example, the name of your Internet service provider, the date and time of your access to the survey tool and/or the recognition data of the browser/operating system used. The web server will also necessarily store your IP address. The access data is not combined with your survey results or other data sources and this data is not evaluated or transmitted to us as the client. Storage of access data is necessary for technical reasons in order to provide a functioning online survey process and to ensure system security for technical reasons. The data is retained only for the period in which this data is needed to achieve the aforementioned purposes. In this case, your IP address will be stored for a maximum of 7 days. You will be informed about any further technically relevant data processing (e.g. the activation of cookies) as part of the online surveys by our partners separately.

3.4 Data processing by our partners:

If you email, use the contact form, or call our partners who conducted the surveys, for example, to ask questions about the survey process, or if you voluntarily provide further (personal) data (e.g. for participation in contests), the information you provide will only be processed by our partners for these purposes and in accordance with their respective privacy notices. This data is kept strictly separate from information provided within the scope of the respective survey. Even in such cases, no further (if necessary, personal) data will be transmitted to us as the client, unless you expressly request this.

4. Recipients of your data and legal bases

We disclose personal data to other MEWA companies, third parties and service providers.

4.1 Other MEWA companies:

Access to personal data shall only be granted to other MEWA companies in accordance with the requirements of Art. 6 Para. 1 (c), (f) GDPR if and insofar as this is necessary to fulfil certain legal obligations or to protect legitimate interests. This may be the case, for example, when the data is required for internal administrative purposes. This includes the coordinating of services for our customers, the centralised provision of internal services or the (anonymised/pseudonymised) evaluation of corporate key figures.

4.2 Third parties:

We only disclose personal data to other third parties outside MEWA, such as customs authorities, tax authorities or other supervisory authorities, in accordance with Art. 6 Para. 1 (c),
(f) GDPR, if and insofar as this is necessary for the fulfilment of certain legal obligations or to protect legitimate interests. In all other cases, we will only send your personal data to other third parties if you have given us a corresponding approval to do so in accordance with Art. 6 (1) (a) GDPR. 

4.3 Service providers (internal and external):

In the course of executing our business relationship with your company, we also work with external and/or internal service providers (other MEWA companies). This is the case, for example, in relation to certain IT services, with regard to sending advertising or in connection with the implementation of our customer surveys. These service providers will always be required to carry out this work out within the limits of and subject to complying with the respectively applicable data protection regulations.

5. Transfer to third countries or international organisations

Recipients of personal data may also include recipients located outside your country, in particular outside the European Economic Area (EEA). This can also be a country for which the European Commission has not yet made an adequacy decision on whether this country ensures an adequate level of data protection (third countries), for example, the USA. In this case, we determine by appropriate means that all recipients based outside the EEA ensure an adequate level of data protection (Art. 45 GDPR) for the personal data and that technical and organisational security measures are taken to prevent personal data from being accidentally deleted or to protect against unlawful destruction, accidental loss or modification, unauthorised disclosure or access and against all other unlawful forms of processing. The appropriate means that we use can be accessed via the contact details specified in Section II.8. Pursuant to the applicable legal provisions, onward transfers of personal data are subject to the necessary appropriate requirements regarding onward transfers.

6. Storage and retention periods

We retain personal data only for as long as is necessary to fulfil the respective processing purpose(s). As soon as personal data is no longer required, we shall erase personal data from our systems and records and/or take measures to anonymise personal data so that it can no longer be used to identify you. In order to comply with legal requirements, however, we must keep or save certain personal data for a specific time. Such data includes, for example, documentation, certification and retention obligations of the national trade and taxation law. For example, the storage and retention periods relevant for us are generally three to ten years or, in exceptional cases, up to 30 years pursuant to the law applicable in Germany.

7. Your legal rights

Under the terms established by applicable law (e.g. GDPR, the German Federal Data Protection Act, BDSG, and the Data Protection Act 2018), you have the following rights: 

7.1 Right of access:

You have the right to obtain information about whether or not your personal data is being processed. Where this is the case, you have the right to be provided with information about personal data, for example, the purposes of the processing, the categories of personal data concerned, and the recipients or categories of recipient to whom the personal data has been or will be disclosed. You have the right to receive a copy of the personal data undergoing processing. For any further copies which you request, we may charge a reasonable fee based on administrative costs.

7.2 Right to rectification:

You have the right to request that we rectify inaccurate personal data concerning ,you. Taking into account the purposes of the processing, you shall have the right to have incomplete personal data completed, including by means of providing a supplementary statement.

7.3 Right to erasure (Right to be forgotten):

You have the right to request that we delete your personal data in certain circumstances.

7.4 Right to restriction of processing:

You also have the right to demand the restriction of processing of your personal data in certain circumstances. In this case, the corresponding data will be marked and may only be processed by us for certain purposes.

7.5 Right to data portability:

You have the right to receive your personal data, which you have provided to us, in a structured, commonly used and machine-readable format. Where technically possible you have the right to transmit such personal data to another controller without us interfering.

7.6 Right to object:

You have the right to object, on grounds relating to your particular situation, at any time to processing of your personal data. Where appropriate, we must stop processing your personal
data. If you exercise your right to object, we will no longer process your personal data for such purposes. There are no costs for exercising this right. Such a right of objection may not exist, in particular if the processing of your personal data is necessary in order to take measures before concluding a contract or to fulfil an already concluded contract.

In the event of any complaints, you also have the right to lodge a complaint with the supervisory authority responsible for the data controller.

8. Contact data and changes to the Privacy Policy

Our Customer Service is always available to answer your questions. Should you wish to exercise your rights as a data subject or have any other questions regarding this information, please contact the MEWA company that is your company’s contractual partner. The contact details can be found on the respective contract documents and also on our business correspondence (e.g. letters, emails, etc.).

This Privacy Policy is subject to change. You shall be provided with adequate information of any such changes.