Privacy Policy
AGA Site Safety Hub
1. Important information about the hub and aga
THE HUB
This privacy policy (“Policy”) relates to the subscription service known as the AGA Site Safety Hub (“Hub”).
The Hub includes the following elements:
- a website accessed at https://www.aga-ltd.co.uk/ ; and
- the following apps (“Apps”):
o an app available through the Apple App Store at https://apps.apple.com/gb/app/site-safety-hub/id6475165758
o an app available through the Google Play Store at https://play.google.com/store/apps/details?id=com.infoanyware.agahs&gl=GB
The Hub is made available by Andrew Goddard Associates Ltd registered in England and Wales with company number 04576753 and with registered address at Samuel House, Chinnor Road, Thame, Oxfordshire OX9 3NU (referred to as "AGA” "we", "us" or "our" in this Policy).
It is made available to the person/firm who subscribes for access to the Hub (“Subscriber”) under a contract incorporating AGA’s subscription service AGA - Terms and Conditions v1.0 (Apr 2024).docx
(“Subscription Agreement”).
RELEVANT PROJECTS
The Hub has been designed to support health and safety efforts in relation to construction projects.
This Policy applies to you where the Subscriber has chosen to use the Hub in relation to a construction project in respect of which you are involved (“Project”).
PRIVACY POLICY
This Policy gives you information about how your personal data is collected through the Hub in relation to a Project and how it is used.
Where you are an “Authorised User” of the Hub, this shall include any data you may provide when you sign up (or our Subscriber signs you up) to become an “Authorised User” on the Hub.
The CONTROLLER of your data
The Subscriber is the “controller” and is responsible for your personal data.
That means the Subscriber determines the purposes and means of processing of your personal data (i.e. it decides the “how and why” of any use of your personal data).
AGA has been contracted by the Subscriber to make available the Hub to support the Project and the business activities of the Subscriber.
Where your personal data is collected through the Hub, we act as a data processor of the Subscriber. That means that we process your personal data on behalf of the Subscriber, solely in the manner agreed with the Subscriber.
2. The types of personal data THE HUB collectS about you
2.1. Personal data means any information about an individual from which that person can be identified.
2.2. The Hub may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:
Identity Data
includes first name, last name, any previous names, username or similar identifier, marital status, title, date of birth and gender.
Contact Data
includes billing address, delivery address, email address and telephone numbers.
Technical Data
includes [internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, device ID and other technology on the devices you use to access the Hub.
Profile Data
includes [your username and password, purchases or orders made by you, your interests, preferences, feedback and survey responses
Usage Data
includes information about how you interact with and use the Hub, products and services.
Marketing and Communications Data
includes your preferences in receiving marketing from us and our third parties and your communication preferences.
2.3. AGA also collects, uses and shares aggregated data such as statistical or demographic data which is not personal data as it does not directly (or indirectly) reveal your identity. For example, AGA may aggregate individuals' Usage Data to calculate the percentage of users accessing a specific feature of the Hub in order to analyse general trends in how users are interacting with the Hub to help improve the user experience and the subscription services AGA offers to its customers.
3. How is your personal data collected?
3.1. The Hub collects data from and about you using various methods, including through:
Supply of data from the Subscriber
Subscribers will provide information via the forms provided in the AGA Site Safety Hub
Data entry by an Authorised User
AGA operatives will use the data provided to populate the AGA Site Safety Hub
Technical data
Technical Data is collected from the following parties:
- analytics providers;
As you interact with the Hub, we will automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies, server logs and other similar technologies. Please see our cookie policy AGA - Cookie Policy v0.1 (Apr 2024) 11.04.24.docx for further details.
4. LEGAL BASIS
4.1. The law requires the Subscriber (as the data controller) to have a legal basis for collecting and using your personal data.
4.2. For details relating to this, please refer to the Subscriber’s privacy policy.
5. Purposes for which your personal data WILL BE USED
5.1. Please refer to the Subscriber’s privacy policy for details of the Subscriber’s use of your personal data.
5.2. In addition we have set out below, in a table format, a description of all the ways we will use the various categories of your personal data, and which of the legal bases we rely on to do so.
5.3. We have also identified what our legitimate interests are where appropriate.
Purpose/Use
Type of data
Legal basis and retention period
To register you as a new Authorised User.
(a) Identity
(b) Contact
Performance of a contract with you
This data will be retained for 30 days post project completion.
To process and deliver your order including:
(a) Manage payments, fees and charges
(b) Collect and recover money owed to us
(a) Identity
(b) Contact
(c) Financial
(d) Transaction
(e) Marketing and Communications
(a) Performance of a contract with you
(b) Necessary for our legitimate interests (to recover debts due to us)
This data will be retained for 30 days post project completion.
To manage our relationship with you which will include:
(a) Notifying you about changes to our terms or privacy policy
(b) Dealing with your requests, complaints and queries
(a) Identity
(b) Contact
(c) Profile
(d) Marketing and Communications
(a) Performance of a contract with you
(b) Necessary to comply with a legal obligation
(c) Necessary for our legitimate interests (to keep our records updated and manage our relationship with you
This data will be retained for 30 days post project completion.
To administer and protect our business and the Hub (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)
(a) Identity
(b) Contact
(c) Technical
(a) Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise)
(b) Necessary to comply with a legal obligation
This data will be retained for 30 days post project completion.
To deliver relevant website content and online advertisements to you and measure or understand the effectiveness of the advertising we serve to you
(a) Identity
(b) Contact
(c) Profile
(d) Usage
(e) Marketing and Communications
(f) Technical
Necessary for our legitimate interests (to study how customers use our products/services, to develop them, to grow our business and to inform our marketing strategy)
This data will be retained for 30 days post project completion.
To use data analytics to improve the Hub, products/services, customer relationships and experiences and to measure the effectiveness of our communications and marketing
(a) Technical
(b) Usage
Necessary for our legitimate interests (to define types of customers for our products and services, to keep the Hub updated and relevant, to develop our business and to inform our marketing strategy)
This data will be retained for 30 days post project completion.
To send you relevant marketing communications and make personalised suggestions and recommendations to you about goods or services that may be of interest to you based on your Profile Data
(a) Identity
(b) Contact
(c) Technical
(d) Usage
(e) Profile
(f) Marketing and Communications
Necessary for our legitimate interests (to carry out direct marketing, develop our products/services and grow our business) OR Consent, having obtained your prior consent to receiving direct marketing communications
This data will be retained for 30 days post project completion.
To carry out market research through your voluntary participation in surveys
Necessary for our legitimate interests (to study how customers use our products/services and to help us improve and develop our products and services).
This data will be retained for 30 days post project completion.
6. Cookies
For more information about the cookies used within the Hub and how to change your cookie preferences, please see AGA - Cookie Policy v0.1 (Apr 2024) 11.04.24.docx
7. Disclosures of your personal data
7.1. Please refer to the Subscriber’s privacy policy for details of the Subscriber’s disclosures of your personal data.
7.2. We may share your personal data where necessary with the parties set out below.
Purpose
Third parties to whom we may choose to sell, transfer or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this Policy.
7.3. We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.
7.4. AGA does not transfer your personal data outside the UK.
8. Data security
8.1. Please refer to the Subscriber’s privacy policy for details of the Subscriber’s disclosures of your personal data.
8.2. Regarding the Hub: We have put in place 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.
9. Data retention
How long will you use my personal data for?
We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.
To determine the appropriate retention period for personal data, we consider the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements.
By law we have to keep basic information about our customers (including Contact, Identity, Financial and Transaction Data) for six years after they cease being customers for tax purposes.
In some circumstances you can ask us to delete your data, see paragraph 10 below for further information.
In some circumstances we will anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes, in which case we may use this information indefinitely without further notice to you.
10. Your legal rights
10.1. You have a number of rights under data protection laws in relation to your personal data.
10.2. You have the right to:
10.2.1. Request access to your personal data (commonly known as a "subject access request"). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
10.2.2. Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
10.2.3. Request erasure of your personal data in certain circumstances. 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 successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
10.2.4. Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) as the legal basis for that particular use of your data (including carrying out profiling based on our legitimate interests). In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your right to object.
10.2.5. You also have the absolute right to object any time to the processing of your personal data for direct marketing purposes.
10.2.6. Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
10.2.7. [Withdraw consent at any time where we are relying on consent to process your personal data (see the table in section 4 for details of when we rely on your consent as the legal basis for using your data). However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent].
10.2.8. Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in one of the following scenarios:
10.2.8.1. If you want us to establish the data's accuracy;
10.2.8.2. Where our use of the data is unlawful but you do not want us to erase it;
10.2.8.3. Where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or
10.2.8.4. You have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
If you wish to exercise any of the rights set out above, please contact us (see Contact details (paragraph 11)).
No fee usually required
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 is clearly unfounded, repetitive or excessive. Alternatively, we could refuse to comply with your request in these circumstances.
What we may need from you
We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.
Time limit to respond
We try to respond to all legitimate requests within one month. Occasionally it could take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.
11. Contact details
If you have any questions about this Policy or about the use of your personal data or you want to exercise your privacy rights, please contact AGA in the following ways:
Method
Address
Email address
info@aga-ltd.co.uk
Postal address
Data Protection
Samuel House
Chinnor Road
Thame
Oxfordshire
OX9 3NU
If you have any questions about the Subscriber’s privacy policy, please contact the Subscriber.
12. Complaints
You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK regulator for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.
13. Changes to this Policy and your duty to inform us of changes
We keep our Policy under regular review. This version was last updated on 10th July 2024.
It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us, for example a new address or email address.
14. Third-party links
The Hub may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave the Hub, we encourage you to read the privacy policy of every website you visit.