Wall Colmonoy respects your privacy and is committed to protecting your personal data. This privacy notice will inform you as to how we look after your personal data when you visit our website and tell you about your privacy rights and how the law protects you. We are an international group, with valued customers based all over the world. Laws relating to data protection and privacy vary between country to country, and for those of our customers based in the EU, clause 7 of this privacy notice sets out how we comply with the EU privacy laws.
This privacy notice aims to give you information on how Wall Colmonoy collects and processes your personal data through your use of this website, including any data you may provide through this website when you sign up to our newsletter or purchase a product or service.
This website is not intended for children and we do not knowingly collect data relating to children.
It is important that you read this privacy notice together with any other privacy notice or fair processing notice we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. This privacy notice supplements the other notices and is not intended to override them.
The Wall Colmonoy Group is made up of two different legal entities: Wall Colmonoy Corporation is a US company with its headquarters at 101 W. Girard, Madison Heights, MI 48071 and Wall Colmonoy Limited is a company incorporated in England and Wales with its registered office at Alloy Industrial Estate, Pontardawe, Swansea, SA8 4HL.
For customers accessing our website or purchasing goods or services within the European Union (“EU”), the data controller will usually be Wall Colmonoy Limited. When you buy goods or services from us, we will confirm in our documentation which member of our group you are contracting with, which will be the data controller. Both Wall Colmonoy Corporation and Wall Colmony Limited jointly control and monitor our website.
If you have any questions about this privacy notice, including any requests to exercise your legal rights, please contact the relevant company in our group at the address shown below.
Our full details are:
Wall Colmonoy Corporation (USA Headquarters)
Email address: email@example.com
Postal address: 101 W. Girard, Madison Heights, MI 48071
Telephone number: +1 248-585-6400
Wall Colmonoy Limited (UK Registered Office)
Email address: firstname.lastname@example.org
Postal address: Alloy Industrial Estate, Pontardawe, Swansea, SA8 4HL
Telephone number: +44 (0) 1792 862287
If you have any queries or concerns about how we use your information, you have the right to complain to us.
If you are based in the EU, you have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK supervisory authority 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.
Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).
We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:
We do not collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data). Nor do we collect any information about criminal convictions and offences.
We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data may be derived from your personal data but is not considered personal data in law as this data does not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy notice.
If you fail to provide personal data
Where we need to collect personal data by law, or under the terms of a contract we have with you and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with goods or services). In this case, we may have to cancel a product or service you have with us but we will notify you if this is the case at the time.
We use different methods to collect data from and about you including through:
We will only use your personal data when the law allows us to. Most commonly, we will use your personal data for the purposes of fulfilling our contractual obligations to you, in relation to marketing and where we need to comply with a legal or regulatory obligation.
If you are based in the EU, we have set out some further detail about when we will use your personal data, and specifically when we consider it is within our legitimate interests to use it, in clause 7.
We may have to share your personal data with the parties set out below from time to time.
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.
If you are based in the EU, please see clause D which sets out specific provisions relating to the transfer of your information outside of the European Economic Area (“EEA”).
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.
We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.
How long will you use my personal data for?
We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.
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 requirements.
By law we have to keep basic information about our customers (including Contact, Identity, Financial and Transaction Data) for a certain period of time (usually for 5 years) after they cease being customers for tax purposes.
In some circumstances we may 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.
If you are in the EU, there are some circumstances in which you can ask us to delete your data, which are set out in clause 7 below.
If the EU privacy laws apply to you, this clause 4 sets out how we will comply with those laws. These clauses complement the additional information set out elsewhere in this privacy notice.
We will comply with the EU data protection law. This says that the personal information we hold about you must be:
Clause 3 of this policy (above) sets out the common ways in which we will use your data. We will also use your data where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests. These are set out in the table below under “Purposes for which we will use your personal data”.
Generally we do not rely on consent as a legal basis for processing your personal data other than in relation to sending third party direct marketing communications to you via email or text message. You have the right to withdraw consent to marketing at any time by contacting us.
We have set out below, in a table format, a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.
Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below.
The following terms are used in the table below:
Type of data
Lawful basis for processing including basis of legitimate interest
|To register you as a new customer||
|Performance of a contract with you|
To process and deliver your order including:
(a) Manage payments, fees and charges
(b) Collect and recover money owed to us
(e) Marketing and Communications
(a) Performance of a contract with you
(b) Necessary for our legitimate interests (to recover debts due to us)
To manage our relationship with you which will include:
(b) Asking you to leave a review or take a survey
(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 to study how customers use our products/services)
|To administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)||
(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
|To deliver relevant website content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you||
(e) Marketing and Communications
|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)|
|To use data analytics to improve products/services, marketing, customer relationships and experiences including sharing your data with third parties for marketing purposes||
|Necessary for our legitimate interests (to define types of customers for our products and services, to develop our business and to inform our marketing strategy)|
|To make suggestions and recommendations to you about goods or services that may be of interest to you. Again, this may involve sharing your data with third parties.||
|Necessary for our legitimate interests (to develop our products/services and grow our business)|
We may use your Identity, Contact, Usage and Profile Data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which products, services and offers may be relevant for you (we call this marketing).
You will receive marketing communications from us if you have requested information from us or purchased goods or services from us and, in each case, you have not opted out of receiving that marketing.
We will get your express opt-in consent before we share your personal data with any company outside the Wall Colmonoy Group for marketing purposes.
You can ask us or third parties to stop sending you marketing messages at any time by following the unsubscribe instructions at the bottom of our marketing emails, replying to “contact” by direct email or by writing to us at our UK registered office or USA Headquarters.
Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of a product/service purchase, warranty registration, product/service experience or other transactions.
We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.
If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.
Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.
We share your personal data within the Wall Colmonoy Group in the United States. This will involve transferring your data outside the European Economic Area (EEA).
Whenever we transfer your personal data out of the EEA, we ensure a similar degree of protection is afforded to it by ensuring that appropriate safeguards are implemented:
Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the EEA.
Under certain circumstances, you have rights under data protection laws in relation to your personal data.
You have the right to:
If you wish to exercise any of the rights set out above, please contact us using the contact details set out above.
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 may refuse to comply with your request in these circumstances.
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.
We try to respond to all legitimate requests within one month. Occasionally it may 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.