Privacy Policy

1. PREAMBLE AND PURPOSE

SFA Saniflo UK Ltd ("we","us","our"), as data controller, develops a website accessible at www.sfasaniflo.co.uk (the "Site"). As such, we process, the personal data of users of the Site ("Data Subjects" or"Users"), in compliance with the applicable regulations, i.e. to date, Regulation No. 2016/679 (EU) of April 27, 2016 known as the General Data Protection Regulation ("GDPR"), and the applicable local data protection act (together, the"Applicable Regulations").

As such, the purpose of this privacy policy is to inform you about the processing of your personal data that we implement in the context of the use of the Site, and about your rights in this respect.

2. DEFINITIONS

Terms beginning with a capital letter are either defined herein or have the meaning given to them by the applicable Regulations, and in particular the GDPR, such as in particular the terms "Personal Data or Data", "Processing", "Data Subjects", "Data Controller", "Data Processor", "Recipient" or "Data Breach".

3. PROCESSING CHARACTERISTICS

The Processing activities that we carry out regarding your Data are presented in the following tables.

3.1 Forms on the Site

3.2 Newsletter

3.3 Other purposes

4. USE OF COOKIES

To ensure the proper functioning of the Site, Users are informed that we use: 
- technical cookies, which are necessary for the proper operation of the Site and do not require your prior consent, 
- statistical and audience measurement cookies, which enable us to measure the number of visitors to the Site, and which require your prior consent.

Data resulting from the use of cookies on our Site is kept for a period of 25 months, for the sole purpose of measuring the Site's audience and to be used to produce anonymous statistical data only and is intended for our authorized personnel or Data Processors and partners on the basis of your consent.

The Data concerned are as follows: 
- Internet browser cookie data: cookie identifiers, time/date, chosen services/products, consent, and types of approved cookies;
- Device data: device type, screen resolution, operating system version, browser rendering engine, its version, and basic settings;
- Log data: time and duration of Site usage and search data;
- Location data: data related to your access country as indicated by your device;
- Behavioral data: data related to your use of the Site that we may process if you visit or use third-party sites or applications to cooperate with us, and data related to how you interact with the Site content (such as pages visited, if you come from a marketing campaign, clicks on buttons, etc.).

The recipients of your Data from cookies are the following:
- our authorized personnel;
- our third-party service providers, business partners, group companies and other third parties, acting as data processors on our behalf; 
- other companies, acting as separate Data Controllers.

For further information on the use of cookies, please refer to our Cookies policy.

5. RECIPIENTS OF PERSONAL DATA

As specified in the processing characteristics (table above), we may communicate your Personal Data to authorized Recipients, subject to an appropriate statutory obligation of confidentiality, which may be internal or external as appropriate:
 

Internal recipients are as follows:
 

• Members of our staff whose duties, functions and missions justify the processing of you Personal Data (e.g. communications department, marketing department, client and prospect relations department, IT department) solely for the purposes set out in this Privacy Policy and within the framework of the technical and organizational measures we implement to preserve the confidentiality and security of Personal Data detailed below;
   

External recipients are:
 

• Subsidiaries of the SFA Group and the parent company in their capacity as data processors whose attributions, functions and missions justify that they process your Personal Data (e.g. SFA Tech in charge of IT services at Group level or SFA Support).
• Service providers acting as data processors we may use for Processing purposes (e.g. hosting service providers, call centers, emailing);
• Consulting, auditing and financial control entities (statutory auditors, lawyers);
• Administrative or judicial authorities within the scope of their powers;
• In the event of a project to raise funds, acquire or dispose of a business or assets by any means whatsoever, including by disposal of the company carrying on that business or owning those assets, the potential acquirer(s) and their advisors as part of an audit preceding the transaction. In the event of an acquisition by a third party, Personal Data will form part of the assets transferred and as such will be processed by the acquirer who will act as the new Data Controller under its own privacy policy.
   

6. YOUR RIGHTS

6.1 Statement of rights

In accordance with the Applicable Regulations, the following rights may apply to you, depending on the situation:

• A right to request confirmation that your Personal Data is being processed, to obtain information on the characteristics of such Processing, to access such data and to request a copy thereof (right of access);
• A right to rectify or complete any of your Personal Data that is incorrect or obsolete (right to rectification);
• A right to withdraw your consent at any time, provided that the Processing concerned is based exclusively on this legal basis (right to withdraw consent);
• A right to object to the Processing of your Personal Data for reasons relating to your particular situation and to obtain erasure, in which case we will grant this request unless the Processing is justified on legitimate and compelling grounds (right to object on legitimate grounds and right to erasure);
• A right to obtain the limitation of Processing of your Personal Data temporarily in the event of a request for rectification or opposition on legitimate grounds while we analyse the request, which in practice means that the Personal Data is retained, but we cannot process it (right to limitation);
• A right to Data portability, i.e. a right to receive your Personal Data provided to us in a structured, and commonly used and machine-readable format and the right to transmit those Data to another Data Controller, provided that the Processing is automated and based on consent or on the performance of a contract (right to data portability);
• A right to formulate instructions concerning the Processing of your Personal Data after your death and to ask us to retain, delete or communicate your Data to an expressly designated third party, it being specified that once we become aware of your death and in the absence of instructions from you, we undertake to destroy your Personal Data, unless their retention proves necessary for evidentiary purposes or to meet a legal obligation (post mortem right).

6.2 How to exercise your rights

If you have any questions about data protection or wish to exercise your rights, please contact our data protection officer at the following postal address: Unit 1, Watford Interchange, Colonial Way, Watford, Hertfordshire, WD24 4WP or by email at [email protected]
In the event of difficulties, you can submit a complaint to the local data protection authority.

7. TRANSFERS OF PERSONAL DATA ABROAD

Due to SFA's international dimension, we may transfer your Personal Data abroad, to countries outside the European Economic Area.
In such a case, we will comply with all obligations relating to the transfer of Personal Data to a third country and will implement appropriate safeguards to ensure the security of Data.

8. POLICY UPDATE

We may modify, supplement or update this policy at any time in order to take into account legal, regulatory and/or case law developments, changes in the characteristics of the Processing or the implementation of a new Processing. 
We will notify you of any substantial changes to this privacy policy and how they may affect you.

Last modified on: February 3, 2025