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DOCUMENTS, FORMS AND KEY INFORMATION

LEGAL

Privacy Policy

This notice describes how we collect, store, use and share your personal information. It also explains the rights you have in relation to the personal information that we hold about you and it applies to personal information provided to us, both by you or by others on your behalf.

Who We Are

When we say ‘we’ or ‘us’ in this notice we are referring to Future Garments Ltd (England & Wales registration number: 02690536 and this may refer to our brand names or subsidiary companies. When we use “you” or “your”, we refer to you as an individual. This policy covers the following (collectively called Future Garments):

Name & Brand

Address/Contact Information

Registration

Number

Future Garments Ltd

(for all locations): Eurox Trackman

Aqua House, Buttress Way, Smethwick, West Midlands, B66 3DL

0121 555 1026

dpo@future-gmts.com

02690536

Universal PPE

As above

10046980

You can also use the above information to contact us, with any aspects of your data protection legal rights under EU GDPR or the UK DPA 2018/UK GDPR.

Future Garments uses multiple brands across our own websites,

 

What Information We Collect

In our business activities, like all businesses, we collect personal information from you. It is possible that you may have multiple types of interactions with us. Mostly this is used to execute orders for products you buy, and sometimes used to market products that may be applicable to you.

Who we collect from

What personal data we collect

Prospective employment candidates.

Applicant details as included within a curriculum vitae (CV), including name, contact number and email, previous employment history.

Employees

Name, address, next of kin, nationality, age, gender, previous employment details, curriculum vitae (CV), drivers license, passport, employment references, pensions beneficiaries, tax code and national insurance details, health or disability conditions, bank account or other

relevant financial details.

Individual Customers or prospective customers (also Corporate Buyers on behalf of companies)

Login information, names, shipping address, product sizing or modifications to products, delivery contact name if different, payment (credit card for example) details etc., telephone call recording for customer services or complaint procedures, online “Live Chat” messages,

catalogue requests,

Website Visitors

Technical information, for example cookies, browser type, and IP address (your computer’s internet address), if you use our websites. If you order a product, you also become an Individual Customer.

Catalogue or other marketing information requests & newsletter requests.

Corporate Customer

employees (wearers)

Only if your personal data is provided to us by your employer, do we

use that data for sizing, shipping, or order confirmations.

Where We Store Your Personal Data

We have several UK locations. Access to data is available from any of our office locations as needed for staff to perform their duties.

These staff may need to execute activities such as, among other things, the fulfilment of your order, the processing of your payment details and the provision of support services. By submitting your personal data, you agree to this data processing to execute these tasks. We will take reasonable steps to secure and protect your data in accordance with this privacy policy.

As a normal part of data security, we also use Microsoft’s cloud services, based in the UK, to hold copies of all our data. This helps us provide a more reliable service to you and provides a safe backup of all our business data

 

How We Use Your Information

Depending on your role (visitor, customer, wearer etc.) we will collect and use the data differently, these are summarised below:

Category

Lawful Purpose

Account creation, order processing, invoicing/billing, contract obligations from your employer, order information status & updates, customer service.

Execution or performance of a

contract

Promotion of Goods similar/connected to your browsing or orders.

Legitimate interest.

Technical information to ensure that the websites perform as needed and technical issues are resolved.

Legitimate interest.

Provision of marketing information (catalogues, newsletters, promotions etc.)

Opt-in consent.

Anonymised data. Using general and statistical data to identify trends or market research.

Legitimate interest.

Regulator requests, government requests etc.

Legal or Regulatory requirement.

Marketing Preferences

If you choose to opt-in to receive marketing information, we will provide you with information about goods or services we feel may interest you. If your preferences change, you can request that we stop sending you marketing information. Your marketing webpage also allows you to change your preferences. This process usually takes 48 hours to complete as the preferences are used in multiple systems.

Telephone Call Recording policy

We have a telephone system that is capable of recording conversations. This is a standard industry practice that allows the recording of telephone calls for the fulfilment of our contractual obligations, for quality monitoring, training, compliance, and security purposes.

Inbound and Outbound calls for the following departments (such as Customer Services, Sales and Credit Control) may be recorded and retained in accordance with pre-defined retention periods. These recordings will only be used for the purposes specified in our Telephone Call Recording policy which is available at our web site or upon request. If calls are transferred from Sales, Customer Services or Credit Control to a member of staff outside of these departments, the call recording will cease once the call is successfully transferred.

Credit References

In cases where credit is offered, in order to process your application we will then supply your personal information to credit reference agencies and they will give us information about you, such as your financial history. We do this to assess creditworthiness and product suitability, check your identity, manage your account, trace and recover debts and prevent criminal activity. We will also continue to exchange information about you with those agencies on an ongoing basis, including about your settled accounts and any debts not fully repaid on time. The identities of the CRAs, and the ways in which they use and share personal information, are explained in more detail at http://www.experian.co.uk/crain/index.html

 

CRAIN (Credit Reference Agency Information Notice) is a document produced by the three Credit Reference Agencies- Experian, Equifax and TransUnion that explains the use of personal data they receive from third parties about individuals and/or their businesses in relation to credit activity.

CRAIN has been produced in conjunction with the UK Information Commissioner’s Office (ICO).

Security

We take on-line data security very seriously. We know how much data security matters to all our customers, employees and visitors. We will take all appropriate steps to protect it. We do this in the following ways:

Employee access to data

To protect your data we have employed specific individuals, who oversee compliance with legislation and specialist individuals for our technical infrastructure, applications, data stores and access controls.

Those employees that do have access to your personal information are restricted by their specific roles and general access to all data is not permitted.

Browser & Web Server

We use Transport Layer Security (TLS) to encrypt data transmissions between your browser and our web server, to ensure that all personal and transactional information is protected from eavesdropping, tampering or alteration.

Payments, PCI/DSS

Also, protection and security of the payment system itself is important. We safely process your card payment(s) through your bank and complete the transaction(s) securely behind protected firewalls and encrypted connections between the bank and us. PCI / DSS is the worldwide payment card industry data security standard that was set up to help businesses process card payment securely and reduce card fraud. We are PCI / DSS compliant.

Technology

We regularly monitor our system for possible vulnerabilities and attacks, and we carry out penetration testing to identify ways to further strengthen security. We also use hard disk encryption, firewalls, password protections, anti-virus and access checks for our employees. The security measures described above ensure that all reasonable steps are taken to protect your personal information. However, the nature of the Internet means that an absolute guarantee of security cannot be offered, and you should be aware that there may be a small security risk in exceptional circumstances when disclosing information online.

 

Do We Sell Your Information To Third Parties?

Other divisions/brand/entities within our group

We do allow transfers of personal data within the group in the normal business process, such as filling an order, performing a credit check if needed, processing payment details, or servicing a customer request.

We also transfer personal data to our vendors, if they are required to perform activities such as personalisation of products, or direct shipping from our supplier to yourself. The circumstances under which this is allowed are limited.

External Organisations

In some circumstances, it may be necessary to cooperate with authorities in relevant countries in the case of fraud, regulatory or legal actions. We abide by those actions based on our legal review.

If you have provided consent to marketing information, you may also receive marketing information from external companies related to the products or services you are interested in.

We sometimes share personal data with trusted partners that provide optional services. An example of this is product and service surveys that are important to us to gather customer feedback. You are not obligated to enter any information, as they are optional.

Under no circumstances do we permit the selling of your personal data to other organisations.

International Data Transfers

In cases where we transfer data as part of our normal business activities we will have the appropriate contractual safeguards in place, including those with our suppliers

How Long Do We Keep Your Data?

In order to provide a high-quality of service, it is necessary that we keep some data to continue to service your customer needs. As such, the following retention periods apply:

Types of data

Purpose(s)

Retention Period

Prospective Customer/Recruitment Candidate Data

For potential employment within the Future Garments .

• 13 months, live 12 months, 1 month in archive.

Employee data

Employment. Legal Obligation

• 7 years after the employee leaves us.

 

Customer data

Execution or performance of a contract (corporate).

• Either 10 years after the last transaction

takes place, or

• Indefinitely if any illegal or fraud activity is detected, or it is additionally required for legal or regulatory purposes.

Telephone Recordings

To monitor customer service performance, to

prevent fraud etc.

• 13 months in total. 12 months accessible, 1 month in an archive.

Accounts and legal data.

Execution or performance of a contract (corporate).

As required by UK laws. Normally 7 years.

 

Your Rights

When We Act as a Data Controller or as a Data Processor

If you are an employee and we have a contract with your employer, we may only be a processor of your personal data. In these cases, we forward any requests to your employer.

When we sell products through a reseller or online marketplace, again we may only be a data processor and the seller will be the actual data controller. They will respond with respect to your data rights. Any requests made though us will be forwarded to the relevant data controller and they will manage all communications with you.

If the purchase is directly through us (phone, post, website) then we are the data controller and we will respond to your request.

Under EU GDPR and UK DPA 2018 (UK GDPR), you have certain data protection rights.

Right to Information/Notification

This right provides you to ask us for information about what personal data we hold about you, how it is being processed and the reasons for that processing.

Where you have bought a product or service from any of our resellers, or on their online stores, they will have your customer details, so any notifications or access to data will be managed by them.

If we ever experience a data leak that could have significant negative consequences for your personal privacy rights and freedoms, then you as a customer will be personally informed of the circumstances and actions we are currently taking and will take in the future.

Right to access

This right provides you with the ability to get access to your personal data that is being processed. You can request to see or view your own personal data, as well as to request copies of the personal data if you do not already have a copy, or you do not know it. You may also use a third party to make the request, and we will ask for authorisation proof (power of attorney etc.) if needed.

Right to rectification

This right provides you with the ability to ask for modifications to your personal data in case you believe that the personal data is inaccurate. We are happy to do this via our customer services team or via the Data Privacy Office contact information.

Right to withdraw consent

This right provides you with the ability to withdraw a previously given consent for processing of your personal data. The request requires us to stop the processing of that data for that specific purpose in the future. Mainly, for us, this applies to marketing activities and if you ask us to stop sending you particular or all product

 

or services information, we will do so.

Right of Erasure/Right to be forgotten

This right allows you the ability to ask for the deletion of your data. This will generally apply to situations where we no longer have a customer relationship with you and the data has not been deleted already. In some cases, we have a legal obligation to keep certain data (invoices, financial records etc.) .and therefore this right is not an absolute right.

Right to object

This right provides you with the ability to object to the processing of your personal data. For example; you can also ask for your data not to be processed for scientific or historical research purposes (if relevant) unless it is necessary for public interest reasons.

However, this is also not an absolute right, as we may have legal, regulatory, contractual, or legitimate interest processing reasons to consider also.

Right to object to automated processing/automated decision

You can also object to a decision that is made automatically, and to have that decision reviewed by a person. This is usually used for credit agreements if you believe that the decision does not account for unique personal circumstances.

Right to Data Portability

If you have consented or contracted to provide us personal information and our processing is automated, then you can ask for that data to be made portable. However, at present there is no standard on which this portability occurs to allow easy transfer and we do not have partners that would use that data in this way.

Escalation to Your Supervisory Authority

In the event that you are unhappy with our processing of your personal data, you also have the right to lodge a complaint, at any time, with the relevant supervisory authority in the country where you live, or as below:

information Commissioner’s Office (ICO)

https://ico.org.uk/concerns/

If you live outside the United Kingdom, your complaint will remain on file within your country, but will be addressed by the data authority listed above.

Changes to this Privacy Notice

Any changes we may make to our Privacy Notice in the future will be posted on this webpage and, where appropriate, notified to you. The new terms may be displayed on-screen and you may be required to read and accept them to continue your use of our Website.

Although this Website may be linked to other websites, we are not, directly or indirectly, implying any approval, association, sponsorship, endorsement, or affiliation with any linked website, unless specifically stated herein.

You should carefully review the legal statements and other conditions of use of any website which you access through a link from this Website. Your linking to any other off-site pages or other websites is at your own risk.

Cookie Policy

Cookies are small bits of text sent by our servers to your computer or device when you access our services. They are stored in your browser and later sent back to our servers so that we can provide contextual content. Without cookies, using the web would be a much more frustrating experience. We use them to support your activities on our website. For example, your session (so you don't have to login again) or your shopping cart.
Cookies are also used to help us understand your preferences based on previous or current activity on our website (the pages you have visited), your language and country, which enables us to provide you with improved services. We also use cookies to help us compile aggregate data about site traffic and site interaction so that we can offer better site experiences and tools in the future.

Here is an overview of the cookies that may be stored on your device when you visit our website:

Category of Cookie Purpose Examples

Session & Security

Authenticate users, protect user data and allow the website to deliver the services users expects, such as maintaining the content of their cart, or allowing file uploads.

The website will not work properly if you reject or discard those cookies.

session_id (Odoo)
fileToken (Odoo)

Preferences

Remember information about the preferred look or behavior of the website, such as your preferred language or region.

Your experience may be degraded if you discard those cookies, but the website will still work.

frontend_lang (Odoo)
Interaction History

Used to collect information about your interactions with the website, the pages you've seen, and any specific marketing campaign that brought you to the website.

We may not be able to provide the best service to you if you reject those cookies, but the website will work.

im_livechat_previous_operator_pid (Odoo)
utm_campaign (Odoo)
utm_source (Odoo)
utm_medium (Odoo)

Advertising & Marketing

Used to make advertising more engaging to users and more valuable to publishers and advertisers, such as providing more relevant ads when you visit other websites that display ads or to improve reporting on ad campaign performance.

Note that some third-party services may install additional cookies on your browser in order to identify you.

You may opt-out of a third-party's use of cookies by visiting the Network Advertising Initiative opt-out page. The website will still work if you reject or discard those cookies.

__gads (Google)
__gac (Google)

Analytics

Understand how visitors engage with our website, via Google Analytics. Learn more about Analytics cookies and privacy information.

The website will still work if you reject or discard those cookies.

_ga (Google)
_gat (Google)
_gid (Google)
_gac_* (Google)

You can choose to have your computer warn you each time a cookie is being sent, or you can choose to turn off all cookies. Each browser is a little different, so look at your browser's Help menu to learn the correct way to modify your cookies.

We do not currently support Do Not Track signals, as there is no industry standard for compliance.

FG CO POL 016 V2 Modern

Slavery Policy Rectified : Jan 2017 Revised Jan 2021

MODERN SLAVERY STATEMENT

FUTURE GARMENTS LTD

This statement is made pursuant to s.54 of the Modern Slavery Act 2015 and sets out the steps that Future Garments Limited has taken and is continuing to take to ensure that modern slavery or human trafficking is not taking place within out business or supply chain. Modern slavery encompasses slavery, servitude, human trafficking and forced labour. Future Garments Limited has a zero tolerance approach to any form of modern slavery. We are committed to acting ethically and with integrity and transparency in all business dealings and to putting effective systems and controls in place to safeguard against any form of modern slavery taking place within business or our supply chain. Our Business Future Garments Limited specialize in providing PPE, work wear bespoke clothing and protective clothing to businesses worldwide. Our head offices are based within the UK with manufacturing sources carefully selected as far as the Far East. All Future Garments Limited employees have the necessary documentation to legally work in the UK and no one under the legal minimum age for admission is to work In the UK. We take pride in providing salary/contract packages that also meet and exceed the current legislation of employment law. Our High Risk Areas Our suppliers and contractors worldwide. Specifically those of Chinese and Indian origin are carefully selected before a contract is agreed. This includes completion of tenders to ensure that all legal requirements are met as per the guidelines set out in Future Garments Limited ethnical and sustainable procurement policy.

FG CO POL 016 1

Our Policies

We operate a number of internal policies to ensure that we are conducting business in an ethnical and transparent manner. These include:

1.Anti-Slavery Policy. This policy sets out the organisation’s stance on modern slavery and explains how employees can identify any instance of this and where they can go for help.2.Recruitment Policy. We operate a robust recruitment policy, including conducting eligibility to work in the UK checks for all employees to safeguard against human trafficking or individuals being forced to work against their will.3.Whistleblowing Policy. We operate a whistleblowing policy so that all employees know that they can raise concerns about how colleagues are being treated, or practices whining our business or supply chain, without fear of reprisals.4.Code of Business Conduct. This code explains the manner in which we behave as an organization and how we expect our employees and suppliers act.5.Anti-Corruption and Bribery Policy. This policy sets out the companies zero tolerance approach to corruption and bribery within the business.

Future Garments Limited operates a supplier policy and maintains a preferred supplier list. We conduct due diligence on all suppliers before allowing them to become preferred supplier. This will include an online search to ensure that particular organisation has never been convicted of offences relating to modern slavery and on site adults which include a review of working conditions. Our anti-slavery policy forms part of our contract with all suppliers and they are required to confirm that no part of their business operations contradicts this policy. In addition to the above, as part of our contract with suppliers, we require that they confirm to us that:

1.They have taken steps to eradicate modern slavery within their business.2.They hold their own suppliers to account over modern slavery.3.(For UK based suppliers) they pay their employees at least the national minimum wage/national living wage (as appropriate).4.(For international suppliers) they pay their employees any prevailing minimum wage applicable within their country of operations.5.We may terminate the contract at any time should any instances of modern slavery come to light.6.No harsh or inhuman treatment is carried and there employees are provide with a safe and healthy working conditions.

FG CO POL 016 2

Training

We regularly conduct training for our procurement/buying teams so that they understand the signs of modern slavery and what to do if they suspect that it is taking place within our supply chain. With also carry out regular annual visits to our suppliers within the UK and international to ensure that requirements are met.

Our Performance Indicators

We will know the effectiveness of the steps that we are taking to ensure that slavery and/or human trafficking is not taking place within our business or supply chain if:

•No reports are received from employees, the public, or law enforcement agencies to indicatethat modern slavery practices have been identified.

•All required documentation/reports are not provided.

This statement was approved by the Board of Directors

Name:

Mr. Kuldip Palak

Position:

Managing Director FG CO POL 016 3