What is this?
At the Fulcrum Group we take privacy seriously and we are committed to protecting it.
This policy explains when and why we collect personal information about individuals, how this information is used, and the conditions under which it may be disclosed to others and how it is kept secure.
This policy may change from time to time so please check this page occasionally to ensure that you’re happy with any changes. This policy was last updated on 29/07/20. Please see Changes to this policy.
Who we are
The Fulcrum Group, headed by Fulcrum Utility Services Limited (company number BR015000) is made up of numerous individual companies. For a full list of these companies please see Schedule 1 to this policy. Whenever dealing with one of our group companies the ‘controller’ of your personal information will be the company that corresponds with you and identifies itself as a data controller.
Where this policy refers to “Fulcrum” “we”, “our” or “us” below, unless it mentions otherwise, it is referring to the particular company/companies that is/are the controller of your personal information.
How we collect your personal information
The personal information we collect and the way in which we collect it are as follows:
Personal information you give to us:
This is information about you that you give to us by entering information via our site (https://investors.fulcrum.co.uk/), corresponding with us by phone, email or otherwise or entering into agreements with us, and is provided entirely voluntarily.
This includes information provided when contacting us or requesting a quote via our site, subscribing to the services we provide, managing your account online, requesting further services and engaging in correspondence with us by phone, email or otherwise. Such personal information may consist of, but is not limited to, your title, name, email address, telephone numbers, details about your job role, and information contained in our correspondence or other communications with you about our business.
We may also ask you for information when you report a problem with our site. If you complete any surveys that we request you complete for research purposes, we will collect information in such circumstances as well. Such personal information may consist of, but is not limited to, your title, name, email address, telephone numbers, details about your job role, and may include records of any correspondence and responses to any surveys.
Personal information we collect about you:
We may automatically collect the following information: details of transactions you carry out through the site, and your visits to our site, including, but not limited to, traffic data, location data, weblogs and other communication data, and the resources you access. We may also automatically collect technical information, including anonymous data collected by the hosting server for statistical purposes, the Internet protocol (IP) address used to connect your computer or device to the Internet, browser type and version, time zone setting, browser plug-in types and versions, operating system and platform. Please see Cookies for further information. We may also collect any personal information which you allow to be shared that is part of your public profile or third party social network, type and version, time zone setting, browser plug-in types and versions, operating system and platform.
Personal information we may receive from other sources:
We obtain certain personal information about you from sources outside of our business which may include our group companies or other third-party companies. In addition, we may also receive certain personal information about you from our customers with whom we enter into agreements. We offer our services to business customers and the personal information that you provide to those businesses may be sent to us in order to deliver the service. The personal information received is as described in the two paragraphs above and may also include special category personal data which relates to your health where it is necessary for us to provide our services.
How we use your personal information
The purposes for which we use your information and the legal basis under data protection laws on which we rely to do this are explained below.
Performance of the contract with you or take steps to enter into. We may use and process your personal information where we have supplied you (or continue to supply you) with any products or services, where we are processing an order from you, where we have arranged for the supply of another company’s products or services to you or where you are in discussions with us about any new product or service. We will use this information in connection with the contract for the supply of services/products when it is needed to carry out that contract with you or for you to enter into it. Please see Data we collect and how we collect it above for details of the types of personal information we process for these purposes.
Legitimate interests. We may use and process your personal information where it is necessary for us to pursue our legitimate interests as a business, or that of a third party, for the following purposes:
- for marketing activities (other than where we rely on your consent to contact you by email or text with information about our products and services, as explained below in Consent for data processing);
- for analysis to inform our marketing strategy, and to enhance and personalise your client experience (including to improve the recommendations we make to you on our website);
- to monitor usage of our site, record traffic flows, and to carry out research about its user demographics, interests and behaviour in order to better understand the users of its website and clients;
- to correspond or communicate with you, including about our services and any changes or improvements to our website or services;
- to carry out database and website administration;
- to verify the accuracy of data that we hold about you and create a better understanding of you as a customer (if applicable);
- for network and information security in order for us to take steps to protect your information against loss or damage, theft or unauthorised access;
- for prevention of fraud and other criminal activities;
- to comply with a request from you in connection with the exercise of your rights (for example where you have asked us not to contact you for marketing purposes, we will keep a record of this on our suppression lists in order to be able to comply with your request);
- to assess and improve our service to clients;
- for the management of queries, complaints, or claims; and
- for the establishment and defence of our legal rights.
Consent for data processing. We may use and process your personal data where you have consented for us to do so. This includes contacting you with marketing information about our products and/or services if you have:
- signed up to our mailing list/e-newsletters via our website or other medium where available; or
- when you refresh your marketing preferences and provide a consent when responding to a request from us to do so.
We may also process your special category personal information where it is necessary for us to provide our services. Occasionally we will seek your explicit consent to do this where appropriate. However, we will usually rely on alternative lawful bases for processing, such as processing which is necessary:
- to carry out obligations relating to employment, social security and social protection law;
- to protect Your vital interests;
- for the establishment, exercise or defence of legal claims;
- for the purposes of preventive or occupational medicine for the assessment of working capacity of an employee; and
- for reasons of substantial public interest.
You may withdraw your consent for us to use your information in any of these ways at any time. Please see Withdrawing your consent for further details.
Vital interests. Where we have supplied you with any goods, we may use your personal information to contact you if there are any urgent safety notices to communicate to you or where we otherwise reasonably believe that the processing of your personal information will prevent or reduce any potential harm to you. It is in your vital interests for us to use your personal information in this way.
Legal requirement. We will use your personal information to comply with our legal obligations: (i) to assist any public authority or criminal investigation body; (ii) to identify you when you contact us; and/or (iii) to verify the accuracy of data we hold about you.
Others who may receive or have access to your personal information
We may share your information with other companies within the Fulcrum group. They may use your personal information in the ways set out in How we use your personal information, in order so that we can provide our services to you as requested. Please see the start of this policy for the details of our group companies with whom we may share your personal information.
Our suppliers and service providers
We may disclose your information to our third-party service providers, agents, subcontractors and other organisations for the purposes of providing services to us or directly to you on our behalf. Such third parties may include subcontractors engaged to carry out infrastructure works, cloud service providers (such as hosting and email management), IT providers, legal advisers, advertising agencies and administrative services.
When we use third party service providers, and they are acting as our processors, we only disclose to them any personal information that is necessary for them to provide their service and we have a contract in place that requires them to keep your information secure and not to use it other than in accordance with our specific instructions.
Third parties who provide products and services
We work closely with various third parties to bring you a range of products and services that are complementary to those that we provide. When you enquire about or purchase one or more of these products or services through us, the relevant third party may use your details to provide you with information and carry out their obligations arising from any contracts you have entered into with them.
Other ways we may share your personal information
We may transfer your personal information to a third party as part of a sale of some or all of our business and assets to any third party or as part of any business restructuring or reorganisation. We may also transfer your personal information if we’re under a duty to disclose or share it in order to comply with any legal obligation, to detect or report a crime, to enforce or apply the terms of our contracts or to protect the rights, property or safety of our visitors and customers. We will always take steps with the aim of ensuring that your privacy rights continue to be protected.
Where we store your personal information
All information you provide to us is stored on our secure servers which are located within the United Kingdom and/or the Cayman Islands.
If at any time we transfer your personal information to, or store it in, countries located outside of the European Economic Area (EEA) (for example, if our hosting services provider changes) we will ensure that appropriate safeguards are in place for that transfer and storage as required by applicable law. Similar safeguards may also be put in place for a transfer of your personal information to the United Kingdom in the event of the United Kingdom’s departure from the EEA. This is because some countries outside of the EEA do not have adequate data protection laws equivalent to those in the EEA.
How long we keep your personal information for
If We collect your personal information, the length of time we retain it is determined by a number of factors including the purpose for which We use that information and our obligations under other laws. We do not retain personal information in an identifiable format for longer than is necessary.
We may need your personal information to establish, bring or defend legal claims. For this purpose, we will always retain your personal information for 7 years after the date it is no longer needed by us for any of the purposes listed under “How We Use Your Personal Information”. The only exceptions to this are where:
- the law requires us to hold your personal information for a longer period, or delete it sooner;
- you exercise your right to have the information erased (where it applies) and we do not need to hold it in connection with any of the reasons permitted or required under the law (taking into consideration a data subject’s rights to erasure and restriction of processing as set out below); or
- in limited cases, the law permits us to keep your personal information indefinitely provided we put certain protections in place.
We retain technical information obtained via Google Analytics for 24 months from the date it is collected.
When it is no longer necessary to retain your data, we will delete the personal information that we hold about you from our systems. After that time, we may aggregate the data (from which you cannot be identified) and retain it for analytical purposes.
Security and links to other sites
Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal information, we cannot guarantee the security of your information transmitted to our website and any transmission is at your own risk. Once we have received your personal information, we put in place reasonable and appropriate controls to ensure that it remains secure against accidental or unlawful destruction, loss, alteration, or unauthorised access.
Where we collect or obtain any special category personal information about your health, ethnic background, sex life, political opinions, religion, trade union membership or criminal record, we will apply additional security controls to protect that data.
Where we have given (or where you have chosen) a password which enables you to access an account, you are responsible for keeping this password confidential. We ask you not to share your password with anyone.
Our website may contain links to other websites run by other organisations. This policy does not apply to those other websites‚ so we encourage you to read their privacy statements. We cannot be responsible for the privacy policies and practices of other websites even if you access them using links that we provide. In addition, if you linked to our website from a third-party website, we cannot be responsible for the privacy policies and practices of the owners and operators of that third-party website and recommend that you check the policy of that third-party website.
We may collect your preferences to receive marketing information directly from us by telephone, text message and email in the following ways:
- E.g. if you register an account with us online, we will ask you if you would like to provide your consent to receive email updates directly from us; or
- E.g. if you make a sales enquiry or place an order we may contact you with marketing information in the ways mentioned in the notices presented to you, except where you indicate you would prefer otherwise.
We also use advertising cookies (Google Ads) to record your visit to our site and use this information to deliver advertising to you for marketing purposes. Please see our Cookie declaration for further information.
If you request a quote from us and do not agree to that quote for our services, and you have not indicated that you would prefer otherwise, we may send a reminder to you about the quote we provided you.
From time to time, we may ask you to refresh your marketing preferences by asking you to confirm that you consent to continue receiving marketing information from us.
You have the right to opt-out of our use of your personal information to provide marketing to you in any of the ways mentioned above. Please see Withdrawing your Consent and Objecting to our use of your personal information and automated decisions made about you above for further details on how you can do this.
You have a number of rights in relation to your personal information under data protection law. In relation to certain rights, we may ask you for information to confirm your identity and, where applicable, to help us to search for your personal information. Except in rare cases, we will respond to you within one month from either (i) the date that we have confirmed your identity or (ii) where we do not need to do this because we already have this information, from the date we received your request.
- Accessing your personal information. You have the right to ask for a copy of the information that we hold about you by emailing or writing to us at the address at the end of this policy. We may not provide you with a copy of your personal information if this concerns other individuals or we have another lawful reason to withhold that information.
- Correcting and updating your personal information. The accuracy of your information is important to us. If you change your name or email address, or you discover that any of the other information we hold is inaccurate or out of date, please either update your account details online using the functionality provided or let us know by using the contact details described at the end of this policy to contact us.
- Withdrawing your consent. Where we rely on your consent as the legal basis for processing your personal information, you may withdraw your consent at any time by contacting us using the details at the end of this policy. If you withdraw your consent, our use of your personal information before you withdraw is still lawful.
- Objecting to our use of your personal information and automated decisions made about you. Where we rely on your legitimate business interests as the legal basis for processing your personal information for any purpose(s), as out under How we use your personal information, you may object to us using your personal information for these purposes by emailing or writing to us at the address at the end of this policy. Except for the purposes for which we are sure we can continue to process your personal information, we will temporarily stop processing your personal information in line with your objection until we have investigated the matter. If we agree that your objection is justified in accordance with your rights under data protection laws, we will permanently stop using your data for those purposes. Otherwise we will provide you with our justification as to why we need to continue using your data. You may also contest a decision made about you based on automated processing by emailing or writing to us at the address at the end of this policy.
- Erasing your personal information or restricting its processing. In certain circumstances, you may ask for your personal information to be removed from our systems by emailing or writing to us at the address at the end of this policy. Unless there is a reason that the law allows us to use your personal information for longer, we will make reasonable efforts to comply with your request. You may also ask us to restrict processing your personal information where you believe it is unlawful for us to do so, you have objected to its use and our investigation is pending or you require us to keep it in connection with legal proceedings. In these situations, we may only process your personal information whilst its processing is restricted if we have your consent or are legally permitted to do so, for example for storage purposes, to protect the rights of another individual or company or in connection with legal proceedings.
- Transferring your personal information in a structured data file. Where we rely on your consent as the legal basis for processing your personal information or need to process it in connection with your contract, as set out under How we use your personal information, you may ask us to provide you with a copy of that information in a structured data file. We will provide this to you electronically in a structured, commonly used and machine-readable form, such as a CSV file. You can ask us to send your personal information directly to another service provider, and we will do so if this is technically possible. We may not provide you with a copy of your personal information if this concerns other individuals or we have another lawful reason to withhold that information.
- Complaining to the UK data protection regulator. You have the right to complain to the Information Commissioner’s Office (ICO) if you are concerned about the way we have processed your personal information. They encourage complaints to be made to organisations first before complaining to them, so if you do have a complaint, please contact us first. If we do not resolve it then please visit the ICO’s website for further details.
Changes to this policy
We may review this policy from time to time and any changes will be notified to you by posting an updated version on our website and/or by contacting you by email. Any changes will take effect 7 days after the date of our email or the date on which we post the modified terms on our website, whichever is the earlier. We recommend you regularly check for changes and review this policy whenever you visit our website. If you do not agree with any aspect of the updated policy, you must immediately notify us and cease using our services.
Please direct any queries about this policy or about the way we process your personal information to our Data Protection Officer using our contact details below.
If you wish to write to us, please write to the following address:
2 Europa View
Sheffield Business Park
Our email address for data protection queries is DPO@fulcrum.co.uk.
If you would prefer to speak to us by phone, please call 03330 146 466 and ask to speak to our Data Protection Officer.