Privacy Policy


Sterling is the trading name of Clearwater Products Ltd (Company Reg No 03949040). This Privacy Policy sets out how Sterling uses and protects any information that you provide when engaging with our services. Sterling are committed to protecting your privacy and are compliant with all relevant GDPR and Data Protection laws applicable in the UK.


Our Approach

Sterling places a high priority on safeguarding confidential information and processing personal data in an ethical manner. We take our responsibility for the security of customer and user data very seriously. To help us continue to achieve this, we have embedded privacy by design and by default within our operating procedures and service delivery. This means that privacy and data protection is taken into consideration and implemented in the design and delivery of our business services, marketing functions, IT services and overall business practices so that our customers, employees and service users right to data privacy and data protection is our default position when processing data.

This ensures that no additional actions are required by you to ensure your privacy is honored and protected. It also means we will not share your data with third parties for marketing purposes and will only do so when necessary to provide a business service you have requested, or if legally obligated to do so.

In order to carry out other business functions and to deliver our services, we rely on the following lawful conditions for processing personal data:

  • Consent – the individual has given their consent to the processing of their personal data.
  • Contractual – processing of personal data is necessary for the performance of a contract to which the individual is a party or for Sterling to take pre-contractual steps at the request of the individual.
  • Legal Obligation – processing of personal data is necessary for compliance with a legal obligation to which Sterling is subject.
  • Legitimate Interest – processing is necessary under the legitimate interests of Sterling or an associated third party, unless these interests are overridden by the individual’s interests or fundamental rights.


Collecting Personal Data

In order to deliver our services and to carry out necessary business functions, we may collect certain personal data from you in a variety of ways, such as, via email, website contact form, account application, or verbally e.g. by phone. These details may include (where applicable), names, contact information and account details. Depending on the service we are delivering to you or your company, we may also ask for more detailed information about your business and/or employment.

Personal data we obtain is collected in a few key ways:

- Data disclosed by the individual
- Data disclosed by an authorised third party
- Data obtained from linked system or database
- Data generated through user interaction with systems/services

Where your data is provided to us by an authorised third party it is the third party’s responsibility to ensure they have the correct lawful basis in place to share this data with Sterling.

We may collect and process the following data about you which you submit in relation to our products and services: -

- If you contact us, we may keep a record of that correspondence.
- Where you place an order with us or otherwise purchase our services, confirmation of your payment.
- Information you provide to us in relation to the provision of the Service.
- E Mail and/or business addresses
- Account details

 We use information held about you in the following ways: -

- To provide our products and services as requested by you.
- To maintain our accounts.
- For billing.
- To enable us to answer your enquiries.
- For verifying your identity for security purposes.
- To provide you with information, products or services that you request from us or which we feel may interest you, where you have consented to be contacted for such purposes.
- To carry out our obligations arising from any contracts entered into between you and us.
- To help make our website more useful to you.
- To notify you about changes to the Website.
- To enable us to provide the Service and comply with our obligations under the Agreement we enter into with you to provide the Service.

 

The personal data you provide to us is only available to relevant employees and contracted service providers e.g. third-party delivery companies when used. If required by law, Sterling may disclose data to government and or enforcement agencies.


Cookies

Cookies are used to identify you when you visit a particular site, analyse web traffic, and help facilitate a more personal web experience. Sterling uses cookies to identify the pages that are being used and to help us tailor our website to our customers needs, thus allowing our website to respond to you as an individual.

Cookies do not provide us with access to your computer or any information about you, other than that which you choose to share with us. Cookies can also be controlled by the settings within your browser, so do consider changing as you see fit.

The website uses tracking software to monitor its visitors to better understand how they use it. This software is provided by Google Analytics which uses cookies to track visitor usage.

 

Storing Personal Data

Sterling ensures that client information is protected with security measures to safeguard confidentiality, integrity and availability. These security measures are designed to prevent unauthorised access, improper use or disclosure, unauthorised modification and unlawful destruction or accidental loss. All information you provide to us is stored on secure servers. Access to Sterling’s systems can only be gained via secure login processes including complex passwords.

We have in place a procedure if a breach of security leading to the accidental or unlawful destruction, loss, alteration, unauthorised disclosure of, or access to, personal data transmitted, stored or otherwise processed in connection with the provision of a public electronic communications service occurs. If the nature of the breach requires, we will inform the ICO within 72 hours of becoming aware of the essential fact of the breach.


Who has Access to the Data

The data we collect about you is generally accessed only by authorised Sterling employees or third parties for legitimate business purposes and providing services as part of a contract. Authorised third party’s or contractors, may have limited access to your personal data but only as much to do their job.

The following outlines who has access to your personal data, and under what circumstances:

- Sterling employees and other authorised individuals who are involved in arranging and delivering the services you request (where privacy is legally covered under their contract of employment or service contract);

- A third party who is contracted by Sterling to provide services to you on our behalf, and therefore bound under terms within their contract relating to confidentiality and privacy that is to the same standard and level as Sterling


How Long Data is Stored

It is Sterling’s practice that data is only stored for the appropriate period of time. We have in place internal guidelines on how long data should be retained detailed in a Data Retention Policy. Customer personal data will be held for as long as the business or individual is in receipt of services from Sterling, plus up to a maximum of 6 years to meet certain legal and compliance requirements. Where information in relation to life time warranties is concerned this is not deleted as it will be required indefinitely to ensure that the consumer’s rights are capable of being upheld.

Where data is held by third parties in support of the services we provide, the third parties are required to either delete data upon our request, delete data at the end of our supplier contract with them, or to anonymise data after 2 years of receipt.


Changes to the Privacy Policy

We regularly review our Privacy Policy and reserve the right to amend or modify this Policy from time to time. Such modifications shall be effective immediately. Your continued use and access of Sterling services will constitute your acceptance of any changes or revisions to this Privacy Policy.


Contacting us

Sterling can be contacted in the following ways:

Email – admin@sterling.eu.com

Telephone – 01684 299555

Mail – Sterling, Shannon Place, Tewkesbury Business Park, Tewkesbury, Gloucestershire, GL20 8SL