Privacy Policy

 

1. Introduction
We are committed to safeguarding your privacy and we want you to feel comfortable with how we collect and use your personal information. This Privacy Policy explains how we do this. 

Turner ECS ("we", "us" or "our") is the controller of personal information collected by us.

If you have any questions about this Privacy Policy, including any requests to exercise your legal rights, please contact us using the information set out in the How to Contact Us section below. 

This Privacy Policy may change from time to time. We recommend you regularly check this page for any changes when you visit our website. 

This Privacy Policy was last updated on 7th February 2025.

2. Personal information we collect and use
Personal information we collect, use, disclose, store and transfer may include:

Contact information: information which identifies you or allows us to contact you in person (including name, telephone number, email and postal address).

Information you provide: personal information you choose to give to us when you interact with our website or you are in contact with us, for example if you fill out a form or contact us with an enquiry.

Feedback: information that you share with us about your experience in using our website or our products or services (e.g. your comments and suggestions, testimonials and other feedback).

3. How we collect personal information
We may collect your personal information from a variety of sources, including through:

Requests and forms: for example, personal information you choose to give to us by entering information via our website or our social media pages or by corresponding with us by email, telephone or post.

Newsletters and marketing activities: for example, where you provide your personal information to receive newsletters and other marketing information from us.

Cookies: our website uses cookies - please see the Cookies section below for more details.

4. Why we collect and use personal information
We collect and use your personal information for some or all of the following reasons:

Contracts: where this is necessary to perform contracts we enter into with you or in preparation for this.

Customer service: to deal with your enquiries and requests via forms on our website or other forms of communication, including email, telephone, post and social media.

Marketing activities: to provide news and information about us, our group or products/services, for example where you subscribe to receive newsletters or other information from us. Contact with you may be by different methods, including email, telephone, SMS text and post.

Security: to maintain the security of our website, facilities and systems.

Legal compliance: to comply with our legal and regulatory responsibilities, to respond to legal requests for information issued by government authorities or regulatory bodies, to prevent and detect crime and fraud, or to protect your, our or others’ rights.

Website: to operate our website, personalise it to you and to understand how the website is used so that we can improve it.

Privacy Policy: Data Processing Activities

Processing Activity Purpose Legal Basis Categories of Personal Data Retention Period

Account Registration  

To create and manage your account  

Contractual necessity  

Name, email address, password  

Retained until account deletion by user or becomes inactive for 5 years

Order Fulfillment  

To process and deliver your order  

Contractual necessity  

Name, email, address, phone number  

Retained for 7 years (legal obligation)  

Order Fulfillment  

To send promotional offers and newsletters  

Consent  

Name, email address  

Retained until consent withdrawal  

Customer Support

To respond to your inquiries or issues  

Contractual necessity  

Name, email, phone number, chat logs  

Retained for 2 years after resolution  

Website Analytics

To improve website functionality and performance  

Consent  

IP address, device data, cookies  

Retained for 1 year  

Legal Compliance

To comply with legal and regulatory obligations  

Legal obligation  

Any data required by law  

Retained as per statutory requirements

5. Legal basis for collecting and using personal information
EU data protection law requires that we have a legal basis for collecting and using personal information. We rely on one or more of the following for collecting and using your personal information:

Consent: we rely on consent to use your personal information only where we have obtained your active agreement to this for a specified purpose. You have the right to withdraw your consent at any time

Performance of a contract: we may use your personal information where we need to perform a contract with you or in preparation for this.

Legal Obligations: we may use your personal information where it is necessary for compliance with a legal obligation to which we are subject.

Legitimate Interest: we may use your personal information where it is necessary to conduct our business and pursue our legitimate interests, for example:

- to administer our website, correspond or communicate with you;

-we process personal data for fraud prevention or other criminal activity under legitimate interest, ensuring it does not override    users’ rights, as evaluated through our balancing test.

-carry out marketing activities to grow our business.

-to enable us to give you the best and most secure service or experience.

- to create a better understanding of you as a customer or website visitor.

-for network and information security, including measures to protect your information against loss or damage, theft or unauthorised access.

-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 in order to be able to comply with your request).

We make sure we consider and balance any potential impact on you and your rights (both positive and negative) before we process your personal information for our legitimate interests. We do not use your personal information for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law).

You have the right to request information on how our balancing test was conducted for any processing based on legitimate interest. To do so, please contact us at datacompliance@turner-ecs.com.

6. Cookies

Our website uses cookies to help make your browsing experience more personalised and effective. Please see our Cookie Policy for more details about the cookies we use and how to change your cookie preferences here.

7.Sharing your personal information with others
In some circumstances we may share your personal information with third parties:

Group companies: we may share your personal information with our subsidiaries and other companies within our group. Unless they provide you with their own privacy policy, they may use your personal information in the ways set out in this Privacy Policy.

Service providers: we may use service providers, agents, suppliers or contractors to provide services to us or on our behalf, including administering services to you. These third parties may access or otherwise process your personal information in the course of providing these services. We require such third parties to comply with all relevant data protection laws and security requirements in relation to your personal information.

Legal requirements: we may disclose your personal information if we are required to do so by law or if disclosure is reasonably necessary to comply with legal processes, meet or enforce a legal obligation, respond to any claims or for a business acquisition or sale involving us (or as part of a business restructuring or reorganisation).

8.Transfers of personal information outside the EU
In certain circumstances we may securely transfer personal information to countries outside the EU.

We will only transfer your personal information where either:
the transfer is to a country which the EU has decided ensures an adequate level of protection for your personal information; or
- we have put in place measures to ensure adequate security as required by EU data protection law. These measures include ensuring that your personal information is kept safe by carrying out strict security checks on our overseas partners and suppliers, backed by strong contractual undertakings approved by the relevant regulators such as the EU or UK standard contractual clauses

Privacy Policy: Cross-Border Data Transfers  

Country Purpose of Transfer Lawful Basis Safeguards
United States Hosting of website and cloud storage Adequacy decision (EU-US Data Privacy Framework) Data protected under the EU-US Data Privacy Framework
India Customer support and IT services Standard Contractual Clauses (SCCs) SCCs ensure equivalent data protection standards
Australia Marketing and advertising services Legitimate interest Binding Corporate Rules (BCRs)
United Kingdom Financial transactions and order processing Adequacy decision UK is considered to provide an adequate level of protection
Philippines Data processing for analytics services Standard Contractual Clauses (SCCs) SCCs approved by the European Commission

9. Data security
We use technical and organisational security measures including encryption and authentication tools to protect your personal information against manipulation, loss, destruction, and unauthorised access by third parties. In particular, we store your personal information in secure operating environments only accessible to our employees, agents, suppliers and contractors on a need-to-know basis. 

10.Retention
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 legal obligations.

We will only retain your personal information for as long as it is necessary to fulfil the purposes for which we collected it, taking into account our need to answer queries or resolve problems, provide our products or services to you, and comply with legal requirements. This means that we may retain your personal information for a reasonable (or legally required) period after your last interaction with us. When the personal information that we collect is no longer required in this way, we destroy or delete it in a secure manner.

If you require further information around retention periods that we follow, please contact us at datacompliance@turner-ecs.com.

Category Retention Period
Account Registration Retained until the account is deleted by the user or becomes inactive for 5 years (inactive accounts are deleted after notification).
Order Fulfillment Retained for 7 years, in compliance with tax and legal regulations.
Marketing Communications Retained until the user withdraws consent or unsubscribes from marketing emails.
Customer Support Retained for 2 years after the resolution of the inquiry or issue.
Website Analytics Retained for 1 year to evaluate trends and improve website functionality.
Legal Compliance Retained as per statutory requirements, typically for 10 years (e.g., for legal or audit purposes).

11. Your rights
You have a number of legal rights in relation to your personal information, including:

Request access: you have the right to ask for a copy of personal information that we hold about you and how we use it.

Request correction: you have the right to ask us to update or correct any inaccurate or incomplete personal information that we hold about you.

Request deletion: you have the right to ask us to delete or remove your personal information where it is no longer necessary for us to use it, you have withdrawn consent, or where we have no continuing lawful basis for keeping it.

Object: you have the right to object to the processing of your personal information if we do not have a continuing lawful basis to use it.  You also have the right to opt out of or unsubscribe from marketing communications that we may send at any time (this does not include administrative communications).

Restrict processing: in certain circumstances you have the right to restrict the processing of your personal information.

Data portability: in certain circumstances you have the right to ask us to send personal information that you have provided to us, either to you or to a third party in a structured, commonly used, machine-readable format.

Is Providing Personal Data Mandatory?
Providing personal data is:

Not a Statutory Requirement: There is no legal obligation for you to provide personal data to use our website.

May Be a Contractual Requirement: In some cases, providing specific data is necessary to fulfill a contract. For example, we require your contact details to process your subscription or deliver a product you’ve purchased.

Consequences of Refusal to Provide Data

If you choose not to provide the necessary personal data:

-You may be unable to access certain services or features of our website. 
-We may not be able to fulfill our contractual obligations, such as delivering products or services you have requested.

We will inform you at the time of collection if providing specific data is required to complete a particular process.

Data Category Requirement Type Necessity for Contract Consequences of Refusal
Account Registration Yes, required to create an account Yes, required to create an account Unable to access account-based services or features.
Order Fulfillment Contractual Requirement Yes, required to process orders Orders cannot be processed or delivered.
Marketing Communications Voluntary No No marketing emails or promotional offers will be sent.
Customer Support Legitimate Interest No We may be unable to assist with specific inquiries or issues.
Legal Compliance Statutory Requirement Yes, required by law Unable to comply with legal or regulatory obligations.
Website Analytics Voluntary No Limited functionality or inability to optimize user experience.
If you wish to exercise any of the rights set out above, please contact us at datacompliance@turner-ecs.com

12. How to contact us
If you have any questions or comments regarding this Privacy Policy or our personal information collection practices, please contact us in the following ways:

Email address: datacompliance@turner-ecs.com
Postal address: Company Secretary, Turner ECS. Dirk Storklaan 76
2132 PX Hoofddorp, Netherlands

13. Complaints
You have the right to make a complaint at any time to the European Data Protection Board (EDPB), which is the EU regulator for data protection issues. Below is a direct link to all European DPAs:

https://www.edpb.europa.eu/about-edpb/about-edpb/members_en.

We would, however, appreciate the chance to deal with your concerns before you approach the EDPB so please contact us in the first instance.

14. Third-party links
This website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy policy of every website you visit.

Contact us
Turner ECS Netherlands

Dirk Storklaan 76
2132 PX Hoofddorp
The Netherlands
Tel: +31 (0) 23 566 23 00

24/7: +31 (0) 6 57 59 22 50
info.nl@turner-ecs.com

Unit 1 High Carr Business Park
Newcastle-under-Lyme
Staffordshire ST5 7XE
United Kingdom
Tel: +44 1782 569190
info.uk@turner-ecs.com

Turner MCS Italy

Polo Tecnologico della Brianza Edif. 9 Lab 3
Via Lavoratori Autobianchi 1
20832 Desio, Italy
Tel: +39 0362 62 12 40
info.it@turner-mcs.com

Turner ECS Germany

OhmStraße 2
D63225 Langen
Germany
Tel.: +49 (0) 6103 73 299 0
info.de@turner-ecs.com

Turner ECS Abu Dhabi

Bin Hamoodah Building
7th Floor, Sh. Khalifa Street
P.O. Box 203, Abu Dhabi
United Arabic Emirates
Tel: +971 02 626 7912
info.me@turner-ecs.com

Turner ECS Saudi Arabia

Office No. 702
7th Floor Al Mousa Tower
6682 Al Amir Turki-Al Yarmok Dst.
Al Khobar - Saudi Arabia
General: +966 138343734

Mobile: +966(0)504827421
info.me@turner-ecs.com

Turner ECS Qatar

P.O Box 153
Ein Khalid Commercial Building
Doha, Qatar
Tel: +974 3338 0351
info.me@turner-ecs.com