Introduction

The purpose of this policy is to set out the responsibilities of the in observing and upholding our position on collection, use and disclosure of personal information, and is our principal external facing privacy notice. Please read this policy carefully. It may be updated from time to time, so please you check back regularly to review any changes.

The AS Utilities comprises AS Utilities plc and its subsidiaries and affiliates. The “controller” of your personal information (for the purposes of data protection law) will be the AS Utilities company which collected your personal data. However, other AS Utilities companies may need to use your information from time to time, in accordance with the purposes set out in this Policy.

Policy objectives

To achieve this commitment AS Utilities will:

Process personal information lawfully, and share information about the processing in a concise, transparent, intelligible and easily accessible form.
Collect personal data for a specific legitimate purpose and not process it in any way that is not aligned to that purpose.
Limit personal information to the purpose for which it is being processed.
Take reasonable steps to keep collected personal information accurate and up to date.
Only keep personal data for as long as is necessary for the purpose for which it is being processed.

Process personal information in a manner that protects the security of the personal data.
Establish processes and procedures to maintain accountability for processing personal information.

Delivering our objectives

People we collect information from

We collect personal information from:

individual representatives (employees, directors, members etc.) of the organisations who are our prospective and current customers (‘customers’);
individual representatives (employees, directors, members etc.) of the organisations who are our prospective and current suppliers (‘suppliers’);
prospective, current and former shareholders in AS Utilities plc;
visitors to our websites.

Information we collect automatically

When you visit our websites, our server automatically collects certain browser or device generated information, including but not limited to your:

domain;
IP address;
visit e.g. date, time and duration;
browser type;
operating system; and
page visits.

Information you provide

If you are a customer or supplier, you may voluntarily provide us with personal information (normally limited to basic information, such as your name and contact details) by:

corresponding with AS Utilities colleagues;
attending AS Utilities events;
working with AS Utilities on contracts or other projects.
We may collect other personal information about you when carrying out due diligence checks (e.g. sanctions checks) on our customers and suppliers, particularly where you are a director or company owner.

If you are an investor in AS Utilities, you will have provided basic personal information when subscribing for our shares.

Use of personal information

In the majority of cases, use or processing of your personal information will be justified on the basis that:

you have consented to the processing (for example, where you consent to the placing of cookies on our websites, or where you proactively sign-up for an AS Utilities email alert);
it is necessary for us to comply with a legal requirement (for example, in relation to certain checks we are required to carry out on prospective customers or suppliers, disclosures we are required to make to tax authorities, or information we are required to keep about our shareholders); or
it is in our legitimate interests, subject to your interests and fundamental rights.

Disclosure of personal information and international transfers

We are a with divisions, businesses and offices throughout the world, so it will be necessary, from time to time, for us to pass your information between different locations internationally. A full list of our locations is available here: https://www.asutilities.com/worldwide-contacts.

In relation to international transfers in AS Utilities, we have entered into an intra-group data transfer agreement. This incorporates the EU Commission approved Standard Contractual Clauses, ensuring that your personal information receives the same level of protection as if it remained within the European Economic Area (EEA).

We may share your personal information with third parties if we, or substantially all of our or the relevant affiliated company’s assets are acquired by a third party.

We will also respond to requests for information where required by to do so by law.

Cookies

A cookie is a small file that can be placed on your device’s hard drive or on a website server. We use cookies to obtain some of the automatically collected information described above. Most browsers automatically collect cookies but you can refuse the use of cookies. For more information on how to do this, see our cookies page.

Marketing alerts and emails

We may communicate with you by email to tell you about our products and services. If you wish to opt out, please use the ‘unsubscribe’ link in our emails or contact us directly.

Security

We take the security of the information we collect seriously. We use data storage and security techniques to protect your personal information from unauthorized access.

Retention of your information

Generally, we only keep personal information for as long as required to fulfil the purposes for which it was collected.

External links

Our websites may contain links to third-party sites. This policy applies solely to personal information collected by our websites.

Your rights

Under EU data protection laws, you may have rights in respect of your personal information, including to:

get a copy of your personal information;
rectify inaccurate personal information;
erase your personal information;
restrict processing;
challenge processing based on legitimate interest;
prevent direct marketing;
withdraw consent;
object to automated decisions;
obtain safeguards for international transfers.