Privacy Statement

LPA Group Plc (“LPA”, also referred to as “we”, “us”, “our” or the “Company”) respects your privacy and your personal data.  This Privacy Policy explains what personal data we collect and how it is used.  It also explains what rights you have over your data and how you can use those rights.

Who we are

LPA is a world leader in the design, build and supply of LED lighting, electrical connectors/connector systems, and high performance electrical components within the B2B sector.

LPA comprises a number of entities (our “Site(s)”, together the “Group”) to which this Privacy Policy applies.  Personal information maybe shared amongst the LPA entities for marketing or business relevant activities, employee personal information where services, such as the provision of benefits and pensions, are administered centrally within a Group Site.

Summary

• Summary of how we use your data
• Information we collect from you
• How we use information and the legal basis
• Withdrawing consent or otherwise objecting to direct marketing
• Data sharing
• International data transfers
• Cookies and similar technologies
• Data retention
• Your rights
• Your responsibilities
• Contact details
• Which LPA entity is the controller?
• Summary of how we use your data

LPA uses your personal data to undertake its contractual obligations, business marketing and product awareness activities including dealing with enquiries and enable users to receive new documents and material through direct marketing activities or uploaded to our website and deal with enquiries.  As a B2B Company we hold minimal personal data that is not already available in the public domain.

Our website may use cookies.  In simple terms, cookies improve functionality and customise the site for you.  This allows us to send you LPA promotional material we think is most relevant for you, based on your use of our site.  If your settings allow us to, our cookies capture grouped data to understand how our site works for users.  This helps us improve our site and your experience.

Information we collect from you

We collect information from you on certain occasions.  This may include your name, IP address, email, date of birth, gender, phone number, address, telephone conversations and correspondence.  Visitors to our sites may be captured by CCTV and visitor information will be requested, including the time and date of your visit and vehicle details.  In particular:

We keep information you give us directly such as contact details, address, comments, feedback and marketing preferences.

If you engage with us online via our website our cookies will capture your IP address, your location, and record how you use the site to help improve it and improve your user experience.

If you post information online about us or provide feedback, we may keep a record.

If you give feedback we will record details and all related information such as emails, letters and phone calls

How we use information and the legal basis

To do what we need to, in order to run our business (and ‘pursue our legitimate interests’),

• we use your information to provide and improve our website and businesses, and respond to any comments or complaints you may send us,
• we monitor the LPA website and postal communications and responses to email marketing,
• to maintain records for our administrative purposes,
• to undertake our contractual obligations with our employees, investors, customers, suppliers and all stakeholders in our Company.

We may, if you give us consent:

• send you hard copy or electronic marketing in relation to our relevant products and services, or those of other LPA Group companies and carefully selected partners of ours. You can subscribe or unsubscribe from our marketing communications by contacting us,
• pass your personal data on to a Group site or a supplier to assist in providing the administration of our products, website or our services,
• place cookies and use similar technologies – for more information on our use of Cookies see below,
• use data for other purposes where we explain that purpose when we ask for consent,

Where we are required to process your data by law:

• In response to requests by the government or law enforcement authorities conducting an investigation,
• in connection with complaints, legal claims, compliance, regulatory and investigative purposes as necessary.

If you exercise your rights under data protection legislation such as where you wish to subscribe or unsubscribe from our marketing communications.

Withdrawing consent or otherwise objecting to direct marketing

Wherever we rely on your consent to process your personal data, you will always be able to withdraw that consent, although we may have other legal grounds for processing it, such as those set out above. Nevertheless, you have an absolute right to opt-out of direct marketing, or profiling we carry out for direct marketing at any time. You can do this by following the instructions in the communication where this is an electronic message, or by contacting us using the details set out below.

When you give consent, you can withdraw that consent at any time by contacting us. If you do so we can only continue to use your data if another legal basis applies, such as when we’re required to do something by law or to fulfil our contractual obligations.

Data Sharing

Data maybe shared within the LPA Group. We use third party providers for the following services:

• Hosting and maintenance of our website and IT services,
• marketing, such as customer insight, relationship management and research,
• investor relations and maintenance of our Company registers, provision of investor materials and payment of dividends,
• provision of employee benefits including pensions and wellbeing services,
• insurances,
• external audits for regulatory and financial purposes, insurances and accreditation.

In the event that the business is sold or integrated with another business, your details will be disclosed to our advisers and any prospective purchaser’s adviser and will be passed to the new owners of the business, in which case you will be notified.

Personal data may be shared with government authorities and/or law enforcement officials if required by law or if required for a legal claim.

International Data Transfers

Your personal data will not be transferred outside the European Economic Area.   LPA’s Sites are based within the UK but operates in markets worldwide.

Cookies and similar technologies

Our website uses cookies.  Full information is in our cookies policy. This includes information on how to adjust your browser settings to accept or reject cookies.

Data Retention

We keep information on active stakeholders, until you advise us you no longer wish to receive notifications or our contractual obligations have expired.

Customer and supplier interactions are stored, depending on the nature of the interaction and any applicable law.  We look to keep information for the minimum time in line with data protection principles and our processes.

If you unsubscribe from marketing communications, we keep a record of this request indefinitely to ensure we do not send you direct marketing again.

Your rights

You have rights over your personal data.  You can ask for a copy of your information.  You can ask for information to be corrected or deleted.  You can ask for us to limit or restrict processing.  You can object to us processing your data.  You can ask for a copy to be sent in structured digital format or ask for us to send it to another party.

Some rights may however be limited, for example we may be obliged by law to keep information, and as we have to respect other people’s privacy so we may not be able to meet your request where that would reveal personal data about someone else.  Sometimes there may be a compelling legitimate interest to keep processing data.

To process a request from you, we will need to confirm your identity to ensure we’re accessing the right data.

If you have a data protection question or concern please contact us at the LPA contacts provided below You have a right to complain to an EU data protection authority.  This can be where you live, work or where the matter occurred. In the UK, the authority is the Information Commissioner’s Office (the “ICO”), details available at: www.ico.org.uk.

Your responsibilities

We will maintain your data accurately but rely upon you advising of any changes or omissions.  Please keep us informed of any changes by contacting us.

Contact details

Contact details, including addresses, phone numbers and email addresses for our Sites can be found on our website.

For any queries relating to data protection please contact us as shown, where your query will be passed to our relevant Site contact.

If we make any changes or updates to this notice we will communicate these.  Our Group entities administer and maintain data privacy procedures in line with this Privacy Policy.

Which LPA Site is my data controller, and which affiliates might my data be shared with?

The Group Site you communicate with is the data controller but data may be shared within the LPA Group.  Each Site is its Data Controller and records who are their data processors.

Issue: 21.1 effective 5 May 2021