CMS Distribution Privacy Statement

1. Purpose and Scope

This CMS Distribution Privacy Statement (the “Privacy Statement”) explains how CMS Distribution and companies that we own or control (“Affiliates”) (collectively, “CMS Distribution”, “we”, or “us”) collect, use, store, process, disclose, and delete Personal Data (as defined in this Privacy Statement) you provide directly to us or that we receive from your authorised third parties including, without limitation, that you provide to us via our website, located at the cmsdistribution.com & techxperts.eu domain, or any website of any one of our Affiliates that post or link to this Privacy Statement (individually and collectively, “Website”), accessed through any medium, including via computer, mobile device, or other device (collectively, “Device”).  This Privacy Statement also outlines your rights in respect to your Personal Data.

CMS Distribution is a distributor and reseller of IT products and services, headquartered in Ireland but with Affiliates all around the world.

CMS Distribution provides you with the ability to purchase or access a variety of product and service offerings made available by CMS Distribution and various preferred providers (“Offerings”) both directly from CMS Distribution and through resellers, distributors and vendors. EACH OFFERING MAY BE SUBJECT TO OFFERING-SPECIFIC PRIVACY POLICIES, WHICH MAY SUPERCEDE OR COMPLEMENT THE TERMS OF THIS PRIVACY STATEMENT. CMS DISTRIBUTION ENCOURAGES YOU TO CAREFULLY READ THE PRIVACY POLICY OF ANY OFFERING BEFORE ACCESSING OR USING THAT OFFERING.

Although we encourage you to read this entire Privacy Statement, this is a summary of some of the more important aspects of the Privacy Statement:

  • Each Offering may include its own specific privacy policy. You should carefully read the privacy policy of any Offering before accessing or using that Offering.
  • We may collect Personal Data and other information from you through a variety of sources, including Personal Data we have collected from you, on or offline. We may also combine it with information we receive about you from other sources, such as Affiliates, publicly available information sources (including information from your publicly available social media profiles), and other third parties.
  • We will not use or share your Personal Data except as described in this Privacy Statement.
  • Where applicable, we honor opt out instructions from you for certain uses of your Personal Data under this Privacy Statement, such as, for example, when you opt out of receiving marketing email communications from us or request us to delete your Personal Data.
  • We use appropriate technical and organisational controls to secure and protect your Personal Data, but we cannot ensure or warrant that your Personal Data will be completely secure from misappropriation by hackers or from other nefarious or criminal activities.

2. General Principles for the Processing of Personal Data

Personal Data will be collected, stored, processed and transmitted in accordance with CMS Distribution’s established policies and applicable  local and international laws, rules and regulations.

The principles of CMS Distribution with respect to the processing of Personal Data are as follows:

  1. Personal Data will be processed fairly and lawfully,
  2. Personal Data will be collected for specified, explicit, and legitimate purposes and not further processed for incompatible purposes,
  3. Personal Data collected by CMS Distribution will be adequate, relevant, and not excessive in relation to the purposes for which it is collected,
  4. Personal Data collected by CMS Distribution will be accurate and, where necessary, kept up to date to the best of our ability,
  5. Personal Data will be protected against unauthorised access and processing using appropriate technical and organisational security measures and controls; and
  6. Personal Data collected by CMS Distribution will be retained as identifiable data for no longer than necessary to serve the purposes for which the Personal Data was collected.

If CMS Distribution engages in the processing of Personal Data for purposes other than those specified in this Privacy Statement, CMS Distribution will provide notice of these changes, the purposes for which the Personal Data will be used, and the recipients of Personal Data.

3. Collection of Information

CMS Distribution may collect Personal Data about you from a variety of sources, including, directly from you, from other Users, from resellers and distributors, from our vendors, from our service providers, from third party information providers, from our Affiliates, and through the operation of the Website.

“Personal Data” collected by CMS Distribution includes:

  • your first and last name;
  • billing or shipping address;
  • credit card or payment information;
  • email address;
  • phone number;
  • purchase information and history;
  • your account number;
  • For employment purposes, your CV or professional information; and
  • a combination of your username and password used to access the Website.

Sensitive Information (Special Categories of Data)

Unless we specifically request or invite it, we ask that you not send us, and you not disclose, any sensitive personal data (e.g., information related to racial or ethnic origin, political opinions, religion or other beliefs, health, criminal background or trade union membership) on or through this Website or otherwise to us. In those cases where we may request or invite you to provide sensitive personal data, we will do so with your explicit consent.

CMS Distribution collects your Personal Data as follows:

Information You Provide Voluntarily

We may collect Personal Data directly from you when you voluntarily provide it to us. For example, when you communicate with us over the telephone or through the Website by way of email, online chat, web form, or online account registration to obtain access to Offerings, register for an event or training, purchase an Offering, ask questions, attempt to resolve any issues related to the Website or Offerings, submit a job application, or submit feedback and comments.

Information that We Collect Automatically

When you visit our Website, we may collect certain information automatically from your Device.  In some countries, including countries in the European Economic Area, this information may be considered Personal Data under applicable data protection laws.

Specifically, the information we collect automatically may include information like your IP address, device type, unique device identification numbers, browser-type, your Media Access Control (MAC) Address, broad geographic location (e.g. country or city-level location) and other technical information.  We may also collect information about how your device has interacted with our Website, including the pages accessed and links clicked.

We use this information for our internal analytics purposes and to improve the quality and relevance of our Website to our visitors.

Some of this information may be collected using cookies and similar tracking technology, as explained further under the heading “Cookies and Other Website Usage Information.”

From Other Users

We may receive Personal Data about you from other users of the Website when they provide information to us. For example, we may receive information when they communicate with you or with us through the Website.

From Resellers and Distributors

We may obtain Personal Data about you from the resellers and distributors that purchase Offerings available from us and provide such Offerings to you.

From Our Vendors

We may obtain Personal Data about you from vendors that make Offerings available through us.

From Third Party Information Providers

CMS Distribution may also obtain Personal Data from third parties that have obtained or collected information about you and that have the right to provide that Personal Data to us. CMS Distribution will only obtain this Personal Data where we have checked that these third parties either have your consent or are otherwise legally permitted or required to disclose your Personal Data to us.

4. Use of Information

CMS Distribution uses Personal Data we collect to operate our business and provide you with Offerings, which includes using this data to improve our Offerings and personalise your experiences. We also may use the data to communicate with you, for example, informing you about your account and product information.

CMS Distribution may use your Personal Data for a variety of purposes (the “Purposes”), including to:

  • Provide you with the products and services you purchase. We provide these in line with our contractual obligations to you, either directly through us or through our partners
  • Provide, maintain, and improve the Website and our Offerings, including to operate certain features and functionality of the Website
  • Understand user preferences to enhance users’ experience with CMS Distribution and its Affiliates, contractors, and business partners;
  • Research and analyse the effectiveness of the Website and the marketing, advertising and sales efforts of CMS Distribution, its Affiliates, contractors, and business partners;
  • Collect account receivables owed by customers of CMS Distribution;
  • Process orders and payments made through the Website;
  • Develop additional Offerings;
  • Process job applications;
  • Comply with a legal obligation or respond to lawful requests by public authorities (including national security or law enforcement requirements);
  • Manage our everyday business needs;
  • Enforce compliance with our Terms of Use and applicable law;
  • Prosecute and/or defend a court, arbitration or similar legal proceedings;
  • Communicate directly with you by sending you newsletters, promotions and special offers or information about new products and services on an ongoing basis in accordance with your marketing preferences. You can unsubscribe from our marketing communications by clicking “Unsubscribe” at the bottom of any communication we issue, or by contacting us using the “Questions and Contact Information” details.
  • Communicate directly with you by phone to respond to customer service inquiries or comments through the Website, social media or otherwise, to discuss issues relating to your account or the Website, and to provide customer support.
  • Deliver advertising to you, including to help advertisers and publishers serve and manage ads on the Website or on third party sites, and to tailor ads based on your interests and browsing histories.
  • Compile aggregated statistics about the operation and use of our Website and to better understand the preferences of the visitors of our Website; and

We may combine and enhance the Personal Data we collect about you with other information we receive from third parties in order to provide you with the best service possible.

We may also use the Personal Data we collect about you through the Website to generate anonymised, aggregated data. When we do so, we ensure that the anonymised, aggregated data is no longer personally identifiable and may not later be used to identify you.

5. Information Sharing

We share your Personal Data as necessary to complete any transaction or provide any Offering you have requested or authorised or with your consent where appropriate. We also share Personal Data with vendors, resellers and distributors, service providers, Affiliates and business units when required by law. We may do this to respond to legal process, to protect our customers, to maintain the security of our Offerings, and to protect the rights or property of CMS Distribution.

We may disclose your Personal Data as follows:

Vendors

CMS Distribution may share Personal Data about you with the third party vendors that make Offerings available through us. For example, we may share your Personal Data with a third party vendor if you purchase or access an Offering through us, or an CMS Distribution reseller or distributor, and that vendor requires verification of an Offering purchase in order to register that Offering.

Resellers and Distributors

CMS Distribution may share your Personal Data with the resellers and distributors that purchase Offerings available through the Website. For example, we may share your Personal Data if you purchase or access an Offering through a reseller or distributor, and that reseller or distributor leveraged our reseller tools and services.

Affiliates and Business Units

CMS Distribution may share your Personal Data with our Partners  regardless of whether these entities share the CMS Distribution brand. We may also share your Personal Data with other business units that also offer products or services under the CMS Distribution brand or one of our other brands. Our Affiliates and business units will use your Personal Data we share with them in a manner consistent with this Privacy Statement.

Other Users

CMS Distribution may share your Personal Data with other users when you elect to interact with those users (or request that we communicate with them on your behalf) through the Website. This may include facilitating communications with other users or enabling posting of Personal Data to areas of the Website accessible by other users. You should be aware that any Personal Data (or other information) you provide in these areas may be read, collected, and used by others who access them.

Law Enforcement and Safety

CMS Distribution may share your Personal Data with any competent law enforcement, regulatory, government agency, court, other governmental officials, or other third party where we believe disclosure is necessary (i) as a matter of applicable law or regulation, (ii) to exercise, establish or defend our legal rights, or (iii) to protect your vital interests or those of any other person.

Sale or Acquisition of Assets

If CMS Distribution transfers ownership or control of any portion of CMS Distribution or the Website to an actual or potential buyer, whether in the context of an acquisition, merger, reorganisation, or other disposition of all or any portion of our business, assets, or stock (including in connection with any bankruptcy or similar proceedings), we may transfer your Personal Data to that actual or potential buyer, provided that the use of your Personal Data by that third party remains subject to applicable law.

6. Other Important Privacy Information

Below you will find additional privacy information you may find important.

Security of Personal Data

CMS Distribution uses appropriate technical and organisation controls and measures to secure and protect your Personal Data from unauthorised loss, misuse, and disclosure, such as strong user access controls, segmented network architecture, and comprehensive employee policies and training. It is a priority of CMS Distribution to ensure all Personal Data is protected and secured to the highest level.

CMS Distribution cannot ensure or warrant that Personal Data will be completely secure from misappropriation by hackers or from other nefarious or criminal activities, or in the event of a failure of computer hardware, software, or a telecommunications network. CMS Distribution will notify you in the event we become aware of a security breach involving your personally identifiable information (as defined by the applicable foreign, federal, state, and local laws) in line with our Breach Management process.

Legal Basis for Processing Personal Data

Our legal basis for collecting and using the Personal Data information described above will depend on the Personal Data concerned and the specific context in which we collect it.

However, we will normally collect Personal Data from you only (i) where we need the Personal Data to perform a contract with you (such as to fulfill your purchase of an Offering), (ii) where the processing is in our legitimate interests and not overridden by your rights, or (iii) where we have your consent to do so. In some cases, we may also have a legal obligation to collect Personal Data from you or may otherwise need the Personal Data to protect your vital interests or those of another person.

If we collect and use your Personal Data in reliance on our legitimate interests (or those of any third party), this interest will normally be to operate our platform and communicating with you as necessary to provide our services and Offerings to you, and for our legitimate commercial interest, for instance, when responding to your queries, improving our platform, undertaking marketing, or for the purposes of detecting or preventing illegal activities. We may have other legitimate interests, and if appropriate, we will make clear to you at the relevant time what those legitimate interests are.

Accuracy

It is your responsibility to provide CMS Distribution with accurate Personal Data. Except as otherwise set forth in this Privacy Statement, CMS Distribution shall only use Personal Data in ways that are compatible with the purposes for which it was collected or subsequently authorised by you. To the extent necessary for these purposes, CMS Distribution shall take reasonable steps to ensure that Personal Data is accurate, complete, current and relevant to its intended use.

International Data Transfers

Your Personal Data may be transferred to, and processed in, countries other than the country in which you are resident.  These countries may have data protection laws that are different to the laws of your country.

Specifically, our primary Website servers are located in the United Kingdom, and our Affiliates and partners operate around the world.  This means that when we collect your Personal Data we may process it in any of these countries. However, we have taken appropriate safeguards to require that your Personal Data will remain protected in accordance with this Privacy Statement.

These include implementing the European Commission’s Standard Contractual Clauses for transfers of Personal Data between our Affiliates, which require us to protect Personal Data they process from the EEA in accordance with European Union data protection law. We have implemented similar appropriate safeguards with our partners

Retention Period

We retain Personal Data we collect from you in line with our business retention periods. For example, where we have an ongoing legitimate business need to do so (such as to provide you with an Offering you have requested or to comply with applicable legal, tax or accounting requirements, we may retain the data for up to 7 years.

Your Data Protection Rights

You have the following data protection rights:

  • If you wish to access, correct, update or request deletion of your Personal Data, you can do so at any time by contacting us using the contact details provided under the “Questions and Contact Information” heading.
  • In addition, if you are a resident of the European Union, you can object to processing of your Personal Data, ask us to restrict processing of your Personal Data or request portability of your Personal Data. Again, you can exercise these rights by contacting us using the contact details provided under the “Questions and Contact Information” heading.
  • You have the right to opt-out of marketing communications we send you at any time.  You can exercise this right by clicking on the “unsubscribe” or “opt-out” link in the marketing emails we send you.  To opt-out of other forms of marketing (such as postal marketing or telemarketing), then please contact us using the contact details provided under the “Questions and Contact Information” heading or access our preference center.
  • Similarly, if we have collected and process your Personal Data with your consent, then you can withdraw your consent at any time.  Withdrawing your consent will not affect the lawfulness of any processing we conducted prior to your withdrawal, nor will it affect processing of your Personal Data conducted in reliance on lawful processing grounds other than consent.
  • You have the right to complain to a data protection authority about our collection and use of your Personal Data.  For more information, please contact your local data protection authority with for the United Kingdom is: Information Commissioners Office (ICO), Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF. Further information is available here

Children and Vulnerable Customers

CMS Distribution does not knowingly solicit or collect Personal Data from children under 18 years of age

Third Party Websites

In addition to providing access to Offerings, the Website may include links to other websites and web services. This Privacy Statement does not apply to those websites and services and the privacy practices of those websites and services may differ from those described in this Privacy Statement. CMS Distribution encourages you to carefully read the privacy policy of any website or web service you visit.

Compliance

CMS Distribution will use a self-assessment approach to verify compliance with this Privacy Statement and periodically verify that the Privacy Statement is accurate, comprehensive for the information intended to be covered, prominently displayed, implemented and accessible.

Revisions

CMS Distribution may from time to time revise this Privacy Statement in its sole and absolute discretion to reflect changes in our business practices. If we revise this Privacy Statement, we will notify you by posting the updated Privacy Statement on this Website or by sending you a notification by email. Changes to the Privacy Statement will become effective and will apply to the information collected starting on the date CMS Distribution posts the revised Privacy Statement on the Website.  If we are required by applicable data protection laws to seek your consent to any changes in use of your Personal Data described in our updated Privacy Statement, then we will do that.

7. Cookies and Other Website Usage Information

The Website may also monitor and collect information about how you access, use, and interact with the Website automatically through “cookies,” “flash cookies”, “web beacons,” and other automated tracking technology.

A “cookie” is a small text file that is stored on a user’s Device. Cookies allow us to collect information such as browser type, time spent on the Website, pages visited, and language preferences. We and our service providers use the information for security purposes, to facilitate navigation, display information more effectively, and to personalise your experience while using the Website.

For more information please see our Cookie Policy

8. Questions and Contact Information

If you have any questions or concerns about this Privacy Statement, the privacy practices of CMS Distribution, our collection or use of your Personal Data, or you wish to access your Personal Data, please contact us at

Email: compliance@cmsdistribution.com

Post: Compliance, CMS Distribution, Gardner House, Hornbeam Park Avenue, Hornbeam Park, HG2 8NA

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