Devro respects your privacy and is committed to protecting your personal data. This privacy notice will inform you as to how we look after your personal data if you are have been or are currently a shareholder of Devro plc and tell you about your privacy rights and how the law protects you.
This privacy notice is provided in a layered format so you can click through to the specific areas set out below. Alternatively you can download a pdf version of the policy. Please also use the Glossary to understand the meaning of some of the terms used in this privacy notice.
This privacy notice is relevant where you are an individual and are a current or former registered shareholder of Devro plc (Devro). It makes you aware of how and why your personal data will be used, namely for the purposes of managing your shareholding in Devro, and how long it will usually be retained. It provides you with certain information that must be provided under data protection laws.
If you have any questions about this privacy notice, please contact us, as set out under paragraph 12.
We will comply with data protection law which states that the personal information we hold about you must be:
In connection with your shareholding in Devro we will collect, store, transfer, and use the following categories of personal information about you:
We do not knowingly collect any "special categories" of more sensitive personal information or information about criminal convictions and
We collect personal information from you, the shareholder:
We will use the personal information we collect about you when the law allows us to. We have set out below a description of the ways we plan to use your data and the legal bases we rely on to do so:
Purpose / Activity | Lawful basis for processing |
Manage your shareholding in Devro and keep your record on the shareholder register up-to- date | Necessary to comply with a legal obligation |
Make shareholder communications and shareholder meeting materials available to you, such as the Annual Report and the Notice of Annual General Meeting | Necessary for our legitimate interests (to communicate effectively and engage with our shareholders) |
Pay dividends to you | Necessary for our legitimate interests (to engage with our shareholders) |
Allow you to exercise your rights as a shareholder, such as the right to vote at shareholder meetings | Necessary to comply with a legal obligation |
Respond to any correspondence you send to us | Necessary for our legitimate interests (to communicate effectively and engage with our shareholders) |
To help us prevent and detect fraud and fight financial crime, to verify your identity and carry out tracing activities | Necessary for our legitimate interests (to meet our regulatory obligations) |
If you do not provide information when requested, which is necessary for us to register or maintain your shareholding, you may not be able to hold shares in Devro.
We do not use automated decision-
We will only share your personal information with third parties where required by law, where it is necessary for the purposes of managing your shareholding or where we have another legitimate interest in doing so including:
Transferring information outside the EEA
We will retain your personal information for as long as reasonably required to achieve the purposes for which it was collected. Your record in the shareholder register will be maintained while you are a shareholder of Devro.
If you cease to hold Devro shares, your information will be kept for a period of up to 10 years following the last update to your record on the shareholder register, or for as long as is necessary to resolve any outstanding matters relating to your shareholding or to meet legal, regulatory or tax requirements.
Under certain circumstances, by law you have the right to:
If you wish to exercise any of the rights set out above, please contact us in writing as set out under paragraph 12. We will endeavour to respond to you within one month of receipt of your request. Occasionally it could take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.
We reserve the right to update this privacy notice at any
The Data Protection Support Team (the DPST) is responsible for advising and overseeing this Privacy Notice and is contactable by e-mail on dpst@devro.com if you have any queries or comments. If you are dissatisfied with the response to any query or comment you receive from the DPST, please contact The Company Secretary, Devro plc, Gartferry Road, Moodiesburn, Chryston, G69 0JE.
You have the right to make a complaint at any time to the Information Commissioner's Office (ICO), the UK supervisory authority for data protection
If you believe that a breach of your privacy has occurred, we encourage you to contact the Data Protection Support Team using the contact details in section 11 above to discuss your concerns.
You also have the right to make a complaint at any time to the relevant supervisory authority for data protection issues, which in the UK is The Information Commissioner’s Office (“ICO”). Contact details for the ICO are as follows:
Information Commissioner's Office
Wycliffe House
Water Lane
Wilmslow
Cheshire
SK9 5AF
Telephone: 0303 123 1113
Fax: 01625 524510
Term | Definition |
Data Controller | the person or organisation that determines when, why and how to Process Personal information |
Data Retention Policy | explains how we classify and manage the retention and disposal of information. Time periods for retention are set out in the retention schedule attached to the Data Retention Policy. |
Data Subject | a living, identified or identifiable individual about whom we hold Personal information. Data Subjects may be nationals or residents of any country and may have legal rights regarding their Personal information. |
Personal Information | any information identifying a Data Subject or information relating to a Data Subject that we can identify (directly or indirectly) from that data alone or in combination with other identifiers we possess or can reasonably possess. Personal Information includes Special Categories of Personal Information |
Privacy Notice | a separate notice setting out information that may be provided to Data Subjects when the organisation collects information about them. |
Processing or Process | any activity that involves the use of Personal information. It includes obtaining, recording or holding the data, or carrying out any operation or set of operations on the data including organising, amending, retrieving, using, disclosing, erasing or destroying it. Processing also includes transmitting or transferring Personal information to third parties |
Sensitive Data or Special Categories of Personal Information | information revealing racial or ethnic origin, political opinions, religious or similar beliefs, trade union membership, physical or mental health conditions, sexual life, sexual orientation, biometric or genetic data. |
Location | Entity |
Australia and New Zealand | Devro Pty Limited (No. ACN 050 095 755) Registered Address: 139 Sydney Road, Kelso, NSW, 2795, Australia |
China | Devro (Nantong) Technology Co., Limited (913 206 910 850 779 46T) Registered Address: No 329, Xinxing East Road, Nantong Economic and Technological Development Area, Nantong, Jiangsu, People’s Republic of China |
Czech Republic | Devro s.r.o. (No, C19560) Registered Address: Víchovská 830, 514 19 Jilemnice, Czech Republic |
Hong Kong | Devro Asia Limited Devro Asia Limited Registered Address: 7/F C K K, Commercial Centre, Wanchai, 289 Hennessey Road, Hong Kong |
Japan | Devro KK (No: 0100-01-051259) Registered Address: Yasuda Shibaura Building, No 2, 3-2-12, Kaigan Minato-ku, Tokyo, 108-0022 Japan |
Netherlands | Devro B.V. (No. 10041845) Registered Address: Willem Alexanderstraat 9, 6691 EE Gendt, Netherlands |
United Kingdom | Devro plc (No. SC129785) Registered Address: Moodiesburn, Chryston, Scotland, G69 0JE or Devro (Scotland) Limited (No. SC129787) Registered Address: Moodiesburn, Chryston, Scotland G69 0JE |
USA | Devro, Inc (State ID Number: 0763710) Registered Address: 2711 Centerville Road, Suite 400, City of Wilmington 19808, County of New Castle, United States |