HOLT LLOYD INTERNATIONAL LTD
WEBSITE PRIVACY NOTICE
This Privacy Notice applies to users of our website who submit general enquiries, complaints or feedback by phone, email or post and sign up to our email newsletter. We only process your personal information for the purpose of responding to such enquiries and sending email newsletters.
This Privacy Notice explains what data we process, why, how it is legal and your rights.
ABOUT US AND THIS NOTICE
This Privacy Notice applies to personal data collected through our website https://www.holtsauto.com/ which is available for users in the UK, France and Germany or when you contact us by phone, email or post and sign up to our email newsletter.
This Privacy Notice is provided by Holt Lloyd International Ltd (registered in England and Wales with company number 01235124) whose registered address is Unit 100, Barton Dock Road, Stretford, Manchester, M32 0YQ, United Kingdom (“Holts “, “we” or “us”). We are a ‘controller’ for the purposes of the General Data Protection Regulation (EU) 2016/679 (“GDPR“) and the Data Protection Act 2018 and any other national legislation that relates to data protection and privacy (collectively the “Data Protection Laws“).
We take your privacy very seriously. We ask that you read this Privacy Notice carefully as it contains important information about our processing and your rights.
How to contact us
If you have any questions about this Privacy Notice, how we handle your personal data, or want to exercise any of your rights, please contact:
|· Digital Manager||Kat Morris|
|· Address:||Holt Lloyd International Ltd
Unit 100, Barton Dock Road,
Stretford, Manchester, M32 0YQ
|· Telephone number:||+44 (0)161 866 4800|
Changes to the Privacy Notice
We may change this Privacy Notice from time to time. We will alert you on the website when changes are made.
Current version: [June 2019]
WHAT PERSONAL DATA DO WE COLLECT AND WHY?
Personal data provided by you
- Visitors only
If you are just browsing our website we will not collect personal data.
- Information you submit
We process personal information about you (such as your name, address, email address and telephone number and anything else that you provide to us) when you contact us by phone, email or post in order to respond to the enquiry you are making.
We also collect personal information when you contact us, send us feedback or complete surveys which we use to improve our services and products in the future.
- Email newsletter
If you sign up to receive our email newsletter, which contains information about our new products, offers, competitions and news, we will use your name, email address, company name and your area of interest.
You can unsubscribe at any time by contacting us at the details set out above or clicking the “unsubscribe” link in the emails that you receive.
Special categories of personal data provided by you
We do not collect any special categories of personal data about you unless you decide to provide it to us.
Personal information about other individuals
If you give us information on behalf of someone else, you confirm that the other person has appointed you to act on their behalf and has agreed that you can.
HOW IS PROCESSING YOUR PERSONAL DATA LAWFUL?
We are allowed to process your personal data on the following legal bases:
It is in our legitimate interests to:
- Respond to enquiries in order to serve our customers and provide product assistance;
- Generate statistical data that, to the extent that anonymised data ceases to be personal data;
- Monitor how our website is used in order to improve it. We use aggregated data to do this so it does not impact on your privacy; and
- Provide information about our goods and/or services to customers who have purchased similar goods and/or services from us.
Please be aware that you have the right to object to the processing of your data in relation to the legitimate interests identified and we must cease the relevant processing activities if we cannot demonstrate compelling legitimate grounds for the processing which override your interests, rights and freedoms or for the establishment, exercise or defence of legal claims.
We will only send our email newsletter to you if you have provided us with your consent when required. You can withdraw this consent at any time.
WHO WILL HAVE ACCESS TO YOUR PERSONAL DATA?
Like any business, we use service providers to operate our website. Some of these service providers will process your data as part of the services they offer to us. We take steps to ensure that our service providers treat your data in accordance with the law, only use it in accordance with our contract with them and keep it secure.
The table below lists some of our key service providers that act as our processors who will have access to your personal data. If you would like to know the categories of our other service providers, please contact us using the details at the start of this Privacy Notice.
|KIK Custom Products Inc. – IT system support|
|MailChimp – mass mailing service|
|The Foundry Communications – website hosting and servers|
We also share data with our affiliates (for the purposes of taking strategic decisions at group level) and as necessary to enforce our legal rights, defend legal claims and if required by law to disclose to courts, police, law enforcement agencies or regulators.
Transfers of your information out of the European Economic Area (“EEA”)
We need to transfer your data to the US for KIK Custom Products Inc. to provide us with IT services. Any transfer of your data will be carried out in accordance with the law to safeguard your privacy rights and give you remedies in the unlikely event of a security breach or to any other similar approved mechanisms. In the case of the US we ensure that the relevant company has entered into a data transfer agreement containing clauses offering an adequate level protection according to the European Commission, has adopted corporate binding rules, benefits from the U.S. “Privacy Shield” accreditation or has otherwise implemented appropriate safeguards. In the event that KIK Custom Products Inc. use service providers based in other countries outside the UK and the EEA, we will ensure that the transfer of personal data is carried out in accordance with the Data Protection Laws using appropriate safeguards. If you want to know more about how personal data is transferred and obtain a copy of the documentation providing for such appropriate safeguards, please contact us using the details in the section headed “How to Contact Us”.
How we keep your data secure
We strive to implement appropriate technical and organisational measures in order to protect your personal data against accidental or unlawful destruction, accidental loss or alteration, unauthorised disclosure or access and any other unlawful forms of processing. We aim to ensure that the level of security and the measures adopted to protect your personal data are appropriate for the risks presented by the nature and use of your personal data. We follow recognised industry practices for protecting our IT environment and physical facilities.
WHEN WILL WE DELETE YOUR DATA?
The table below provides details about how long we will process your data.
|Data we process||How long this will be held for|
|Information from enquiries||Until the enquiry has been completed and no further responses are received for 3 years.|
|Email newsletter||3 years from your last purchase or other contact (or until you tell us that you no longer wish to receive the email newsletter).|
|Data relating to the exercise of the right of opposition with a controller established in France.||6 – 7 years in archives after the response to the request or, in case of any pending litigation at the end of this period for which this data is relevant, after final settlement thereof|
|Data relating to the exercise of other rights such as the right of access or rectification with a controller established in France||1 – 2 years in archives after the response to the request or, in case of any pending litigation at the end of this period for which this data is relevant, after final settlement thereof|
As a data subject, you have the following legal rights:
- Right of access to personal data relating to you
- Right to correct any mistakes in your information
- Right to ask us to stop contacting you with direct marketing
- Right to prevent your personal data being processed in some circumstances
- Right to object to processing of your data where processed on the grounds of legitimate interests
- Right to erasure in some circumstances
- Right to withdraw consent
If you would like to exercise your rights, please contact us at the details set out above in the section headed “How to contact us”.
We will respond to any rights that you exercise within a month of receiving your request, unless the request is particularly complex and/or if we receive a high number of requests, in which case we will respond within three months.
Please note that exceptions apply to some of these rights which we will apply in accordance with the law.
For users in France, according to the French Data Protection Laws, you may write to us to let us know how to handle your personal information after your death.
What will happen if your rights are breached?
You may be entitled to compensation for damage caused by contravention of the Data Protection Laws.
Complaints to the regulator
If you do not think that we have processed your data in accordance with this Privacy Notice, you should let us know as soon as possible. You also have the right to complain to the relevant supervisory authority in your country. Information about how to do this is available on each supervisory authority’s website as provided below: