PRIVACY POLICY

GDPR: DATA PRIVACY NOTICE FOR EMPLOYEES, CLIENTS AND SUPPLIERS 18/07/21

Introduction

Carrutaco Ltd are committed to protecting and respecting your privacy. We hold honesty and transparency amongst our core values and we believe in investment in our client relationships. This policy, together with our terms and conditions, sets out the basis on which any personal data we collect from you, or that you provide to us, will be processed by us. Please read the following carefully to understand our views and practices regarding your personal data and how we will treat it. The rules on processing of personal data are set out in the General Data Protection Regulation (the “GDPR”).

1. Definitions

Data controller – A controller determines the purposes and means of processing personal data.

Data processor – A processor is responsible for processing personal data on behalf of a controller.

Data subject – Natural person

Categories of data: Personal data and special categories of personal data

Personal data – The GDPR applies to ‘personal data’ meaning any information relating to an identifiable person who can be directly or indirectly identified in particular by reference to an identifier (as explained in Article 6 of GDPR). For example name, passport number, home address or private email address. Online identifiers include IP addresses and cookies.

Special categories personal data – The GDPR refers to sensitive personal data as ‘special categories of personal data’ (as explained in Article 9 of GDPR). The special categories specifically include genetic data, and biometric data where processed to uniquely identify an individual. Other examples include racial and ethnic origin, sexual orientation, health data, trade union membership, political opinions, religious or philosophical beliefs.

Processing – means any operation or set of operations which is performed on personal data or on sets of personal data, whether or not by automated means, such as collection, recording, organisation, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction.

Third party – means a natural or legal person, public authority, agency or body other than the data subject, controller, processor and persons who, under the direct authority of the controller or processor, are authorised to process personal data.

2. Who are we?

Carrutaco Ltd are a Petrochemical and Petroleum trading company. Ben Taverner, Director at Carrutaco Ltd is the data controller. This means Ben Taverner supported by Carrutaco Ltd affiliates, governs and decides how your personal data is processed and for what purposes. Our contact details are: ben@carrutaco.com. For all data matters please contact Ben Taverner, Director, Carrutaco Ltd, 85 Great Portland Street, London W1W 7LT.

3. The purpose(s) of processing your personal data

You may give us information about you by filling in forms on our site www.carrutaco.com (our site) or by corresponding with us by phone, e-mail, WhatsApp, social media interaction or otherwise. This includes information you provide when you register to use our site, subscribe to our service, search for a product or service, place an order, participate in discussion boards or other social media functions on our platforms, enter a competition, promotion or survey online, when you report a problem with our site and request a quote from us.

4. The categories of personal data concerned

With reference to the categories of personal data described in the definitions section, we process the following categories of your data: Name, position, employer, phone numbers inc. personal mobile, email addresses, company addresses, supervisor names and positions, names and positions of colleagues within your company along with copies of NDA & Terms and Conditions of contracts, record of quotes provided, previous work and contracts we have entered into with you and value of that business along with your credit rating score via publicly available sources.

5. What is our legal basis for processing your personal data (article 6 of GDPR)?

Our lawful basis for processing your general personal data:
Processing data necessary for the performance of a contract with the data subject or to take steps to enter into a business contract and agreement of Terms and Conditions of Contracts and/or
Processing necessary for compliance with a legal obligation – HMRC and agreement of Terms & Conditions of Business and/or
Processing data where Consent of the data subject is given directly or
Processing data for potential engagement in a contract of business as a B2B legitimate interest
Processing of B2B data under PECR regulations

6. How do we record this data?

Name, position, employer, phone numbers inc. personal mobile, email addresses, company addresses, supervisor names and positions, names and positions of colleagues within your company, record of quotes provided, record of services provided or enquired after, previous work and contracts we have entered into with you and value of that business are all stored on our secure accounting and Sales and Marketing Software which is accessed via personal login by authorised Carrutaco employees only. Copies of signed NDA & Terms and Conditions of contracts along with all sales invoices are all stored either electronically on the Carrutaco network, which is accessed by authorised Carrutaco employees only via personal login and/or paper copies are stored in secured location within Carrutaco premises.

7. Monitoring of Communication

From time to time, we monitor communications – calls, text messages, emails, social media content and other communications in relation to dealing with customers. We do this for governance of regulatory compliance, self-regulation practice, crime prevention and conduct to protect the security of our communication systems and procedures. To check for obscene or profane content, quality control and staff training and this is justified by our legitimate interests or our legal obligations/NDA with clients.

8. Sharing your personal data

Your personal data will be treated as strictly confidential & will be shared only with Carrutaco Accountants for AR/AC, VAT and Carrutaco employees only.

9. How long do we keep your personal data?

We keep your personal data for no longer than reasonably necessary & we retain your data for the period of engagement in a contract of business and/or period of potential engagement in a contract of business as a legitimate interest. Your data will be securely stored with limited access given to relevant Hoverfly Design Ltd employees and New Business Consultants only as engaged by Hoverfly Design Ltd, until you notify us otherwise in writing, at which time your data will be permanently removed from our records and destroyed at your request. (see 9.)

10. Providing us with your personal data

We require your data to enable us to communicate with you, enter into and fulfil business contracts with you and provide you with ongoing information on Carrutaco Ltd as a legitimate interest.

11. Your rights and your personal data

Unless subject to an exemption under the GDPR, you have the following rights with respect to your personal data:

The right to request a copy of the personal data which we hold about you;

The right to request that we correct any personal data if it is found to be inaccurate or out of date;

The right to request your personal data is erased where it is no longer necessary to retain such data;

The right to request that we provide you with your personal data and where possible, to transmit that data directly to another data controller, (known as the right to data portability), (where applicable i.e. where the processing is based on consent or is necessary for the performance of a contract with the data subject and where the data controller processes the data by automated means);

The right, where there is a dispute in relation to the accuracy or processing of your personal data, to request a restriction is placed on further processing;

The right to object to the processing of personal data where applicable i.e. where processing is based on legitimate interests or the performance of a task in the public interest/exercise of official authority; direct marketing and processing for the purposes of scientific/historical research and statistics.

12. Transfer of Data Abroad

We do not transfer personal data outside the UK without your prior consent. We will only request this in relation to making travel bookings for international business only where appropriate.

13. Automated Decision Making

We do not use any form of automated decision making in our business.

14. Further processing

If we wish to use your personal data for a new purpose, not covered by this Data Privacy Notice, then we will provide you with a new notice explaining this new use prior to commencing the processing and setting out the relevant purposes and processing conditions.

15. Changes to our privacy policy

Any changes we may make to our privacy policy in the future will be posted on this page and, where appropriate, notified to you by e-mail. Please check back frequently to see any updates or changes to our privacy policy.

16. How to make a complaint

To exercise all relevant rights, queries or complaints please in the first instance contact Ben Taverner, Director, ben@carrutaco.com. If this does not resolve your complaint to your satisfaction, you have the right to lodge a complaint with the Information Commissioners Office on 03031 231 113 or via email https://ico.org.uk/global/contact-us/email/ or at the Information Commissioner’s Office, Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF, England.