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Business Partner Privacy Policy

1.       Overview


1.1.    This Policy is applicable to the processing by Autogas Ltd (registered company no. 3523830 Cardiff) whose registered address is Athena House, Athena Drive, Tachbrook Park, Warwick, CV34 6RL (hereafter referred to as ‘the Company’ we or us) of all personal data belonging to customers, suppliers and third parties (“Business Partner”). This Privacy Statement is not applicable to business related data and/or data on companies.


1.2.    The Company takes the security and privacy of data seriously. We need to gather and use information or ‘data’ about you as part of our business and to manage our relationship with you. We intend to comply with our legal obligations under the Data Protection Act 2018 (the ‘2018 Act’) and the EU General Data Protection Regulation (‘GDPR’) in respect of data privacy and security. We have a duty to notify you of the information contained in this policy.


1.3.    This policy applies to customers, suppliers and third parties – hereafter referred to as Business Partner.  If you fall into one of these categories then you are a ‘data subject’ for the purposes of this policy.


1.4.    The Company has separate policies and privacy notices in place in respect of Employees and Job Applicants. A copy of these can be obtained by contacting [email protected]


1.5.    The Company has measures in place to protect the security of your data in accordance with legislative requirements.


1.6.    The Company will hold data in accordance with our Data Retention Policy. A copy of this can be obtained from the General Manager. We will only hold data for as long as necessary for the purposes for which we collected it.


1.7.    The Company is a ‘data controller’ for the purposes of your personal data. This means that we determine the purpose and means of the processing of your personal data.


1.8.    This policy explains how the Company will hold and process your information.  It explains your rights as a data subject.


2.       Data Protection Principles


2.1.    We are committed to protecting the privacy and security of your personal information and we will always treat you and your data with the respect you deserve. Personal data must be processed in accordance with six ‘Data Protection Principles.’ We are accountable for these principles and must be able to show that we are compliant.


2.2.    It must:

·         be processed fairly, lawfully and transparently;

·         be collected and processed only for specified, explicit and legitimate purposes;

·         be adequate, relevant and limited to what is necessary for the purposes for which it is processed;

·         be accurate and kept up to date. Any inaccurate data must be deleted or rectified without delay;

·         not be kept for longer than is necessary for the purposes for which it is processed;

·         be processed securely.


3.       How we define personal data


3.1.    Personal data’ means information which relates to a living person who can be identified from that data (a ‘data subject’) on its own, or when taken together with other information which is likely to come into our possession. It includes any expression of opinion about the person and an indication of the intentions of us or others, in respect of that person. It does not include anonymised data.


3.2.    This policy applies to all personal data whether it is stored electronically, on paper or on other materials.


4.       How we define processing


4.1.    ‘Processing’ means any operation which is performed on personal data such as:

·         collection, recording, organisation, structuring or storage;

·         adaption or alteration;

·         retrieval, consultation or use;

·         disclosure by transmission, dissemination or otherwise making available;

·         alignment or combination; and

·         restriction, destruction or erasure.


4.2   This includes processing personal data which forms part of a filing system and any automated processing.


5.       For which purposes do we process your personal data?


5.1.    Autogas Ltd may collect personal information which we receive when:

·                  you use our website

·                  you contact us

·                  you are a recipient of our services


5.2.    When you use our Website: By using our Website, you grant us permission to collect, use and process both the direct and indirect information you provide. If you use our Website, we process technical data to offer you our Website’s functionalities and to allow our Website's administrators to manage and improve our Website's performance. If you enter data in our Website, such as your location to receive relevant information or functionalities, Autogas Ltd processes this data to provide you with the requested information or functionalities. For this purpose: we process personal data based on our legitimate interest to offer technically adequately working Website and to improve our Website performance; we process the personal data you have entered into our Websites or that is generated by the functionalities you have used in our Website and the technical data from your device such as its IP address, the internet browser you use and the pages you have visited on our Website.


5.2.1. Links to other websites: Our Website may contain links to other websites of interest. However, you should note that we do not have any control over these other websites. Once you have used any of these links to leave our site, therefore, we cannot be responsible for the protection and privacy of any information which you provide whilst visiting these sites and such sites are not governed by this privacy statement.


5.2.2. Cookies: Cookies are small pieces of data stored within your internet browser. They contain information about your browsing preferences, any relevant log-in details and other activity related to a particular website. Enabling cookies will improve the experience you receive on our website, making it more convenient to browse, navigate and make repeat visits and transactions. Cookies identify you only through a unique user ID number, unless specifically stated otherwise at the request location. You can disable cookies on your computer by changing the settings in your browser. However, if you disable cookies then you may be unable to access certain areas of our website.


5.3.    For customers:

5.3.1. For answering your questions: If you get in touch with us, we will use your personal data in order to reply to and answer your question(s). For this purpose we process your personal data for this purpose on the basis of your consent when you provide us with your personal data; we process your name, contact details, your correspondence with us, your question(s) and all other personal data which are necessary to answer your question(s).


5.3.2. For marketing purposes: We use the information stored in our customer and prospect databases for the development, execution and analysis of market research and marketing strategies. For this purpose: we may send you marketing communications based on your consent; we may also use personal data based on our legitimate interest to improve our marketing strategies; we process data including but not limited to your name, address, email address, contact preferences, type of vehicle, correspondence with us. If you have consented to receive marketing information, you may opt out at a later date by writing to us at [email protected]  You have a right at any time to stop us from contacting you for marketing purposes.


5.3.3. To allow you to connect with us: Autogas Ltd is active on social media platforms like Facebook, Twitter, LinkedIn and YouTube. When you contact Autogas Ltd via social media, we process your personal data in order to answer your questions and to respond to your messages. For this purpose: we process personal data based on our legitimate interest to adequately respond to your questions and correctly refer you to our social media pages: we process the communication channel you have chosen to use to connect with us and the personal data you supply to Autogas Ltd. This includes your (user) name, address, email address and the personal data you have included in your message.


5.3.4. When you participate in events or promotions:  If you choose to participate in promotions or events, we need your personal data to be able to announce and organise these. In addition, if you participate in any of these activities, we need your personal data to measure the response to events and/or promotions. For this purpose: we process personal data based on your consent. You can withdraw your consent at any time, without this affecting the lawfulness of processing based on consent before withdrawal; we process your name, address, email address and your entries and/or participation in the relevant event.


5.4.    For Suppliers/Third Parties:


5.4.1. For the assessment and acceptance of a supplier or business partner: When you get in contact with us, we will process your personal data for assessment and acceptance purposes, for example in order to confirm and verify your identity. Autogas Ltd will further process your personal data for other administrative purposes such as due diligence and screening against publicly available government and/or law enforcement agency sanctions lists. For this purpose: we process personal data because this is necessary for the conclusion of a contract between you and us. Autogas Ltd cannot enter into contracts without obtaining the required information; we process your contact details such as your address and email address, personal details such as your name and date of birth, payment and credit information and details of your correspondence with us.


5.4.2. For relationship management and the conclusion and execution of agreement: When you work together with us as a supplier or business partner, we process your personal data for administrative purposes such as sending invoices, making payments, and performing account management. We use your personal data in order to deliver or receive and administer our or your products or services and to further execute our agreement. For this purpose: we process personal data because this is necessary for the conclusion of a contract between you and us. Autogas Ltd cannot enter into contracts without obtaining the required information; we process your contact details such as your address and email address, personal details such as your name and date of birth, payment and credit information and details of your correspondence with us.


5.4.3. For business process execution and internal management: We process your personal data in the performance and organisation of our business. This includes general management, order management and management of our assets. Autogas Ltd also processes your personal data for its internal management.  We conduct audits and investigations, and implement business controls. Also, we process your personal data for finance and accounting, archiving and insurance purposes, legal and business consulting and in the context of dispute resolution. For this purpose: we process personal data based on our legitimate interest to maintain and improve sound business operations; we process your contact details such as your address and email address, personal details such as your name, payment and credit information, payment and order history, correspondence with us and data generated during the performance of the agreement between you and Autogas Ltd.


5.4.4. To comply with the law: In some cases, we process your personal data to comply with laws and regulations. This could be the case, for example, where tax or business conduct related obligations apply. In order to comply with relevant laws and regulations, we may need to disclose your personal data to government institutions or supervisory authorities. For this purpose we process your personal data in order to comply with the law; we process your contact details such as your address and email address, personal details such as your name and date of birth, payment information, payment and order history, and your Companies House registration and VAT details and tax details.


6.       How long do we retain your personal data?


6.1.    Autogas Ltd will generally retain Business Partner data only for the period required to serve the applicable Business Purpose, to the extent reasonably necessary to comply with an applicable legal requirement or as advisable in light of an applicable statute of limitations.


6.2.    Further information is detailed in our Data Retention Policy.


6.3.    Promptly after the applicable storage period has ended, the Data shall be:

·                  securely deleted or destroyed;

·                  anonymized;

·                  transferred to an archive (unless this is prohibited by law or an applicable records retention schedule).



7.       Who has access to your personal data?


7.1.    Autogas Ltd employees are authorised to access personal data only to the extent necessary to serve the applicable purpose and to perform their jobs.


7.2.    The following third parties (but not limited to) may have access to your personal data where relevant for the provisioning of their products or services to Autogas Ltd: banks, insurance companies and brokers, IT suppliers, accountants, forensic specialists, consultants and lawyers, and other sub-contractors who help us deliver or process products and services to or from you. When third parties are given access to your personal data, Autogas Ltd will take the required contractual, technical and organisational measures to ensure that your personal data are only processed to the extent that such processing is necessary. The third parties will only process your personal data in accordance with applicable law. In other cases, your personal data will not be supplied to third parties, except when required by law.


7.3.    We do not send your personal data outside the European Economic Area. If this changes you will be notified of this and the protections which are in place to protect the security of your data will be explained.


8.       How is your personal data secured?


8.1.    We have taken adequate safeguards to ensure the confidentiality and security of your personal data. We have implemented appropriate technical, physical and organisational measures to protect personal data against accidental or unlawful destruction or accidental loss, damage, alteration, unauthorised disclosure or access, and against all other forms of unlawful processing (including, but not limited to unnecessary collection) or further processing.


9.       Data subject access requests


9.1.    You can make a ‘data subject access request’ (‘DSAR’) to find out the information we hold about you. Autogas Ltd must respond within 30 days unless the request is complex or numerous in which case the period in which we must respond can be extended by a further two months.


9.2.    There is no fee for making a DSAR. However, if your request is manifestly unfounded or excessive we may charge a reasonable administrative fee or refuse to respond to your request.


9.3.    Please keep in mind we will ask for proof of identity before processing your DSAR.


9.4.    Further information is available in our Data Subject Access Request Policy.


10.   Your privacy rights


10.1.     You have the right to information about what personal data we process, how and on what basis, as set out in this policy.


10.2.     You have the right to access your own personal data by way of a data subject access request (see above).


10.3.     You can correct any inaccuracies in your personal data.


10.4.     You have the right to request that we erase your personal data where we were not entitled under the law to process it or it is no longer necessary to process it for the purpose it was collected. While you are requesting that your personal data is corrected or erased or are contesting the lawfulness of our processing, you can apply for its use to be restricted while the application is made.


10.5.     You have the right to object to data processing where we are relying on a legitimate interest to do so and you think that your rights and interests outweigh our own and you wish us to stop.


10.6.     You have the right to object if we process your personal data for the purposes of direct marketing without your consent.


10.7.     You have the right to be notified of a data security breach concerning your personal data.


10.8.     Once given, you may always withdraw your consent. Please keep in mind that withdrawal does not have retrospective effect and the withdrawal of your consent is only possible in case you first have given your consent. To withdraw your consent, you should contact us at [email protected]


10.9.     You have the right to complain to the Information Commissioner. You can do this be contacting the Information Commissioner’s Office directly. Full contact details including a helpline number can be found on the Information Commissioner’s Office website (www.ico.org.uk). This website has further information on your rights and our obligations.


10.10. If you have any questions you can contact us at [email protected] 


11.          Changes to this policy


11.1.     This Policy came into force on 25th May 2018. We reserve the right to update this policy at any time and the most up-to-date version is published on our website.


Autogas Ltd has separate Privacy Policies for Employees and Job Applicants. Please contact us at [email protected] for further information.


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