Privacy Policy

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Fleetwind Ltd

Privacy policy (v2.0)

Purposes for which we will use your personal information

We may use your personal information for a number of different purposes. For each purpose, we are required to confirm the ‘legal basis’ that allows us to use your information, as follows:

·  To register you as a customer of or supplier to our company. It will be necessary for the performance of the contract between you and us.

·  To process your instructions as a customer and provide our services to you, or as a supplier and receive your services (including managing payments, fees and charges). It will be necessary for the performance of the contract between you and us.

·  Where you are acting as a representative of a company or organisation, then to register that company or organisation as a customer of or supplier to our company. It will be necessary for our legitimate business interests, and your company’s or organisation’s legitimate business interests, namely with a view to us providing or receiving services.

·  Where you are acting as a representative of a company or organisation, to process your instructions as a customer and provide our services to your company or organisation, or as a supplier and receive your company’s or organisation’s services (including managing payments, fees and charges). It will be necessary for our legitimate business interests, and your company’s or organisation’s legitimate business interests, namely with a view to us providing or receiving services.

·  To obtain further information about you, any company or organisation you represent, and the matter that is the subject of the services we have agreed to provide or receive. It will be necessary for our legitimate business interests to ensure we are fully aware of all issues relating to the matter that is the subject of the services we have agreed to provide or receive.

·  To collect and recover money owed to us. It will be necessary for our legitimate business interests, namely to ensure we receive payment for services that we have provided.

·  To notify you about changes to our contractual terms or this privacy policy. It will be necessary for our legitimate business interests, namely to ensure you are aware of our current terms and conditions.

·  To administer our website , to apply online security processes and for internal operations, including troubleshooting, data analysis, remote email access, cyber-security, testing, research, statistical and survey purposes, to allow you to participate in interactive features of our service, when you choose to do so, to measure or understand the effectiveness of advertising we serve to you and others, and to deliver relevant advertising to you and to make suggestions and recommendations to you and other users of our website about goods or services that may interest you or them. It will be necessary for our legitimate business interests to ensure you receive the best experience possible and that appropriate cyber-security measures are applied when accessing and using our website or otherwise communicating with us electronically. We will comply with our cookie policy when processing this information.

·  To enable you to participate in a prize draw, competition or complete a survey. It will be necessary for our legitimate business interests, namely to study how customers and suppliers, prospective customers and suppliers, business partners and other third parties use our services, to develop them and help grow our business.

·  To provide you with information about special offers and other services we provide. Where you have previously received marketing communications from us, then it will be necessary for our legitimate business interests, namely to ensure you continue to receive communications that you have previously agreed to receive unless you decide to ‘opt out’ of receiving those communications. Where you specifically ask us to provide you with certain marketing communications, then it will be necessary for our legitimate business interests, namely to ensure we provide you with the communications that you have requested. In all other cases, we will only do this if you give us your consent.

·  To invite you to corporate or hospitality events, and thereafter to manage your attendance at the event. It will be necessary for our legitimate business interests to ensure you are aware of the latest developments in relation to the services we have provided to you, or are providing to you, or otherwise to develop our relationship with you outside of the working environment. Where you would not normally have a reasonable expectation of receiving such invites from us, we will only send you invites if you agree. Where the information collected relates to any dietary preference which may be considered to be 'special category data', for example by indicating a particular religious or philosophical view, or a medical issue or allergy, we will only process this information with your explicit consent.

What if you cannot or will not provide us with your personal information

It is a contractual requirement for you to provide us with certain information, namely sufficient information to allow us to perform the terms of any contract we have entered into with you, or with any company or organisation that you represent. If you do not provide us with that information, we may be unable to accept your instructions and/or provide you with the full range of our services.

How we collect your personal information

We may obtain personal information by interacting directly with you.

We may obtain personal information via automated technology when you interact with our website by using cookies, server logs and other similar technologies.

We may also collect personal information about you from third parties or publicly-available sources, such as:

• your family members, your business colleagues and other contacts,
• the ‘other side’ in any dispute or negotiation,
• official bodies such as the Ministry of Defence,
• your professional advisers and business networks with which both you and we are connected,
• analytics providers (such as Google),
• advertising networks,
• providers of technical, payment and delivery services, and
• by conducting searches of publicly-available databases or social media sites, such as Companies House, Facebook, X (formerly known as Twitter), LinkedIn and the electoral register.

Disclosure of your information

We may share your personal information with the parties set out below:

• any other parties to a contract in relation to which you are performing or receiving services where we reasonably consider that it is appropriate or in your best interests for us to do so,
• institutions within the British government, such as the Ministry of Defence,
• HM Revenue & Customs, the Information Commissioner’s Office, the National Crime Agency, the Serious Fraud Office and any other regulators and other authorities who require reporting of processing activities in certain circumstances,
• credit-reference and fraud prevention agencies,
• identification verification services,
• where you are referred or introduced to us by a third party, we may provide them with certain information about you and your transaction,
• professional advisers and business networks with which we are connected,
• our outsourced IT services provider, GoDaddy Inc, together with providers of wi-fi, IT, mailing list and system administration services to our business (including Xero Accounting and Ark SW Ltd),
• our professional advisers (including solicitors, bankers, auditors and insurers),
• business partners, suppliers and sub-contractors to the extent we consider it reasonably necessary for us to perform our services,
• analytics and search engine providers that assist us in the improvement and optimisation of our website,
• caterers and hospitality staff, event organisers, training providers and other parties we collaborate with for the purposes of organising and staging our corporate or hospitality events, and
• third parties to whom we may choose to sell, transfer, or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal information in the same way as set out in this policy.

Transferring your personal information overseas

All information you provide to us is stored on our secure servers in the United Kingdom, or on secure cloud-based services in a country within the European Economic Area.

From time to time, we may have to transfer your personal information to third parties outside the United Kingdom, or to third parties who will store the data outside the United Kingdom. In those cases, we will take all steps reasonably necessary to ensure that your data is treated securely by ensuring that we apply appropriate safeguards (either by ensuring your information is transferred to or stored in the European Economic Area or another country determined by the United Kingdom to have adequate or equivalent levels of data protection, or by using specific contracts approved by the UK Information Commissioner).

If you are concerned about the levels of data security in those countries, please let us know and we will endeavour to advise what steps will be taken to protect your data when stored overseas.

How long we will store your personal information

The length of time that we will store your data will depend on the ‘legal basis’ for why we are using that data, as follows:

·  Where we use/store your data because it is necessary for the performance of the contract between you and us. We will use/store your data for as long as it is necessary for the performance of the contract between you and us.

·  Where we use/store your data because it is necessary for us to comply with a legal obligation to which we are subject. We will use/store your data for as long as it is necessary for us to comply with our legal obligations.

·  Where we use/store your data because it is necessary for our legitimate business interests. We will use/store your data for as long as it is necessary for our legitimate business interests, or such earlier time as you ask us to stop. However, if we can demonstrate the reason why we are using/storing your data is more important than your interests, rights and freedoms, then we will be allowed to continue to use/store your data for as long as it is necessary for our legitimate business interests.

·  Where we use/store your data because it is necessary for your or a third party’s legitimate business interests. We will use/store your data for as long as it is necessary for your or the third party’s legitimate business interests, or such earlier time as you ask us to stop. However, if we can demonstrate the reason why we are using/storing your data is more important than your interests, rights and freedoms, then we will be allowed to continue to use/store your data for as long as it is necessary for your or their legitimate business interests.

·  Where we use/store your data because you have given us your specific, informed and unambiguous consent. We will use/store your data for as long as it is necessary for our business purposes, or such earlier time as you ask us to stop.

To determine the appropriate retention period for personal information, we consider the amount, nature and sensitive of the personal information, the potential risk of harm from unauthorised use or disclosure of your personal information, the purposes for which we process your personal information and whether we can achieve those purposes through other means, and the applicable legal requirements.

Your rights

You have various legal rights in relation to the information you give us, or which we collect about you, as follows:

• You have a right to access the information we hold about you free-of-charge, together with various information about why and how we are using your information, to whom we may have disclosed that information, from where we originally obtained the information and for how long we will use your information.
• You have the right to ask us to rectify any information we hold about you that is inaccurate or incomplete.
• You have the right to ask us to erase the information we hold about you (the ‘right to be forgotten’). Please note that this right can only be exercised in certain circumstances and, if you ask us to erase your information and we are unable to do so, we will explain why not.
• You have the right to ask us to stop using your information where: (i) the information we hold about you is inaccurate; (ii) we are unlawfully using your information; (iii) we no longer need to use the information; or (iv) we do not have a legitimate reason to use the information. Please note that we may continue to store your information, or use your information for the purpose of legal proceedings or for protecting the rights of any other person.
• You have the right to ask us to transmit the information we hold about you to another person or company in a structured, commonly-used and machine-readable format. Please note that this right can only be exercised in certain circumstances and, if you ask us to transmit your information and we are unable to do so, we will explain why not.
• Where we use/store your information because it is necessary for our legitimate business interests, you have the right to object to us using/storing your information. We will stop using/storing your information unless we can demonstrate why we believe we have a legitimate business interest which is more important than your interests, rights and freedoms.
• Where we use/store your data because you have given us your specific, informed and unambiguous consent, you have the right to withdraw your consent at any time.
• You have the right to object to us using/storing your information for direct marketing purposes.

If you wish to exercise any of your legal rights, please contact us by writing to the address below, or emailing us at linda@fleetwind.co.uk.

You also have the right, at any time, to lodge a complaint with the Information Commissioner’s Office if you believe we are not complying with the laws and regulations relating to the use/storage of the information you give us, or that we collect about you.

Automated decision-making

We do not use automated decision-making processes.

Data controller

The data controller is Fleetwind Ltd of Sladen House, 78a Fore Street, Polruan, Cornwall, PL23 1PH, England.

Questions, comments and requests regarding this policy are welcomed and should be addressed to us by writing to that address, or by emailing us at linda@fleetwind.co.uk.

Additional fair processing notices

On some occasions, such as when we collect or process your personal information for very specific, unusual or exceptional purposes, we may provide you with additional fair processing notices. Those notices will provide you with important additional information, and should be read in conjunction with this policy.

Changes to our policy

Any changes we make to our policy in the future will be posted on our website and, where appropriate, notified to you by email or other appropriate forms of communication. Please check our website frequently to see any updates or changes to our policy.