Privacy Policy

WhiteTEC Consultancy UK Limited (‘We’) (also known as WhiteTEC or WhiteTEC UK) Under the Data Protection Laws, we are engaged as a Data Controller and a Data Processor. We are registered with the Data Protection Registrar with the UK Information Commissioner’s Office – Registration Number ZA32844.

WhiteTEC 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 when you visit our website (regardless of where you visit it from) or instruct our services. We will tell you about your privacy rights and how the law protects you.

Please also use the Glossary to understand the meaning of some of the terms used in this privacy notice.

Important information and who we are

Purpose of this privacy notice

This privacy notice aims to give you information on how WhiteTEC collects and processes your personal data through your use of our website, or our supply of services, including any data you may provide when you use our products and services or receive marketing information about our products and any special offers.

Our website or our products and services are not intended for children and we do not knowingly collect data relating to children.

It is important that you read this privacy notice together with any other privacy notice or fair processing notice we may provide you on specific occasions when we are collecting or processing personal data about you, so that you are fully aware of how and why we are using your data. This privacy notice supplements the other notices and is not intended to override them.

Controller

WhiteTEC is the controller and responsible for your personal data (referred to as ‘WhiteTEC’ ‘we’, ‘us’ or ‘our’ in this privacy notice).

Data Protection Officer

We have appointed a data protection officer (DPO) who is responsible for overseeing questions in relation to this Privacy Notice. If you have any questions about this Privacy Notice, including any requests to exercise your legal rights, please contact the DPO using the details set out below.

The DPO can be contacted:

  • Email address: Jane@whitetec.co.uk
  • Postal address: WhiteTEC UK, Little Orchard, Kellaton, Kingsbridge, Devon. TQ7 2ES.
  • Telephone number: 01548 511738

You have the right, if you wish to do so, to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues.

We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.

Changes to the privacy notice and your duty to inform us of changes

This version was last updated on 03 May 2021.

The Data Protection Laws give you a right to prevent your personal data being processed for direct marketing, so you can at any time give written notice to us to stop sending marketing information to you. You can do this by notifying our Data Protection Officer in writing or by email at the address given in paragraph 3 of this notice.

If you have decided to receive marketing information from us, we shall retain a copy of your consent for the time being, but you have a right at any time to withdraw your consent to our keeping and processing your personal data and can do so at any time by notifying our Data Protection Officer by email or in writing at the addresses given in paragraph 3 of this Notice. If you do so we undertake to review your request to delete your personal data from our records.

The accuracy of your information is important to us. Please keep us informed if your personal data changes during your relationship with us. If you change your postal address, email address or your telephone number, please let us know by contacting us on:

Email address: Jane@whitetec.co.uk.

Third-party links

Our website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy notice of every website you visit.

The data we may collect about you

We may collect and process the following data about you:

  • Information that you provide by filling in forms on our www.whitetec.co.uk (our site)
  • Information provided when you complete our online form and enquiry form
  • If you contact us, we may keep a record of that correspondence
  • We may also ask you to complete surveys/polls that we use for research and marketing purposes
  • Details of transactions you carry through our business and of the fulfilment of contracts, orders, where applicable.
  • Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).
  • Details of your visits to our site including, but not limited to, traffic data, location data, weblogs and other communication data, whether this is required for our own billing purposes or otherwise and the resources or services you access.

We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data may be derived from your personal data but is not considered personal data in law as this data does not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy notice.

We do not collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data). Nor do we collect any information about criminal convictions and offences.

If you fail to provide personal data

Where we need to collect personal data by law, or under the terms of a contract we have with you, and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with goods or services). In this case, we may have to cancel a product or service you have with us, but we will notify you if this is the case at the time.

How is your personal data collected?

We use different methods to collect data from and about you including: Direct interactions.

You may give us your:

  • Address history, name, contact details, employment information, or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:
  • Create an account on our website;
  • Request marketing or information to be sent to you;
  • Give us some feedback.
  • Automated technologies or interactions. As you interact with our website, we may automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies, server logs and other similar technologies. We may also receive Technical Data about you if you visit other websites employing our cookies.

We may also use your data, or permit selected third parties to use your data to provide you with information about goods and services which may be of interest to you and we or they may contact you about these by post, telephone or email.

If you are an existing customer, we will only contact you by electronic means (email or SMS) with information about goods and services similar to those which were the subject of a previous sale to you. If you are a new customer, and where we permit selected third parties to use your data, we (or they) will contact you by electronic means only if you have consented to this. If you do not wish to use your data in this way, or to pass your details on to third parties for marketing purposes, please tick the relevant box on the enquiry form.

If WhiteTEC or substantially all of its assets are acquired by a third party, in which case personal data held by it about its customers will be one of the transferred assets.

If we are under a duty to disclose or share your personal data in order to comply with any legal obligation, or in order to enforce or apply any other agreements; or to protect the rights, property or safety of WhiteTEC, our customers, or others, we may do so. This includes exchanging information with other companies and organisations for the purpose of fraud protection and credit risk reduction.

IP addresses & Cookies

How we use your personal data

We may collect information about your computer, including where available your IP address, operating system and browser, type for system administration and to report aggregate information to our advertisers or marketing team. This is statistical data about our user’s browsing actions and patterns and does not identify any individual and only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:

  • Where we need to perform the contract we are about to enter into or have entered into with you.
  • Where it is necessary for our legitimate interests (or those of a third party).

Marketing – Clients

You are a valued customer of WhiteTEC who has purchased services related to sales and marketing of your business, through us, so that the individual who has made contact to engage us in the use of services, we will provide updates in relation to contracted services. In addition, from time to time, we will provide up to date information regarding our business and services.

The Data Protection Laws give you a right to prevent your personal data being processed for direct marketing, so you can at any time give written notice to us to stop sending marketing information to you. You can do this by notifying our Data Protection Officer in writing or by email.

If you have decided to receive marketing information from us, we shall retain a copy of your consent for the time being, but you have a right at any time to withdraw your consent to our keeping and processing your personal data and can do so at any time by notifying our Data Protection Officer by e-mail or in writing. If you do so we undertake to review your request to delete your personal data from our records.

The accuracy of your information is important to us. If you change your postal address, your email address or telephone number, please let us know by contacting us on 01548 511738.

Promotional offers from us

We may use your Identity, Contact, Technical, Usage and Profile Data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which products, services and offers may be relevant for you (we call this marketing).

You will receive marketing communications from us if you have requested information from us or purchased goods or services from us or if you provided us with your details when you entered a competition or registered for a promotion and, in each case, you have consented to and opted into receiving that marketing.

Opting out

You can ask us or third parties to stop sending you marketing messages at any time by logging into our website and checking or unchecking relevant boxes to adjust your marketing preferences or by following the opt-out links on any marketing messages sent to you or by contacting us at any time.

Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of a product/service, purchase, warranty registration, product/service experience or other transaction.

Cookies

You can set your browser to refuse all or some browser cookies, or to alert you when any websites set or access cookies. If you disable or refuse cookies, please note that some parts of this website may become inaccessible or not function properly.

Change of purpose

We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the

processing for the new purpose is compatible with the original purpose, please contact us.

If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.

Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

International transfers

We share your personal data within WhiteTEC, we do not transfer your personal data outside the European Economic Area (EEA).

Data security

Our Customers/ Clients

We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions, and they are subject to a duty of confidentiality.

We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

Client Data in service of our products and services provision

We have put in place appropriate security measures to prevent your customer data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your data extracts to those employees, agents, contracted third parties who have a business to know, as part of the work agreed to be undertaken between WhiteTEC and our Client. They will only process the data on our instructions and are subject to a duty of confidentiality.

Customer Data provided by our Clients, in relation to contracted agreed services, will be managed in secure environments, and will be managed as agreed as part of the contracted service agreement and/ or Campaign delivery schedules. (Refer to Data Processing Agreement.)

We have put in place strict procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

Data retention

How long will you use my personal data for?

We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.

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

If you proceed to purchase a vehicle from us, you should be aware that we keep a record of all sales and transactions including your personal data for a period of 6 years plus one month from the date when you took delivery of your vehicle. Even if you do not proceed with the purchase of a vehicle, we will hold details of your personal data for a period of 12 months.

We may record calls for training and monitoring purposes, which are retained for a period of 30 days.

No fee usually required

You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.

What we may need from you

We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

Time limit to respond

We try to respond to all legitimate requests within one month. Occasionally, it may 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.

Glossary

LAWFUL BASIS

Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give you the best service/product and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by:

  • Performance of Contract means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.
  • Comply with a legal or regulatory obligation means processing your personal data where it is necessary for compliance with a legal or regulatory obligation that we are subject to.

YOUR LEGAL RIGHTS

You have the right to:

  • Request access to your personal data (commonly known as a ‘data subject access request’). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
  • Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
  • Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
  • Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
  • Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios: (a) if you want us to establish the data’s accuracy; (b) where our
  • use of the data is unlawful but you do not want us to erase it; (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
  • Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
  • Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.
  • Not to be subject to automated decision making or profiling based on your personal data, including profiling, which has legal or other similarly significant effects on you as a data subject.

If you wish to exercise any of the rights set out above, please contact our Data Protection Officer.

You have the right, if you wish to do so, to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues. Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF or contact our Data Protection Officer.