GENERAL DATA PROTECTION REGULATIONS POLICY
Introduction
SFI LOGISTICS LTD (‘SFI’) is committed to protecting the rights and freedoms of data subjects and safely and securely processing data in accordance with all of our legal obligations.
We hold data about our employees, clients, suppliers and other individuals for a variety of business purposes.
This privacy notice sets out how we seek to protect personal data and ensure that visitors to our website understand the rules governing the use of data to which they have access in the course of their work. In particular, this policy requires staff to ensure that the Data Protection Officer (DPO) be consulted before any significant new data processing activity is initiated to ensure that relevant compliance steps are addressed.
It includes information you provide when you register to use our site, subscribe to our service, and request a call back or a request for support or additional information, search for a product and when you report a problem with our site. This website is 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 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.
This privacy notice is issued on behalf of the SFI. We have appointed a 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.
Name of legal entity: SFI Logistics Limited
Registered Office: Finsgate, 5-7 Cranwood Street, London EC1V 9EE
Company number: 00359491.
Data Privacy Officer email address: info@sfi-uk.com
Postal address: Unit C, Twickenham Trading Estate, Rugby Road, Twickenham, TW1
Telephone number: +44 (0) 208 891 8740
You have the right to make a complaint at any time to the Information Commissioner's Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk). We would appreciate the opportunity to deal with your concerns before you approach the ICO. Please do contact us in the first instance.
Amendments/changes to the Privacy Notice and your Obligations
This version was last updated on February 2019 and historic versions can be obtained by contacting us. It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.
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.
Data and Information SFI Collects about You
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).
We may collect, use, store and transfer different kinds of personal data about you which we have grouped together follows:
- Identity Data includes first name, last name, title, gender.
- Contact Data includes address, email address and telephone numbers.
- Technical Data includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access this website.
- Usage Data includes information about how you use our website.
- Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.
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 but is not limited to 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. However if SFI needs 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 through:
Direct Interactions
You may give us your Identity and Contact Data by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:
- register to use our site;
- apply for our products or services;
- request a call back;
- subscribe to our service or publications;
- request for support or additional information;
- request for marketing to be sent to you;
- search for a product;
- enter a competition, promotion or survey;
- report a problem with our site; or
- 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. Please see our cookie policy for further details.
Third parties or publicly available sources
We may receive personal data about you from various third parties and public sources as set out below:
- Technical Data from the following parties:
(a) Analytics providers such as Google based outside the EU;
(b) Advertising networks; and
(c) Search information providers.
- Identity and Contact Data from publicly availably sources such as Companies House and the Electoral Register based inside the EU.
How SFI uses your Personal Data
We will 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) and your interests and fundamental rights do not override those interests.
- Where we need to comply with a legal or regulatory obligation.
Generally we do not rely on consent as a legal basis for processing your personal data other than in relation to sending third party direct marketing communications to you via email or text message. You have the right to withdraw consent to marketing at any time by contacting us at info@sfi-uk.com
Purposes for which SI will use your Personal Data
We have set out below a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate. Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us at info@sfi-uk.com if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out below.
Purpose/Activity |
Type of Data |
Lawful Basis for Processing Data and/or Legitimate Interest |
To register you as a new customer |
(a) Identity & contact |
Performance of a contract with you |
To process and deliver your order including,
(a) Manage payments, fees and charges
(b) Collect and recover money owed to us
|
(a) Identity & contact?
(b) Financial
(c) Transaction
(d) Marketing & Communication
|
(a) Performance of a contract with you
(b) Necessary for our legitimate interest e.g. to recover debts due to SFI
|
To manage our relationship with you which will include:
(a) Notifying you about changes to our terms or privacy policy
(b) Asking you to leave a review or take a survey
|
(a) Identity & contact
(b) Profile
(c) Marketing & Communication
|
(a) Performance of a contract with you
(b) Necessary to comply with a legal obligation
(c) Necessary for our legitimate interest
e.g. to keep our records updated and to study how our customers use our products and/or services
|
To enable you to participate in a prize draw, competition or complete a survey |
(a) Identity & contact
(b) Profile
(c) Usage
(d) Marketing & Communication
|
(a) Performance of a contract with you
(b) Necessary for our legitimate interest
e.g. to keep our records updated and to study how our customers use our products and/or services)
|
To administer and protect our business and
this website (including troubleshooting, data
analysis, testing, system maintenance, support
reporting and hosting of data)
|
(a) Identity & contact
(b) Technical
|
(a) Necessary for our legitimate interest
e.g. for running our
business, provision of business, admin
and IT services, network security, to
prevent fraud and in the context of a
business re-organisation or group
restructuring exercise.
(b) Necessary to comply with a legal obligation
|
Purpose/Activity |
Type of Data |
Lawful Basis for Processing Data and/or Legitimate Interest |
To deliver relevant website content and
advertisements to you and measure or try to
understand the effectiveness of the
advertising we provide to you |
(a) Identity & contact
(b) Profile
(c) Usage
(d) Marketing & Communication
(e) Technical
|
Necessary for our legitimate interests
(to study how customers use our
products/services, to develop them, to
grow our business and to better inform our future
marketing strategy)
|
To use data analytics to improve our website,
products/services, marketing, customer
relationships and experiences |
(a) Technical
(b) Usage
|
Necessary for our legitimate interests
(to define types of customers for our
products and services, to keep our
website up dated and relevant, to develop
our business and to inform our future
marketing strategy)
|
To make suggestions and recommendations
to you about goods or services that may be of
interest to you
|
(a) Identity & contact
(b) Technical
(c) Usage
(d) Profile
|
Necessary for our legitimate interests
(to develop our products/services and
grow our business)
|
Marketing
We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising. We have established the following personal data control mechanisms,
- Promotional offers from SFI.
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 not opted out of receiving that marketing.
We will get your express opt-in consent before we share your personal data with any company outside of SFI for marketing purposes.
You can ask us or third parties to stop sending you marketing messages at any time by following the opt-out links on any marketing message sent to you or by contacting us at info@sfi-uk.com 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 transactions.
You can set your browser to refuse all or some browser cookies, or to alert you when 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. For more information about the cookies we use, please see our Cookie Policy.
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 at info@sfi-uk.com
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.
Disclosures of your Personal Data
We may have to share your personal data with the parties set out below for the purposes set out above.
- Internal Third Parties
- External Third Parties
- 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 data in the same way as set out in this privacy notice.
We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our prior instructions.
Data Security
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 also 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.
Data Retention
By law we have to keep basic information about our customers (including Contact, Identity, Financial and Transaction Data) for six years after they cease being customers for tax purposes. In some circumstances you can ask us to delete your data: see below for further information.
In some circumstances we will anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes, in which case we may use this information indefinitely without further notice to you.
Your Legal Rights
Under certain circumstances, you have rights under data protection laws in relation to your personal data. Please click on the links below to find out more about these rights,
- Request access to your personal data
- Request correction of your personal data
- Request erasure of your personal data.
- Object to processing of your personal data.
- Request restriction of processing your personal data.
- Request transfer of your personal data.
- Right to withdraw consent.
If you wish to exercise any of the rights set out above, please contact us at info@sfi-uk.com
You will not usually 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 SFI may ask of 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 four weeks. 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 OF TERMS USED
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 contacting us at info@sfi-uk.com
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.
Third Parties
External Third Parties
- Service providers acting as processors based in the United Kingdom who provide IT and system administration services.
- Professional advisers acting as processors including lawyers, bankers, auditors and insurers based in the United Kingdom who provide consultancy, banking, legal, insurance and accounting services.
- HM Revenue & Customs, regulators and other authorities acting as processors based in the United Kingdom who require reporting of processing activities in certain circumstances.
Your Legal Rights
You have the right to,
- Request access to your personal data. 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 that overrides 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.