Rotowash Limited understands that your privacy is important to you and that you care about how your personal data is used and shared online. We respect and value the privacy of everyone who visits this website, www.rotowash.com (“Our Site”) and will only collect and use personal data in ways that are described here, and in a manner that is consistent with Our obligations and your rights under the law.
1. Definitions and Interpretation
In this Policy the following terms shall have the following meanings:
“Account” : means an account required to access and/or use certain areas and features of Our Site;
“Cookie” : means a small text file placed on your computer or device by Our Site when you visit certain parts of Our Site and/or when you use certain features of Our Site. Details of the Cookies used by Our Site are set out in section 13, below;
“Cookie Law” : means the relevant parts of the Privacy and Electronic Communications (EC Directive) Regulations 2003;
“personal data” : means any and all data that relates to an identifiable person who can be directly or indirectly identified from that data. In this case, it means personal data that you give to Us via Our Site. This definition shall, where applicable, incorporate the definitions provided in the EU Regulation 2016/679 – the General Data Protection Regulation (“GDPR”); and
“We/Us/Our” : means Rotowash Limited, a limited company registered in England under company number 06160994, whose registered address is 9 Station Parade, Uxbridge Road, London W5 3LD, and whose main trading address is 7 Victory Business Centre, Fleming Way, Isleworth, Middlesex, TW7 6DB.
2. Information About Us
Our Site is owned and operated by Rotowash Limited, a limited company registered in England under company number 06160994, whose registered address is 9 Station Parade, Uxbridge Road, London, W5 3LD and whose main trading address is 7 Victory Business Centre, Fleming Way, Isleworth, Middlesex, TW7 6DB.
2.1 Our VAT number is 906 9158 06.
2.2 Our Data Protection Officer (DPO) is an existing Rotowash employee, working in a senior role. He/she can be contacted by email at email@example.com, by telephone on 020 8847 4545, or by post at 7 Victory Business Centre, Fleming Way, Isleworth, Middlesex, TW7 6DB.
3. What Does This Policy Cover?
4. Your Rights
4.1 As a data subject, you have the following rights under the GDPR, which this Policy and Our use of personal data have been designed to uphold:
4.1.1 The right to be informed about Our collection and use of personal data;
4.1.2 The right of access to the personal data We hold about you (see section 12);
4.1.3 The right to rectification if any personal data We hold about you is inaccurate or incomplete (please contact Us using the details in section 14);
4.1.4 The right to be forgotten – i.e. the right to ask Us to delete any personal data We hold about you (We only hold your personal data for a limited time, as explained in section 6 but if you would like Us to delete it sooner, please contact Us using the details in section 14);
4.1.5 The right to restrict (i.e. prevent) the processing of your personal data;
4.1.6 The right to data portability (obtaining a copy of your personal data to re-use with another service or organisation);
4.1.7 The right to object to Us using your personal data for particular purposes; and
4.1.8 Rights with respect to automated decision making and profiling.
4.2 If you have any cause for complaint about Our use of your personal data, please contact Us using the details provided in section 14 and We will do Our best to solve the problem for you. If We are unable to help, you also have the right to lodge a complaint with the UK’s supervisory authority, the Information Commissioner’s Office.
4.3 For further information about your rights, please contact the Information Commissioner’s Office or your local Citizens Advice Bureau.
5. What Data Do We Collect?
5.2 business/company name
5.3 job title;
5.5 contact information such as email addresses and telephone numbers;
5.6 demographic information such as post code, preferences and interests;
5.7 financial information such as credit/debit card numbers;
5.8 IP address;
5.9 web browser type and version;
5.10 operating system;
5.11 a list of URLs starting with a referring site, your activity on Our Site, and the site you exit to;
6. How Do We Use Your Data?
6.1 All personal data is processed and stored securely, for no longer than is necessary in light of the reason(s) for which it was first collected. We will comply with Our obligations and safeguard your rights under the GDPR at all times. For more details on security see section 7, below.
6.2 Our use of your personal data will always have a lawful basis, either because it is necessary for Our performance of a contract with you, because you have consented to Our use of your personal data (e.g. by subscribing to emails), or because it is in Our legitimate interests. Specifically, We may use your data for the following purposes:
6.2.1 Providing and managing your Account;
6.2.2 Providing and managing your access to Our Site;
6.2.3 Personalising and tailoring your experience on Our Site;
6.2.4 Supplying Our products and services to you (please note that We require your personal data in order to enter into a contract with you);
6.2.5 Personalising and tailoring Our products and services for you;
6.2.6 Replying to emails from you;
6.2.7 Supplying you with emails that you have opted into (you may unsubscribe or opt-out at any time by following the instructions at the bottom of each email;
6.2.8 Market research;
6.2.9 Analysing your use of Our Site to enable Us to continually improve Our Site and your user experience;
6.3 With your permission and/or where permitted by law, We may also use your data for marketing purposes which may include contacting you by email or telephone or text message or post with information, news and offers on Our products and services. We will not, however, send you any unsolicited marketing or spam and will take all reasonable steps to ensure that We fully protect your rights and comply with Our obligations under the GDPR and the Privacy and Electronic Communications (EC Directive) Regulations 2003.
6.4 You have the right to withdraw your consent to Us using your personal data at any time, and to request that We delete it.
6.5 We do not keep your personal data for any longer than is necessary in light of the reason(s) for which it was first collected. Data will therefore be retained for the following periods (or its retention will be determined on the following bases):
personal data will not be retained by Rotowash for longer than necessary in relation to the purposes for which it was originally collected, or for which it was further processed. Where personal data needs to be retained, Rotowash takes into account the legal and contractual requirements, both minimum and maximum, that influence the retention periods. All Personal Data should be deleted or destroyed as soon as possible where it has been confirmed that there is no longer a need to retain it.
7. How and Where Do We Store Your Data?
7.1 We only keep your personal data for as long as We need to in order to use it as described above in section 6, and/or for as long as We have your permission to keep it.
7.2 Your data will only be stored in the UK.
7.3 Data security is very important to Us, and to protect your data We have taken suitable measures to safeguard and secure data collected through Our Site.
7.4 Steps We take to secure and protect your data include:
7.4.1 Principle One – Lawfulness
Lawfulness, Fairness and Transparency personal data shall be processed lawfully, fairly and in a transparent manner in relation to the data subject. This means, We must tell the data subject what processing will occur (transparency), the processing must match the description given to the data subject (fairness) and it must be for one of the purposes specified in the applicable Data Protection regulation (lawfulness).
7.4.2 Principle Two – Purpose Limitation
Personal data shall be collected for specified, explicit and legitimate purposes and further processed in a manner that is incompatible with those purposes. This means that We must specify exactly what the personal data will be used for and limit the processing of that personal data to only what is necessary to meet the specified purpose.
7.4.3 Principle Three – Data Minimisation
Personal data shall be adequate, relevant and limited to what is necessary in relation to the purposes for which they are processed. This means that We must not store any personal data beyond what is strictly required.
7.4.4 Principle Four – Accuracy
Personal data shall be accurate and kept up to date. This means that We must have in place processes for identifying and addressing out-of-date, incorrect and redundant personal data.
7.4.5 Principle Five – Storage Limitation
Personal data shall be kept in a form which permits identification of data subjects for no longer than is necessary for the purposes for which the personal data is processed. This means that We must, wherever possible, store personal data in a way that limits or prevents identification of the data subject.
7.4.6 Principle Six – Integrity & Confidentiality
Personal data shall be processed in a manner that ensures appropriate security of personal data, including protection against unauthorised or unlawful processing and against accidental loss, destruction or damage. We must use appropriate technical and organisational measures to ensure the integrity and confidentiality of personal data is maintained at all times.
7.4.7 Principle Seven – Accountability
The DPO shall be responsible for and be able to demonstrate compliance. This means that We must demonstrate that the six data protection principles (outlined above) are met for all personal data for which it is responsible.
8. Do We Share Your Data?
8.1 Subject to section 8.2, We will not share any of your data with any third parties for any purposes.
8.2 In certain circumstances, We may be legally required to share certain data held by Us, which may include your personal data, for example, where We are involved in legal proceedings, where We are complying with legal obligations, a court order, or a governmental authority.
8.3 We may compile statistics about the use of Our Site including data on traffic, usage patterns, user numbers, sales, and other information. All such data will be anonymised and will not include any personally identifying data, or any anonymised data that can be combined with other data and used to identify you. We may from time to time share such data with third parties such as prospective investors, affiliates, partners, and advertisers. Data will only be shared and used within the bounds of the law.
8.4 In certain circumstances, We may be legally required to share certain data held by Us, which may include your personal data, for example, where We are involved in legal proceedings, where We are complying with legal requirements, a court order, or a governmental authority.
9. What Happens If Our Business Changes Hands?
9.2 In the event that any of your data is to be transferred in such a manner, you will be contacted in advance and informed of the changes. When contacted you will be given the choice to have your data deleted or withheld from the new owner or controller.
10. How Can You Control Your Data?
10.1 In addition to your rights under the GDPR, set out in section 4, when you submit personal data via Our Site, you may be given options to restrict Our use of your data. In particular, We aim to give you strong controls on Our use of your data for direct marketing purposes (including the ability to opt-out of receiving emails from Us which you may do by unsubscribing using the links provided in Our emails and at the point of providing your details).
10.2 You may also wish to sign up to one or more of the preference services operating in the UK: The Telephone Preference Service (“the TPS”), the Corporate Telephone Preference Service (“the CTPS”), and the Mailing Preference Service (“the MPS”). These may help to prevent you receiving unsolicited marketing. Please note, however, that these services will not prevent you from receiving marketing communications that you have consented to receiving.
11. Your Right to Withhold Information
11.1 You may access Our Site without providing any data at all.
12. How Can You Access Your Data?
You have the right to ask for a copy of any of your personal data held by Us (where such data is held). Under the GDPR, no fee is payable and We will provide any and all information in response to your request free of charge. Please contact Us for more details at firstname.lastname@example.org, or using the contact details below in section 14.
14. Contacting Us