We take your privacy very seriously. Please read this Privacy Notice carefully as it contains important information on who we are and how and why we collect, store, use and share your personal information. It also explains your rights in relation to your personal information and how to contact us or supervisory authorities in the event you have a complaint.
We collect, use and are responsible for certain personal information about you. When we do so we are subject to the General Data Protection Regulation, which applies across the European Union and we are responsible as ‘controller’ of that personal information for the purposes of those laws.
It would be helpful to start by explaining some key terms used in this Notice:
|We, us, our||CargoLogicAir Limited and our group and associated companies|
|Personal information||Any information relating to an identified or identifiable individual|
|Special category personal information||Personal information revealing racial or ethnic origin, political opinions, religious beliefs, philosophical beliefs or trade union membership|
Genetic and biometric data
Data concerning health, sex life or sexual orientation
Personal information we collect about you
We may collect and use the following personal information about you:
- your name and contact information, including email address and telephone number and company details
- Information to enable us to check and verify your identity, e.g. your date of birth
- your gender information
- location data
- your personal or professional interests
- your professional online presence, e.g. LinkedIn profile
- information from accounts you link to us, e.g. Facebook and LinkedIn
- Information about how you use our website, IT, communication and other systems
- your responses to surveys, competitions and promotions
This personal information is required to provide services to you and/or receive services from you. If you do not provide personal information we ask for, it may delay or prevent us from providing services and/or receiving services and goods.
How your personal information is collected
We collect most of this personal information directly from you- in person, by telephone, text or email and/or via our website (and, in the future, perhaps also from apps). However, we may also collect information:
- from publicly accessible sources, e.g. Companies House or HM Land Registry;
- directly from a third party, e.g.:
- sanctions screening providers;
- customer due diligence providers (including credit reference agencies);
- employers / principals;
- business associates
- from a third party with your consent
- via our IT systems, e.g.:
- door entry systems and reception logs;
- automated monitoring of our websites and other technical systems, such as our computer networks and connections, CCTV and access control systems, communications systems, email and instant messaging systems;
How and why we use your personal information
Under data protection law, we can only use your personal information if we have a proper reason for doing so, e.g.:
- to comply with our legal and regulatory obligations;
- for the performance of our contract with you or to take steps at your request before entering into a contract;
- for our legitimate interests or those of a third party; or
- where you have given consent.
A legitimate interest is when we have a business or commercial reason to use your information, so long as this is not overridden by your own rights and interests.
The table below explains what we use (process) your personal information for and our reasons for doing so:
|What we use your personal information for||Our reasons|
|To provide services to you||For the performance of our contract with you or to take steps at your request before entering into a contract|
|To provide services to customers||For the performance of our contract with customers or to take steps at your request before entering into a contract|
|To receive services and/or goods from suppliers||For the performance of our contract with suppliers and/or customers or to take steps at your request before entering into a contract|
|To prevent and detect fraud against you or the organisation for which you work||For our legitimate interests or those of a third party, i.e. to minimise fraud that could be damaging for us and for you or your organisation|
|Conducting checks to identify our customers and suppliers, and to verify their identity|
Screening for financial and other sanctions or embargoes
Other processing necessary to comply with professional, legal and regulatory obligations that apply to our business, e.g. under health and safety regulation or rules issued by our professional regulator
|To comply with our legal and regulatory obligations|
|Gathering and providing information required by or relating to audits, enquiries or investigations by regulatory bodies||To comply with our legal and regulatory obligations|
|Ensuring business policies are adhered to, e.g. policies covering security and internet use||For our legitimate interests or those of a third party, i.e. to make sure we are following our own internal procedures so we can deliver the best service to you and/or our customers|
|Operational reasons, such as improving efficiency, training and quality control||For our legitimate interests or those of a third party, i.e. to be as efficient as we can so we can deliver the best service for you and/or our customers at the best price|
|Ensuring the confidentiality of commercially sensitive information||For our legitimate interests or those of a third party, i.e. to protect trade secrets and other commercially valuable information|
To comply with our legal and regulatory obligations
|Statistical analysis to help us manage our business, e.g. in relation to our financial performance, customer base, product range or other efficiency measures||For our legitimate interests or those of a third party, i.e. to be as efficient as we can so we can deliver the best service for you and/or our customers at the best price|
|Preventing unauthorised access and modifications to systems||For our legitimate interests or those of a third party, i.e. to prevent and detect criminal activity that could be damaging for us and for you, customers and/or suppliers|
To comply with our legal and regulatory obligations
|Updating and enhancing customer records||For the performance of our contract with you and/or our customers or to take steps at your request before entering into a contract|
To comply with our legal and regulatory obligations
For our legitimate interests or those of a third party, e.g. making sure that we can keep in touch with our customers about existing contracts and new services
|Statutory returns||To comply with our legal and regulatory obligations|
|Ensuring safe working practices, staff administration and assessments||To comply with our legal and regulatory obligations|
For our legitimate interests or those of a third party, e.g. to make sure we are following our own internal procedures and working efficiently so we can deliver the best service to you and/or our customers
|Marketing our services and those of selected third parties to:|
– existing and former customers;
– third parties who have previously expressed an interest in our services;
– third parties with whom we have had no previous dealings.
|For our legitimate interests or those of a third party, i.e. to promote our business to existing and former customers|
|Customer due diligence and credit reference checks via external credit reference agencies||For our legitimate interests or those of a third party, i.e. to ensure our customers are likely to be able to pay for our products and services|
|External audits and quality checks, e.g. for ISO or Investors in People or other such accreditation or quality assurance and the audit of our accounts||For our legitimate interests or a those of a third party, i.e. to maintain our accreditations and control quality so we can demonstrate we operate at the highest standards|
To comply with our legal and regulatory obligations
We may use your personal information to send you updates (by email, text message, telephone or post) about our services, including exclusive offers, promotions or new services.
We have a legitimate interest in processing your personal information for promotional purposes (see above ‘How and why we use your personal information’). This means we do not usually need your consent to send you promotional communications. However, where consent is needed, we will ask for this consent separately and clearly.
We will always treat your personal information with the utmost respect and never sell OR share it with other organisations outside our group for marketing purposes.
You have the right to opt out of receiving promotional communications at any time by:
- contacting us at [email protected]
- using the ‘unsubscribe’ link in emails or ‘STOP’ number in texts
- updating your marketing preferences on our website
We may ask you to confirm or update your marketing preferences if you instruct us to provide further services in the future, or if there are changes in the law, regulation, or the structure of our business.
Please read this Notice alongside our Mailing Lists & Marketing Privacy Notice.
Regarding how we use personal information during recruitment, please read this Notice alongside our Recruitment Privacy Notice.
Who we share your personal information with
We routinely share personal information with:
- companies within our group and companies who are affiliated by reason of them having some or all of the same shareholders as us;
- third parties we use to help deliver our services to you, e.g. warehouses, agents instructed by you and/or customers and freight-forwarding and other delivery companies;
- other third parties we use to help us run our business, e.g. marketing agencies or website hosts;
- third parties approved by you, e.g. social media sites you choose to link your account to, your insurer or third party payment providers;
- credit reference agencies;
- our insurers and brokers;
- our banks
We only allow our service providers to handle your personal information if we are satisfied they take appropriate measures to protect your personal information. We also impose contractual obligations on service providers relating to ensure they can only use your personal information to provide services to us and to you and/or our customers. We may also share personal information with external auditors, e.g. in relation to quality assurance accreditations and the audit of our accounts.
We may disclose and exchange information with law enforcement agencies and regulatory bodies to comply with our legal and regulatory obligations.
We may also need to share some personal information with other parties, such as potential buyers of some or all of our business or during a re-structuring. Usually, information will be anonymised but this may not always be possible. The recipient of the information will be bound by confidentiality obligations.
Where your personal information is held
Information may be held at our offices and those of our group and affiliated companies, third party agencies, service providers, representatives and agents as described above (see above: ‘Who we share your personal information with’).
Some of these third parties may be based outside the European Economic Area. For more information, including on how we safeguard your personal information when this occurs, see below: ‘Transferring your personal information out of the EEA’.
How long your personal information will be kept
We will keep your personal information while we are providing services to your organisation or otherwise have a business relationship with you. Thereafter, we will keep your personal information for as long as is necessary:
- to respond to any questions, complaints or claims made by you or on your behalf;
- to show that we treated you fairly;
- to keep records required by law.
We will not retain your personal information for longer than necessary for the purposes set out in this Notice. Different retention periods apply for different types of personal information.
Transferring your personal information out of the EEA
To deliver services to you, it is sometimes necessary for us to share your personal information outside the European Economic Area (EEA), e.g.:
- with our offices outside the EEA;
- with your and our service providers located outside the EEA;
- if you are based outside the EEA;
- where there is an international dimension to the services we are providing to you.
These transfers are subject to special rules under data protection law of European and of our local jurisdiction.
The following countries to which we may transfer personal information have been assessed by the European Commission as providing an adequate level of protection for personal information:
- Faroe Islands;
- Isle of Man;
- New Zealand;
- US (limited to the Privacy Shield framework)
Except for the countries listed above, non-EEA countries do not have the same data protection laws as the United Kingdom and EEA. We will, however, ensure the transfer complies with data protection law and all personal information will be secure. Our standard practice is to use standard data protection contract clauses that have been approved by the European Commission. To obtain a copy of those clauses – see below: ‘How to contact us’
If you would like further information please contact us (see ‘How to contact us’ below).
You have the following rights, which you can exercise free of charge:
|Access||The right to be provided with a copy of your personal information (the right of access)|
|Rectification||The right to require us to correct any mistakes in your personal information|
|To be forgotten||The right to require us to delete your personal information- in certain situations|
|Restriction of processing||The right to require us to restrict processing of your personal information- in certain circumstances, e.g. if you contest the accuracy of the data|
|Data portability||The right to receive the personal information you provided to us, in a structured, commonly used and machine-readable format and/or transmit that data to a third party- in certain situations|
|To object||The right to object:|
– at any time to your personal information being processed for direct marketing (including profiling);
– in certain other situations to our continued processing of your personal information, e.g. processing carried out for the purpose of our legitimate interests.
|Not to be subject to automated individual decision-making||The right not to be subject to a decision based solely on automated processing (including profiling) that produces legal effects concerning you or similarly significantly affects you|
For further information on each of those rights, including the circumstances in which they apply, please contact us or see the Guidance from the UK Information Commissioner’s Office (ICO) on individuals’ rights under the General Data Protection Regulation.
If you would like to exercise any of those rights, please:
- email, call or write to us – see below: ‘How to contact us’; and
- let us have enough information to identify you (e.g. your full name, address and customer or matter reference number);
- let us have proof of your identity and address (a copy of your driving licence or passport and a recent utility or credit card bill); and
- let us know what right you want to exercise and the information to which your request relates.
Keeping your personal information secure
We have appropriate security measures to prevent personal information from accidentally being lost, or used or accessed unlawfully. We limit access to your personal information to those who have a genuine business need to access it. Those processing your information will do so only in an authorised manner and are subject to a duty of confidentiality.
We also have procedures in place to deal with any suspected data security breach. We will notify you and any applicable regulator of a suspected data security breach where we are legally required to do so.
If you want detailed information from Get Safe Online on how to protect your information and your computers and devices against fraud, identity theft, viruses and many other online problems, please visit www.getsafeonline.org. Get Safe Online is supported by HM Government and leading businesses.
How to complain
We hope that we can resolve any query or concern you may raise about our use of your information.
The General Data Protection Regulation also gives you right to lodge a complaint with a supervisory authority, in particular in the European Union (or European Economic Area) state where you work, normally live or where any alleged infringement of data protection laws occurred. The supervisory authority is:
The Information Commissioner who may be contacted at https://ico.org.uk/concerns or telephone: 0303 123 1113 / +44 1625 545 700.
Changes to this Privacy Notice
This privacy notice was published on July 12, 2018 and last updated on July 12, 2018.
We may change this privacy notice from time to time to ensure it is accurate and up to date – when we do we will inform you via our website.
How to contact us
Please contact us by post, email or telephone if you have any questions about this Privacy Notice or the information we hold about you.
Our contact details are shown below:
CargoLogicAir Limited, 3 Roundwood Avenue, Stockley Park, Uxbridge UB11 1AF.
T: 020 3198 7070
Do you need extra help?
If you would like this notice in another format (for example audio, large print, braille) please contact us (see ‘How to contact us’ above).