General

We understand that you are aware of and care about your own personal privacy interests, and we take that seriously. Ifor Williams Trailers Ltd (IWT) will be the Data Controller and this privacy notice sets out the policies and practices regarding the collection and use of your personal data, and sets forth your privacy rights.

We recognise that information privacy is an ongoing responsibility, and so we will from time to time update this Privacy Notice as we undertake new personal data practices or adopt new privacy policies. Each time you enter this site, you agree that the privacy statement current at that time shall apply to all data which we hold about you.

Our personal information handling policy and procedures have been developed in line with the requirements of the General Data Protection Regulation (GDPR).

We must have a lawful basis to process your personal data, and this policy explains what our lawful basis is in respect of each purpose for which we keep and use information about you. Generally, we are allowed to process your personal data where it is necessary in connection with a contract between us (such as a contract to supply our products or services), where it is necessary in order for us to comply with our legal obligations, or where we have a legitimate interest to do so (but we will always consider whether your right to privacy overrides our interest).

Information we collect and process

We collect information using cookies and other similar technologies to help distinguish you from other users of our website. These can streamline your online experience by saving you from re-inputting some information and also allow us to make improvements to our website. For more information about how and why we use cookies, please take a look through our Cookie Policy.

When you visit our website we may collect the following information:

• Which pages you view and which links you follow
• Your IP address and general location
• Details of the hardware and software that you are using to access the site
• A device identifier (cookie or IP address) for fraud prevention
• Details of your visits to our website and the resources that you access, including, but not limited to, traffic data, location data, weblogs and other communication data 

We collect and process personal data about you when you interact with us, purchase goods and services from us, register a trailer with us, or make an application for employment with us. The personal data we process includes:

• Your name
• Your home or work address, email address and/or phone number
• Recordings of telephone calls you make to our customer care team
• Your payment and delivery details, including billing and delivery addresses and credit/debit card details, where you make purchases from us
• CCTV footage whilst you are on any Ifor Williams Trailers Ltd premises
• And/or any other information you provide

For job applicants, in addition to the above and unless we inform you otherwise during the recruitment process, we may collect and process the following personal data about you when you apply for a job with us:

• Your nationality and National Insurance number (where you provide this to us)
• Your educational and employment history
• Other information contained within your CV or other documents, or information you submit to us
• Information from the selection process
• References relating to your work for previous employers
• Medical and financial information (where you provide this to us)
• Information to confirm your identity and right to work, such as a copy of your passport and/or driving licence
• Details of any unspent criminal convictions 

We obtain this information directly from you, our own personnel, as well as from third parties such as recruitment agencies, background checking companies or former employers. We may also obtain it from your public profiles available online.

How we use this information and the legal basis for this use

Supplying our products and providing our services

It is necessary for us to use personal information about you to enter into and perform the contracts that we make with you, such as when you become a customer. Using your information in this context is necessary so that we can:

• Provide you with information about the products and services
• Contact you for the purpose of sales enquiries and sales
• Carry out our obligations arising from any contract that we have with you
• Verify your identity
• Deal with any complaints you may have
• Contact you about any changes that we make to our products, services or organisation
• Administer our website, including troubleshooting problems, analysing statistics, conducting research and tests and keeping the site secure

If you enquire about, or apply for, a job vacancy, it is necessary for us to use your personal information as part of the recruitment process, in order to assess your suitability for a particular role.

Telling you about products or services that we think may be of interest to you

We may use your information to identify and tell you about events and our products or services that we think may be of interest to you. We will only do this where you have informed us that you would like to receive marketing communications.

If we do contact you about market research you do not have to participate. If you tell us that you do not want to receive market research communications, we will respect this.

Whether you chose to receive marketing communications or market research communications is up to you. You can choose to receive both, none, or just one or the other. Your choice will not affect any products or services that you have purchased from us, nor will it affect any quotes for products or services you buy in future.

You can update your preferences by using the links in any of our emails, or by getting in touch with us using our website.

Telling you about products or services that are similar to ones that you have already bought

If you have already contacted us about purchasing a particular product or services, we may contact you with some information about products and services that are similar.

We will only contact you by email or text message and you can choose not to receive these messages at any time. Simply follow the instructions in the message, or get in touch using our website.

Making our organisation better

We always want to offer the best services, events and experience that we can. Sometimes this means we may use your information to find ways that we can improve what we do, or how we do it.

In this context, we will only use your information where it is necessary so that we can:

• Review and improve our existing services and develop new ones
• Review and improve the performance of our systems, processes and staff (including training)
• Improve our site to ensure that content is presented in the most effective manner for you and for your computer
• Measure and understand the effectiveness of advertising we serve to you and others, and to deliver relevant advertising to you 

Contacting you

We want to stay in touch with you. Sometimes we may need to use the information that we have about you in order to respond to your questions or let you know about important changes. We will only use your information in this respect where it is necessary so that we can:

• Interact and respond to any communications you send us, including where you use the Contact Us section, and any social media posts that you tag us in
• Let you know about any important changes to our business or policies 

Verifying your identity

We may use your information where it is necessary for us to do so in order to meet our legal obligations or to detect and prevent fraud, money-laundering and other crimes. 

Protecting you and others from harm

We may use your information where it is necessary to protect your interests, or the interests of others. This may include in the event of criminality such as identity theft, piracy or fraud.

We need all the categories of information listed above to allow us: 

• To provide our services to you; 
• To enable us to comply with legal obligations; and
• To pursue legitimate interests of our own or those of third parties (provided your interests and fundamental rights do not override those interests). 

The situations in which we will process your personal data are listed set out in the table below and indicate the purpose or purposes for which we are processing or will process your personal information.

Change of purpose

We will only use your personal information 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 we need to use your personal information 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 information without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law. 

Sharing your personal data

We may share your personal data with third-parties including our professional advisors such as our external legal and financial advisors and with our distributors.

We may share your data with selected third-parties. For example, we may share your information with:

• ‘OGL Computer Services Group’, for support and maintenance of our computer systems and associated infrastructure
• ‘Check Group’, for support of our telephone and CCTV systems
• Internet hosting providers, to host the websites, related infrastructure, services and applications, ‘Heart Internet’, ‘OVH’ & ‘Pweb Solutions’
• ‘The Access Group’, to manage accounting, operation, payroll and payments in respect of our employees
• ‘123 Insight’ for support of our ERP systems

There are certain exceptional circumstances in which we may disclose your information to third-parties. This would be where we believe that the disclosure is: 

• Required by the law, or in order to comply with judicial proceedings, court orders or legal or regulatory proceedings
• Necessary to protect the safety of our employees, our property or the public
• Necessary for the prevention or detection of crime, including exchanging information with other companies or organisations for the purposes of fraud protection and credit risk reduction
• Proportionate as part of a merger, business or asset sale, in the event that this happens we will share your information with the prospective seller or buyer involved

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 instructions.

How long we will keep your personal data

We will not keep your personal information for any purpose for longer than is necessary and we will only retain the personal information that is necessary in relation to the purpose. We are also required to retain certain information as required by law or for as long as is reasonably necessary to meet regulatory requirements, resolve disputes, prevent fraud or enforce our terms and conditions.

Where you are or have been a registered keeper of an Ifor Williams Trailers Ltd product, we will keep your contact information indefinitely in order to assist law enforcement agencies and The Equipment Register (TER) https://www.ter-europe.org/ with preventing the theft of trailers, and in recovering stolen trailers and re-uniting them with their registered keepers.

For job applicants we will keep the personal data connected to your job application (including any interview records) indefinitely, or for as long as we believe this is in your and our best interests.

Where we store your personal data

The personal data that we collect from you is stored on our own secure servers and secure document filing systems, and will not be transferred or stored outside the European Economic Area (EEA).

We are committed to ensuring that your information is secure, and in order to prevent unauthorised access or disclosure, we have put in place suitable physical, electronic and managerial procedures to safeguard and secure the information we collect. 

We try to ensure that all information you provide to us is transferred securely via the website. Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted to our site; any transmission is at your own risk. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorised access.

All information you provide to us is stored on our/third party secure servers.

Your rights in relation to your personal data

You have the right to be informed.

We have a legal obligation to provide you with concise, transparent, intelligible and easily accessible information about your personal information and our use of it. We have written this policy to do just that, but if you have any questions or require more specific information, you can get in touch using Contact Us section of the website. 

You have the right to access your personal data

You have the right to ask us to confirm whether or not we hold any of your personal information. If we do, you have the right to have a copy of your information and to be informed of the following:

• Why we have been using your information
• What categories of information we were using
• Who we have shared the information with
• How long we envisage holding your information 

In order to maintain the security of your information, we will have to verify your identity before we provide you with a copy of the information we hold.

The first copy of your information that you request from us will be provided free of charge, if you require further copies we may charge an administrative fee to cover our costs.

You have the right to correct any inaccurate or incomplete personal data.

Where you have requested a copy of the information we hold about you, you may notice that there are inaccuracies in the records, or that certain parts are incomplete. If this is the case you can contact us so that we can correct our records.

You have the right to be forgotten

There may be times where it is no longer necessary for us to hold personal information about you. This could be if:

• The information is no longer needed for the original purpose that we collected it for
• You withdraw your consent for us to use the information (and we have no other legal reason to keep using it)
• You object to us using your information and we have no overriding reason to keep using it
• We have used your information unlawfully
• We are subject to a legal requirement to delete your information

In those situations you have the right to have your personal data deleted. If you believe one of these situations applies to you, please get in touch using our website. 

You have the right to have a copy of your data transferred to you or a third party in a compatible format

Also known as data portability, you have the right to obtain a copy of your personal data for your own purposes. This right allows you to move, copy or transfer your personal data more easily from one IT system to another, in a safe and secure way.

If you would like us to transfer a copy of your data to you or another organisation in a structured, commonly used and machine-readable format, please contact us. There is no charge for you exercising this right.

You have the right to object to direct marketing

You can tell us at any time that you would prefer that we do not use your information for direct marketing purposes. If you would not like to receive any direct marketing from us, please contact us or use the links provided in any of our marketing communications, and we will stop sending direct marketing.

You have the right to object to us using your information for our own legitimate interests

Sometimes, we use your personal information to achieve goals that will help us as well as you. This includes:

• When we tell you about services, products or events that are similar to ones that you have already engaged with, bought or attended
• When we use your information to help us make our business better
• When we contact you to interact, communicate or let you know about changes we are making

We aim to always ensure that your rights and information are properly protected. If you believe that the way we are using your data is not justified due to its impact on you or your rights, you have the right to object. Unless we have a compelling reason to continue, we must stop using your personal data for these purposes.

In order to exercise your right to object to our use of your data for the purposes above, please contact us.

You have the right to restrict how we use your personal data

You have the right to ask us to stop using your personal data in any way other than simply keeping a copy of it. This right is available where:

• You have informed us that the information we hold about you is inaccurate, and we have not yet been able to verify this
• You have objected to us using your information for our own legitimate interests and we are in the process of considering your objection
• We have used your information in an unlawful way, but you do not want us to delete your data
• We no longer need to use the information, but you need it for a legal claim

If you believe any of these situations apply, please contact us.

You have rights related to automated-decision making and profiling

Any automated decision-making or profiling we undertake is solely for the purpose of tailoring the information which we provide to you. We will not use automated decision-making or profiling to make any decisions which will have a legal effect upon you or otherwise significantly affect you, and you have the right not to be subject to such decisions. If you have any concerns or questions about this right, please contact us.

Contacting us

Should you have any queries regarding this privacy notice, about Ifor Williams Trailers Ltd processing of your personal data or wish to exercise your rights you can contact our Data Protection Officer using this email address: dpo ( at ) iwt dot co dot uk.

If you are not happy with our response, you can contact the Information Commissioner's Office: https://ico.org.uk/