Last updated: 11th September 2020
Coltella Ltd (“we” or “us”) is committed to data protection and data privacy. With the General Data Protection Regulation (GDPR) that came into force on 25 May 2018, we have undertaken a GDPR readiness programme to review our entire business, the way we handle data and the way in which we use it to provide our services and manage business operations.
We hold personal data to meet legal and contractual obligations, to perform vital internal functions and to provide services to our customers. This policy details the personal data we may retain, process and share with third parties. We are committed to ensuring that your information is secure, accurate and relevant. To prevent unauthorised access or disclosure, we have implemented suitable physical, electronic, and managerial procedures to safeguard and secure any personal data we hold.
What's this all about?
We respect the privacy rights of individuals and are committed to handling personal data responsibly and in accordance with applicable law.
This policy sets out the personal data that we collect and process about you, the purposes of the processing and the rights that you have in connection with it.
What types of Personal Data does Coltella process?
The information we hold on you will be dependant on our relationship with us. In most cases, such as if you’re a customer, partner or someone we’d like to work with this will include:
- Job role
- Work Address
- Telephone number/s
- Email address
- Payment Information
For visitors to our websites we will also be recording:
- IP Address
- Account Usernames
On what Legal Basis does Coltella process Personal Data?
Depending on the nature of our relationship with you, the legal basis for processing may be:
- where the processing is necessary for the performance of our contract or in order to take steps at your request prior to entering into any contract;
- it is necessary for the purposes of our legitimate interests being managing our relationship with you;
- where you have given consent to the processing of your personal data for one or more specific purposes;
Who might Coltella share Personal Data with?
Whenever we permit a third party to access personal and special category data, we will implement appropriate measures to ensure such data is used in a manner consistent with this policy and that the security and confidentiality of the personal and special category data are maintained.
In addition, we make certain personal available to third parties who provide services to us. We do so on a “need to know basis” and in accordance with applicable data protection and data privacy laws.
We may also disclose personal and/or special category data to third parties on other lawful grounds, including:
- To comply with our legal obligations, including where necessary to abide by law, regulation or contract, or to respond to a court order, administrative or judicial process
- In response to lawful requests by public authorities (including for national security or law enforcement purposes)
- As necessary to establish, exercise or defend against potential, threatened or actual litigation
- Where necessary to protect the vital interests of our employees or another person
- In connection with the sale, assignment or other transfer of all or part of our business; or
- With your freely given and explicit consent.
Transfers of Personal Data outside the EEA
We may need to transfer personal and special category data to countries outside of the United Kingdom. If we export your personal data to a different country, we will take steps to ensure that such data exports comply with applicable laws. For example, if we transfer personal and/or special category data outside the United Kingdom, such as to the United States, we will implement an appropriate data export solution such as entering into Standard Contractual Clauses (SCC).
How long does Coltella retain Personal Data for?
Personal data is stored in accordance with applicable laws and kept for as long as needed to carry out the purposes described in this notice or as otherwise required by law.
We will store your personal data for a period of 12 months following the last contact with you, except where services are provided or there is a legal requirement to retain your data.
How do we keep your data secure?
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 and special category data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.
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. We may need to request confirmation of identity to ensure you have a right to access this data.
- 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.
- The right to object to automated processing which makes decisions regarding the rights of the individual without human involvement.
If you wish to exercise any of the rights set out above, please contact us at firstname.lastname@example.org
Issues and complaints around privacy
We try to meet the highest standards when collecting and using personal information. For this reason, we take any complaints we receive about this very seriously. We encourage people to bring it to our attention if they think that our collection or use of information is unfair, misleading or inappropriate. We would also welcome any suggestions for improving our procedures.
This notice was drafted with clarity in mind. It does not provide exhaustive detail of all aspects of our collection and use of personal information. However, we are happy to provide any additional information or explanation needed.
If you want to make a complaint about the way we have processed your personal information, you can contact the Data Protection Officer.
You can also make a complaint to the Information Commissioner, who is an independent regulator by:
Telephone: 0303 123 1113
Information Commissioner’s Office
Cheshire SK9 5AF
Updates to this notice
This notice may be updated periodically to reflect any necessary changes in our privacy practices. In such cases, if we have relevant contact details then we will inform you of such changes.
We encourage you to check this policy periodically to be aware of the most recent version.
Data Controller & Data Protection Officer
Please address any questions or requests relating to this notice to the Data Protection Officer.
Data Protection Officer
11 Lapwing Lane
Registered in England and Wales: 10894285
Tel: (0)330 043 4019