We are CT2 Ltd (T/A Tower Cold Chain Solutions) with registered number 05639862 and address Unit A, Total Park, Station Road, Theale, Reading, Berkshire, RG7 4PN, UK. Our Data Protection Lead can be contacted at ukandeurope@towercoldchain.com. We have produced this privacy notice in order to keep you informed of how we handle your personal data. All handling of your personal data is done in compliance with the Data Protection Act 2018 and the General Data Protection Regulation (EU) 2016/679 (“Data Protection Legislation”). The terms “Personal Data”, “Special Categories of Personal Data”, “Personal Data Breach”, “Data Protection Officer”, “Data Controller”, “Data Processor”, “Data Subject” and “process” (in the context of usage of Personal Data) shall have the meanings given to them in the Data Protection Legislation. “Data Protection Lead” is the title given to the member of staff leading our data protection compliance programme in lieu of a requirement for a Data Protection Officer.
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What are your rights?
When reading this notice, it might be helpful to understand that your rights arising under Data Protection Legislation include:
- The right to be informed of how your Personal Data is used (through this notice);
- The right to access any personal data held about you;
- The right to rectify any inaccurate or incomplete personal data held about you;
- The right to erasure where it cannot be justified that the information held satisfies any of the criteria outlined in this policy;
- The right to prevent processing for direct marketing purposes, scientific/historical research or in any such way that is likely to cause substantial damage to you or another, including through profile building; and
- The right to object to processing that results in decisions being made about you by automated processes and prevent those decisions being enacted.
You can exercise your right to access personal data held about you by emailing ukandeurope@towercoldchain.com with the subject line: “Subject Access Request”. When you submit a ‘subject access request’, you will need to provide confirmation of your identity by contacting us using the email address associated with your profile or including your phone number for us to contact you to confirm your identity. This is provided free of charge and our response will be made within thirty (30) days unless our Data Protection Lead deems your request as being excessive or unfounded. If this is the case, we will inform you of our reasonable administration costs in advance and/or any associated delays, giving you the opportunity to choose whether you would like to pursue your request. If you believe we have made a mistake in evaluating your request, please see the section ‘Who can you complain to?’. If you have questions about any of the rights mentioned in this section, please contact our Data Protection Lead at ukandeurope@towercoldchain.com.
Who is the Data Controller?
- If we have collected your personal data directly from you for our own purposes, we are the Data Controller.
- If we have been passed your personal data from a third-party for our own purposes, we are the Data Controller. We will contact you to let you know before we first start to use it, or, at the latest, within one month of acquiring it.
- If we have been passed your personal data from a third-party for a joint purpose that we both influence, we are the joint Data Controller. We will contact you to let you know before we first start to use your data, or, at the latest, within one month of acquiring it.
- If we have received your personal data as part of a direct administrative relationship between our business and yours, the Data Controller is your employer for that purpose.
What are the lawful bases for processing personal data?
Under Data Protection Legislation, there must be a ‘lawful basis’ for the use of personal data. The lawful bases are outlined in Article 6, Section 1 of the UK & EU GDPR. They are sub-sections:
- ‘your consent’;
- ‘performance of a contract’;
- ‘compliance with a legal obligation’;
- ‘protection of your, or another’s vital interests’;
- ‘public interest/official authority’; and
- ‘our legitimate interests’.
What are Tower Cold Chain Solutions’ ‘legitimate interests’?
Legitimate interests are a flexible basis upon which the law permits the processing of an individual’s personal data. To determine whether we have a legitimate interest in processing your data, we balance the needs and benefits to us against the risks and benefits for you of us processing your data. This balancing is performed as objectively as possible by our Data Protection Lead. You are able to object to our processing and we shall consider the extent to which this affects whether we have a legitimate interest. If you would like to find out more about our legitimate interests, please contact ukandeurope@towercoldchain.com.
About our processing of your data
We might collect, use, store and transfer different kinds of Personal Data about you which we have grouped together as follows:
Identity Data such as names, usernames or similar; marital status; title; date of birth; sex and gender.
Contact Data such as addresses, email addresses and telephone numbers.
Financial Data such as bank account and payment card information.
Transaction Data such as information about payments and details of purchases you have made.
Technical Data such as IP addresses; login data; browser info; time zone; location; browser plug-ins; operating systems; platforms and other technology on the device used to access this website.
Profile Data such as usernames; passwords; security answers; purchases/orders; interests; preferences; feedback and responses to surveys, blogs and messages.
Usage Data such as analytics relating to how you use the website.
Marketing and Communications Data such as your preferences about receiving communications from us or third parties.
Tower Cold Chain Solutions does not collect any Special Categories of Personal Data about you or any information about criminal convictions/offences.
| Reference | What categories of information about you do we process? | Why are we processing your data? | Where did we get your personal data from? |
|---|---|---|---|
| Client Services |
|
We use the personal data of our clients’ staff in order to communicate with clients and provide our goods and services to our clients. This can also include processing data in relation to billing and support. This processing is conducted lawfully on the basis of ‘performance of a contract’. | Directly obtained from you or referred to us by one of yours or our partners. |
| B2B Marketing |
|
We use the information of business contact information of staff at our current and prospective clients in order to market our products and services to them that we believe they will benefit from. This includes providing relevant industry information and technical data on products. This processing is conducted lawfully on the basis of ‘our legitimate interests’. | Directly obtained from you or referred to us by one of yours or our partners, and occasionally indirectly obtained from public sources. |
| Unsolicited Enquiries |
|
We use the contact information sent to us through web forms, by phone or by email in order to respond to enquiries from existing and potential clients. This processing is conducted lawfully on the basis of ‘our legitimate interests’. | Directly obtained. |
| Tower Control Centre Application (Portal)[EA1] |
|
We use the information of clients’ staff and business contact information to provide access to the application and allow you to track your orders and communicate. We also track your usage of the App in order to assess how it is used by clients and to improve the App. This processing is conducted lawfully on the basis of ‘our legitimate interests’. | Directly obtained from you. |
What happens if I refuse to give Tower Cold Chain Solutions my personal data?
If your personal data is used for Client Services, your personal information has been collected as part of a statutory obligation arising under Companies Act 2006. Failure to process your data could result in us being unable to fulfil the provision of goods/services. The information about you that we have collected for the performance of our contracts is required in order for us to successfully fulfil our obligations to you. If you choose not to provide the personal data requested, we will not be able to enter into a contract with you to provide the services we offer. If we are already processing your personal information under a contract, you must end our contractual relationship (as/where permitted) in order to exercise some of your rights.
What profiling or automated decision making does Tower Cold Chain Solutions perform?
Tower Cold Chain Solutions does not perform any profiling or automated decision making based on your personal data.
How long will your personal data be kept?
Tower Cold Chain Solutions holds different categories of personal data for different periods of time. Wherever possible, we will endeavour to minimise the amount of personal data that we hold and the length of time for which it is held.
- If we process your data on the basis of ‘legitimate interests’, we will retain your data for as long as the purpose for which it is processed remains active. We review the status of our legitimate interests every twelve (12) months and will update this notice whenever we determine that either a legitimate interest no longer exists or that a new one has been found.
- All categories of personal data that are held by us because they are essential for the performance of a contract, will be held for a period of six years, as determined by reference to the Limitations Act 1980, or other periods as might be applicable in other jurisdictions for the purposes of exercising or defending legal claims.
Who else will receive your personal data?
Tower Cold Chain Solutions passes your data to the third parties listed in the section ‘Third Party Interests’ below.
Does your data leave the EU?
Yes. Details are included in the section ‘Third Party Interests’ below.
Third Party Interests
Data Controllers
| Name or Category of Third- Party Controller | What processing are we performing for them? | Why are we processing your data? |
|---|---|---|
| HMRC, regulatory authorities or other authorities | We are joint Controller with these authorities who require reporting of processing in some situations. | N/A |
| Postal/courier providers | We are joint Controller with these providers for the purposes of order fulfilment. | N/A |
Our Data Processors
| Name or Category of Third Party Processor | Purposes for carrying out processing | If applicable – where does data leaving the EEA go and what safeguards are in place? |
|---|---|---|
| Web hosting providers | Website hosting, including the storage of data forming the website content and processing your Technical Data (and Profile Data, where applicable) in order to provide you with access to our websites. | In the interests of providing a quality service, we may use providers located in the United States. With these US based providers Standard Contractual Clauses are in place when personal data is to be shared outside of the UK and EU. |
| Internal technology providers |
|
In the interests of providing a quality service, we may use providers located in the United States. With these US based providers Standard Contractual Clauses are in place when personal data is to be shared outside of the UK and EU. |
| Marketing technology providers | Providers who enable us to send you our marketing emails | In the interests of providing a quality service, we may use providers located in the United States. With these US based providers Standard Contractual Clauses are in place when personal data is to be shared outside of the UK and EU. |
| Banks, Accounting and Payment Services Providers | We use these processors so that we can take electronic or card payments securely and without the requirement for you to disclose this data to us. | In the interests of providing a quality service, we may use providers located in the United States. With these US based providers Standard Contractual Clauses are in place when personal data is to be shared outside of the UK and EU. |
Who can you complain to?
In addition to sending us your complaints directly to ukandeurope@towercoldchain.com, you can send complaints to our supervisory authority. As Tower Cold Chain Solutions predominantly handles the personal data of UK nationals, our supervisory authority is the Information Commissioner’s Office. If you believe that we have failed in our compliance with data protection legislation, complaints to this authority can be made by visiting https://ico.org.uk/concerns/.
