Privacy Policy

Important Information and Who We Are

Introduction

We respect your privacy and are committed to protecting your personal data. This Privacy Policy will inform you about how we look after your personal data, tell you about your privacy rights and how the law protects you. It applies to information we collect in relation to:

· Users of our website;

· People who register to use the We system;

· People who use our online system to enter an event, create a membership or make a purchase with an Organisation;

· Employees or representatives of organisations who use our services or supply us with goods or services;

People who contact us via any medium (e.g. by post, email, telephone or social media).

It is important that you read this Privacy Policy, together with any other Privacy Policy we may provide on specific occasions when we are collecting or processing personal information about you, so that you are aware of how and why we are using such information. This privacy notice supplements the other notices and is not intended to override them.

This Privacy Policy is provided in a layered format so you can click through to the specific areas set out below.

Controller and contact information

We Top Gear Alloys are responsible for your personal data (collectively referred to as “We”, "we", "us" or "our" in this Privacy Policy).

We have appointed a data privacy manager who is responsible for overseeing questions in relation to this Privacy Policy. If you have any questions about this Privacy Policy, please email us on info@topgearalloys.com.

Complaints

You have the right to make a complaint at any time to the Information Commissioner's Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please email us on info@topgearalloys.com in the first instance.

Changes to the Privacy Policy and your duty to inform us of changes

We reserve the right to update this Privacy Policy at any time.

It is important that the personal data we hold about you is accurate and current and to informed us if your personal data changes during your relationship with us.

Third-party links

Our website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the Privacy Policy of every website you visit.

The Data we Collect About You

Types of Date we Collect

Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).

We may collect, use, store and transfer different kinds of personal data about you which we have grouped together follows:

· Identity Data includes first name, last name.

· Contact Data includes contact address, email address, social media account information and telephone numbers.

· Financial Data includes details about payments to and from you. If you choose to pay by credit or debit card we will also ask you for your credit/debit card details. Full card details are only held by approved providers, not by us. All we hold is the card type and last 4 digits of your card number. If you set up a Direct Debit instruction in favour of us then your bank account details will be stored on the our database.

· Transaction Data includes, details of goods or services you have purchased through us.

· Technical Data includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access this website.

· Profile Data includes your username and password, purchases or orders made by you, saved responses to commonly asked event / membership questions, your interests, preferences, feedback and survey responses.

· Usage Data includes information about how you use our website, products and services.

· Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.

We may also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data may be derived from your personal data but is not considered personal data in law as this data does not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this Privacy Policy.

If you fail to provide personal data

Where we need to collect personal data by law, or under the terms of a contract we have with you and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you.

In this case, we may have to cancel a service you have with us but we will notify you if this is the case at the time.

How is your Personal Data Collected?

Methods of Data Collection

We use different methods to collect data from and about you including through:

· Direct interactions. You will give us your Identity, Contact, Financial, Transaction data where applicable, your personal data by completing and submitting a form through our website or by corresponding with us by email, phone, messenger services or post. This includes personal data you provide when you:

1. apply for our services;

2. create an account on our website;

3. subscribe to our service or publications;

4. submit a paper-based Direct Debit Mandate form;

5. request marketing to be sent to you; or

6. give us some feedback.

· Automated technologies or interactions. As you interact with our website, we may automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies, server logs and other similar technologies. Please see our Cookie Policy for further details.

· Third parties. We may receive personal data about you from various third parties as set out below:

o Technical Data from the following parties:

§ Analytics providers such as Google based outside the EU;

o Contact, Financial and Transaction Data from providers of technical, payment and delivery services such as payments providers based outside the EU and BACS based inside the EU.

How we Use your Personal Data

How we Use your Personal Data

We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:

Where we need to perform the contract we are about to enter into or have entered into with you.

Where it is necessary for our legitimate interests (or those of a third party) by which we mean the interest of our business in conducting and managing our business to enable us to give you the best service and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by emailing us on info@topgearalloys.com.

Where we need to comply with a legal or regulatory obligation we are subject to.

Consent and withdrawal of consent

Generally, we do not rely on consent as a legal basis for processing your personal data other than to send to third party direct marketing communications to you via email or text message.

You have the right to withdraw consent to marketing at any time by:

· changing your marketing preferences via your We Account;

· making use of the “unsubscribe” link in emails; and/or

· emailing us at info@topgearalloys.com

You have the right to withdraw consent to our processing of personal data at any time by emailing us on info@topgearalloys.com. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent.

Purposes for which we will use your personal data

We use your personal information in the following ways:

· to provide you with our services and to create and deliver the products you have requested and contact you regarding your use of the services. Such use is necessary to respond to or implement your request and for the performance of the contract between you and us.

· As necessary for certain legitimate business interests, which include the following:

· where we are asked to deal with any enquiries or complaints you make;

· to provide postal, email communications which we think will be of interest to you; where you have given your consent to receiving this information from us where required by law or otherwise in our legitimate interests, provided these interests do not override your right to object to such communications. If you change your mind and would rather not receive this information please send an email at any time to info@topgearalloys.com.

· if you ask us to delete your data or to be removed from our marketing lists and we are required to fulfil your request, to keep basic data to identify you and prevent further unwanted processing; and

· to (a) comply with legal obligations, (b) respond to requests from competent authorities; (b) protect our operations; (c) protect our rights, safety or property, and/or that of our affiliated businesses, you or others; and (d) enforce or defend legal rights, or prevent damage.

· With your consent, we may use your purchased product/service to promote and advertise our business, including (a) in our premises and in our printed publications, presentations, promotional materials (including leaflets, brochures, stickers, bookmarks, posters, factsheets, calendars); (b) on our website and other digital advertising of our services; and (c) in social media forums such as Instagram and Facebook.

· We may provide you with information about goods or services, events and other promotions we feel may interest you. We will contact you by email only with your consent, if this was given at the time you provided us with the personal data. You can object to further marketing at any time by checking and updating your contact details within your account, or selecting the "unsubscribe" link at the end of all our marketing and promotional update communications to you, or by sending us an email to info@topgearalloys.com.

· We may use your personal data for other purposes which you have consented to at the time of providing your data.

As used in this Privacy Policy, “legitimate interests” means our interests in conducting and managing our business. When we process your personal data for our legitimate interests, we make sure to consider and balance any potential impact on you, and your rights under data protection laws. Our legitimate interests do not automatically override your interests.

We will not use your personal data for activities where our interests are overridden by the impact on you, unless we have your consent or those activities are otherwise required or permitted to by law. You have the right to object at any time to processing of your personal data that is based on our legitimate interests, on grounds relating to your particular situation (for more information on your rights, please see “Your Data Protection Rights” section below).

Third-party marketing

We will get your express opt-in consent before we share your personal data with any company for marketing purposes.

Opting out

You can ask us or third parties to stop sending you marketing messages at any time by logging into the website and checking or unchecking relevant boxes to adjust your marketing preferences or by following the opt-out links on any marketing message sent to you or by emailing us on info@topgearalloys.com at any time.

Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of a product/service purchase or other transactions.

Cookies

You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of this website may become inaccessible or not function properly. For more information about the cookies we use, please see our Cookie Policy.

Change of purpose

We will only use your personal data 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 you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please email us on info@topgearalloys.com.

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

Disclosures of your Personal Data

Disclosures of your Personal Data

We require all third parties to whom we disclose your data in accordance with this policy to respect the security of your personal data and to treat it in accordance with the law.

Specific Third Parties

We will pass on your Identity, Contact, Transaction and, where applicable, personal data, to the Organisation supplying the service or providing the facility to purchased goods.

If you pay for a transaction by credit or debit card we pass your Identity, Contact and Financial details to approved payments providers to process your card payment. If you choose to pay for a transaction by direct debit we will pass your Identity and Financial details to BACS to set up and process your direct debit instruction.

Please check their own Privacy Policy/Terms & Conditions to see how they will use this data to manage your activity / purchase.

Third Party Service Providers

We may transfer your personal data to third party vendors which provides sales and marketing, daily administration and general customer facing services to us.

We may also have to share your personal data with the parties set out below for the purposes set out in the table in in the "Purposes for which we will use your personal data" section above.

Service providers acting as processors based within the EU who provide webhosting, back-up and other IT and system administration services.

· Professional advisers acting as processors or joint controllers including lawyers, bankers, auditors and insurers based in the United Kingdom who provide consultancy, banking, legal, insurance and accounting services.

· HM Revenue & Customs, regulators and other authorities acting as processors or joint controllers based in the United Kingdom who require reporting of processing activities in certain circumstances.

· Third parties to whom we may choose to sell, transfer, or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this Privacy Policy.

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.

Data Security

Data Security

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 data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

Data Retention

How long will you use my personal data for?

We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.

To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.

By law we have to keep basic information about our customers (including Contact, Identity, Financial and Transaction Data) for six years after they cease being customers for tax purposes.

Any data we are not required to hold for tax or other legal purposes will be held for no more than 3 years following the event or membership for which it was gathered.

In some circumstances you can ask us to delete your data: see Request erasure below for further information.

In some circumstances we may anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes in which case we may use this information indefinitely without further notice to you.

Your Legal Rights

Your Legal Rights

Under certain circumstances, you have rights under data protection laws in relation to your personal data. 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.

· 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 services to you. We will advise you if this is the case at the time you withdraw your consent.

If you wish to exercise any of the rights set out above, please email us on info@topgearalloys.com.

No fee usually required

You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.

What we may need from you

We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

Time limit to respond

We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.