24th May 2018 Date of next review April 2019
WCF Ltd, Crawhall, Brampton, Cumbria, CA8 1TN (trading as WCF Fuels North West) ("We", "the Company", "WCF Fuels North West”) are committed to protecting and respecting the confidentiality, integrity and security of the personal information we hold about each past or present customer, enquirer, prospect or visitor to our website ("you", "your").
This policy sets out the basis on which any personal data we collect from you, or that you provide to us, will be processed by us, and how we comply with our responsibilities under applicable data protection laws ("Data Protection Laws"). Please read this policy carefully and if you have any questions or concerns please contact us using the information below.
For the purposes of the Data Protection Laws, the data controller of your personal information is WCF Ltd, Crawhall, Brampton, Cumbria, CA8 1TN.
Personal data collection
We only hold personal data about you which you have provided to us or to one of our authorised data processors or has been collected via social media metadata.
Categories of personal data we may collect and hold
We may collect the following information from our customers:
· contact details including billing and delivery addresses;
· purchasing histories;
· credit card or bank details if applicable; and
· social media metadata
Purposes for which your personal data is used
We will use the personal data which you provide to us for the following purposes:-
· identifying customers automatically using their telephone number when ringing customer services;
· taking payments in relation to the purchase of products;
· sending out price information and email newsletters;
· de-duping against alternative and our own databases;
· preventing fraud and enhancing the security of our networks;
· understanding how our customers interact with our websites and personalising their repeat visits;
· determining the effectiveness of our promotional campaigns and advertising;
· responding to queries and complaints; and
· fulfilling our legal and fiduciary responsibilities.
Legal basis for Processing
In processing customer data WCF relies on the following legal bases:
· Where it is necessary for the performance of our contract to deliver bulk fuel oil or lubricants;
· Where it is necessary for compliance with our legal obligations;
· Where it is necessary for the purposes of WCF’s legitimate business interests, which include maintaining direct, relevant and appropriate contact with our customers to enable us to give them the best and relevant service and products; and in some cases
· Where the data subject has given their consent for the processing of their personal data
We may process customer data on more than one legal basis. Please contact us if you need details as to which legal ground we are relying on to process any specific item of personal data.
Where we rely on consent to send marketing communications, you have the right to withdraw your consent at any time by contacting one of our sales team on 01524 733669.
Disclosure of your personal data
We will not disclose personal information we hold about you to any third party except as set out below.
We may disclose personal data to third parties who are providing services to us, in particular to the IT companies that support our order processing, ecommerce and e-mail newsletter systems, to the mailing houses and postal services that distribute our marketing literature and to payment processors for the purposes of order payments and refunds.
We may also disclose personal data we hold to third parties:
(a) in the event that we sell any business or assets, in which case we may disclose personal data we hold to the prospective buyer of such business or assets; and/or
(b) if we are permitted by law to disclose your personal data to that third party or are under a legal obligation to disclose your personal data to that third party.
We occasionally utilise third parties to undertake bulk fuel oil or lubricant deliveries on our behalf, particularly in geographical locations in which we do not have a presence. In these instances, your name, delivery address, contact information and order details would be passed to the third party, in relation to that delivery only.
Updating your marketing preferences
We have no desire to contact those customers, prospects or enquirers who do not wish to receive marketing correspondence from us. We rely on freely given, specific, informed and unambiguous statements from our customers which signifies your agreement to the processing of your personal data for marketing purposes.
If you wish to change your marketing preferences there are various ways in which you can do this:
· by telephone to our sales teams on 01524 733669;
· in writing to WCF Fuels North West, Station Goods Yard, Warton Road, Carnforth, Lancashire, LA5 9EU;
· by email at email@example.com; or
· using the online contact form at https://www.wcfnw.co.uk/contact-us/
Access and other rights
You may request to see the personal information we hold about you either digitally or on file at any point by making a request in writing to us via The Company Secretary, WCF Ltd, Crawhall, Brampton, Cumbria, CA8 1TN or via email on firstname.lastname@example.org. This request will be responded to within 30 working days. You will be provided with a copy of the personal information we hold about you. If we require more time to respond fully to any request, we will notify you in writing within the 30-day period referred to. Any additional copies of any information we provide to you may be subject to a reasonable fee.
You also have other rights under Data Protection Laws in relation to your personal data. In particular, you may have (i) the right to request that we rectify or erase information we hold about you in certain circumstances, (ii) the right to ask us to limit our processing of your information, (iii) the right (if we are processing information based on your consent, such as for marketing purposes) to withdraw your consent, (iv) the right to object to certain processing of your information (including the right to object to processing of your personal data for direct marketing purposes at any time), (v) the right to ask us to move, copy or transfer your personal information to another organisation.
If you wish to exercise any of these rights, please contact us via the Company Secretary at Crawhall, Brampton, Cumbria, CA8 1TN or via email on email@example.com.
Accuracy of personal data
We try to ensure that the information we hold about you is accurate and kept up-to-date and may ask you to re-confirm certain information when you place an order. However, if at any time you believe that any information we are holding about you is inaccurate, out-of-date or incomplete, please notify us in writing via WCF Fuels North West, Station Goods Yard, Warton Road, Carnforth, Lancashire, LA5 9EU, by calling 01524 733669 or via email at firstname.lastname@example.org as soon as possible. We will promptly correct or delete any information found to be incorrect.
We have put in place what we consider to be appropriate security measures against unlawful or unauthorised processing of the personal data we hold about you, and against the accidental loss of, or damage to, such personal data.
Transferring personal data outside the EEA
Except if appropriate safeguards are in place, we will not transfer any data to a country outside of the European Economic Area ("EEA") or to a person based outside the EEA (unless required to do so by applicable EU or member state law to which we are subject) and, in such circumstances, we shall inform you of such requirement (unless prohibited by applicable EU or member state law on important grounds of public interest). If we or one of our data processors enters into EU Standard Contractual Clauses (or their equivalent in the UK) with a third party outside the EEA to whom personal information is being transferred, this will be deemed "appropriate safeguards" for the purposes of this Policy.
Retention of data
We are committed to ensuring that we do not retain personal data for any longer than is necessary for the purposes for which it was obtained. In the majority of cases, all personal data about you will be deleted 6 years after the date of your last order. Credit card tokens are held until expiry of the credit card.
You can update your marketing preferences at any time by using one of the methods outlined above.
Third Party Links
This 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 notice of every website you visit.
Changes to this policy
If you have any queries about this policy or your personal data, or you wish to submit an access request or raise a complaint about the way your personal data has been handled, please do so in writing and address this to the Company Secretary, WCF Ltd, Crawhall, Brampton, Cumbria, CA8 1TN or via email on email@example.com.
If you are not satisfied with our response to any queries or complaints you raise with us or believe we are not processing your personal data in accordance with the Data Protection Laws you have the right to lodge a complaint at the Information Commissioner’s Office (https://ico.org.uk/).