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Autoglym Privacy Notice
Last Updated: 19 October 2018
This Privacy Notice provides you with information about how we will handle your personal information whenever we deal with you and including when you use the following websites which we provide:
Autoglym is committed to protecting and respecting your privacy and complying with data protection laws. This Privacy Notice sets out the basis on which any personal information we collect from or about you, or that you provide to us, will be processed by us. Please read the following carefully to understand the personal information we hold about you, how we use your information and who we share it with. The data controller of the personal information referred to in this Privacy Notice is Altro Limited of Works Road, Letchworth Garden City, Hertfordshire SG6 1NW, with company number 00154159 and contact details at section 10 and 'Autoglym' is an Altro brand.
We may update this Privacy Notice from time to time in response to changing legal, technical or business developments. When we update our Privacy Notice, we will take appropriate measures to inform you, consistent with the significance of the changes we make. We will obtain your consent to any material changes to our Privacy Notice if and where this is required by data protection laws. You can see when this Privacy Notice was last updated at the top of the page.
1. Information we collect automatically
When you visit our Website, we automatically collect certain information from your device using cookies and other online tracking technologies. For more information about the cookies and tracking technologies which we use on our Website, why we use them and how you can manage them, please see our Cookies Policy at www.autoglym.com.au/cookie-policy-au.
2. Information you provide voluntarily
In using our Website, you may voluntarily provide us with personal information in the following ways:
Signing-up to our Newsletter. If we ask you on our Website whether you want to "Sign up" to receive information from us and you provide us with your personal information we will use that personal information to send you the latest case studies, events updates and product news about us and our distributors.
Contact Us. From time to time, you may wish to contact us or your local distributor with queries or complaints regarding our products and services using our Contact Us and Help and Advice pages. You may contact us through a variety of channels including e-mail, letter, phone, through our social media channels or using the Contact Us and Help and Advice pages on our Website. When you contact us and provide us with your contact information (such as your name, user name, address, email address and telephone number) and details of your query or complaint, we and our distributors will use this information to administer your query or complaint and to improve our service in the future. We will manage and record your query or complaint using our Customer Relationship Management (CRM) system, as explained further at section 5 below.
3. Our use of your information
Our legal basis for collecting and using the personal information described above will depend on the personal information concerned and the specific context in which we collect it.
We will normally collect personal information from you only where we need the personal information where the processing is in our legitimate interests and not overridden by your data protection interests or fundamental rights and freedoms, which is assessed through a balancing test we carry out (you can obtain information about the balancing test by contacting us using the contact details at section 10) or where we have your consent to do so. In some cases, we may also have a legal obligation to collect personal information from you or may otherwise need the personal information to perform a contract with you or protect your vital interests or those of another person.
Where we collect and process your information for our legitimate interests, this will normally be to operate our Website and communicating with you as necessary to provide our products and services to you. We will also use your information for other legitimate commercial interests, for instance, when responding to your queries, improving our Website, sending you marketing about us or our distributors or for the purposes of detecting or preventing illegal activities. We may have other legitimate interests and we will make clear to you at the relevant time what those legitimate interests are.
Where you have provided us with your contact details, we will use these to send you marketing communications about us and our distributors by phone and post and also by e-mail where you have provided your consent or where the law allows us to do so. You can opt-out of receiving marketing communications from us at any time by using the opt-out link in each message or by contacting us using the contact details at section 10. We will not send marketing communications to individuals who have registered their preference not to receive marketing communications and where the law states that we must not do so.
If we ask you to provide personal information to comply with a legal requirement or to perform a contract with you, we will make this clear at the relevant time and advise you whether the provision of your personal information is mandatory or not (as well as of the possible consequences if you do not provide your personal information).
4. Electronic communications
As explained above, we may send you marketing communications or newsletters by email, either where you have actively consented to these, or where we are entitled to do so by law.
If at any stage you no longer wish to receive these types of email, please use the opt-out link at the bottom of every message or contact us using the contact details provided at section 10.
To opt-out of any other types of marketing (such as postal marketing or telemarketing), then please contact us using the contact details provided at section 10.
Please note that even where you have opted-out of marketing communications, we may still need to send you service messages, for example, a confirmation email about a product you have ordered through our distributors or to respond to your questions or complaints.
5. Telephone communications
When you telephone us or our local distributor your call may be recorded for training and quality purposes. We will only do this in order to make sure that our teams are operating as well as they can, allowing us to provide you with our greatest level of customer service. The call recording is used only by us for checking and improving the quality of our service. We will also record the fact that we have spoken with you on our CRM so that we have a record of your call and can manage our relationship with you.
6. Our disclosure of your information
We do not sell or rent any of your personal information to any third party. However, your personal information may be shared with or disclosed to third parties from time to time, as described in this section.
We may disclose your personal information to the following categories of recipients:
any of our distributors who provide our products or services to you in in order to manage any enquiry or complaint which you send to us. If you contact or deal direct with one of our distributors, they will collect and process your information in accordance with data protection laws and they will be the data controller of any information which you provide to them. We may also share your details with our distributors for marketing purposes, but only where we have your consent for this or the law allows it;
to our third party service providers who provide data processing services to us (for example, to support the performance of our Website, to enhance the security of our Website, to send you e-mails and to provide you with materials, products and services that you have ordered or requested from us or our distributors);
to any competent law enforcement body, regulatory body, government agency, court or other third party where we believe disclosure is necessary (i) as a matter of applicable law or regulation, (ii) to exercise, establish or defend our legal rights, or (iii) to protect your vital interests or those of any other person;
to a potential buyer (and its agents and advisers) in connection with any proposed purchase, merger or acquisition of any part of our business, provided that we inform the buyer it must use your personal information only for the purposes disclosed in this Privacy Notice; and
to any other person with your consent to the disclosure.
If you are a customer in Australia, We may disclose your personal information overseas to recipients located in the EEA. We store and process your personal information within the European Economic Area ("EEA") and the majority of recipients identified above are located in the EEA.
However, if at any time we need to transfer your personal information outside of the EEA, we will take steps to ensure that the information receives the same level of protection as if it remained within the EEA, including by entering into data transfer agreements, using the EU Commission approved Standard Contractual Clauses, or by relying on certification schemes such as the EU - US Privacy Shield. If you would like more details of the mechanism under which your data is transferred outside of the EEA, please contact us using the contact details in section 10.
7. Security of your information
We employ appropriate technical and organisational security measures in an effort to protect your personal information from unauthorised access, improper use or disclosure, unauthorised modification or unlawful destruction or accidental loss. However, it is important to remember that no web based platform can be 100% secure and we cannot be held responsible for unauthorised or unintended access that is outside of our control.
If we become aware of any breach of your personal information, we will take steps to promptly assess and remediate the breach. Where appropriate, and in accordance with our legal obligations, we may also take steps to notify you about the breach, in particular where we believe that the breach has resulted in a high risk to your rights and freedoms.
8. Retention of your information
We keep personal information only for as long as required to fulfil the purposes for which it was collected. However, in some circumstances we may retain personal information for longer periods of time, for instance where we are required to do so in accordance with legal, tax and accounting requirements. For example, if you report a complaint to us about one of our distributors, we will keep your complaint in order to investigate and resolve your complaint. Once your complaint has been investigated and resolved, we will keep a record of the complaint, our investigation and its resolution on our records in order to manage any claim which you or we may have in the future until the period in which a claim may be brought has come to an end. When we have no ongoing legitimate business need to process your personal information, we will either delete or anonymise it or, if this is not possible (for example, because your personal information has been stored in backup archives), then we will securely store your personal information and isolate it from any further processing until deletion is possible. For more information on specific retention periods contact us using the contact details provided at section 10.
9. Your rights
If you are located in Australia:
You may access the personal information we hold about you, upon making a written request. We will respond to your request within a reasonable period. We may charge you a reasonable fee for processing your request (but not for making the request for access).
We may decline a request for access to personal information in circumstances prescribed by the Privacy Act, and if we do, we will give you a written notice that sets out the reasons for the refusal (unless it would be unreasonable to provide those reasons).
If, upon receiving access to your personal information or at any other time, you believe the personal information we hold about you is inaccurate, incomplete or out of date, please notify us immediately. We will take reasonable steps to correct the information so that it is accurate, complete and up to date.
If we refuse to correct your personal information, we will give you a written notice that sets out our reasons for our refusal (unless it would be unreasonable to provide those reasons), including details of the mechanisms available to you to make a complaint.
If you are located in the EEA, you have the following rights in respect of your personal information:
If you wish to access, correct, update or request deletion of your personal information, you can do so at any time by contacting us using the contact details in section 10.
In addition, you can object to processing of your personal information, ask us to restrict processing of your personal information or request portability of your personal information. Again, you can exercise these rights by contacting us using the contact details in section 10.
You have the right to opt-out of marketing communications we send you at any time. You can exercise this right by clicking on the “unsubscribe” or “opt-out” link in the marketing e-mails we send you. To opt-out of other forms of marketing (such as postal marketing or telemarketing), then please contact us using the contact details in section 10.
Similarly, if we have collected and process your personal information with your consent, then you can withdraw your consent at any time by contacting us using the contact details in section 10. Withdrawing your consent will not affect the lawfulness of any processing we conducted prior to your withdrawal, nor will it affect processing of your personal information conducted in reliance on lawful processing grounds other than consent.
We will respond to and manage any requests which you make in relation to the rights set out above in accordance with data protection laws. In addition to the above, you have the right to lodge a complaint with the UK data protection authority or your local data protection authority - you can find contact details for data protection authorities in EU countries here. If you are located in Australia, you can submit a complaint to the Office of the Australian Information Commissioner at http://www.oaic.gov.au/privacy/privacy-complaints. We are keen to address any issues with our use of your personal information or the exercising of your rights, and in the first instance we would ask that you attempt to resolve the problem with us directly.
In relation to all of these rights, please contact us using the details given below. Please note that we may request proof of identity, and we reserve the right to charge a fee where permitted by law, for instance if your request is manifestly unfounded or excessive.
10. Contact us
If you have any questions about this Notice, or any queries or complaints about how your personal information is used, or if you wish to exercise any of your information rights, please contact us by email at firstname.lastname@example.org.