Revised 6th July 2018
This Website is owned and operated by Dalair Limited ("We", "Us" and "Our", as appropriate in the context). We are registered in England under company registration number 1578326 and our registered office is at Southern Way, Wednesbury, West Midlands, WS10 7BU.
We respect your right to privacy. This policy summarises what personal information we may collect, how we may use this information and other important topics relating to your privacy and data protection.
This policy not only applies to our website but is also applicable to personal information we may otherwise collect through our products and services or when you interact with us by other means; for example, in person, by post, by telephone or if your information is passed to us by your employer, who may be one of our customers, suppliers or other business partners (collectively “Business Partners”).
It is our policy to comply with all applicable privacy and data protection laws. This commitment reflects the value we place on earning and keeping the trust of our business partners and others who share their personal information with us.
Dalair Limited is a 'Data Controller' and in some instances a 'Data Processor' as set out under the Data Protection Act 1998, (as amended), inclusive of the General Data Protection Regulation (GDPR) which came into force on the 25th of May 2018. We are committed to protecting and respecting your privacy in accordance with these regulations.
Please read the following carefully to understand our views and practices regarding how we process your personal data. We hope that the following answers any questions you may have but please contact us if it does not.
General principles of collection, use and disclosure of personal information
A summary of the Personal Information we collect
Additional information about the personal information we collect
How we use your personal information
When we may share your personal information
Security of your personal information
Links to third party internet sites
Access to your personal information
Retention of your personal information
Additional information for EU residents
Your individual rights
To the extent required by applicable law, whenever Dalair Limited collects personal information, we will:
(i) provide timely and appropriate notice to you about our data practices;
(ii) collect your personal information only for specified and legitimate purposes;
(iii) ensure that the information we collect will be relevant, adequate and not excessive for the purposes for which it is collected;
(iv) process your personal information in a manner consistent with the purposes for which it was originally collected or to which you have subsequently consented;
(v) take commercially reasonable steps to ensure that your personal information is reliable for its intended use, accurate, complete, and, where necessary, kept up-to-date;
(vi) not use your personal information for direct marketing purposes without giving you an opportunity to “opt-out”; and
(vii) take appropriate measures, by contract or otherwise, to provide adequate protection for personal information that is disclosed to a third party.
Dalair Limited collects the following types of personal information:
• Information you provide
We collect personal information you provide us, which may include:
(i) contact information, such as your name, company name, job title, address, e-mail address, and phone number;
(ii) additional information about how you use our products;
(iii) comments, questions, requests and orders you may make;
(iv) financial information needed to process payments.
• Information automatically gathered from your device
(i) Device and browser information.
We may collect technical information about your device, such as device type, browser type, IP address, operating system, and device identifier. This information is collected automatically from your device and web browser through cookies and similar technologies.
(ii) Information about how you interact with us.
We may collect technical data about your usage of our website, such as content viewed or downloaded, features used, links clicked and dates and times of interactions. We collect this information using cookies and similar technologies.
(iii) Cookies and Similar Technologies:
A “cookie” is a file of information placed on your device when you visit a website. Cookies and similar technologies can enhance your user experience by saving your preferences, personalizing your online experience, holding items in your shopping cart, and sometimes providing you with advertising which is tailored to your interests.
• Information you provide when visiting our Head Office and Technical Centre
Visitors are only allowed by appointment and must report to our gatehouse and/or reception area on arrival;
(i) you will be issued with a visitor's pass, showing contact information, such as your name, the company you represent and your vehicle registration number; and
(ii) you will be required to sign the Visitor's Book on entering or leaving the premises.
• Information automatically gathered from our CCTV systems
Visitors to our Head Office and Technical Centre should be aware that Dalair Limited operates CCTV systems, both inside and outside our buildings, with the purpose of:
(i) reducing the threat of crime generally;
(ii) protecting our premises; and
(iii) ensuring the health and safety of all our employees and visitors.
CCTV footage is captured with due diligence and respect for the individuals' privacy.
Our CCTV systems record picture only and data is kept for a maximum of 25 days before it is deleted.
• Information collected using Cookies
(i) The Dalair Limited website uses “session cookies.” A session cookie does not identify you personally and expires after you close your browser. For example, we may place a session cookie to note what pages you have viewed.
(ii) We do not use “persistent cookies.” These are cookies that do not expire when you close your browser. Persistent cookies stay on your computer until you delete them, or they expire.
(iii) Your browser may allow you to adjust settings to accept or reject cookies, or to alert you when a cookie is placed on your computer.
(iv) Although you are not required to have cookies enabled when you visit our website, you may not be able to use all of the functionality of the site if you have disabled cookies in your browser settings.
• Information from Third-Parties and Business Partners
We may collect personal information through Third-Parties and our Business Partners
(i). This information may include contact information, such as name, company name, job title, address, e-mail address, and phone number.
(ii) We may also obtain personal information from other third-party sources, including publicly and commercially available sources.
(iii) We may combine the information we receive from our Business Partners and other third-party sources with information that we collect from you or your device, as described above.
• Your choices with regard to providing personal information
You have choices about the personal information you provide to us:
(i) You do not need to provide us with any personal information when you visit our website and, although you are not required to accept cookies, you may be unable to use all of the functionality of our website if you disable them in your browser settings.
(ii) You may choose not to provide the personal information that we request, when you contact us using the form provided on our website, by email, post or telephone but, if you do so, it is important to understand that this may mean that we are unable to provide you with our products or services.
We may use your personal information to:
• Develop and manage our relationships with you and our Business Partners
This may include:
(i) delivering services or carrying out transactions that you or our Business Partners have requested;
(ii) providing information about our products, services, and transactions that may be of interest to you;
(iii) providing you and our Business Partners a more consistent experience in interacting with us, including by learning more about you and how you use and interact with our website; and
(iv) planning, managing, and performing under our contractual relationships with our Business Partners.
• Communicate with you or your company
This may include:
(i) informing you of our products and services that may be of interest to you or your company;
(ii) providing information about our products, services, and transactions, including, for example, pricing information, technical data, invoice, shipping, production information or warranty information;
(iii) responding to questions or inquiries that you make, including customer service requests; and
(iv) inviting you to provide feedback or to participate in, customer satisfaction surveys.
• Provide and improve our website
This may include:
(i) customizing our website to your preferences or interests;
(ii) making our website more compatible with your technology
(iii) making our website easier to use; and
(iv) maintaining the security of and otherwise protecting our website.
• Address legal issues
This may include:
(i) complying with our obligations to retain certain business records for minimum retention periods;
(ii) establishing, exercising, or defending legal claims;
(iii) complying with laws, regulations, court orders, or other legal process;
(iv) detecting, preventing, and responding to fraud, intellectual property infringement, violation of our contracts or agreements, violations of law, or other misuse of our website, products or services; and
(v) protecting Dalair's rights or property, or yours or others’ health, safety, welfare, rights, or property.
We may also use your personal information for other uses consistent with the context in which the information was collected or with your consent.
Additionally, we may anonymize or aggregate any of the information we collect and use it for any purpose, including for research and product-development purposes. Such information will not identify you individually.
Your personal information will never be shared or sold to any to third parties for marketing purposes, nor do we use it to engage in any form of marketing ourselves.
We will not disclose your personal information except as described here:
We may share your personal information with third parties we hire to perform support services for us. These third parties are required to use the personal information we share with them only to perform services on our behalf and to treat your personal information in compliance with all applicable privacy and data protection laws.
In some cases, we may share your personal information with third parties who partner with us to provide products and services to our customers, such as external haulage contractors. If so, we will require our Business Partners to use that information in a manner consistent with this Policy, any applicable Specific Privacy Statements together with all applicable privacy and data protection laws.
We may also share your personal information with third parties when we have a good faith belief that disclosure is necessary:
(i) to comply with a law, regulation, court order, or other legal process;
(ii) to detect, prevent, and respond to fraud, intellectual property infringement, violation of our contracts or agreements, violation of law, or other misuse of our website, products or services;
(iii) to protect our rights or property or yours or others’ health, safety, welfare, rights, or property; or
(iv) under similar circumstances. If such an event occurs, we will take appropriate steps to protect your personal information.
Dalair Limited may share your personal information with third parties in connection with the sale, purchase, merger, reorganization, liquidation or dissolution of Dalair Limited or under similar circumstances. If such an event occurs, we will take appropriate steps to protect your personal information.
We may share your information with your permission or at your request.
We may also share anonymized or aggregated information internally and with third parties for any purpose. Such information will not identify you individually.
Dalair Limited has implemented appropriate physical, technological and organisational security measures to prevent unauthorised access and to ensure that your personal information is kept safe. Access to personal information is limited to employees who need to access to perform their duties.
Your personal information will generally be stored on personal computers or databases maintained by our service providers. No personal information is stored on servers located outside of the European Economic Area (EEA). Dalair Limited takes appropriate measures, by contract or otherwise, to provide adequate protection for personal information that is disclosed to a third party.
We maintain reasonable safeguards to protect the confidentiality, security and integrity of your personal information. Although we use security measures to help protect your personal information against unauthorized disclosure, misuse, or alteration, as is the case with all computer networks linked to the Internet, we cannot guarantee the security of information provided over the Internet and will not be responsible for breaches of security beyond our reasonable control.
Our website may contain links to websites that are not operated by Dalair Limited and plugins from social media platforms and other third parties. An example of a social media plugin is the Facebook “Like” button. We provide these links and plugins as a service and do not imply any endorsement of the activities or content of the related websites or social media platforms, nor any association with their operators. To learn about how the information collected by these third-party websites is collected and used, please visit their privacy policies. We encourage you to review the privacy policies for the websites and social media platforms you visit before using them or providing personal information.
You may review, correct and update the personal information you provide to us by completing this request form and sending it to us by email to firstname.lastname@example.org or by post to The Data Controller, Southern Way, Wednesbury, West Midlands, WS10 7BU.
How long we keep your personal information will vary and will depend on the purpose and use of information collected. There are legal requirements that we keep some types of data for specific periods. Otherwise, we will retain it for no longer than is necessary for the purposes for which the data was collected.
Our website is not intended for children. Dalair Limited will not knowingly solicit or collect personal information from or about any child. If we should discover that a child has provided us with personal information, we will take immediate action to delete this from our records.
• Dalair Limited’s lawful basis for processing your personal data
The lawful basis for our processing of your personal data will depend on the purposes of the processing.
Where we process personal data in relation to a contract or a potential contract with you, the lawful basis is that the processing is necessary for the performance of our contract with you or to take steps at your request prior to entering into a contract.
When we are required to share personal data with law enforcement agencies or other governmental bodies, we do so on the basis that we are under a legal obligation to do so.
We will also use consent as the legal basis where we deem appropriate or to the extent required by applicable law.
• Processing based on legitimate business interests.
When we process personal information on the basis that the processing is necessary for our legitimate business interests, such interests include:
(i) providing, improving, and promoting Dalair's website, products and services;
(ii) communicating with current and potential customers, other Business Partners, and their individual points of contact;
(iii) managing our relationships with our customers and other Business Partners and their individual points of contact;
(iv) other business development purposes;
(v) sharing information with service providers and other third parties; and
(vi) maintaining the safety and security of our products, services and employees, including fraud protection.
• Processing on the basis of performance of a contract.
Examples of situations in which we process personal information as necessary for performance of a contract transactions in which you purchase a product or service from Dalair Limited.
• Processing because Dalair Limited is under a legal obligation to do so.
Examples of situations in which we must processes personal data to comply with its legal obligations include:
(i) payment of taxes and other government levies;
(ii) providing your personal data to law enforcement agencies and other governmental bodies when required by applicable laws; (iii) retaining business records required to be retained by applicable laws; and
(iv) complying with court orders or other legal process.
• Additional information about the retention of your personal data
To determine the period for which your personal data will be retained in accordance with this Policy, Dalair limited considers criteria such as:
(i) any applicable legal requirements to retain data for a certain period of time;
(ii) any retention obligations related to actual or potential litigation or government investigations;
(iii) any retention requirements in relevant agreements with our Business Partners;
(iv) the date of your last interaction with us (including visiting our website, your communications, etc.);
(v) the length of time between your interactions with Dalair Limited;
(vi) the sensitivity of the data; and
(vii) the purposes for which the data was collected.
In accordance with the applicable laws in the European Union, you have the following rights with respect to your personal data, which apply differently in different circumstances: right of access, right to rectification, right to erasure, right to restriction of processing, right to data portability and right to object to processing. Most of these rights are not absolute.
Below we describe these rights in more detail and provide information on how you can exercise them. If you make a request to exercise your rights, we will respond within one month, but reserve the right to extend this period by two additional months, where necessary if your request is complex. If we extend the response period, we will notify you within one month from your initial request.
You can exercise your rights by completing this Data Subject Access Request form and sending it to us by email to email@example.com or by post to The Data Controller, Dalair Limited, Southern Way, Wednesbury, West Midlands, WS10 7BU.
• Right of Access.
You have the right to ask us to confirm whether we process your personal data.
If we do, you have the right to request access to your personal data that we process and the following information:
(i) the purposes of the processing;
(ii) the categories of personal data we process;
(iii) the recipients or categories of recipients of your personal data;
(iv) the envisaged retention period of the data where possible, or the criteria we use to determine the retention period;
(v) your right to request rectification or erasure of your personal data, or restriction of the processing of such data;
(vi) your right to file a complaint with a supervisory authority;
(vii) if we have not collected the data from you, any information we have available about the source of the data; and
(viii) whether we use your personal data to make any automated decisions that have legal or other similar significant effects on you.
• Right to rectification.
You have the right to have us correct your personal data if they are inaccurate. Considering the purposes of the processing, you may also have the right to have incomplete personal data about you completed, including by providing a supplementary statement to us.
• Right to object to processing for Dalair Limited’s legitimate business interests.
You have the right to object to us processing your personal data when that data is processed based on Dalair Limited’s legitimate business interests.
Dalair Limited will honour your objection and stop processing the relevant personal data unless:
(i) we have compelling legitimate grounds for the processing that override your interests, rights, and freedoms; or
(ii) we need to continue processing your personal data to establish, exercise, or defend a legal claim.
• Right to object to processing for direct marketing.
If we should, (at some time in the future), processes your personal data for direct marketing purposes, you have the right to object to this processing. If you exercise this right, Dalair Limited will stop processing your personal data for direct marketing purposes.
• Right to restrict processing.
You have the right to request that Dalair Limited restrict the processing our your personal data in the following circumstances:
(i) for the period of time we need to verify the accuracy of your personal data when you contest its accuracy;
(ii) when the processing of your personal data is unlawful and you oppose the erasure of the data, and instead request that we restrict the use of the data;
(iii) when we no longer need your personal data for the purposes of processing, but you need the data to establish, exercise, or defend a legal claim; or
(iv) for the period of time Dalair Limited needs to verify if it has compelling legitimate grounds for processing that override your interests, rights, and freedoms when you object to the processing of your personal data for our legitimate business interests.
If, following your request, Dalair Limited restricts the processing of your personal data, we will store your data and otherwise process it only with:
(i) your consent;
(ii) to establish, exercise, or defend a legal claim;
(iii) to protect the rights of another natural or legal person; or
(iv) for reasons of important public interest of the European Union or a Member State.
We will also inform you before lifting the restriction of processing.
• Right to erasure.
The right to erasure is also called the “right to be forgotten.”
You may ask us to delete your personal data. This right not absolute.
Dalair Limited is required to delete your personal data upon your request only in the following circumstances:
(i) your personal data is no longer necessary for the purposes for which we collected or processed them;
(ii) if we processes your personal data on the basis of consent, you withdraw your consent, and no other legal ground exists for us to continue processing your personal data;
(iii) if we processes your personal data for its legitimate business interests, you object to the processing, and there are no overriding legitimate grounds for us to continue processing your personal data;
(iv) if we have processed your personal data unlawfully; or
(v) the personal data must be erased to comply with a legal obligation under European Union or Member State law to which we are subject.
We are not required to erase your personal data to the extent that Dalair Limited needs to process them to:
(i) exercise its right of freedom of expression and information;
(ii) comply with a legal obligation under European Union or Member State law to which we are subject; or
(iii) to establish, exercise, or defend a legal claim.
• Right to data portability:
You have the right to receive personal data you provided to Dalair Limited when:
(i) the processing of the data is based on your consent or is necessary for the performance of a contract between you and Dalair Limited;
(ii) Dalair Limited’s processing of your personal data is carried out by automated means; and
(iii) complying with your request will not adversely affect the rights and freedoms of others.
If you have the right to receive such personal data and request that Dalair Limited provide it, we will provide it to you in a structured, commonly used, and machine-readable format.
• Right to lodge a complaint with a supervisory authority.
If you wish to raise a complaint on how we have handled your personal information, we would appreciate the chance to deal with your concerns before you approach the Information Commissioner’s Office. (ICO, the UK supervisory authority for data protection issues.)
Please contact us in the first instance by email to firstname.lastname@example.org or in writing to The Data Controller, Dalair Limited, Southern Way, Wednesbury, West Midlands, WS10 7BU. We will investigate the matter, respond to you promptly and will use our best efforts to settle any requests or complaints brought to our attention.
We hope that we can address any concerns you may have, however, if a satisfactory compromise cannot be reached and you are dissatisfied with our response, you have the right to approach the Information Commissioner’s Office (ICO).
For more information about how to make a complaint to the ICO, please visit www.ico.org.uk. You can also contact the ICO at Information Commissioner's Office, Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF or by telephone on 0303 123 1113 (local rate) or 01625 545 745.
If you have any questions about this Policy or our use of your personal information, please contact us by telephone on 0121 556 9944, by email to email@example.com or in writing to The Data Controller, Dalair Limited, Southern Way, Wednesbury, West Midlands, WS10 7BU.
Revised 6th July 2018