Howard Tenens

Third Party Privacy Policy

1. Background

This is the privacy notice of Howard Tenens Limited (Howard Tenens, we, us, our) and sets out how we collect and process your personal data. This privacy notice also provides certain information that is legally required and lists our rights in relation to your personal data.

This Privacy Notice relates to personal information that identifies you, meaning our clients, potential clients, suppliers, potential suppliers and any other individuals outside of the Howard Tenens organisation with whom we interact from time to time. If you are an employee, contractor or otherwise engaged in work for us or applying to work for us, a separate privacy notice applies to you instead.

We refer to this information throughout this Privacy Notice as personal data and paragraph 3 sets out further detail of what this includes. Please read this Privacy Notice to understand how we may use your personal data.

It is important that the personal data we hold about you is accurate and current and we take all reasonable precautions to ensure that this is the case but we do not undertake to check or verify the accuracy of personal data provided by you. Please keep us informed if your personal data changes during your relationship with us by contacting us in accordance with this Privacy Notice. We will not be responsible for any losses arising from any inaccurate, inauthentic, deficient or incomplete personal data that you provide to us.

This Privacy Notice may vary from time to time so please check it regularly. This Privacy Notice was last updated on 17/08/2018.

2. How to contact us

For the purposes of relevant data protection legislation, we are a controller of your personal data and as a controller we use the personal data we hold about you in accordance with this Privacy Notice.

If you need to contact us in connection with our use or processing of your personal data, or gain access to it, please contact dataprotection@tenens.com.

3. Categories of personal data we collect

The categories of personal data about you that we may collect, use, store, share and transfer are:

Individual Data. This includes personal data which relates to your identity, such as your first name, middle name, last name, username or similar identifier, job title, date of birth and gender and your contact details such as your billing address, delivery address, email address and telephone numbers;

Advertising Data. This includes personal data which relates to your advertising preferences, such as information about your business interests, preferences in receiving marketing materials from us and our third parties and your communication preferences;

Information Technology Data. This includes personal data which relates to your use of our website, such as your internet protocol (IP) address, login data, traffic data, weblogs and other communication 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 our website;

Sales Data. This includes personal data which relates to the transactions you have conducted with us, such as details we collect for case studies about products and services you have purchased from us; and

Audio and Visual Data. This includes personal data which is gathered using our CCTV or other recording systems in the form of images, video footage and sound recordings that is taken at any of our locations.

We may also create Personal Data about you, for example, if you contact us by telephone to make a complaint, for example about our services or goods, then we may make a written record of key details of the conversation so that we can take steps to address the complaint.

4. The sources from which we obtain your personal data

We will often collect personal data directly from you, either in person, via our website or by telephone, email or other electronic communications.  This could be when we are dealing with your questions about the services which we can provide or the products which we supply or when we start to provide services or products to you.  Further personal information may be collected as work proceeds.

We may also collect your personal data from other sources, which may include:

(i) automated technologies, such as CCTV or other recording systems, cookies, server logs and other similar technologies. We may automatically collect Information Technology Data about your equipment, browsing actions and patterns by using cookies, server logs and other similar technologies. We may also receive Information Technology Data about you if you visit other websites employing our cookies. Please see our cookie policy [LINK] for further details.

(ii) third parties, such as the Chartered Institute of Logistics and Transporting (CILT), Mint UK and providers of social media platforms (such as Facebook, Twitter and Instagram) for example where you share our content through social media, by liking us on Facebook, or following or tweeting about us on Twitter.

5. How we use your personal data and our basis for using it

We have set out below the purposes for which we may process your personal data, and in each case may rely on one or more of the following legal bases when processing your personal data:

Purposes for which we process your personal data

  1. To register you as a new customer and process your order.
  2. In order to perform our contractual obligations to you. This would include: processing and performing specific jobs as part of our business relationship; orders placed by us where you are a supplier; making or receiving payments, fees and charges; and collecting and recovering money owed.
  3. In order to comply with our own legal obligations, e.g. health and safety legislation, or to assist in an investigation (e.g. from the police)
  4. In order to manage our relationship with you including: to send you important notices such as communications about changes to our terms and conditions and policies (including this Privacy Notice); to provide you with important real-time information about products or services you have ordered from us (e.g. a change of time or location due to unforeseen circumstances); and to send you information you have requested; to deal with your enquiries; and to ask you to leave a review or feedback on us.
  5. In order to administer and protect our business, deal with any misuse of our website and to comply with our security policies at our locations
  6. In order to make suggestions and recommendations to you about goods or services that may be of interest to you, deliver relevant website content and advertisements to you and to measure or understand the effectiveness of our advertising.
  7. For internal purposes to use data analytics, to identify usage trends, determine and measure the effectiveness of promotional campaigns and advertising and to improve our website, products/services, marketing, customer relationships and experiences.
  8. To sell, make ready for sale or dispose of our business in whole or in part including to any potential buyer or their advisers.
  9. In order to enforce or apply our terms of use, terms and conditions of supply and other agreements with third parties.

Categories of personal data                 

  1. Individual Data.
  2. Individual Data; Information Technology Data; and Sales Data.
  3. Individual Data; and Audio and Visual Data.
  4. Individual Data; Advertising Data; Information Technology Data; Sales Data; and Audio and Visual Data.
  5. Individual Data; Advertising Data; Information Technology Data; Sales Data; and Audio and Visual Data.
  6. Individual Data; Advertising Data; Information Technology Data; and Sales Data.
  7. Individual Data; Advertising Data; Information Technology Data; and Sales Data.
  8. Individual Data; Advertising Data; Information Technology Data; Sales Data; and Audio and Visual Data.
  9. Advertising Data; Information Technology Data; Sales Data; and Audio and Visual Data.

The basis on which we can do this (this is what the law allows)

  1. to perform a contract with you; and our legitimate interest in the provision of goods and services to our customers.
  2. The processing is necessary to perform any contract entered into with you; and our legitimate interest in the provision of goods and services to our customers and in recovering debts owed to us.
  3. The processing is necessary for us to comply with the law.
  4. The processing is necessary to perform a contract with you; and our legitimate interest in the provision of goods and services to our customers.
  5. The processing is necessary: for our legitimate interest in provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise; and necessary to comply with the law.
  6. The processing is necessary for our legitimate interests to study how customers use our products/services, to develop our products and services and ensure our marketing is relevant to you, to grow our business and to inform our marketing strategy.
  7. The processing is necessary for our legitimate interests in defining types of customers for our products and services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy.
  8. The processing is necessary for our legitimate interests in the sale or disposal of our business or assets.
  9. The processing is necessary for our legitimate interests in protecting our business and property and recovering debts owed to us.

We do not need your consent if we process your data under one or more of the other legal bases set out above. In limited circumstances we may approach you for your written consent to allow us to process certain data. Where you have given your consent, you may withdraw your consent at any time, and we will make this process clear to you in each case that we seek your consent. You should be aware that it is not a condition of your contract with us that you agree to any request for consent from us.

6. Who receives your personal data?

We may disclose your personal data to:

(i) our group companies and affiliates or third-party data processers (including outsourced providers) who may process data on our behalf to enable us to carry out our usual business practices. Any such disclosure will only be so that we can process your personal data for the purposes set out in this Privacy Notice;

(ii) HMRC, legal and other regulators or authorities, including those who request your personal data or to report any potential or actual breach of applicable law or regulation;

(iii) external professional advisers such as accountants, bankers, insurers, auditors and lawyers;

(iv) law enforcement agencies, courts or other relevant party, to the extent necessary for the establishment, exercise or defence of legal rights;

(v) third parties where necessary for the purposes of prevention, investigation, detection or prosecution of criminal offences or the execution of criminal penalties;

(vi) third parties which are considering or have decided to acquire some or all of our assets or shares, merge with us or to whom we may transfer our business (including in the event of a reorganisation, dissolution or liquidation);

7. What happens if I don’t wish to provide personal information to Howard Tenens Limited?

We seek personal information from you for the purposes set out in this Privacy Notice.  Without such information we are not likely to be in a position to trade with you. If, of course, we have personal information relating to you and you have no wish to deal with us, or if the information is not strictly necessary to enable us to trade with you, please let us know.

8. How long will Howard Tenens Limited keep personal information for?

We will only retain personal information for as long as necessary to fulfil the purposes it was collected for as set out in this Privacy Notice.

We keep the length of time that we hold your personal data under review. These reviews take place annually.

9. Your rights in relation to the information held in relation to you

Subject to applicable law including relevant data protection laws, in addition to your ability to withdraw any consent you have given to our processing your personal data (where we have asked for the same in accordance with this Privacy Notice), you may have a number of rights in connection with the processing of your personal data, including:

(i) the right to request access to your personal data that we process or control;

(ii) the right to request rectification of any inaccuracies in your personal data or, taking into account the purposes of our processing, to request that incomplete data is completed;

(iii) the right to request, on legitimate grounds as specified in law:

(a) erasure of your personal data that we process or control; or

(b) restriction of processing of your personal data that we process or control;

(iv)  the right to object, on legitimate grounds as specified in law, to the processing of your personal data;

(v)  the right to receive your personal data in a structured, commonly used and machine-readable format and to have your personal data transferred to another controller, to the extent applicable in law; and

(vi)  the right to lodge complaints regarding the processing of your personal data with the Information Commissioner’s Office or other relevant supervisory body. Please see https://ico.org.uk/concerns/ for how to do this.

If you would like to exercise any of the rights set out above, please contact us using the contact details set out in paragraph 2.

10. International transfers of personal data

We do not transfer any of your personal data outside of the European Economic Area.  If it subsequently becomes apparent that we need to do so then we will discuss this with you on a case by case basis, including in relation to the measures that we will put in place in connection with any such transfer.

11. Automated decision making

We may employ automated decision-making tools in our processing of your personal data and, in particular, use Google Analytics. We may use Google Analytics to undertake limited profiling activities in relation to our customer base from time to time, so that we are better able to understand our own business practices and optimise our products and services for our customers.

12. If I have any questions who do I ask?

Please ask the individual with responsibility for dealing with your matter.  If this person cannot help, or if it is inappropriate to contact him or her, then please contact dataprotection@tenens.com.