Hubbard Systems (part of HTG Trading Ltd) Privacy & Data Protection Policy
Updated: 24th May 2018
[HTG Trading Ltd, including the trading companies; Taylor UK (Taylor Company UK) and Hubbard Systems, “Us”, “We”, “Our”] registered in England and Wales under company number 1828642 is the Data Controller of your Information for the purposes of the General Data Protection Regulations (GDPR).
We respect your privacy and we are committed to protecting your personal Information as that term is defined in GDPR (“Information”). We comply with the principles of GDPR and aim to maintain consistently high levels of best practice in our processing of your Information. Our aim is to work in a transparent, lawful and fair manner respecting the rights of our customers at all times.
And here’s our upfront promise. We know how important it is for you to have control over any communications that you receive from us, so here’s a quick and easy way of opting-out of all marketing communications. BUT please remember that this will remove you from EVERYTHING you’ve signed up for and you may wish to be more selective and choose which communications you no longer wish to receive, particularly by email by clicking on the unsubscribe link provided at the bottom of each and every email marketing message we send you.
Otherwise please email: firstname.lastname@example.org and we shall remove you from current and future marketing campaigns.
Please Note: If you have purchased a piece of equipment from HTG Trading Ltd (Taylor UK or Hubbard Systems) we may contact you regarding that purchase either prior to or following delivery by email or telephone. These communications are directly related to the product which you have purchased and are not marketing related.
HTG Trading Ltd operates on a business to business basis, any information provided to HTG Trading Ltd and the trading companies within will treat any and all contact information; email, postal address, telephone number, company name and other details as ‘Business Contact’ information.
Individuals are advised NOT to provide any personal information (emails, phone numbers, home address) but to provide business only credentials. ALL provided information will be treated as ‘Business Details’ which may result in you being contacted for marketing or other purposes.
Please take a few moments to read and understand this Policy.
By using our website, social media channels and services you consent to the collection and use of your Information as described in this Policy. If we change our Policy and/or procedures, we will update this Policy to keep you aware of what Information we collect, how we use it and under what circumstances we may disclose it. Your continued use of the website or services after this Policy has been amended shall be deemed to be your continued acceptance of the terms and conditions of this Policy, as amended. We encourage you visit one of our webpages and review this Policy regularly.
2.WHAT INFORMATION DO WE COLLECT?
All Information supplied to HTG Trading Ltd will be held and used in accordance with GDPR where applicable. If you want to know what Information we collect and hold about on you, please email us at: email@example.com, or write to us at the address given at the end of this Policy.
When you visit and use our websites or request one of our services you may provide us with or we may collect your information such as; your postal address, email address and other personal business-related information. You may provide, or we may collect this Information in a number of ways:
2.1 Information you voluntarily provide to us:
We collect and maintain Information that you voluntarily submit to us during your use of our website or services. For example:
- When you register on our website or for a product or service, you may provide us with certain information including your name, email address, user name, password and demographic Information
- If you sign up to our services via a social network, we may use the profile information to enable us to contact you regarding your specific interests.
- If you sign up to receive a newsletter or participate in social networking activities, you may provide us with contact Information (e.g., email, telephone and/or or physical address).
- You may provide us with Information in the course of email, customer support interactions and surveys.
Different services operated by us may ask for different pieces of Information. You can choose not to provide us with certain Information, but this may stop you from gaining access to a service or limit the features that you can use on our websites.
For more Information, please see the “How We Use Your Information” section of the Policy below.
2.2 Information we collect through your use of our Website & Services:
All websites operated by HTG TRADING LTD record data in the form of tracking cookies. This is data recorded by the Website which allows us to recognise you and your preferred settings, this saves you from re-entering information on return visits to the site. Such data is recorded locally on your computer through the use of these cookies.
Most browsers can be programmed to reject, or warn you before downloading cookies, information regarding this may be found in your browsers ‘help’ facility.
To disable Google Analytics: https://tools.google.com/dlpage/gaoptout?hl=en-GB
2.3 Information we receive from third parties:
We may also combine online, and/or offline Information received from third parties with your Information. The third-party Information is used for a variety of purposes including to verify other Information about you (e.g., verify your mailing address to send you requested products or services) and to enhance the content and relevance of the services we provide.
3. HOW WE USE YOUR INFORMATION
We will use your Information in the ways described below and as described at the time that the Information is collected.
3.1 To Provide Services
In general, we use your Information as necessary or appropriate for our business purposes including to:
- Administer your account where you have opened an account with us or purchased a piece of equipment, spare part or service directly from us.
- Register you and provide you access to the website or services requested by you.
- Respond to inquiries or requests that you direct to us.
- Fulfil your requests for products or services.
- Send communications and administrative emails about the website or our services.
- Personalise and better tailor the features, performance and support of the website and our services for your use; analyse, benchmark and conduct research on user data and user interactions with the website and our services
- Deliver customer services.
- Other purposes related to any of the above.
Where you have provided us with the appropriate consents, or where GDPR entitles us to do so, we may send you marketing materials about other products or services offered by HTG Trading Ltd and the companies within. We operate on a business-to-business basis, should you receive any emails in your personal accounts please ensure you unsubscribe immediately to prevent us sending you anything in the future.
Be assured that we understand the irritations of unsolicited communications and we are fully committed to ensuring the rights and obligations set out in GDPR and the Privacy and Electronic Communications Regulations 2003, updated 2004 and 2011 are respected.
4. HOW CAN I FIND OUT WHAT PERSONAL INFORMATION HTG TRADING LTD HOLDS ON ME?
4.1 Data Portability:
Under GDPR you have the right to request a copy of the Information that we hold about you. It may require two pieces of identification to prove your identity to prevent an easily avoidable data breach. Please make a written application to the HTG Trading Ltd Data Controller at the address listed at the bottom of this page or email firstname.lastname@example.org. The statutory time for us to respond to any request is 30 days but with your help in providing us with relevant Information we endeavour to respond sooner. Information will be provided in the form of a CSV file. There is no administrative charge for this service.
If any of the Information that we hold about you is incorrect and you’d like it amended, please email the email@example.com and we’ll review your request as soon as we possibly can.
4.2 Under GDPR you have the right to ensure that any information which we hold on you is legitimate and accurate. Please feel free to contact us if you believe that any of the information which we hold on you is incorrect or irrelevant in anyway and we will endeavour to update out records as quickly as possible. It is not in our interest to hold out of date or incorrect information. Any request to update information will be completed with 30 days of receipt of the request, please email firstname.lastname@example.org
4.3 Your right to be forgotten:
Under GDPR you have the right to request that you “be forgotten” and that we delete any and all information which we may hold on you. Please email email@example.com to submit this request. To facilitate any requests in a swift manner, we may request additional proof of identity to ensure that we do not violate any other individual’s data protection rights. Any requests to be forgotten will be processed within the 30-day period outlined in the GDPR regulations.
Please note: If we delete ALL information which we hold, you may in the future receive information from us as your details may get re-entered into third-party database system (Caterlyst Ltd) and without any records we will not necessarily know not to contact you. Using the UNSUBSCRIBE options on any marketing emails may be a more suitable option if you just wish to stop receiving marketing related communications.
If you have purchased a piece if equipment from HTG Trading Ltd, we are legally obliged to store transactional and invoice data for a period of seven years for HRMC and auditing purposes even if you request for us to delete all of your other details. Once the seven-year period expires, HTG Trading Ltd securely destroys all copies of these records as a standard procedure.
5. HOW WE DISCLOSE YOUR INFORMATION TO THIRD PARTIES
We may share your Information with third parties as specifically approved by you or under the circumstances described below and in this Policy.
5.1 Disclosure for legal reasons:
We may disclose your Information if we are under a duty to disclose or share your Information to comply with any legal obligation or in order to enforce or apply or fulfil our terms and conditions and other agreements or protect the rights, property, or safety of our customers, our group companies or others. This includes exchanging Information with other companies and organisations for fraud protection and credit risk reduction.
We use a number of third party organisations to help provide a professional service to our customers. These organisations act as data processors and are strictly contractually controlled in how they may/may not use your Information and we remain responsible for the protection of your Information.
5.2 Changes to our Company
In the event we go through a business transition such as a merger, acquisition by another company, or sale of all or a portion of our assets, your Information may be among the assets transferred. You acknowledge that such transfers may occur and are permitted by this Policy.
5.3 Updating of third party CRM database – Caterlyst Ltd
HTG Trading Ltd subscribes to a third-party Customer Relations Management (CRM) database system called Caterlyst. The information which you provide us maybe used to update the information held on the Caterlyst database system. This information may include, but isn’t limited to; business postal addresses, business contact telephone numbers, business related email addresses, information of business sectors along with any specific information relating to the products and services provided by the companies within HTG Trading Ltd. The data shared with Caterlyst does not contain information of a sensitive nature for example; bank details or any sensitive personal details.
The Caterlyst system is a business to business CRM system and is maintained by Caterlyst and the information contained within it is controlled and managed by them. All of the information held within the Caterlyst system should be business related and not ‘personal details’ except in the case of ‘Sole Traders’ where a contacts personal information may also be their business information, Sole Traders are clearly identified and treated in a manner in line with the GDPR. The Caterlyst CRM system provides business contact details to HTG Trading Ltd which can be legitimately used for business to business marketing, cold calling and canvasing purposes. Any customer information, business details and contact details (including email addresses) which are uploaded/added to the Caterlyst CRM system by any of the users within HTG Trading Ltd remain the ‘property’ of HTG Trading Ltd and will not be directly distributed to other subscribers of the Caterlyst System. Any new business information added to the Caterlyst system will be verified by the Caterlyst data team and once suitable permissions have been achieved, new business contact details will be added to the wider database (excluding any HTG Trading Ltd related information).
HTG Trading Ltd use the Caterlyst Database for direct email marketing purposes, should you receive any marketing via the Caterlyst portal and you no longer wish to do so, you can unsubscribe at anytime by clicking the ‘Unsubscribe’ links located at the bottom of every email alternatively email firstname.lastname@example.org
5.4 Tracking Cookies & IP Addresses
The websites controlled by HTG Trading Ltd place a tiny tracking cookie on your web browser. Data recorded by the Website allows us to recognise you and your preferred settings, this saves you from re-entering information on return visits to the site. Such data is recorded locally on your computer through the use of these cookies.
Our websites note the unique IP Address of your computer, phone or tablet. This information is recorded by our web server when you request any page or component on the Website. This information is passed on to Google for analytical purposes. The IP address is logged anonymously, and any personal details cannot be extracted from this information.
5.5 Sharing of information with trusted product partners
On occasion, HTG Trading Ltd may share basic contact details with specific, trusted product partners with the aim to provide additional services which we feel will be of genuine benefit to our customers. These partners may include ingredients suppliers, ancillaries’ suppliers, additional equipment suppliers and service agents.
5.6 Sharing of information for warranty purposes:
HTG Trading Ltd will need to share specific information with the manufacturers of the equipment which we supply to ensure that any warranty provision is activated and supplied as described. Information from customers who purchase equipment from brands including, but not restricted to, Taylor Company, TurboChef and Pratica will be passed onto these manufacturers to facilitate warranty activations. This data may be held outside of EEA, but all reasonable steps will be taken to ensure that any data provided for these purposes are held securely.
Specific customer contact details; business address, contact name, phone number etc. may be passed on to a third-party service provider to facility any service or warranty work which cannot be directly provided by HTG Trading Ltd.
5.7 Sharing of information for logistical reasons
To facilitate the efficient delivery of the goods which HTG Trading Ltd supply, we will share basic contact details with our trusted logistics partners.
5.8 HTG Trading Ltd will NOT sell your data
The companies within the HTG Trading Ltd umbrella may, on occasion, may share information within the other HTG business with the aim of providing additional beneficial services to the customers who we work with. HTG TRADING LTD will NEVER sell your data.
6. UPDATING AND CONTROL OF YOUR INFORMATION
There are a number of ways in which you can control the collection, use, and sharing of your Information and update your Information and preferences.
6.1 Opting-Out on receiving Marketing Communications
When you receive electronic marketing communications from us you will have the opportunity to “optout” by following the unsubscribe instructions provided in emails covering any marketing communication from us.
Alternatively, you can email email@example.com and request that your details be removed from any future marketing correspondence. (You will still receive information relating to any order placed with us or for any service related matter).
6.2 Preference Services
The Telephone Preference Service (TPS), the Corporate Telephone Preference Service (CTPS) and the Mailing Preference Service (MPS) allow you to choose to opt out of unsolicited marketing contact.
However, if you are registered on any of the preference services, which are general opt-out registers, you may still receive marketing communications from us if you have given us your consent previously, if you subsequently give us that consent or have specifically requested additional information or services from us.
6.3 Contacting Us
If your Information or circumstances have changed or if you no longer wish to receive marketing communications from us then please email firstname.lastname@example.org
Please note that:
- Even if you request that we delete your Information, we may retain specific detail in conformance with our data retention policy most specifically for legal and tax reasons and to honour your opt-out requests (for us to know not to contact you, we must keep a little information to remind us of that).
- We do not keep Information longer than we deem necessary.
- We are not responsible for updating or removing your Information contained in the lists or databases of third parties (Caterlyst Ltd) who have previously been provided with Information as permitted by this Policy. Please contact Caterlyst Ltd directly to make any necessary requests.
7. THIRD PARTY LINKS AND SERVICES
7.1 Please remember that when you use a link to go from our website to another website or you request a service from a third party, our Policy no longer applies. Your browsing and interaction on any other website or your dealings with any other third-party service provider, is subject to that website’s or third-party service provider’s own rules and policies. We do not monitor, control, or endorse the Information collection or privacy practices of any third parties. We encourage you to become familiar with the privacy practices of every website you visit or third-party service provider that you deal with and to contact them if you have any questions about their respective privacy policies and practices. This Policy applies solely to Information collected by us through our website or services and does not apply to these third-party websites and third-party service providers.
8. WHERE WE STORE YOUR INFORMATION
The Information that we collect from you may be transferred to, stored and processed at a destination outside the European Economic Area, (all EU countries plus Norway, Iceland and Liechtenstein). Your Information may also be processed by staffs operating outside the EEA who work for us or for one of our suppliers, for instance, for customer service or warranty purposes. By submitting Information to us, you agree to this transfer, storing or processing. We will take all reasonable steps necessary, including the use of the Model Contractual Arrangements as approved by the EU, or other contractual means to ensure that your Information is treated securely and in accordance with this Policy and the GDPR.
8.1 HTG Trading Ltd will hold the information of any customer who has ordered or purchased any piece of equipment, spare part or service from any of the companies under the HTG Trading Ltd umbrella. This information is held on a secure database system and is used to facilitate ongoing services in relation to the original purchase or enquiry.
HTG Trading Ltd stores all of it’s customer data on secure servers located within the UK and are protected by all necessary security protocols and firewalls to prevent unauthorised access for either internal or external sources.
9. SECURITY OF YOUR INFORMATION
We follow appropriate security procedures in the storage and disclosure of your Information so as to prevent unauthorised access by third parties. We also require those parties to whom we transfer personal Information to comply with the same. However, unfortunately, the transmission of Information via the Internet is not completely secure. So, we cannot ensure the security of your Information transmitted by you to us via the internet. Any such transmission is at your own risk and you
acknowledge and agree that we shall not be responsible for any unauthorised use, distribution, damage or destruction of your Information, except to the extent we are required to accept such responsibility by GDPR.
Once we have received your Information we will use security procedures and features to prevent unauthorised access to it.
10. REPORTING OF SECURITY VULNERABILITIES
HTG Trading Ltd is committed to the privacy, safety and security of our customers. If you discover a potential security vulnerability, we would appreciate it if you could report it just to us in a responsible manner. Please email us at email@example.com, who will respond to you as soon as possible.
This provides us with an opportunity to work with you and quickly address and resolve any issue. Publicly disclosing a potential vulnerability could put the wider community at risk, and therefore we encourage you to come to us first. We’ll keep you informed as we move forward with our investigations.
Should we detect a security breach in one of our systems we will notify the Information Commissioners Office (ICO), as described in the GDPR regulations, within the allocated 72 hours of us first discovering the breach. Where we will provide all of the necessary information and details of the severity of the incident.
11. SOCIAL MEDIA
11.1 HTG Trading Ltd uses social media including but not exclusively; Facebook, Linkedin, Instagram, Twitter, Google+ and others, to communicate with customers, both new and existing, providing information on the goods and services which we and our sister companies provide.
It is the responsibility of individual users to ensure that the information and personal details which can be accessed via these social media channels is secure and that any information which is accessible is effectively ‘in the public domain’. Anyone using any form of social media is advised to review their own security settings to ensure that their personal information is as secure as possible.
The companies within HTG Trading Ltd may use social media to verify information:
- Basic Information included in your public profile such as name and email address.
- Other Information that is publicly available based upon the privacy settings you have with your social media account.
- Any other details you choose to share according to your specific account settings.
11.2 We do not control how your personal Information is collected, stored or used by such third-party sites or to whom it is disclosed. You should review the privacy policies and settings on any social networking site that you subscribe to so that you understand the Information they may be sharing. If you do not want your networking sites to share Information about you, you must contact that site and determine whether it gives you the opportunity to opt-out of sharing such Information.
HTG Trading Ltd is not responsible for how these third-party sites may use Information collected from or about you.
12. ANTI-SPAM POLICY
Taylor UK and HTG Trading provides interesting and useful content in our marketing emails and aims to tailor them to the specific needs & interests of our audience making sure that they are of genuine, legitimate interest. Our email marketing policy is designed to be business-to-business only and is not aimed at individuals. We hope you enjoy receiving and reading them.
If you receive correspondence from us which you deem as ‘spam’ please report it to us by forwarding the message to: firstname.lastname@example.org and we shall fully investigate it.
HTG Trading Ltd may monitor and record communications with you, such as emails and telephone calls, for the purposes of quality assurance, training, fraud prevention and compliance.
The websites controlled by HTG Trading Ltd are not intended for children of any age and are specifically focused on business to business interaction. The content of our websites are catering equipment sales and service focused and we will never promote, condone or publish any offensive, graphic or illegal content. HTG Trading Ltd will not knowingly solicit or collect personal information from or about children on any of it’s internet websites, social media platforms, or any other method of communication.
15. CONTACT US
HTG Trading Ltd is the parent company of Taylor UK and Hubbard Systems.
Our registered offices: 106 Claydon Business Park, Great Blakenham, Ipswich, Suffolk, IP6 0NL, United Kingdom.
Tel: 01473 350000
Fax: 01473 350001
Company Number: 1828642 (England)
VAT Number: GB171271035
FCA Registration: 717291