Gravy Train Marketing cares about and respects your privacy. We will be clear and transparent about the information we are collecting and what we will do with that information.
This Policy sets out the following:
- Who we are and how to contact us
- What personal data we collect and process about you in connection with your relationship with us as a customer and through your use of our website, mobile applications and online services;
- Where we obtain the data from;
- What we do with that data;
- How we store the data;
- Who we transfer/disclose that data to;
- How we deal with your data protection rights;
- And how we comply with the data protection rules.
All personal data is collected and processed in accordance with the General Data Protection Regulations (GDPR).
- Personal Data: Personal Data means data about a living individual who can be identified from those data (or from those and other information either in our possession or likely to come into our possession).
- Usage Data: Usage Data is data collected automatically either generated by the use of the Service or from the Service infrastructure itself (for example, the duration of a page visit).
- Cookies: Cookies are small pieces of data stored on a User’s device.
- Data Processors: Data Processor means any natural or legal person who processes the data on behalf of the Data Controller.
- Data Subject: Data Subject is any living individual who is the subject of Personal Data.
- User: The User is the individual using our Service. The User corresponds to the Data Subject, who is the subject of Personal Data.
Who we are
Gravy Train Marketing is the data controller for this website.
Trading address: 4 Gratton Drive, Chillington, Devon TQ7 2LT
If you are not happy with any aspect of how we collect and use your data, you have the right to complain to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk). We’d be grateful if you would contact us first if you do have a complaint so that we can try to resolve it for you.
It is very important that the information we hold about you is accurate and up to date. Please let us know if at any time your personal information changes by emailing us at email@example.com.
We will respond to all requests, enquiries or concerns as soon as possible and in any case within 30 days.
What personal data do we collect and how do we collect it?
We collect and use personal data only as it might be needed for us to deliver to you our services. Your personal data includes information such as:
- Telephone number
- Email address
- Other data collected for the purpose of providing the service(s) you have ordered that could directly or indirectly identify you
Much of what you consider personal data is collected directly from you when you:
- create an account or purchase any of our Services (e.g.: billing information, including name, address, email address, telephone number);
- request assistance from our Customer Services team (e.g.: telephone number);
- complete contact forms or request newsletters or other information from us (e.g.: email address, name); or
- participate in contests and surveys, apply for a job, or otherwise participate in activities we promote that might require information about you.
We do not collect any Sensitive Data about you. Sensitive data refers to data that includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data. We do not collect any information about criminal convictions and offences.
What do we use your personal data for, why and for how long
We strongly believe in both reducing the amount of data we collect and limiting the use and purpose of that data to only:
- Where we need to perform the contract between us.
- Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
- Data we might be required or permitted to keep for legal compliance or other lawful purposes.
Generally, we do not rely on consent as a legal ground for processing your personal data, other than in relation to sending marketing communications to you via email or text message. You have the right to withdraw consent to marketing at any time by emailing us at firstname.lastname@example.org.
Purposes for processing your personal data
Below are details of the ways we intend to use your personal data and the legal grounds on which we will process such data. We have also explained what our legitimate interests are where relevant.
We may process your personal data for more than one lawful ground, depending on the specific purpose for which we are using your data.
||Type of data
||Lawful basis for processing
|To register you as a new customer
||(a) Identity (b) Contact
||Performance of a contract with you
|To process and deliver your order including: (a) Manage payments, fees and charges (b) Collect and recover money owed to us
||(a) Identity (b) Contact (c) Financial (d) Transaction (e) Marketing and Communications
||(a) Performance of a contract with you (b) Necessary for our legitimate interests to recover debts owed to us
||(a) Identity (b) Contact (c) Profile (d) Marketing and Communications
||(a) Performance of a contract with you (b) Necessary to comply with a legal obligation (c) Necessary for our legitimate interests to keep our records updated and to study how customers use our products/services
|To use data analytics to improve our website, products/services, marketing, customer relationships and experiences
||(a) Technical (b) Usage
||Necessary for our legitimate interests to define types of customers for our products and services, to keep our site updated and relevant, to develop our business and to inform our marketing strategy
|To make suggestions and recommendations to you about goods or services that may be of interest to you
||(a) Identity (b) Contact (c) Technical (d) Usage (e) Profile
||Necessary for our legitimate interests to develop our products/services and grow our business
You will receive marketing communications from us if you have:
(a) requested information from us or purchased goods or services from us; or
(b) if you provided us with your details and ticked the box at the point of entry of your details for us to send you marketing communications; and
(c) in each case, you have not opted out of receiving that marketing.
We will not share your personal data with any third party for their marketing purposes.
You can ask us to stop sending you marketing messages at any time by following the opt-out links on any marketing message sent to you or OR by emailing us at email@example.com at any time.
Where you opt out of receiving our marketing communications, this will not apply to personal data provided to us as a result of a product/service purchase, warranty registration, product/service experience or other transactions.
Change of purpose
We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to find out more about how the processing for the new purpose is compatible with the original purpose, please email us at firstname.lastname@example.org.
If we need to use your personal data for a purpose unrelated to the purpose for which we collected the data, we will notify you and we will explain the legal ground of processing.
We may process your personal data without your knowledge or consent where this is required or permitted by law.
Retention of your data
We retain personal data only for as long as necessary to provide the Services you have requested and thereafter for a variety of legitimate legal or business purposes. These might include retention periods:
- mandated by law, contract, or similar obligations applicable to our business operations;
- for preserving, resolving, defending, or enforcing our legal/contractual rights; or
- needed to maintain adequate and accurate business and financial records.
- In some circumstances we may anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes in which case we may use this information indefinitely without further notice to you.
When we no longer need your personal data, we will securely delete or destroy it.
Security of your personal data
The security of your data is important to us, but remember that no method of transmission over the Internet, or method of electronic storage is 100% secure. While we strive to use commercially acceptable means to protect your Personal Data, we cannot guarantee its absolute security.
We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know such data. They will only process your personal data on our instructions and they are subject to a duty of confidentiality. The data you provide to us via our website is protected using SSL (Secure Socket Layer) technology. SSL is the industry standard method of encrypting personal information so that it can be securely transferred over the Internet.
We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.
We may provide paid products and/or services within the Service. In that case, we use third-party services for payment processing (e.g. payment processors).
The payment processors we work with are:
Sharing your personal data
- Government authorities, law enforcement bodies and regulators for compliance with legal requirements;
- Trusted third parties who work with Gravy Train Marketing on specific projects.
- Credit and debit card companies which facilitate your payments to us, and anti-fraud screening, which may need information about your method of payment to process payment or ensure the security of your payment transaction;
- Legal and other professional advisers, law courts and law enforcement bodies in order to enforce our legal rights in relation to our contract with you;
Cookies and site tracking
Cookies are small text files that are transferred to your computer’s hard drive through your web browser to enable us to recognise your browser and help us to track visitors to our site; thus enabling us to understand better the products and services that will be most suitable to you. Most Web browsers automatically accept cookies, but, if you wish, you can change these browser settings by accepting, rejecting and deleting cookies. The “help” portion of the toolbar on most browsers will tell you how to prevent your browser from accepting new cookies, how to have the browser notify you when you receive a new cookie, or how to disable cookies altogether. If you choose to change these settings, you may find that certain functions and features will not work as intended. The cookies we use do not detect any information stored on your computers.
For more information about cookies and how to stop cookies being installed visit the following website: http://www.allaboutcookies.org.
We use tracking software to monitor customer traffic patterns and site usage to help us develop the design and layout of our website. This software does not enable us to capture any personal passenger information.
Your Data Protection Rights
Under certain circumstances, by law you have the right to:
- Request information about whether we hold personal information about you, and, if so, what that information is and why we are holding/using it.
- Request access to your personal information (commonly known as a “data subject access request”). This enables you to receive a copy of the personal information we hold about you and to check that we are lawfully processing it.
- Request correction of the personal information that we hold about you. This enables you to have any incomplete or inaccurate information we hold about you corrected.
- Request erasure of your personal information. This enables you to ask us to delete or remove personal information where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal information where you have exercised your right to object to processing (see below).
- Object to processing of your personal information where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground. You also have the right to object where we are processing your personal information for direct marketing purposes.
- Object to automated decision-making including profiling, that is not to be subject of any automated decision-making by us using your personal information or profiling of you.
- Request the restriction of processing of your personal information. This enables you to ask us to suspend the processing of personal information about you, for example if you want us to establish its accuracy or the reason for processing it.
- Request transfer of your personal information in an electronic and structured form to you or to another party (commonly known as a right to “data portability”). This enables you to take your data from us in an electronically useable format and to be able to transfer your data to another party in an electronically useable format.
- Withdraw consent. In the limited circumstances where you may have provided your consent to the collection, processing and transfer of your personal information for a specific purpose, you have the right to withdraw your consent for that specific processing at any time. Once we have received notification that you have withdrawn your consent, we will no longer process your information for the purpose or purposes you originally agreed to, unless we have another legitimate basis for doing so in law.
If you want to exercise any of these rights, then please email us at email@example.com or contact us by post at 4 Gratton Drive, Chillington, Devon TQ7 2LT.
Please include your full name, email address associated with your Account, and a detailed description of your data request. Such requests will be processed in line with local laws. We will respond to any requests for access to personal information within 30 days.
You will not have to pay a fee to access your personal information (or to exercise any of the other rights). However, we may charge a reasonable fee if your request for access is clearly unfounded or excessive. Alternatively, we may refuse to comply with the request in such circumstances.
We may need to request specific information from you to help us confirm your identity and ensure your right to access the information (or to exercise any of your other rights). This is another appropriate security measure to ensure that personal information is not disclosed to any person who has no right to receive it.
Communicating with you.
We may contact you directly, or through a third-party service provider, regarding products or services you have signed up for or purchased from us, such as is necessary to deliver transactional or service related communications. We may also contact you with offers for additional services we think you’ll find valuable if you give us consent, or where allowed based upon legitimate interests. You don’t need to provide consent as a condition to purchase our goods or services. These contacts may include:
- Text (SMS) messages
- Telephone calls
You may also update your subscription preferences with respect to receiving communications from us by sending an email to firstname.lastname@example.org.
If you make use of a service that allows you to import contacts (e.g. using email marketing services to send emails on your behalf), we will only use the contacts and any other personal information needed for the requested service. If you believe that anyone has provided us with your personal information and you would like to request that it be removed from our database, please contact us at email@example.com.
Our Service does not address anyone under the age of 18 (“Children”).
We do not knowingly collect personally identifiable information from anyone under the age of 18. If you are a parent or guardian and you are aware that your Children has provided us with Personal Data, please contact us. If we become aware that we have collected Personal Data from children without verification of parental consent, we take steps to remove that information from our servers.
Your acceptance of these terms
By using this Site, you signify your acceptance of this policy. If you do not agree to this policy, please do not use our Site. Your continued use of the Site following the posting of changes to this policy will be deemed your acceptance of those changes.