
PRIVACY NOTICE
1. Introduction A.U.E. Trading Co Ltd respects your privacy and is committed to protecting your personal data. This privacy notice is for: Our clients (who are individuals) Staff who are employed or engaged by our clients (who are organisations) Our potential clients (who are individuals) The staff who are employed or engaged by our potential clients (who are organisations) Our suppliers’ staff Our potential suppliers’ staff Individuals who receive our marketing communications Job / work experience applicants Users of our website This privacy notice will inform you as to how we look after your personal data, what your privacy rights are and how the law protects you.
2. Important information and who we are Please read this privacy notice It is important that you read this privacy notice together with any other privacy notice or fair processing notice we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data.
ControllerA.U.E. Trading Co Ltd is the controller and responsible for your personal data (collectively referred to as "we", "us" or "our" in this privacy notice). We have appointed a data privacy manager who is responsible for overseeing questions in relation to this privacy notice. If you have any questions about this privacy notice, please contact the data privacy manager using the details set out below.
Contact details Full name of legal entity: A.U.E. Trading Co Ltd (a company registered in England & Wales under company number 12011609). Name of data privacy manager: Feruja Khanam Email address: aueltd@outlook.comYou have the right to make a complaint at any time to the Information Commissioner's Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance. Changes to the privacy notice and your duty to inform us of changes. This version was last updated on 20th March 2024. It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.
3. The data we collect about you Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data). We may collect, use, store and transfer the following different kinds of personal data about you:
• Identity Data includes first name and last name and IP address.
• Contact Data includes home address, business/personal email address and telephone numbers.
• Social Media Data includes your social media profiles and the content that you post on social media.
• Financial Data includes your bank account and/or your debit / credit card details, how much you earn, how your own business performs financially.
• Background Data for example your employment and education history data and your interests as they may appear on a CV or other media.
4. Google Analytics and other service providers that we useThis website uses Google Analytics, a web analytics service provided by Google, Inc. (“Google”). Google Analytics uses cookies to help us analyse how users use our site. The information generated by the cookie about your use of the website will be transmitted to and stored by Google on servers in the U.S. Google will use the information on our behalf for the purpose of evaluating your use of the website, compiling reports on website activity for us and providing us with other services relating to website activity and internet usage. The IP address that your browser conveys within the scope of Google Analytics, will not be associated with any other data held by Google. You may refuse the use of these cookies via the settings in your browser as explained above. You can also opt out of being tracked by Google Analytics in the future by downloading and installing Google Analytics Opt-out Browser Add-on for your current web browser: http://tools.google.com/dlpage/gaoptout?hl=enWe also use Facebook, Click Funnels, Active Campaign, Google Tag Manager and Wistia for identifying and tracking potential clients and marketing to them. These are all US companies that may collect personal data such as your IP address and, with that information, identify your interaction on our website and enable us to send marketing communications to you. These companies store data in the U.S.
5. How is your personal data collected? Direct interactions If you are an individual who signs up to receive our services you give us your Identity Data, Contact Data and Financial Data by filling in our onboarding forms including our services contract. You may also provide us with your Social Media Data as and when we supply our services to you. If you are an individual who is employed or otherwise engaged by an organisation who is our client then you will give us your Identity Data and Contact Data by filling in our onboarding forms including our services contract. If you are our individual supplier or a potential supplier, or if you are employed or otherwise engaged by our supplier or potential supplier then we will receive your Identity Data and Contact Data when you contact us to provide goods or services or when you send marketing messages to us. If you are applying for a job or for work experience we may receive your Identity Data, Contact Data and Background Data when you apply for a position with us. Third parties or publicly available sources We may receive personal data about you from various third parties and public sources as set out below: Identity Data, Contact Data and Social Media Data from searches on websites where you have added this data e.g. LinkedIn, Facebook or from other internet searches.
6. How we use your personal data We will only use your personal data when the law allows us to. Most commonly, we will use your personal data simply to reply to an enquiry that you have sent us, to provide our services to you or your business, to receive goods or services from your business or to consider your job or work experience application. We will also use your personal data to send you information about our services. See section 12 below to find out more about the types of lawful basis that we will rely on to process your personal data. Purposes for which we will use your personal data We have set out below, in table format, a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate. Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below. Purpose/Activity Type of data Lawful basis for processing including basis of legitimate interest to register you as a new client and provide our services to you (a) Identity (b) Contact (c) Social Media (d) Financial Performance of a contract with you. To provide our services to the organisation that you are employed by or otherwise engaged with (a) Identity(b) Contact Necessary for our legitimate interests (to supply our services to our clients)To enquire whether you or the organisation you work for would be interested in receiving our services (a) Identity(b) Contact Necessary for our legitimate interests (to find clients to supply our services to) To receive good or services from you or the organisation you work for (a) Identity(b) Contact Necessary for our legitimate interests (to receive goods or services from our suppliers)To consider your or your organisation’s offer to supply goods or services to us (a) Identity(b) Contact Necessary for our legitimate interests (to identify suppliers to receive goods or services from)To administer and protect our business (e.g. troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data) (a) Identity(b) Contact Necessary for our legitimate interests (for running our business, provision of administration and IT services and network security)To make suggestions and recommendations to you about services that may be of interest to you (a) Identity(b) Contact Necessary for our legitimate interests (to develop our services and grow our business)To consider your application for work experience or a job with us (a) Identity(b) Contact(c) Background Necessary for our legitimate interests (to recruit for our business) Marketing We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising. We have established the following personal data control mechanisms: Service offers from us We may use your personal data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which services may be relevant for you (we call this marketing).You will receive marketing communications from us if you have requested information from us and you may receive marketing communications from us if we are legally permitted to make unsolicited contact with you. We will not contact you if you have opted out of receiving that marketing. Third-party marketing We will get your express opt-in consent before we share your personal data with any third party for marketing purposes.
Opting out: 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 by contacting us at any time. 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 would like an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us. If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so. Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.
7. Disclosure of your personal data We may share your personal data with the parties set out below for the purposes set out in section 5 above.
• External Third Parties as set out in section 12 below.
• Third parties to whom we may choose to sell, transfer, or merge parts of our business or our assets.
Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy notice. All third parties are required to respect the security of your personal data and to treat it in accordance with the law.
8. International transfers We do not transfer your personal data outside the European Economic Area (EEA) other than as set out below. Like most businesses we use software to support our operations. For example, we use Microsoft as our email provider and we use WhatsApp to send messages to our clients. Your personal data may therefore be transferred out of the EEA because Microsoft, Facebook Inc and other major players in the software industry store some of their data in the U.S. Whenever we transfer your personal data out of the EEA, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:
• We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data by the European Commission.
• Where we use certain service providers, we may use specific contracts approved by the European Commission which give personal data the same protection it has in Europe. Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the EEA.
9. Data 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. They will only process your personal data on our instructions and they are subject to a duty of confidentiality. We will notify you and any applicable regulator of a breach where we are legally required to do so.
10. Data retention How long will you use my personal data for? We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements. To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements. In some circumstances you can ask us to delete your data: see “request erasure” in section 10 below for further information. 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.
11. Your legal rights Under certain circumstances, you have rights under data protection laws in relation to your personal data. You have the right to: Request access to your personal data (commonly known as a "data subject access request"). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it. Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us. Request erasure of your personal data. This enables you to ask us to delete or remove personal data 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 data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request. Object to processing of your personal data 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 as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms. Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios: (a) if you want us to establish the data's accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it. Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you. Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent. If you wish to exercise any of the rights set out above, please contact us. No fee usually required You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances. What we may need from you We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response. Time limit to respond We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.
12. Glossary
LAWFUL BASIS Comply with a legal or regulatory obligation means processing your personal data where it is necessary for compliance with a legal or regulatory obligation that we are subject to. Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give you the best service/product and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us.Performance of Contract means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.
THIRD PARTIES
External Third Parties
• Service providers who provide IT and system delivery/administration services.
• Professional advisers who provide, for example, accountancy and legal services.
• Regulators and other authorities who may require reporting of processing activities in certain circumstances.
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