Version 18.0, effective 25/05/18
1. Important information and who we are
1.2 Who we are
Europart is the data controller and is responsible for your personal data. All your personal data shall be held and used in accordance with the EU General Data Protection Regulation 2016/679 ('GDPR'). We have appointed a data protection officer who is responsible for overseeing questions in relation to this privacy notice. If you have any questions about this privacy notice, including any requests to exercise your legal rights, please contact the data protection officer using the details set out below.
Europart Distribution Limited
Company Reg No 02438825
Address: Unit E1-E6 Capital Point, Capital Business Park, Parkway, Cardiff, CF3 2PY United Kingdom
You 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.
1.3 Your duty to inform us of changes
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.
2. The information we collect
2.1 What types of information do we collect about you?
Europart requires a range of information in order to administer your account with us. This typically includes
Contact Details, including Names, Addresses, Phone Numbers, Email Addresses
Company Details, including Company Reg Numbers, VAT Numbers, Website Addresses
Financial Information, including Sales History, Payment History, Credit Ratings, Credit Limits
Marketing Preferences ‐ whether or not you have opted to receive marketing communications from Europart
Technical & Usage Data, including internet protocol (IP) address, your login 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, information about how you use our website. This is statistical data about our operational performance and service delivery and any information that is shared is for internal use only and does not include personal data.
2.2 What if you fail to provide personal data?
If you fail to provide certain information when requested or required, we may not be able to perform the contract we have entered into with you, or we may be prevented from complying with our legal obligations. In this case, we may have to cancel services you have with us, but we will notify you if this is the case at the time.
3. How we collect your information
3.1 Direct Interactions: Contact Details and Company Details will be provided to Europart by you during the process of setting up an account or placing orders with Europart. This will be done by completing application forms, or by correspondence via our website, by telephone, email, post, or otherwise.
3.3 Publicly Available Sources: It may be necessary for us to collect Contact Details, Company Details and Financial Information from publicly available sources such as Companies House, and credit reference agencies.
4. How and why we process your information
4.1 We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:
Where we need to perform the contract we are about to enter into or have entered into with you.
Where we need to comply with a legal or regulatory obligation.
For marketing purposes ‐ only where you have consented to receive marketing communications from Europart.
4.2 GDPR sets out the lawful bases for storing and processing personal data ‐ Europart's use of personal data falls under the following categories:
Contractual Necessity: Data we require in order to be able to perform the contract we have with you, e.g. to enable processing of orders.
Compliance with Legal Obligations: Data we require in order to be compliant with various legal and financial obligations, e.g. recording of financial transactions, and ongoing storage of these.
Consent: In some circumstances, we may ask for your consent to process your information in a particular way.
5. How we share your information
We may have to share your personal data with the third parties set out below:
Trusted third parties: In order to provide certain services to you we may share your information with third party service providers, acting as data processors, e.g. IT infrastructure providers, logistics companies. We will not share your data with any third party where it is not necessary to do so to provide a service to you or fulfil a contract with you. Where we use providers based in the US, we may transfer data to them if they are part of the Privacy Shield which requires them to provide similar protection to personal data shared between the Europe and the US. For further details, see European Commission: EU-US Privacy Shield.
HM Revenue & Customs, regulators, auditors and other authorities based in the United Kingdom who require reporting of processing activities in certain circumstances.
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.
We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions. We do not pass your details to any third parties for marketing purposes.
6. Data Security
Europart has 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 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.
7. Data Retention
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. By law we have to keep basic information about our clients (including Contact, Company, and Financial Data) for six years after they cease being clients for regulatory purposes.
8. Your Legal Rights
8.1 The GDPR outlines certain rights which you have in relation to the personal information we hold about you. 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.
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 services to you. We will advise you if this is the case at the time you withdraw your consent.
8.2 You can exercise any of the above rights by contacting us at the address or email address set out in section 1.2. 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.
8.3 Most of the above rights are subject to limitations and exceptions. Please note also, 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.
8.4 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.
We may use your Technical and Usage data, as well as your sales history 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 and offers may be relevant for you. You may receive marketing communications from us in these circumstances, or if you have requested information from us, previously purchased from us or provided us with your details and, in each case, you have not opted out of receiving marketing from us. You can ask us to stop sending you marketing messages at any time by following the unsubscribe or opt-out links on any marketing message sent to you or by contacting us at any time.
10. 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 get 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.