Privacy
Policy

WHAT IS OUR PRIVACY POLICY?

The Transatlantic Trading Company Ltd. (TATC) CUSTOMER PRIVACY POLICY. The Transatlantic Trading Company Limited is a company registered in England, Scotland and Wales will be collectively referred to as “TATC”, “we” or “us” in this policy).

OVERVIEW

Maintaining the security of your data is a priority at TATC, and we are committed to respecting your privacy rights. We pledge to handle your data fairly and legally at all times. TATC is also dedicated to being transparent about what data we collect about you and how we use it. This policy, which applies to when you visit our website, use your mobile device or go on line, provides you with information about:

how we use your data;

what personal data we collect;

how we ensure your privacy is maintained; and

your legal rights relating to your personal data.

General public via CCTV camera at TATC premises

HOW WE USE YOUR DATA

GENERAL

TATC (and any nominated trusted partners acting on our behalf) uses your personal data:

to provide goods and services to you;

to make our website available to you;

to manage any registered account(s) that you hold with us;

to verify your identity;

for crime and fraud prevention, detection and related purposes;

with your agreement, to contact you electronically about promotional offers and products and services which we think may interest you;

for market research purposes – to better understand your needs;

to enable TATC to manage customer service interactions with you; and

where we have a legal right or duty to use or disclose your information (for example in relation to an investigation by a public authority or in a legal dispute).

TATC AND OTHER MARKETING

PROMOTIONAL COMMUNICATIONS

TATC may use your personal data for electronic marketing purposes (with your consent) and may send you postal mail from time to time to update you on the latest TATC offers. TATC aims to update you about products & services which are of interest and relevance to you as an individual. You have the right to opt out of receiving promotional communications at any time, by:

changing marketing preferences via the TATC website;

making use of the simple “unsubscribe” link in emails or the “STOP” number for texts; and/or

contacting TATC via the contact channels set out in this Policy.

SHARING DATA WITH THIRD PARTIES

OUR SERVICE PROVIDERS AND SUPPLIERS

In order to make certain services available to you, we may need to share your personal data with some of our service partners. These include IT, delivery and marketing service providers. TATC only allows its service providers to handle your personal data when we have confirmed that they apply appropriate data protection and security controls. We also impose contractual obligations on service providers relating to data protection and security, which mean they can only use your data to provide services to TATC and to you, and for no other purposes.

OTHER THIRD PARTIES

Aside from our service providers, TATC will not disclose your personal data to any third party, except as set out below. We will never sell or rent our customer data to other organisations for marketing purposes.

WE MAY SHARE YOUR DATA WITH:

our carefully selected partners who provide ‘TATC’ branded products and services (for example, Approved Parts Suppliers), if we have your consent to do so;

governmental bodies, regulators, law enforcement agencies, courts/tribunals and insurers where we are required to do so: –

to comply with our legal obligations;

to exercise our legal rights (for example in court cases);

for the prevention, detection, investigation of crime or prosecution of offenders; and

for the protection of our employees and customers.

INTERNATIONAL TRANSFERS

To deliver products and services to you, it is sometimes necessary for TATC to share your data outside of the European Economic Area. This will typically occur when service providers are located outside the EEA or if you are based outside the EEA. These transfers are subject to special rules under data protection laws. If this happens, we will ensure that the transfer will be compliant with data protection law and all personal data will be secure. Our standard practice is to use ‘standard data protection clauses’ which have been approved by the European Commission for such transfers. Those clauses can be accessed here. How long do we keep your data? We will not retain your data for longer than necessary for the purposes set out in this Policy. Different retention periods apply for different types of data, however the longest we will normally hold any personal data is 5 years.

WHAT PERSONAL DATA DO WE COLLECT?

TATC may collect the following information about you:

your name, age/date of birth and gender;

your contact details: postal address including billing and delivery addresses, telephone numbers (including mobile numbers) and e-mail address;

purchases and orders made by you;

your on-line browsing activities on TATC websites;

your password(s);

when you make a purchase or place an order with us, your payment card details;

your communication and marketing preferences;

your interests, preferences, feedback and survey responses;

your location;

your correspondence and communications with TATC; and

other publicly available personal data, including any which you have shared via a public platform (such as a Twitter feed or public Facebook page).

Our websites are not intended for children and we do not knowingly collect data relating to children. This list is not exhaustive and, in specific instances, we may need to collect additional data for the purposes set out in this Policy. Some of the above personal data is collected directly, for example when you set up an on-line account on our websites, or send an email to our customer services team. Other personal data is collected indirectly, for example your browsing or shopping activity. We may also collect personal data from third parties who have your consent to pass your details to us, or from publicly available sources. We may also receive personal data in future from trusted third parties who provide services to our customers under the TATC brand, such as TATC Vehicle Editions and TATC Servicing.

HOW WE PROTECT YOUR DATA

OUR CONTROLS

TATC is committed to keeping your personal data safe and secure. Our security measures include:

encryption of data;

regular cyber security assessments of all service providers who may handle your personal data;

regular scenario planning and crisis management exercises to ensure we are ready to respond to cyber security attacks and data security incidents;

regular penetration testing of systems;

security controls which protect the entire TATC IT infrastructure from external attack and unauthorised access; and

internal policies setting out our data security approach and training for employees.

WHAT YOU CAN DO TO HELP PROTECT YOUR DATA

TATC will never ask you to confirm any bank account or credit card details via email. If you receive an email claiming to be from TATC asking you to do so, please ignore it and do not respond. If you are using a computing device in a public location, we recommend that you always log out and close the website browser when you complete an online session. In addition, we recommend that you take the following security measures to enhance your online safety both in relation to TATC and more generally:

keep all your account passwords private. Remember, anybody who knows your password may access your accounts.

when creating a password, use at least 8 characters. A combination of letters and numbers is best. Do not use dictionary words, your name, email address, or other personal data that can be easily obtained. We also recommend that you frequently change your password. You can do this accessing your account, clicking ‘your account’, clicking ‘your data’ and selecting ‘change password’.

avoid using the same password for multiple online accounts.

YOUR RIGHTS

You have the following rights:

the right to ask for a copy of personal data that we hold about you (the right of access);

the right (in certain circumstances) to request that we delete personal data held on you; where we no longer have any legal reason to retain it (the right of erasure or to be forgotten);

the right to ask us to update and correct any out-of-date or incorrect personal data that we hold about you (the right of rectification);

the right to opt out of any marketing communications that we may send you and to object to us using / holding your personal data if we have no legitimate reasons to do so (the right to object);

the right (in certain circumstances) to ask us to ‘restrict processing of data’; which means that we would need to secure and retain the data for your benefit but not otherwise use it (the right to restrict processing); and

the right (in certain circumstances) to ask us to supply you with some of the personal data we hold about you in a structured machine-readable format and/or to provide a copy of the data in such a format to another organisation (the right to data portability).

If you wish to exercise any of the above rights, please contact us using the contact details set out below.

LEGAL BASIS FOR USING DATA

We are required to set out the legal basis for our ‘processing’ of personal data.

DATA PROTECTION OFFICER

TATC has appointed a Data Protection Officer to ensure we protect the personal data of our customers (and others) and comply with data protection legislation. Access to TATC client data (both hard and soft copy) is limited to those who have a legitimate need. Computer Data is backed up every week and stored in rotation in a secure location off site (within the UK) Hard Copy data is stored onsite initially under strict control measures and then off site at a secure location (within the UK) If you have any questions about how TATC uses your personal data that are not answered here, or if you want to exercise your rights regarding your personal data, please contact our Data Protection Officer’s team by

phone: +44 7867 690430;

e-mail:Customer.DPO@tatc.us.com or

write to: Data Protection Officer, TATC , Venn Farm, Sandford, Crediton Devon, EX14 4BR

You have the right to lodge a complaint with the Information Commissioner’s Office. Further information, including contact details, is available at https://ico.org.uk.

THIRD PARTY SITES AND MICROSITES

TATC may, in future, partner with certain trusted third parties to make additional products and services available to you. These products and services can be accessed online through the relevant third party’s “microsite”. These websites, and others linked to from this Policy, are owned and operated by a third party and they are responsible for processing personal data in accordance with their own privacy policies.

CCTV

CCTV cameras are installed in TATC premises for the purpose of crime detection, crime prevention and the safety of both the public and employees. Images captured by CCTV will not be kept for longer than necessary. TATC will only disclose recorded images to authorised bodies who intend to use it for the purposes stated above.

TATC UPDATES

This policy was last updated in May 2018