GENERAL PRIVACY POLICY

Culina Logistics Limited (“we” “us”) are committed to protecting and respecting your privacy

This policy (together with our terms of use and any other documents referred to on it) sets out the basis on which any personal data we collect from you, or that you provide to us, will be processed by us. Please read the following carefully to understand our views and practices regarding your personal data and how we will treat it.

For the purpose of the Data Protection Act 1998 (the Act), the data controller is Culina Logistics Limited of Shrewsbury Road, Market Drayton, Shropshire, TF9 3SQ.

WELCOME TO THE CULINA PRIVACY NOTE:

This information has been produced to help you understand everything you need to know about the way Culina collects, uses and shares personal data, what your legal rights are and how to exercise them.

We hope that you’ll take some time to read this document; we’ve tried to keep it all as simple as possible and to avoid jargon, and we’ll keep you informed if there are any changes to the way we process your personal data in the future.

Culina takes its responsibility of protecting your data very seriously and we do advise you get to know your practices – if there’s anything here you don’t understand or if you want to ask any questions please feel free to contact us (details are at the end).

WHO IS THE DATA CONTROLLER?

We are Culina Group Limited trading as Culina Logistics, a UK limited company, registered in England and Wales at Culina Group Limited, Shrewsbury Road, Market Drayton, Shropshire, TF9 3SQ (05525931).

In this document, Culina will sometimes be referred to as “we” or “the Company”. Culina Group Limited includes the following Group Companies:

Culina Logistics Limited
Great Bear Distribution Limited
Fowler Welch Limited
Eddie Stobart Limited
Integrated Packaging Services Limited
CML (F&L) Telford Limited
Warrens’ Warehousing and Distribution (Midlands) Limited
Stobart Truckstops Limited
iForce Limited
The Pallet Network Limited
The Logistics People Limited
Culina Asset Management
International Road Ferry

Depending on your relationship with us, the relevant Culina Group company may act as the Data Controller of your personal data.

This notice is not directed at children and we do not knowingly collect personal data relating to children.

WHAT KINDS OF PERSONAL DATA DOES CULINA GROUP PROCESS?

Culina collects personal data for specific purposes; with that in mind we have created a list of the types of data that we may collect, either directly from yourself or from other sources in order to achieve those purposes.

The kinds of personal data we may collect are:

Identification details (name, date of birth)
Contact details
Business information
Financial information
CCTV images
Vehicle registration details
Access control and visitor records
Correspondence records
Website usage data
Marketing preferences
Due diligence information
Complaint and investigation records
In limited circumstances we may process special category personal data where permitted by law, such as information relating to health, disability, criminal allegations, fraud prevention investigations and safeguarding concerns. Where we do so, we rely on a condition under Article 9 of the UK GDPR (for example, that the processing is necessary for the purposes of carrying out our obligations under employment law, for reasons of substantial public interest, or because you have given your explicit consent), and we will identify the specific condition relied on at the point of collection.

WHAT ARE THE PURPOSES CULINA GROUP COLLECTS PERSONAL DATA?

Culina uses personal data firstly to fulfil any contractual obligations that exist between us and yourself; where we request personal data be provided to enter into, or meet the terms of any such contract, you will be required to provide the relevant personal data or we will not be able to deliver the goods or services you want. In such cases the lawful basis of us processing the personal data is that it is necessary for the performance of a contract. Where provision of personal data is a contractual requirement in this way, we will tell you this is the case at the point of collection, together with the possible consequences of not providing that data (for example, that we may be unable to supply the goods or services you have requested).

Our lawful basis for processing personal data for the following purposes is that it is necessary for compliance with a legal obligation to which we are subject. We are required by law to process personal data for purposes relating to our legal obligations, these include:

To provide for the organisation’s financial commitments, or to relevant financial
To comply with regulatory requirements and any self-regulatory schemes.
To carry out required business operations and due diligence (e.g. administration, reorganisations, security, investment or corporate/asset sales).
To cooperate with relevant authorities for reporting criminal activity or to detect and prevent
To investigate any insurance claims, claims of unfair dismissal, claims of any kind of harassment or of discrimination or any other claim whereby the organisation may have to defend

We will also process personal data to achieve our various legitimate business interests; these are purposes that have been defined by us where we have balanced the necessity on our part to process the data for each purpose against your own expectations, interests and legal rights.

Our lawful basis for processing personal data for the following purposes is that it is necessary for our legitimate interests, as described below, except where those interests are overridden by your own interests or fundamental rights and freedoms:

To provide you with goods and services you are looking for
To inform you or other goods or services we provide, or offers that may interest you (direct marketing).
To notify you of any changes to the goods and/or services we provide, or have provided that may affect you.
To investigate any insurance.
To protect the company’s assets.

DIRECT MARKETING

Where permitted by law, we may use your personal data to send information about our services, events, business updates or other information which may be of interest to you. You may opt out of receiving marketing communications at any time by using the unsubscribe facility provided within our communications or by contacting us using the details in this notice. If you object to direct marketing, we will stop processing your personal data for those purposes.

WHERE DO WE OBTAIN YOUR PERSONAL DATA?

We will collect personal data directly from you in various ways. This could include when you complete an online form or if you provide the data directly to a representative of Culina.

We may also obtain personal data from:

Recruitment agencies
Customers and suppliers
Publicly available sources
Companies House
Credit reference agencies
Regulatory bodies
Fraud prevention agencies
Government agencies
Professional advisers
Regulatory authorities
Customer representatives

WHO WILL WE SHARE YOUR INFORMATION WITH?

Other companies within the Culina

We may share your personal data with the other members of our group of companies, which includes any subsidiary or the holding company (each as defined by the Companies Act 2006) of the Company.

In order to achieve the above stated purposes for which we process your personal data, we may need to share your personal data with some specific third-party organisations.

We shall make all reasonable efforts to ensure that any third party we share your personal data with is also compliant with data protection law.

Culina is not responsible for the data protection compliance of any of these third parties. If we sell or reorganise our business, or if otherwise required by law or by an authorised regulator, we may transfer your personal data as part of the general business data to the relevant parties.

We may share personal data with:

Group companies
Professional advisers
Insurers
Auditors
IT Service providers
Payroll providers
Recruitment providers
Regulatory bodies
Law enforcement agencies
Courts and Tribunals
Banking and payment providers

WHERE IS MY DATA GOING TO BE STORED?

We shall take all reasonable measures to ensure those third parties are also compliant with data protection law.

We may transfer personal data outside the UK. Where we do so, we will ensure appropriate safeguards are in place including:

UK adequacy regulations
International Data Transfer Agreements (IDTAs)
The UK Addendum to EU Standard Contractual Clauses or
Other lawful transfer mechanisms recognised under UK data protection

HOW LONG WILL WE KEEP YOUR DATA FOR?

We will keep your personal data only for as long as required in order to achieve the purposes for which it was collected, in line with this privacy notice.

We determine the period for which we store your personal data by reference to the following criteria, which are applied on a case-by-case basis depending on the type of data and purpose of processing:

Until we are no longer required to do so in order to comply with any regulatory requirements or financial obligations that we are subject to.
Until we are no longer required to do so by law it is subject
Until all purposes for which the data was originally gathered have become irrelevant or

Further information about retention periods is available within the Culina Data Retention Schedule which can be obtained by contacting us.

It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes, for example if you change address or email address.

HOW WE PROTECT YOUR INFORMATION

We have implemented appropriate technical and organisational measures designed to protect personal data against accidental loss, unauthorised access, misuse, alteration and disclosure.

We have put in place procedures to deal with any suspected personal data breach and will notify you and the ICO of a breach where we are legally required to do so.

YOUR RIGHTS, OUR RESPONSIBILITY

There are several rights granted to you immediately upon providing us with your personal information and some of these are mentioned above.

You will not usually have to pay a fee to exercise any of these rights. However, we may charge a reasonable fee, or refuse to act on your request, if it is clearly unfounded, repetitive or excessive. We try to respond to all legitimate requests within one month. Occasionally this may take longer than one month if your request is particularly complex or you have made a number of requests, in which case we will notify you and keep you updated.

We may need to request specific information from you to help us confirm your identity before we can act on your request. This is a security measure to ensure that your personal data is not disclosed to someone who has no right to receive it. We may also contact you to ask for further information to speed up our response.

We would like you to know that the Company takes your rights as a natural person seriously and will always conduct ourselves in a way that is considerate of our responsibility to serve your legal rights.

9.1 : You have the Right of Access:

This grants you the right to confirm whether or not your personal data is being processed, and to be provided with relevant details of what those processing operations are and what personal data of yours is being processed.

If you would like access to the personal data we have about you, we ask that you contact us by using any of the contact details below.

9.2 : The Right to Rectification:

This one is fairly straight forward. If you notice that the data we have about you is inaccurate or incomplete, you may request we rectify the mistake. We will make every effort to respond to requests of this type immediately.

9.3 The Right to Object

You have the right to object to the processing of your personal data where we rely on legitimate interests as our lawful basis. You may object on grounds relating to your particular situation. You also have the right to object to the processing of your personal data for direct marketing purposes.

9.4 : The Right to Portability:

You may have the right to receive personal data that you have provided to us in a structured, commonly used and machine-readable format and to that information transmitted to another organisation where technically feasible. This right only applies in certain circumstances.

9.5 The Right to Complain

We will always try to maintain the highest standards and encourage the confidence our customers have in us as an organisation. In order that we can achieve this, we ask that any complaints about how we have handled your personal data are first brought to our attention, so we can properly investigate the matter. You can raise a complaint with us using the contact details set out below, or by contacting our Data Protection Officer using the contact details given later in this notice. We will acknowledge receipt of your complaint within 30 days and, without undue delay, make appropriate enquiries, keep you updated on progress and inform you of the outcome.

If, having raised your complaint with us, you remain dissatisfied, you have the right to complain about the Company to the Information Commissioner’s Office, the UK’s supervisory authority for data protection matters, by contacting them on 0303 123 1113, or using any of the other reporting methods listed on their website https://ico.org.uk/concerns.

9.6 : Right to Erasure

You may have the right to request that we delete your personal data in certain circumstances.

9.7 Right to Restriction of Processing

You may have the right to request that we temporarily restrict the processing of your personal data.

9.8 Rights Relating to Automated Decision-Making

You have the right not to be subject to a decision based solely on automated processing where that decision produces legal or similarly significant effects. We do not currently carry out solely automated decision-making which produces legal or similarly significant effects. If this position changes, this Privacy Notice will be updated accordingly.

9.9 Right to withdraw consent

Where we rely on your consent to process personal data, you have the right to withdraw that consent at any time. Withdrawal of consent will not affect the lawfulness of processing carried out before consent was withdrawn.

OUR CONTACT DETAILS

If you wish to contact the Company about this notice or to exercise any of your rights, please do so using any of the following contact details:

Culina Group Limited trading as Culina Logistics
Shrewsbury Road Market Drayton Shropshire TF9 3SQ
01630 695000
@: [email protected]

UPDATES TO THIS NOTICE

We may update this Privacy Notice from time to time. The latest version will always be available on our website.