1. Introduction

1.1 Who we are – HTS Spares LTD

This Privacy Policy is issued on behalf of HTS Spares LTD so when we mention "HTS", "we", "us" or "our" in this privacy notice, we are referring to HTS Spares LTD responsible for processing your data. HTS Spares LTD is the controller for your data when you purchase a product or service with us. HTS Spares LTD is the controller and responsible for this website.  HTS Spares LTD is also sometime known under it’s old trading names “Holmwood Tractors” or “Commercial and Plant”

1.2 Contact Details

            Company name: HTS Spares LTD

            Contact Name: Simon Knappett

            Contact Email: gdpr@htsspares.com

            Postal Address: 7 Beacon Road          

                                     Rotherwas                 

                                     Hereford

                                     HR2 6JF

1.3 We take your privacy very seriously and have put in place a global privacy policy. This policy governs the use of your data by us and ensures that we manage your personal data with appropriate care. This Privacy Policy sets out details of how, when and why your personal data is collected and processed by or on behalf of us.

1.4 This Privacy Policy was last updated on 24 May 2018.

1.5 We may review this Privacy Policy from time to time and any changes will be notified to you by posting an updated version on our website and/or by contacting you by email. Any changes will take effect 7 days after the date of our email or the date on which we post the modified terms on our website, whichever is the earlier. We recommend you regularly check for changes and review this Privacy Statement whenever you visit our website.

1.6 If you have any questions about how we collect, store and use your personal information, or if you have any other privacy-related questions, please contact our Privacy Correspondent, Simon Knappett by email at gdpr@htsspares.com. 

2. How we collect personal data

2.1 Personal information you may give us by:

• Entering information on one of our websites;
• Via social media platforms;
• When you open an account with us;
• When visiting a trade counter;
• Via our mobile applications;
• When corresponding with us by phone, email or otherwise;
• By entering competitions run by us;
• By taking surveys undertaken by us or on our behalf;
• When participating in promotional events;

2.2 Personal information we may collect about you: 

• We may collect the following information from the sources named above;
• Details of transactions you carry out through our websites, and/or your visits to our websites, including, but not limited to, pages and resources you access, location data, webchats and other communication data, traffic data;
• Technical information including anonymous data collected by the hosting server for statistical purposes, the Internet Protocol (IP) address used to connect your computer or device to the Internet, browser type and version, time zone setting, browser plug-in types and versions, operating system and platform;
• Any personal information which you allow to be shared as part of your public profile or third party social network;
• Information you provided to us in response to a survey or competition;
• Information resulting from enquiries, quotations or sales whether by phone, email or in person at a trade counter.

2.3 Personal information we may receive from other sources: 

• We may obtain certain personal information about you from sources outside our business, including, but not limited to, credit checking agencies and business directories.

3. Data we collect and process about you
 

3.1 We may collect the following information:

• Name and job title;
• Address information;
• Email address(es);
• Telephone number(s);
• Demographic information such as, preferences and interests;
• Sales information relating to the sale of products or services to you or their repair or return; Correspondence or other communications with you about our products, services or business;
• Your signature;
• Geo-location data eg; when you sign for delivery;
• Financial information eg; credit rating, bank details;
• Technological information collected from cookies – see our cookie policy for more information - https://www.htsspares.com/cookies .

4. Why we use your personal information
 

4.1 We use the information we hold on you for the following purposes:

• For account administration: including opening an account, verifying your identity, undertaking credit related searches, invoicing, managing credit limits and payments.
• For managing and performing our contracts with you: including answering enquiries, providing quotations, dealing with plans and specifications, placing orders, delivering goods to you or your customers and dealing with any issues arising including warranty claims.
• For marketing: monitoring your transactions with us to enable us to provide you with the most relevant offers and information to you and marketing to you unless you've told us not to.  Every marketing email carries an unsubscribe link for you to withdraw consent at any time.

5. Who we share your data with

5.1. We may share your personal information to third parties in the following circumstances:

• Our suppliers, service providers and subcontractors, such as credit reference agencies, fraud prevention agencies, payment processors, suppliers of technical and support services, insurers, logistics providers, manufacturers and cloud service providers, debt collectors, our legal and other professional advisors, including auditors;
• Companies assisting us in our marketing, advertising and promotional activities;
• Third party payment processor in relation to credit/debit card payments;
• Fraud prevention agencies if false or inaccurate information is provided to us as part of your use of our services or otherwise, and fraud is identified or suspected;
• If we are under a duty to disclose or share it in order to comply with any legal obligation, to detect or report a crime, to enforce or apply the terms of our contracts or to protect the rights, property or safety of our visitors and customers; and
• If we restructure or sell our business or its assets or have a merger or re-organisation.

5.2  International Transfer of data:

• Wherever data is transferred or made available outside of the EEA, we undertake due diligence on the entity accessing or receiving your data to ensure that they have put in place appropriate technical and organisational measures to protect and secure your data. We also put in place contractual safeguards in accordance with our obligations under the GDPR. These contractual safeguards limit their ability to use your personal information so that it can be used solely to provide services to us and/or to you and not otherwise.

6. Your legal rights

6.1 Under certain circumstances, you have rights under data protection laws in relation to your personal data, you can:

• Request access to your personal data;
• Request correction of your personal data;
• Request erasure of your personal data;
• Object to processing of your personal data;
• Request restriction of processing your personal data;
• Request transfer of your personal data;
• Request to withdraw consent;

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

6.2 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.

6.3 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.

6.4 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.

7. Data security
 

7.1 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 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.

8. Lawful Basis

8.1 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 on the details in section 1.2

8.2 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.

8.2 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.