Elite Coldrooms is committed to protecting personal information and handling personal data responsibly, securely and lawfully.
This GDPR Policy explains how we comply with UK data protection requirements, including the UK General Data Protection Regulation and the Data Protection Act 2018.
This policy applies to personal data collected through elitecoldrooms.co.uk and personal data processed as part of our business activities.
Our Commitment to Data Protection
Elite Coldrooms processes personal data in accordance with applicable UK data protection law.
We aim to ensure that personal data is:
processed lawfully, fairly and transparently;
collected for specified and legitimate purposes;
limited to information that is relevant and necessary;
accurate and kept up to date where necessary;
retained only for as long as reasonably required;
protected against unauthorised or unlawful processing;
protected against accidental loss, destruction or damage; and
handled in a way that respects the rights of individuals.
We take reasonable technical and organisational measures to support these principles.
What Is Personal Data?
Personal data is information relating to an identified or identifiable individual.
Depending on how you interact with Elite Coldrooms, personal data may include:
your name;
email address;
telephone number;
postcode;
home or business address;
company or organisation details;
information about your property or premises;
enquiry details;
quotation information;
customer correspondence;
service and installation records;
payment and transaction information;
IP address;
device and browser information; and
other information you voluntarily provide to us.
Information that cannot reasonably be used to identify an individual is not normally considered personal data.
How We Collect Personal Data
We may collect personal data when you:
visit our website;
complete an online enquiry form;
request a quotation;
contact us by telephone or email;
arrange a site survey;
purchase products or services;
arrange installation, maintenance or repair work;
communicate with us as a customer or prospective customer; or
otherwise interact with Elite Coldrooms.
Some technical information may also be collected automatically when you use our website.
We may receive personal data from third parties where there is a legitimate and lawful reason for them to provide it.
Why We Process Personal Data
We process personal data where necessary to operate Elite Coldrooms and provide our services.
Purposes may include:
responding to enquiries;
preparing quotations;
arranging site surveys;
assessing refrigeration requirements;
communicating with prospective and existing customers;
supplying products and services;
arranging installations;
providing maintenance and repairs;
providing customer support;
managing customer relationships;
processing transactions;
maintaining financial and business records;
managing suppliers and contractors;
improving our website and services;
maintaining website and information security;
preventing fraud and misuse;
complying with legal and regulatory requirements; and
establishing, exercising or defending legal claims.
We will not use personal data for a purpose that is incompatible with the reason it was collected unless the processing is permitted by law.
Lawful Bases for Processing
We only process personal data where we have an appropriate lawful basis.
Depending on the circumstances, we may rely on one or more of the following bases.
Contract
We may process personal data where processing is necessary to take steps at your request before entering into a contract or to perform a contract with you.
This may include processing information to prepare quotations, arrange surveys, provide services, complete installations or manage repairs and maintenance.
Legitimate Interests
We may process personal data where it is necessary for our legitimate business interests and those interests do not override your fundamental rights and freedoms.
Our legitimate interests may include responding to enquiries, operating and improving our business, managing customer relationships, maintaining records, securing our systems, preventing fraud and protecting our legal interests.
Legal Obligation
We may process personal data where necessary to meet a legal, regulatory, accounting or tax obligation.
Consent
Where appropriate, we may rely on your consent.
This may apply to certain forms of marketing, cookies or other processing where consent is legally required.
Where processing relies on consent, you can withdraw your consent at any time.
Withdrawal of consent does not affect processing that was lawful before consent was withdrawn.
Data Minimisation
Elite Coldrooms aims to collect only the personal data reasonably required for a specific purpose.
For example, when you request a quotation, we may need your contact information and details about your premises or refrigeration requirements because we cannot properly assess the enquiry without relevant information.
We avoid requesting unnecessary personal information.
Accuracy of Personal Data
We take reasonable steps to ensure personal data is accurate and, where necessary, kept up to date.
You can contact us if you believe information we hold about you is incorrect or incomplete.
Where appropriate, we will correct or update inaccurate information.
Data Retention
We do not retain personal data indefinitely.
We keep personal data for as long as reasonably necessary for the purposes for which it was collected and to meet applicable legal, accounting, tax, insurance and regulatory requirements.
Retention periods may vary depending on the type of information and our relationship with you.
Customer and transaction records may need to be retained after our relationship ends because businesses have legal and financial record-keeping obligations.
Information relating to enquiries that do not result in a customer relationship will be removed when there is no longer a reasonable business or legal requirement to retain it.
We may retain relevant information for longer where a dispute, complaint, investigation or potential legal claim exists.
Data Security
Elite Coldrooms takes reasonable technical and organisational measures to protect personal data.
These measures are designed to reduce the risk of:
unauthorised access;
accidental loss;
inappropriate disclosure;
alteration;
destruction;
misuse; and
unlawful processing.
Access to personal data is restricted to people and service providers who reasonably require access for legitimate business purposes.
Anyone handling personal information on our behalf is expected to treat that information appropriately and securely.
Sharing Personal Data
We may share personal data with trusted third parties where this is reasonably necessary to operate our business or provide our services.
Recipients may include:
IT and website service providers;
website hosting providers;
email and communications providers;
payment providers;
accountants;
insurers;
professional advisers;
suppliers;
refrigeration engineers;
contractors and installers;
delivery and logistics providers;
legal advisers;
government authorities;
regulators; and
law enforcement organisations where disclosure is legally required.
We only share personal data where there is an appropriate reason for doing so.
We do not sell personal data.
Where an organisation processes personal data on our behalf, we take reasonable steps to ensure appropriate data protection arrangements are in place.
International Data Transfers
Some technology or service providers may process personal data outside the United Kingdom.
Where personal data is transferred internationally, we take appropriate steps to ensure the transfer complies with UK data protection requirements.
This may include relying on UK adequacy regulations, recognised contractual safeguards or another lawful international transfer mechanism.
Marketing
Elite Coldrooms may use personal information for marketing where permitted by law.
Where consent is required, marketing communications will only be sent after appropriate consent has been obtained.
You can object to direct marketing at any time.
Where you ask us to stop sending marketing communications, we will take reasonable steps to honour that request.
We may retain limited information to record an opt-out because retaining this information helps us avoid contacting you again for marketing purposes.
Cookies and Online Data
Our website may use cookies and similar technologies.
Some cookies are necessary for the website to operate. Other cookies may be used for functionality, analytics or marketing purposes.
Where UK law requires consent for a cookie or similar technology, it should not be used until appropriate consent has been obtained.
Visitors can manage available cookie preferences through the website and their browser settings.
Your GDPR Rights
UK data protection law provides individuals with a number of rights.
Depending on the circumstances and the type of processing involved, you may have the right to:
be informed about how your personal data is used;
request access to personal data we hold about you;
request correction of inaccurate personal data;
request completion of incomplete personal data;
request deletion of personal data in certain circumstances;
request restriction of processing in certain circumstances;
object to certain processing;
object to direct marketing;
request data portability where applicable;
withdraw consent where processing relies on consent; and
have certain rights relating to automated decision-making.
Not every right applies in every situation. UK data protection legislation allows certain exemptions and restrictions.
Subject Access Requests
You have the right to request access to personal data Elite Coldrooms holds about you.
This is commonly known as a subject access request.
Where applicable, we will provide information about:
the personal data we process;
why we process it;
relevant categories of personal data;
who receives or may receive the information;
applicable retention information; and
your data protection rights.
We may need to verify your identity before releasing personal data because this helps prevent information from being disclosed to an unauthorised person.
We will respond within the period required by applicable data protection law.
A fee will not normally be charged. However, data protection legislation allows fees or other measures in certain circumstances, including where requests are manifestly unfounded or excessive.
Right to Rectification
You can ask us to correct personal data that is inaccurate.
You can also ask us to complete information that is incomplete.
We will consider the request and take appropriate action in accordance with applicable data protection requirements.
Right to Erasure
You may have the right to request deletion of your personal data in certain circumstances.
This right is sometimes known as the right to be forgotten.
The right is not absolute. We may need to retain information where there is a legal obligation, contractual requirement, legitimate reason or need to establish, exercise or defend legal claims.
Right to Restrict Processing
In certain circumstances, you may ask us to restrict how we process your personal data.
Where processing is restricted, we may continue to store the information but limit other uses unless processing is permitted by law.
Right to Object
You may have the right to object to processing based on legitimate interests.
If you object, we will consider your circumstances and determine whether we have compelling legitimate grounds to continue processing.
You have the right to object to the use of your personal data for direct marketing.
Data Portability
Where the legal requirements are met, you may have the right to receive certain personal data in a structured, commonly used and machine-readable format.
You may also have the right to ask for eligible information to be transferred to another organisation where technically feasible.
Automated Decision-Making
Elite Coldrooms does not use personal data to make solely automated decisions that produce legal or similarly significant effects on individuals.
Personal Data Breaches
A personal data breach may include the accidental or unlawful loss, destruction, alteration, disclosure of or access to personal data.
If we become aware of a suspected personal data breach, we will assess the circumstances and take reasonable steps to limit potential harm.
Where a breach must be reported to the Information Commissioner's Office under applicable law, we will make the required notification.
Where a breach is likely to result in a high risk to an individual's rights and freedoms, affected individuals will be informed where required by law.
Third-Party Data Processors
Where third-party service providers process personal data on our behalf, we expect them to handle that information securely and in accordance with applicable data protection requirements.
We take reasonable steps to use providers that offer appropriate technical and organisational safeguards.
Third parties acting as independent data controllers are responsible for their own compliance with applicable data protection law.
Data Protection by Design
We consider data protection when introducing or changing processes, systems and services that involve personal data.
Where appropriate, we aim to minimise the amount of personal data collected, restrict unnecessary access and consider privacy and security risks before implementing new processing activities.
Changes to This GDPR Policy
We may update this GDPR Policy when our business practices, website, technology or legal obligations change.
The latest version will be published on elitecoldrooms.co.uk.
Contact Elite Coldrooms
If you have questions about this GDPR Policy, want to exercise your data protection rights or have concerns about how your personal data is processed, please contact Elite Coldrooms through elitecoldrooms.co.uk.