Who are we?
Alcohols Ltd is the Data Controller of the personal Information you provide to us. All of the trading companies within the W.H.Palmer & Co. (Industries) Ltd group of companies are registered with the Information Commissioners Office (ICO). You can contact us in relation to general data protection queries by sending an e-mail to [email protected] or writing to:
The Finance Director
The personal information we collect?
When you become one of our clients or suppliers, we will need to obtain from you certain information in order to set you up on our systems. If you are trading as an individual, some of this information may be considered personal information. If you are trading as a company, the only personal information we are likely to require is your name, title and contact details, as a representative of your company.
We also acquire personal information of job applicants. This information is used to assess their suitability for the role they are applying for.
Purpose and legal basis for processing
Any personal information we collect, store and process will be for the following purposes and on the following legal basis:
|Customer/supplier||Transacting with you||Contractual|
|Employee||Employing, paying and managing you||Legitimate interests|
|Employee relative||Emergency contact details||Legitimate interests|
|Shareholder||Contacting you and paying dividends||Legal obligation|
|Job applicant||Assessing your application||Legitimate interests|
If you have provided your consent to do so, we may use your personal information for marketing purposes, such as sending you information about new products or services.
We will only collect and process personal information where it is critical for the performance of the purpose. We will not seek your express consent to process this information, as it is required by us in order to complete the sales/purchase transaction, employ and manage staff, liaise with the company’s owners or make emergency contact. If we request personal information for any other reason, such as for marketing purposes, we will ask you directly for your express consent.
You can withdraw your consent for us to contact you, and for the continued collection, processing or disclosure of your information at any time, by contacting us at [email protected] or writing to:
The Finance Director
If you pay for your purchases by cheque or BACS payment, this process does not give rise to the transfer of any personal data. Occasionally, we may accept small payments by card. In such circumstances, any printed record of the transaction which may contain personal data is securely locked away until such time as it is reconciled to the relevant transaction paperwork, at which point it is destroyed.
Where we pay you, we will only hold the relevant personal information to enable us to do so.
To protect your personal information, we take reasonable precautions and follow industry best practices to make sure it is not inappropriately lost, misused, accessed, disclosed, altered or destroyed, including virus protection, firewalls, etc. Our offices are also protected with the physical protections that would be expected to prevent intruder access.
In general, the third-party providers used by us will only collect, use and disclose your information to the extent necessary to allow them to perform the services they provide to us.
However, certain third-party service providers, such as payment gateways and other payment transaction processors, have their own privacy policies in respect to the information we are required to provide to them for your payment transactions. For these providers, we recommend that you read their privacy policies so you can understand the manner in which your personal information will be handled by these providers.
In particular, remember that certain providers may be located in or have facilities that are located in a different jurisdiction than either you or us. In these circumstances your information may become subject to the laws of the jurisdiction(s) in which that service provider or its facilities are located.
As an example, if you are located in Canada and your transaction is processed by a payment gateway located in the United States, then your personal information used in completing that transaction may be subject to disclosure under United States legislation, including the Patriot Act.
We will not pass on your personal information to any third parties for their own marketing purposes or for onward sale to other third parties, even if you have consented to us using your personal information for our own marketing purposes.
If our company is acquired or merged with another company, your information may be transferred to the new owners so that they may continue to transact with.
In most circumstances, we will only share your personal information for the purposes of completing a transaction with you or if you have consented for us to do so. Outside of these circumstances, we will only disclose your personal information to the police or other law-enforcement body or a statutory or regulatory authority, if required to do so to comply with the law.
Cross border transfers
Data retention period
As stated above, any personal data in relation to a card payment transaction is retained only until such time as it can be reconciled to the relevant paperwork. If you are a registered customer or supplier recorded on our ledgers, we are required by law to retain records of our transactions with you for a minimum of 6 years from our year end date. It is likely that we will retain your standing data, which may include some personal information, for as long as there is a reasonable expectation that you will continue to transact with us. If you no longer wish to transact with us, you may request that we remove any of your personal information from our records (see section on “Your Rights” below).
Shareholders’ personal information is retained as long as that individual remains a shareholder. After a job vacancy has been filled, the personal data of failed applicants is destroyed, unless we have requested and they have consented to us retaining it for a longer period.
If you have consented to us retaining and processing your personal information for marketing purposes, we may periodically use that information to send you information about our products and services until such time as we recognise that the personal information relating to you is out of date or you withdraw your consent to use it for this purpose.
Under data protection law, you have the right to request details of any personal data we hold about you and, if any of it is erroneous, to have it corrected. Where there is no legitimate reason for us to continue to hold your information, you have the right to have it deleted from our records.
You have the right to withdraw your consent for us to use your personal information for marketing purposes at any time.
We may use automated decisioning processes on your personal information, in order to better identify products and services which may be of interest to you. If such processes are used, you have the right to request a manual review of the accuracy of such a process on your personal information.
If you wish to invoke any of the above rights, please contact us at to e[email protected] or writing to:
The Finance Director