Privacy Policy
Summary
In this notice, “we”, “us” and “our” refer to FreelanderSpecialist.com (a business partnership operated by Sue Maddock and Nobert Ngwenya with registered place of business at Glebewood Lodge, Brandon Road, Methwold, Norfolk, IP26 4RH).
We are committed to safeguarding the privacy of our website visitors and people who we conduct business with (“our customers”). For the purpose of the General Data Protection Regulation (EU Regulation 2016/679, when applicable, the “GDPR”), and the EU Data Protection Directive (Directive 95/46/EC), this notice applies where we are acting as a data controller with respect to our customers where we determine the purposes and means of the processing of that personal data. We also acknowledge our obligations under GDPR Article 28 as a data processor for companies submitting personal details for us. This may include, but is not limited to, delivery contact information, and vehicle registration details.
1. Usage and Storage of your Personal Data
In this section we have set out the general categories of personal data that we may process (website & blog usage data, customer data and vehicle records, employee data, and CCTV data), the purposes and legal basis for which we may process this data, as well as our retention policy.
Your personal data that we process for any purpose shall not be kept for longer than is necessary and is listed in the table below. It may be necessary to keep your data for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person.
We have classified your personal data you share with us as follows:
Category |
Description |
Business Purpose |
Legal Basis for Collection |
Retention Period |
| Website and Blog Visitors | May include IP address, geographical location, browser type and version, operating system, referral source, length of visit, page views and website navigation paths, as well as information about the timing, frequency and pattern of your service use (no tracking cookies are used) | Monitoring and improving our website and services | Article 6(1)(a) – consent | See HostGator (our website service provider) cookie policy |
| Customer Data & Vehicle Records | May include you or your client’s name, telephone number, email address, details regarding your required services, as well as all financial, payment and contract data. | Performance of a contract between you and us and/or taking steps, at your request, to enter into such a contract (for example, repair work) | Article 6(1)(b) – contract | 7 yrs. (IRS guidance) |
| Responding to any enquiry you submit to us via email or our blog for the purposes of technical advice or providing relevant goods and/or services to you. | Article 6(1)(a) – consent | 3 years (maybe withdrawn at any time) | ||
| Vehicle details (make, model, colour, VIN, registration) and details of the work performed. | Useful in providing technical advice (e.g. diagnostic information), warranty claims or safety recalls. | Article 6(1)(b) – contract | 7 yrs. | |
| Sales Enquiries | May include name, job title or role, your contact details, information contained in communications between us (e.g. email and website metadata), vehicle make, model, registration and service history. | Responding to any enquiry you submit to us via email, telephone or our blog for the purposes of offering, marketing and selling relevant goods and/or services to you, or for providing technical advice about your vehicle. | Article 6(1)(a) – consent | 3-years (maybe withdrawn at any time) |
| Employee data | May include name, address, age, date of birth, National Insurance number and bank account data. | Legal requirement to furnish this information to HMRC for tax and national insurance purposes. | Article 6(1)(f) – legitimate interests | 7 yrs. (IRS guidance) |
| CCTV data | Personally identifiable characteristics (e.g. facial features) of customers, visitors, suppliers or couriers | For the safety and security of our employees and customers; protecting our premises, equipment and customer’s property; assisting the police, insurance agencies or other bodies with any criminal or civil investigations or legal proceedings. | Article 6(1)(f) – legitimate interests | 7-days |
We may process any of your personal data identified in this notice where necessary for the purposes of obtaining or maintaining insurance coverage, managing risks, or obtaining professional advice. The legal basis for this processing is our legitimate interests, namely the proper protection of our business against risks. Please do not supply any other person’s personal data to us, unless we prompt you, and you have their explicit permission to do so.
2. Personal Data Sharing with Others
Your or your client’s personal data may also be shared with companies who help us run our business, subject to appropriate organisational and technical safeguards. These companies (our “processors”) are listed below:
Processor |
Business Function |
Location of Data |
Safeguards |
| HMRC | Employee payroll | UK | Varied technical measures |
| Payment Sense | Credit Card Processing | United States | PCI-DSS Level 1 service provider accreditation |
| HostGator | Website | United States, India, Philippines | Privacy Shield, Model Contractual Clauses, Standard Contractual Clauses |
| Dropbox | Admin (data backup) | United States | Privacy Shield & Encrypted transfer and storage |
| Google (Gmail) | Admin (email) | United States | Privacy Shield and Model Contractual Clauses |
| NetGear (Arlo) | CCTV | United States | Standard Contractual clauses and AES and TLS encryption |
In addition, we may disclose your personal data to our insurers and/or professional advisers only insofar as reasonably necessary for the purposes of obtaining or maintaining insurance coverage, managing risks, obtaining professional advice, or the establishment, exercise or defence of legal claims, whether in court proceedings or in an administrative or out-of-court procedure.
In addition to the specific disclosures of personal data set out in this section, we may disclose your personal data where such disclosure is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person. We may also disclose your personal data where such disclosure is necessary for the establishment, exercise or defence of legal claims, whether in court proceedings or in an administrative or out-of-court procedure.
Notwithstanding these protections, you acknowledge that personal data that you submit for the provision of services may be available, via the internet, around the world. Whilst we attempt to keep this information secure, we cannot guarantee against the use (or misuse) of such personal data by others.
3. Your Rights
GDPR provides you with eight rights related to our use and retention of your personal data. These rights are:
- The Right to be Informed
- The Right of Access
- The Right to Rectification
- The Right to Erasure
- The Right to Restrict Processing
- The Right to Data Portability
- The Right to Object to Processing
- Rights Related to Automated Decision Making & Profiling
You may exercise any of your rights in relation to your personal data by written notice to us, either by mail, email (privacy@freelanderspecialist.com), or telephone. Some of the rights are complex, and not all of the details have been included in our Appendix A. Accordingly, you should read the relevant laws and guidance from the UK’s GDPR regulatory authority (the Information Commissioner’s Office) for a full explanation of these rights.
4. Amendments
We may update this notice from time to time by publishing a new version on our website. You should check this page occasionally to ensure you are happy with any changes to this notice. We may notify you of significant changes to this notice by email.
5. Managing cookies
We do not actively use cookies on our website other than those required by our service provider, Hostgator (details of the Hostgator cookie policy can be found here). These cookies are for security and functionality and while Hostgator may track visitor behaviour, we do not use any of that data for any form of advertising. Details regarding how to manage these cookies with your browser settings can be found in Appendix B.
6. Our Details
This website is owned and operated by FreelanderSpecialist.com. Our registered office / principal place of business is at Glebewood Lodge, Brandon Road, Methwold, Norfolk, IP26 4RH.
You can contact us by post, to the postal address given above, by using our website contact form, by telephone on the contact number published on our website home page, or by email (privacy@freelanderspecialist.com).
7. Credits
This document was created by Data Compliance Specialists using a template originally supplied from SEQ Legal (https://seqlegal.com).