Please read the following carefully to understand our views and practices regarding your personal data and how we will treat it.
Important information and who we are
We are Treng Ltd T/A Owen Brothers. We are a company incorporated and registered in England. Our company number is 12836317. Our registered address is Owen Brothers, Units C3-C4, 32-34 Jaggard Way London SW12 8SG.
When we refer to “we”, “us” or ”our” in this policy, we are referring to Owen Brothers. We are the data ‘controller’ in relation to the personal data you provide to us, which means we determine the purposes and the way in which your personal data is, or will be, processed.
We use the following definitions in this policy to cover the different categories of individuals we interact with via our Site and Services:
- Business contact: means an individual employee, consultant or agent of any supplier, distributor, purchaser or other commercial organisation we engage with in relation to our business.
- Customer: means an individual customer we sell to, whether via our Site or otherwise.
- User: means any person accessing our Site.
Our Site may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our Site, we encourage you to read the privacy notice of every website you visit.
How is your personal data collected?
We use different methods to collect data from and about you including through:
- Direct interactions. You may give us your personal data by filling in forms or by corresponding with us in person, by email, by phone, by post or otherwise. This includes personal data you provide when creating an account with us and when you request marketing communications to be sent to you.
- Automated technologies or interactions. As you interact with our Site, we may automatically collect Technical data about your equipment, browsing actions and patterns. We collect this personal data by using cookies and other similar technologies. Please see below on Cookies for further information.
- Third parties or publicly available sources. We may receive personal data about you from various third parties and public sources. For example, analytics providers such as Google.
Information we collect from you
We may collect and process the following data about you:
- Account data. When you purchase something from us, you will need to set up an account before you order. As part of this process, we collect your name, address and email address.
- Contact data. This is the information provided about you when forms on our Site are completed or provided to us by other mediums such as email, fax and phone. This includes information provided to create an account and log-in details for our Services including name, last name, date of birth, billing address, residential address, email address, telephone numbers.
- Marketing data.Includes your preferences in receiving marketing from us and our third parties and your communication preferences.
- Payment data.We do not store your payment card information
- Technical data. This includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access the Site.
- Transaction data: This includes details about Products and Services that you have purchased from us and payments to and from you.
- Usage data. This is the information we record about you how use our Site, Products and Services.
How do we use your personal data?
We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:
- Where we need to perform a contract we are about to enter into or have entered into with you (i.e. when you purchase something from us).
- Where we have your prior consent to use your personal data (for example, where you have consented to receiving marketing).
- Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests. 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 at email@example.com
- Where we need to comply with a legal or regulatory obligation.
We have set out below, in a table format, a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.
Please note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below.
|Purpose/activity||Type of data||Lawful basis for processing|
|To set up your account||Account data||Performance of a contract with you|
|To respond to your enquiries||Contact data||Consent (as you are requesting us to respond to you)
|To process your order||Account data
|Performance of a contract with you|
|Storing payment cards||Payment data||We do not hold any card details ever on our website|
|To send you marketing emails||Marketing data||Legitimate interests (to market our goods services to our customer and contact base).
|To personalise our Site and improve User experience||Technical data||Legitimate interests (to improve customer interactions)|
|To liaise with you if you are a Business contact in relation to our work your business||Contact data||Legitimate interests (to comply with obligations to partner organisations)|
|For audit, record keeping and management purposes||Transaction data||Legitimate interests (to run our business in a professional manner)|
|To manage our relationship with you which will include:
• Notify you about changes to our terms or privacy notice;
• Contact you to provide reminders on important usage issues;
• Ask you to leave a review or take a survey;
• Following up on enquiries or expressions of interest whether online, at a trade show or by phone.
|Contact Marketing||Performance of a contract with you, Necessary to comply with a legal obligation, Necessary for our legitimate interests (to keep our records updated, study how our Products and Services are used and to improve them into the future)|
|To administer and protect our business, Site and Services (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)||Contact
|Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise, or crossreferencing social media traffic with our client base) Necessary to comply with our legal obligations|
|To use data analytics to improve our Site, Products and/or Services, marketing, customer relationships and experiences||Technical||Necessary for our legitimate interests (to define types of users of our Site, Products and Services, to keep our Site updated and relevant, to develop our business and to inform our marketing strategy)|
Disclosure of your information
We will never to share your personal information with third parties for the purposes of sales & marketing, however the list below are the only Third parties who will access to some of your data:• External third-party service providers acting as processors who provide the following services:
- Web hosting;
- Metrics and analytics; and
- Payment transaction processors.
• Please note this includes the international service providers listed below in 'International transfers'.
• Professional advisers, including lawyers, bankers, auditors and insurers who provide consultancy, banking, legal, insurance and accounting services.
• HM Revenue & Customs, regulators and other authorities acting as processors, controllers or joint controllers who require reporting of processing activities in certain circumstances.
• In the event that we sell or buy any business or assets, in which case we may disclose yourpersonal data to the prospective seller or buyer of such business or assets.
• If Owen Brothers and its assets are acquired by a third party, in which case personal data held by it about its Customers will be one of the transferred assets.
We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.
If we transfer your personal data out of the EEA, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:• The country has been deemed to provide an adequate level of protection for personal data by the European Commission. For further details, see European Commission: Adequacy of the protection of personal data in non-EU countries.
• If we use certain service providers based out of the EEA, we may use specific contracts approved by the European Commission which give personal data the same protection it has in Europe. For further details, see European Commission: Model contracts for the transfer of personal data to third countries.
• If we use providers based in the US, we may transfer data to them if they are part of the Privacy Shield which requires them to provide similar protection to personal data shared between the Europe and the US. For further details, see European Commission: EU-US Privacy Shield.
• In any other case, we will obtain your explicit consent before any transfer takes place.
Some of our external third parties are based outside the EEA so their processing of your personal data will involve a transfer of data outside the EEA. The table below sets out details of transfers to such third parties and the relevant safeguards.
|Service provider||Description of service||Safeguards|
|Mailchimp||Email newsletter||Privacy Shield|
|Proofpoint||Spam filter||Privacy Shield|
|Office 365||Productivity tools and services||Privacy Shield|
|Google Drive||Shared drives||Privacy Shield|
Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the EEA.
We have put in place appropriate security measures in accordance with industry best practice 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.
All information you provide to us is stored on secure servers. Any payment transactions will be encrypted using SSL technology and using trusted third parties. Where we have given you (or where you have chosen) a password which enables you to access certain parts of our Site, you are responsible for keeping this password confidential. We ask you not to share a password with anyone.
Unfortunately, no method of transmission of information via the internet is completely secure. However, we follow all PCI-DSS requirements and implement additional generally accepted industry standards so that we can do our best to protect your personal data.
How long we store your personal data for
We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.
To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.
We normally delete personal identifiable information we hold on you within 24 months unless there’s a statutory requirement to keep it for a specified period. In some circumstances you can ask us to delete your data sooner: see 'Deleting personal data' below for further information.
Where we anonymise your personal data (i.e. so that it can no longer be associated with you) for further research or statistical purposes, then we may use this information indefinitely without further notice to you.
Our cookies help us:• Make our Site work as you’d expect
• Enhance the security of our Site
• To anonymously measure Site usage
• To improve your User experience
• Continuously improve our Site for you
• Collect any sensitive information (without your express permission)
• Pass data to advertising networks
• Pass personally identifiable data to third parties
• Pay sales commissions
We use four groups of cookies on our Site:
Session cookies are stored only for the duration of your visit to a website and these are deleted from your device when your browsing session ends. These cookies allow us to make sure you get the best possible experience on our Site and are essential for you to be able to search our products online.
All these cookies are used by Google Analytics to keep stats of the traffic to our Site. Personal information such as your name or address is not collected, and all information is completely anonymous. This information helps us to improve our Site and our customers experience.
Spam protection cookiestntcon
We use a CAPTCHA code on our contact form to stop spam. This creates a cookie, which is placed on your PC and is deleted from your device once you close your browser.
WordPress (blog) cookies
Important information about cookies
You block cookies by activating the setting on your browser that allows you to refuse the setting of all or some cookies. However, if you use your browser settings to block all cookies (including essential cookies) you may not be able to access all or parts of our Site.
Under certain circumstances, you have rights under data protection laws in relation to your personal data. Please click on the links below to find out more about these rights:• to your information
• Request correction of your personal data
• Request deletion of your personal data
• Object to processing of your personal data
• Request restriction of processing your personal data
• Request transfer of your personal data
• Right to withdraw consent
• Right to review by an independent authority
If you wish to exercise any of the rights set out above, please contact us. 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.
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.
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.
Access to your information
You have the right to ask for a copy of the information which we hold on you (commonly known as a ‘data subject access request’).
This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
Correcting personal data
You have the right to request that we correct personal data that we hold about you. This enables you to have any incomplete or inaccurate information we hold corrected, though we may need to verify the accuracy of the new data that you provide to us.
Deleting personal data
You may ask us to delete or remove personal data where there is no good reason for us continuing to process it. This is more commonly known as the ‘right to be forgotten’. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law.
Please note, however, that we may not always be able to comply with your request to delete or remove personal data for specific legal reasons which will be notified to you, if applicable, at the time of your request.
Objecting to processing
You have the right to stop us processing your personal data for direct marketing purposes. We will always inform you if we intend to use your personal data for such purposes, or if we intend to disclose your information to any third party for such purposes. You can usually exercise your right to prevent such marketing by checking certain boxes on the forms we use to collect your data. You can also exercise the right at any time by contacting us.
You may also object to us processing your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
Restriction of processing
This enables you to ask us to suspend the processing of your personal data in the following scenarios:
• if you want us to establish the data's accuracy;
• where our use of the data is unlawful but you do not want us to erase it;
• where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or
• you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
Transferring your personal data
In certain circumstances, you may request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format.
Please note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
Where we are relying on consent to process your personal data you can withdraw your consent at any time. Please note that this will not affect the lawfulness of any processing carried out before you withdraw your consent.
Review by an independent authority
You will always have the right to lodge a complaint with a supervisory body. The relevant authority in the UK is the Information Commissioner’s Office. If you do have a complaint, we would appreciate the chance to deal with your concerns before you approach the ICO, so please do contact us in the first instance if possible.
This version was last updated on 24th July 2021.
A historic version of this policy 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 during your relationship with us.
Questions, comments and requests regarding this policy are welcomed and should be addressed to our Privacy Compliance Officer at firstname.lastname@example.org