PRIVACY NOTICE

  1. Overview & About Us

1.1. This Privacy Notice applies to all companies within the Heathcote Holdings Group Limited (“Heathcote Holdings”), including but not limited to FGS Industrial Facilities Management trading as FGS Agri Limited (“FGS Agri”). Each company is committed to safeguarding the privacy of its customers, website visitors, and other individuals whose Personal Data it processes.

1.2. Heathcote Holdings’ registered office is at Stanford Bridge Farm, Station Road, Pluckley, Ashford, Kent TN27 0RU.

1.3. This Privacy Notice describes how Heathcote Holdings companies collect, use, and share information that may contain Personal Data.

1.4. For questions about this Privacy Notice or the privacy practices of a specific Heathcote Holdings company, please contact our Data Protection Officer at: dataprotection@fgsagri.co.uk

  1. Customers and Other Individuals

2.1. Under the EU General Data Protection Regulations (GDPR) Heathcote Holdings is obliged to provide individual customers and individuals identifiable from data that we hold relating to our corporate or local authority customers, with certain information relating to Heathcote Holdings and how we collect and use their ‘Personal Data’.

2.2.Why do we process your Personal Data?

2.2.1. We need to hold basic Personal Data so that we can provide our services to you in accordance with our terms of business entered into with you.

2.2.2. Without this Personal Data Heathcote Holdings would be unable to provide its contracted services to you or your business.

2.2.3. We only collect and process Personal Data that we need in order to provide you with, and to manage, Heathcote Holdings’s contracted services.

2.3. What type of Personal Data do we process?

2.3.1. Account Data: this includes details such as your name and email address;

2.3.2. Profile Data: this would include, in addition to your name, your address, telephone number, gender, date of birth and possibly, employment details/job title;

2.3.3. Transaction Data: this covers Personal Data provided in the course of using Heathcote Holdings’s services and may include details of the transaction you have entered into with us and the payment methodology you used (including payment card details); and

2.3.4. Notification Data: this information you provide to us for the purposes of subscribing to Heathcote Holdings’s email or newsletter notifications.

2.4. Where is your Personal Data processed and by whom?

2.4.1. Your Personal Data is only processed by Heathcote Holdings staff located in the United Kingdom.

2.4.2. No one else has access to your Personal Data unless Heathcote Holdings has a legal obligation to provide that third party with your Personal Data (eg: it is reasonably necessary to do so to obtain or maintain insurance coverage) or you give us your consent to do so.

2.4.3. It is likely that we will need to share your Personal Data with Heathcote Holdings’s suppliers or contractors in order, for example, to distribute our newsletter or to maintain our database software.

2.5. What is the legal basis for Heathcote Holdings processing your Personal Data?

2.5.1. Legal Obligation: Heathcote Holdings processes some Personal Data in order to comply with a legal obligation for example under the requirements of the Waste Duty of Care obligations imposed by Section 34 of the Environmental Protection Act 1990; and/or

2.5.2. Contractual Obligation: Heathcote Holdings also processes Personal Data where it is necessary in order to perform a contract with you for the delivery of Heathcote Holdings’s services or in order to enter into such a contract with you; and/or

2.5.3. Legitimate Interest: Heathcote Holdings also processes Personal Data where it is necessary in order to pursue a legitimate interest such as for the proper administration of our business, for example, by updating you on our activities and other services we can offer you; and/or

2.5.4. Insurance Risk: Heathcote Holdings may process Personal Data where necessary for obtaining or maintaining insurance coverage, managing risk or obtaining professional advice, the legal basis for doing so is the proper protection of our business against risk.

2.5.5. Your Consent: if your Personal Data is used for anything other than the above reasons, Heathcote Holdings will always obtain your consent to such use first.

2.6. How secure is your Personal Data?

2.6.1. Heathcote Holdings takes all reasonable steps to ensure that your Personal Data is processed securely.

2.6.2. Heathcote Holdings has implemented technology and security policies, rules and measures designed to protect your Personal Data under our control.

2.6.3. Other than online data, all your Personal Data is restricted to our offices and only Heathcote Holdings employees have access to this data. There are exceptions to this as outlined in paragraph

2.4.3 and in these cases, the third party receiving your Personal Data for these limited circumstances is the subject of a non-disclosure agreement with Heathcote Holdings or separate privacy policies.

2.7. How long do we keep your Personal Data?

2.7.1. Your Personal Data may be kept for 2 or 3 years to comply with Waste Duty of Care obligations (depending on whether the waste we manage for you is non-hazardous (2 years) or hazardous (3 years)).

2.7.2. If your Personal Data relates to the accounting or financial records of Heathcote Holdings that may be available for inspection by HMRC, we are obliged to keep this data for a minimum of 6 years.

2.7.3. All Personal Data falling within the categories in paragraphs 2.7.1 and 2.7.2 above will be destroyed after these time periods if not longer required for any lawful purpose.

2.7.4. If you have provided your consent to the processing of your Personal Data for marketing purposes, this will be kept until such time as you notify us that you no longer wish to receive information from Heathcote Holdings.

  1. Website Visitors

3.1. About Cookies.

3.1.1. By using Heathcote Holdings’s website and agreeing to this Privacy Notice, you consent to our use of cookies in accordance with the terms of this Privacy Notice.

3.1.2. Heathcote Holdings uses cookies for the following purposes:

3.1.2.1. Authentication: we use cookies to identify you when you visit our website and as you navigate our website;

3.1.2.2. Security: we use cookies as an element of the security measures used to protect user accounts, including preventing fraudulent use of login credentials, and to protect our website and services generally;

3.1.2.3. Analysis: we use cookies to help us to analyse the use and performance of our website and services.

3.1.3. For administration and internal business purposes, Heathcote Holdings may collect information about your computer, such as, your IP address and operating system. This information does not identify you personally and is statistical data only which identifies your browsing patterns.

3.1.4. You may prevent us from storing a cookie on your computer by setting your browser so that it will not accept cookies.

  1. What are your rights?

4.1. Summary: Your principal rights under GDPR are as follows:

4.1.1. the right to access;

4.1.2. the right to rectification;

4.1.3. the right to erasure;

4.1.4. the right to restrict processing;

4.1.5. the right to object to processing;

4.1.6. the right to data portability;

4.1.7. the right to complain to a supervisory authority; and

4.1.8. the right to withdraw consent.

4.2. Access to your information: You have the right to request a copy of the Personal Data that we hold about you. If you like a copy of some or all of your Personal Data please contact our Head of Privacy on the email address in paragraph 1.4 above or write to the Head of Privacy at the registered office of Heathcote Holdings set out in paragraph 1.2 above.

4.3. Request to correct or remove your Personal Data: Heathcote Holdings wants to be sure that your Personal Data is accurate and up to date. You may ask us to correct or remove such information that you think is inaccurate at any time.

4.4. Proof of Identity: If you make a request to access, correct or remove your Personal Data under paragraphs 4.1 or 4.2 above, we will ask you to supply appropriate evidence of your identity (for this purpose, we will usually accept a photocopy of your passport certified by a solicitor or bank plus an original copy of a utility bill showing your current address).

4.5. Complaint: If you wish to raise a complaint about the way Heathcote Holdings handles your Personal Data, again please write to our Head of Privacy at the email address or the registered office of the Company referred to above. If you are not satisfied with the way Heathcote Holdings handles your complaint you can take your complaint to the Information Commissioner’s Office (ICO). You can contact the ICO via the link https://ico.org.uk/concerns/.

  1. Amendments

5.1. Heathcote Holdings may update this Privacy Notice from time to time by publishing a new version on its website. Please check this page occasionally to ensure you are happy with any changes to this Privacy Notice.

5.2. Heathcote Holdings will notify users of any material changes to this Privacy Notice by identifying a link on its homepage of its website to the updated policy for a period of not less than 14 days.

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