Protecting your personal information
Carousel is committed to protecting the privacy and security of your personal information. This privacy notice describes how we collect and use personal information about you in accordance with the General Data Protection Regulation (GDPR). Please read it carefully.
The GDPR says that the personal information we hold about you must be:
- Used lawfully, fairly and in a transparent way.
- Collected only for valid purposes that we have clearly explained to you and not used in any way that is incompatible with those purposes.
- Relevant to the purposes we have told you about and limited only to those purposes.
- Accurate and kept up to date.
- Kept only as long as necessary for the purposes we have told you about.
- Kept securely.
This notice is separated into the following sections for ease of use. If you have any questions about this notice or how we collect and use personal information about you please contact us.
1. Information about us
2. What personal information do we collect and how do we collect it?
3. How and why do we use your information?
4. Automated decision making
5. Sharing your information
6. Where we store your information
7. Data Security
8. How long will we keep your information for?
9. Your rights
11. Third party websites
12. Changes to this privacy notice
1. Information About Us
We are Carousel Logistics Limited. Our registered office is at Number 22 Mount Ephraim, Tunbridge Wells, Kent TN4 8AS and our registered company number is 01908712.
2. What Personal Information Do We Collect and How Do We Collect It?
Personal data, or personal information, means any information about an individual who can be identified. It does not include data where an individual cannot be identified (anonymous data). We collect personal information from you in the following ways.
Form information. This is information about you (such as your name, address, email address, telephone number, date of birth and credit card information) that you provide when filling in forms whether on our website, forms on another website (e.g. LinkedIn) or offline. This could include, for example, forms which you complete to register for a service, place an order, sign-up for a newsletter or enter a competition
Content. This is information about you which you provide when you post content on our website. This may include status updates, photographs, videos, blog posts, discussion board posts, survey responses and other content which you post on our website.
Emails and records of other contact. This is information you provide when you contact us (for example by email, post or SMS) or when you respond to correspondence from us. This may include enquiries about our services or products, reviews, follow-up comments or complaints.
Technical information. This is information about you which is collected via technical means such as cookies, webpage counters and other analytics tools.
Visitor information. We collect information about visitors to our premises. We may record information on your visit, including the date and time, who you are visiting, your name, employer, contact details and vehicle registration number. If you have an accident at our premises, this may include an account of your accident.
Caller information. We may collect details of phone numbers used to call our organisation and the date, time and duration of any calls. Please note that if we record your calls to or from us, we will inform you of this.
CCTV. We operate CCTV at our premises which may record you and your activities. We display notices to make it clear what areas are subject to surveillance.
Employee information. If you work for us or one of our customers, suppliers or business partners, the information we collect about you may include your contact information, details of your employment and our relationship with you.
Information we receive from third parties. As well as the information listed above, we may also receive the following types of personal information about you from the following sources:
Our other channels. This is information we receive about you if you use any of the other websites we operate or the other services or products we provide. In this case we will have informed you when we collected that data if we intend to share those data internally and combine it with data collected on this website. We will also have told you for what purpose we will share and combine your data.
Publicly available sources. We obtain information from the following publicly available sources:
- LinkedIn and other social media, e.g. Twitter
- Freely available online resources and web sites
- Companies House
Our service providers. We work closely with third parties (including, for example, business partners, sub-contractors in technical, payment and delivery services, advertising networks and marketing companies, analytics providers, search information providers and credit reference agencies) who may provide us with information about you as well as about your interaction with our website and other websites that provide similar products and services.
Credit information. We may also collect credit information on you from third party reference agencies.
Businesses we have bought. If we have acquired another business, or substantially all of its assets, which originally held your information, we will hold and use the information you provided to them, or which they otherwise held about you, in accordance with this privacy notice.
Special Categories of data
We may also collect and use the following “special categories” of more sensitive personal information in the following situations:
- Information about your race or ethnicity, religious beliefs and sexual orientation. This may be collected from you via an Equal Opportunities Questionnaire prior to becoming a Carousel employee.
- Information about your health, including any medical condition, health and sickness records. This may be collected from you via a Medical Questionnaire prior to becoming a Carousel employee.
- Information about criminal convictions and offences. This may be collected as part of a criminal records check prior to becoming a Carousel employee.
3. How and Why Do We Use Your Information?
Common uses of your information
We will only use your personal information when the law allows us to do so. Most commonly, we will use your personal information in the following circumstances:
- Where we need to perform a contract we have entered into with you.
- Where we need to comply with a legal obligation.
- Where we have your consent to do so e.g. to send you marketing communications in certain circumstances.
- 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 may also use your personal information where we need to protect your interests (or someone else’s interests) or where it is needed in the public interest although these circumstances are likely to be rare.
Specific examples of ways in which we may use your personal information include:
Website administration. We may use technical information, information about your visit to our website, cookie data, content and other information gathered during your participation in discussion boards or other functions on our website. We use this as necessary for our legitimate interests in administering our website and to ensure it operates effectively and securely.
Website advertising. We, or third-party advertisers, may serve adverts on you. Where those adverts are targeted, this may involve using technical information, information about your visit to our website, cookie data and information we (or our third-party advertisers) have obtained from third parties. More information is available in our Cookie Notice. This won’t include information such as your name or contact details. Where our adverts are displayed to you using your information, your information is used as necessary for our legitimate interests in marketing to you.
Customer Administration. We may use information about you including form information, content and other information you provide to us or which we collect about you as necessary to carry out our contracts with you, and for our legitimate interests in administering your account and any subscriptions or competitions we operate, as well as to review and improve our offerings, including troubleshooting, data analysis, testing, research, statistical and survey purposes.
Direct Marketing. We may use information about you to contact you about content, products and services that may be of interest to you. We may send direct postal or electronic marketing to you or make marketing calls to you using your contact details and other information that has been provided to us. We use this as necessary for our legitimate interests in marketing to you where permitted and to maintain a list of potential customers. If you are not acting as a business (or are a sole trader), we will only send you electronic marketing or make marketing calls to you if you have consented to that marketing or as otherwise permitted. We will always provide an “opt-out” option on any marketing messages we send you. If you “opt-out” of our marketing materials, you will be added to our suppression list to ensure we do not accidentally contact you again for marketing purposes.
Third Party Personnel Administration. If you work for one of our customers, suppliers or business partners, we may hold information on you. This includes information you provide when you correspond with us, as well as details of your employment, contact details, and our relationship with you. We use this as necessary for our legitimate interests in managing our relationship with your employer.
CCTV Information and Visitor Information. We use CCTV information and visitor information as necessary for our legitimate interests in administering your visit, ensuring site security and visitor safety, and administering parking.
Job Applications. If you apply for a position with us, we hold and use information on you. This will include information you provide to us in your application, as well as opinion information on you from any referees you provide. We may also obtain criminal record and identity verification information from reference agencies. We use this as necessary to enter into an employment contract with you, and for our legitimate interests in evaluating candidates and recording our recruitment activities, and as necessary to exercise and perform our employment law obligations and rights.
Former Employees. If you used to work for us, your information will be used in accordance with our employee privacy notice. If you are a former employee or contractor and require a copy of this, please contact us.
Special Categories of data
Where we collect “special categories” of particularly sensitive personal information (as set out in section 2 above) this information requires higher levels of protection and by law we need to have further justification for collecting, storing and using this type of personal information. We may process special categories of personal information in the following circumstances:
- In limited circumstances, with your explicit written consent.
- Where we need to carry out or exercise our legal obligations or rights under employment law.
- Where it is needed in the public interest.
- Where it is needed in relation to legal claims or where it is needed to protect your vital interests (or someone else’s vital interests) and you are not capable of giving your consent.
- Where you have already clearly made the information public.
Change of purpose
We will only use your personal information for the purposes for which we collected it as set out in this notice, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If we need to use your personal information for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.
Please note that we may process your personal information without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.
4. Automated Decision Making
As part of our service optimisation, our Clever Technology platform may automatically pass consignment data to trusted network partners based on predefined routing rules. Consignment data may include essential personal information required to perform the services, such as the consignee’s name, address, telephone number and email address. The routing logic can be based on a number of factors including but not limited to client preference, consignment weight, volume, destination and service type. All of our partners are carefully selected and take your privacy extremely seriously.
5. Sharing Your Information
As well as any sharing listed in section 3 (How and why do we use your information) we may also share your information with third parties, including third-party service providers and other entities in our group. We require third parties to respect the security of your personal information and to treat it in accordance with the law. We may transfer your personal information outside the EU and the UK. If we do, you can expect a similar degree of protection in respect of your personal information.
Why might we share your personal information with third parties?
We may share your personal information with third parties if we are under a duty to disclose or share your personal information in order to comply with any legal obligation, or in order to enforce or apply our agreements with you, or to protect the rights, property, or safety of us, our customers, or others or where we have another legitimate interest in doing so. This includes exchanging information with other companies and organisations for the purposes of fraud protection and credit risk reduction.
Which third-party service providers process your personal information?
“Third parties” includes third-party service providers (including contractors and designated agents) and other organisations within our group. The activities carried out by third-party service providers include but may not be limited to: contract administration, order fulfilment, delivery, administration, IT services, payment processing.
How secure is your information with third-party service providers and other entities in your group?
All our third-party service providers and other entities in the group are required to take appropriate security measures to protect your personal information in line with our policies. We do not allow our third-party service providers to use your personal information for their own purposes. We only permit them to process your personal information for specified purposes and in accordance with our instructions.
When might we share your personal information with other entities in the group?
We may share your personal information with other entities in our group as part of solution design, our regular reporting activities on company performance, in the context of a business reorganisation or group restructuring exercise, for system maintenance, support and hosting of data.
What about other third parties?
We may share your personal information with other third parties, for example in the context of the possible sale or restructuring of the business. We may also need to share your personal information with a regulator or to otherwise comply with the law.
6. Where We Store Your Information
Our office headquarters are based in Sittingbourne and our main data centre is located in UK and/or EIRE. However, where required to perform our contract with you or for our wider business purposes, the information that we hold about you may be transferred to, and stored at, a destination outside the UK and the EU. It may also be processed by staff operating outside the UK and EU who work for us or for one of our service providers. We will take all steps reasonably necessary to ensure that your personal information is treated securely and in accordance with this privacy notice.
7. Data Security
We have put in place measures to protect the security of your information. Details of these measures are available upon request.
Third parties will only process your personal information on our instructions and where they have agreed to treat the information confidentially and to keep it secure.
We have put in place appropriate security measures to prevent your personal information from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal information to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal information on our instructions and they are subject to a duty of confidentiality.
We have put in place procedures to deal with any suspected data security breach and will notify you and any applicable regulator of a suspected breach where necessary.
8. How Long Will We Keep Your Information For?
We will only retain your personal information 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 information, we consider the amount, nature, and sensitivity of the personal information, the potential risk of harm from unauthorised use or disclosure of your personal information, the purposes for which we process your personal information and whether we can achieve those purposes through other means, and the applicable legal requirements.
Details of our typical retention periods for different aspects of your personal information are set out below. If you would like details of our retention periods for a particular aspect of your personal information which is not detailed below, please contact us:
Order information including information about you such as your name, address, email address, telephone number, products / services ordered, order date, delivery date and other correspondence with us are kept for a period of up to 7 years after the date of order to enable us to deal with any after sales enquiries or claims.
Business contact information such as your name, email address and telephone number may be kept for marketing purposes. All marketing data is reviewed annually and erased where no longer relevant to our Sales and Marketing strategy (which shall be 2 years for data regarding potential customers and no later than 3 years after contract end for any customer details kept for marketing purposes).
Content which you post on our website such as status updates, photographs and other content is kept for as long as you have an account with us and may be retained for a period of up to 7 years after you close your account.
Technical information which is collected via technical means such as cookies, webpage counters and other analytics tools is kept for a period up to 24 months.
Visitor information which is collected about visitors to our premises is kept for a period of up to 3 years. If you have an accident on our premises, our accident records are also retained for a period of up to 3 years.
Telephone recordings which we make of your telephone conversations with us may be kept for a period of up to 24 months.
CCTV recordings may be kept for a period of up to 60 days (unless there an incident occurs and it is necessary for us to keep recordings for longer to properly deal with it).
Special categories of data are typically kept for a maximum period of 6 years after employment with Carousel has ended but may vary dependent on applicable employment law.
In some circumstances we may anonymise your personal information so that it can no longer be associated with you, in which case we may use such information without further notice to you.
9. Your Rights
The GDPR gives you a number of rights when it comes to personal information we hold about you. The key rights are set out below. More information about your rights can be obtained from the Information Commissioner’s Office (ICO). Under certain circumstances, by law you have the right to:
Be informed in a clear, transparent and easily understandable way about how we use your personal information and about your rights. This is why we are providing you with the information in this notice. If you require any further information about how we use your personal information, please let us know.
Request access to your personal information (commonly known as a “data subject access request”). This enables you to receive a copy of the personal information we hold about you and to check that we are lawfully processing it.
Request correction of the personal information that we hold about you. This enables you to have any incomplete or inaccurate information we hold about you corrected.
Request erasure of your personal information. This enables you to ask us to delete or remove personal information where there is no good reason for us continuing to process it (for instance, we may need to continue using your personal data to comply with our legal obligations). You also have the right to ask us to delete or remove your personal information where you have exercised your right to object to processing (see below).
Object to processing of your personal information 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 us using your information on this basis and we do not have a compelling legitimate basis for doing so which overrides your rights, interests and freedoms (for instance, we may need it to defend a legal claim). You also have the right to object where we are processing your personal information for direct marketing purposes.
Request the restriction of processing of your personal information. This enables you to ask us to suspend the processing of personal information about you, for example if you want us to establish its accuracy or the reason for processing it.
Request the transfer of your personal information to another party where you provided it to us and we are using it based on your consent, or to carry out a contract with us, and we process it using automated means.
Withdraw consent. In the limited circumstances where we are relying on your consent (as opposed to the other bases set out above) to the collection, processing and transfer of your personal information for a specific purpose, you have the right to withdraw your consent for that specific processing at any time. Once we have received notification that you have withdrawn your consent, we will no longer process your information for the purpose or purposes you originally agreed to, unless we have another legitimate interest in doing so.
If you want to review, verify, correct or request erasure of your personal information, object to the processing of your personal information, withdraw your consent to the processing of your personal information or request that we transfer a copy of your personal information to another party, please contact us in writing.
In addition to the right set out above, you also have the right to ask us not to process your personal information for marketing purposes. We will usually inform you (before collecting your personal information) if we intend to use your personal information for such purposes or if we intend to disclose your information to any third party for such purposes. You can exercise your right to prevent such processing by checking certain boxes on the forms we use to collect your personal information or letting us know if we call you for marketing purposes. You can exercise the right at any time by contacting us in writing. You can also use the unsubscribe option in our marketing emails to unsubscribe from further marketing emails. Please note that where you unsubscribe from any postal marketing, you may initially still receive some content which has already been printed or sent, but we will remove you from any future campaigns.
No fee usually required
You will not have to pay a fee to access your personal information (or to exercise any of the other rights). However, we may charge a reasonable fee if your request for access is clearly unfounded or excessive. Alternatively, we may refuse to comply with the request in such circumstances.
What we may need from you
We may need to request specific information from you to help us confirm your identity and ensure your right to access the information (or to exercise any of your other rights). This is another appropriate security measure to ensure that personal information is not disclosed to any person who has no right to receive it.
Please consider your request responsibly before submitting it. We will respond to your request as soon as we can. Generally, this will be within one month from when we receive your request but, if the request is going to take longer to deal with, we will let you know.
For the same reason, we may obtain information about your general internet usage by using a cookie file which is stored on the hard drive of your computer. Cookies contain information that is transferred to your computer’s hard drive. They help us to improve our site and to deliver a better and more personalised service. They enable us:
- To estimate our audience size and usage pattern.
- To store information about your preferences, and so allow us to customise our site according to your individual interests.
- To speed up your searches.
- To recognise you when you return to our site.
Most browsers are set to automatically accept cookies. If you’re using Microsoft’s Internet Explorer, Mozilla Firefox, Google Chrome or Safari you should be able to configure your browser to restrict or block cookies, or you may wish to delete them, by going to your browsers settings.
11. Third Party Websites
Our website may, from time to time, contain links to and from the websites of our partner networks, advertisers and affiliates. If you follow a link to any of these websites, please note that these websites have their own privacy policies and that we do not accept any responsibility or liability for these policies. Please check these policies before you submit any personal information to these websites.
12. Changes to this Privacy Notice
Any changes we make to our privacy notice in the future will be posted on this page and, where appropriate, notified to you by e-mail or otherwise. Please check back frequently to see any updates or changes to our privacy notice.