Privacy Policy

CONTENTS OF PRIVACY POLICY

Important Information and who we are
The Data we collect about you
How is your Personal Data collected?
How we use your Personal Data
Disclosures of Personal Data
International Transfers
Data Security
Data Retention
Your Legal Rights
Contacting the Regulator

IMPORTANT INFORMATION AND WHO WE ARE

This Privacy Policy has been prepared in accordance with the General Data Protection Regulations (“GDPR”) which aims to protect and enhance the rights of data subjects. Star Refining (London) Ltd. recognises the importance of the correct and lawful treatment of personal information and will only use personal data as set out in this Privacy Policy. This Privacy Policy explains in detail the types of personal data collected and how we will store and handle that data.

It is important that you read this Privacy Policy together with any other guidelines or terms and conditions we may provide on specific occasions when we are collecting or processing personal data about you, so that you are fully aware of how and why we are using your data.

CONTROLLER

This Privacy Policy is issued on behalf of Star Refining (London) Ltd, referred to as “we”, “us”, or “our” in this Privacy Policy.

You have the right to request a copy of any information about you that we hold at any time, and also to have that information corrected if it is inaccurate. To ask for your information or to have your information adjusted, please contact DPO, Star Refining (London) Ltd, PO Box 31, London, EC1N 8JR, or email london@starrefining.co.uk.

It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes. We may change this Privacy Policy at any time by updating this page so you should therefore check our website from time to time to ensure you are aware of any changes.

THE DATA WE COLLECT ABOUT YOU

Personal data, or personal information, means any information about an individual from which that person can be identified.

We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:

Identity Data - first name, maiden name, last name, username or similar identifier, marital status, title, date of birth and gender.
Contact Data - billing address, delivery address, email address and telephone numbers.
Financial Data - bank account and payment card details.
Transaction Data - details about payments to and from you.
Technical Data - 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 website.
Profile Data - your username and password, purchases or orders made by you, your interests, preferences, feedback and survey responses.
Usage Data - information about how you use our website, products and services
Marketing and Communications Data - your preferences in receiving marketing from us and our third parties and your communication preferences.

We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data may be derived from your personal data but is not considered personal data in law as this data does not directly or indirectly reveal your identity.

We do not collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data). Nor do we collect any information about criminal convictions and offences.

Where we need to collect personal data by law, or under the terms of a contract we have with you and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you. In this case, we may have to cancel a product or service you have with us but we will notify you if this is the case at the time.

HOW IS YOUR PERSONAL DATA COLLECTED?

Direct interactions. You may give us your Identity, Contact and Financial Data by filling in forms or by corresponding with us by post, phone email or otherwise. This includes personal data when you:

open an Account with us
supply us material to process
visit our websites
engage with us on Social Media
ask us to email or post you information about a service we provide
contact us via any means with a query, complaint or quotation request
choose to complete any surveys we send you
fill in any forms we provide you
comment on or review us or our services
visit our premises which have CCTV systems operated for the purposes of security. These systems may record your image during your visit.
visit our premises operating electronic sign in systems. These systems will request and store your personal information in order to manage our security at these sites.

Automated technologies or interactions. As you interact with our website, 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.

HOW WE USE YOUR PERSONAL DATA

The law on data protection sets out the reasons for which a company may collect and process your personal data, including:

Consent

In specific situations, we can collect and process your data with your consent.

When collecting your personal data, we’ll always make clear which data is necessary in connection with a service.

Contractual obligations

In certain circumstances, we need your personal data to comply with our contractual obligations.

For example, if we process / purchase your material we will need to contact you to advise you of the results and to supply you with an invoice. Your contact information will be used to facilitate this requirement.

Legal compliance

If the law requires us to, we may need to collect and process your data.

For example, we are obliged to keep records of our transactions in order to comply with HRMC regulations.

Legitimate interest

In specific situations, we require your data to pursue our legitimate interests in a way which might reasonably be expected as part of running our business and which does not materially impact your rights, freedom or interests.

As a customer we will use your email address details to send you marketing emails and offers, information on our services and to supply information useful to your business.

We may use your telephone contact details to discuss our services and check if you have material available for collection/ processing.

We may use your address details to send you direct marketing information by post, telling you about our services that we think might interest you.

Purpose/Activity	Type of Data	Lawful basis for processing including basis of legitimate interest
Contacting you regarding orders	Identity, Contact	Performance of contract
Register you as a new customer	Identity, Contact, Financial	Necessary to comply with a legal obligation Performance of a contract with you
Retain transactions	Financial	Necessary to comply with a legal obligation
Record CCTV images	Identity	Legitimate business interests – safeguarding the business and its assets against crime and protecting the safety of our staff and customers.
Signing in Visitors	Identity	Legitimate business interests – safeguarding the business and its assets against crime and protecting the safety of our staff and customers.
Email offers, service updates and relevant information.	Identity, Contact, Marketing and Communications	Legitimate business interests – to maintain our relationship with the customers and to keep them informed of our activities, new equipment, processing capabilities. Consent (prospective customers).
Sending you marketing information by post	Identity, Contact, Marketing and Communications	Legitimate business interests – promotion of our business in terms of our processing capabilities and the services we can offer.
Contacting you by telephone to discuss our services	Identity, Contact, Marketing and Communications	Legitimate business interests – promotion of our business in terms of our processing capabilities and the services we can offer.
Visit our websites	Identity, Contact	Legitimate business interests – general enquiry forms – Google Analytics, cookies and IP address information to provide guidance on how users use our site.

MARKETING

We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising. We have established the following personal data control mechanisms:

Within our CRM system we have preference fields covering email, telephone and postal communications. If you choose to object to a form of communication, this will be updated on your record to ensure you are not contacted via this method ongoing.

PROMOTIONAL OFFERS FROM US

We may use your Identity, Contact, Technical, Usage and Profile Data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which products, services and offers may be relevant for you (we call this marketing).

You will receive marketing communications from us if you have requested information from us or have engaged our services, or if you provided us with your details when you entered a competition or registered for a promotion and, in each case, you have not opted out of receiving that marketing. There may be occasions where we contact you using contact information freely available within the public forum; however, this will not be the case if you have previously opted out of receiving marketing from us.

OPTING OUT

You can ask us or third parties to stop sending you marketing messages at any time. Here are the ways you can stop direct marketing communications from us:

Respond to our email communication advising you would like to no longer receive email contact. We will then stop any further emails from being sent to you.
Contact us directly and we will update your preferences for each communications channel on our systems.
Write to Data Protection Officer, Star Refining (London) Ltd, 85 Hatton Garden, London, EC1N 8JR.

Please note that you may continue to receive communications for a short period after changing your preferences while our systems are fully updated.

Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of any order you make with us.

You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of this website may become inaccessible or not function properly.

CHANGE OF PURPOSE

We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purposes is compatible with the original purpose, please contact us.

If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.

DISCLOSURES OF PERSONAL DATA

We sometimes share your personal data with trusted third parties, only when this is essential to allow us to fulfil our contractual or legal requirements. (for example, delivery/ shipping companies/ Police/ HMRC/ payment facilitators)

Here’s the policy we apply to those organisations to keep your data safe and protect your privacy:

We provide only the information they need to perform their specific services.
They may only use your data for the exact purposes we specify in our contract with them.
We work closely with them to ensure that your privacy is respected and protected at all times.
If we stop using their services, any of your data held by them will either be deleted or rendered anonymous.

The third parties we work with are:

IT companies who support our website and other business systems.
Operational companies such as delivery couriers.
Direct marketing companies who help us manage our electronic communications with you.
Banks and financial organisations.
Government and legal organisations.

Sharing your data with third parties for their own purposes:

We will only do this in very specific circumstances, for example:

For fraud management, we may share information about fraudulent or potentially fraudulent activity in our premises or systems. This may include sharing data about individuals with law enforcement bodies.
We may also be required to disclose your personal data to the police or other enforcement, regulatory or Government body, in your country of origin or elsewhere, upon a valid request to do so. These requests are assessed on a case-by-case basis and take the privacy of our customers into consideration.

DATA SECURITY

We know how much data security matters to all our customers; therefore, we will treat your data with the utmost care and take all appropriate steps to protect it.

Access to your personal data within all our systems is password-protected and access levels granted based on job role.
We regularly monitor our network and systems for possible vulnerabilities

DATA RETENTION

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 your personal data is required and whether we can achieve those purposes through other means, and the applicable legal requirements.

YOUR LEGAL RIGHTS

An overview of your different rights

You have the right to:

Request access to your personal data (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.
Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.
Object to processing of 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. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. 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 above), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, at the time of your request.
Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios: (a) if you want us to establish the data’s accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) 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 (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
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. 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.

If you wish to exercise any of the rights set out above, please contact Data Protection Officer, Star Refining (London) Ltd, 85 Hatton Garden, London, EC1N 8HP, or email london@starrefining.co.uk. To ask for your information to be amended, please contact us directly.

If we choose not to action your request, we will explain to you the reasons for our refusal.

NO FEE USUALLY REQUIRED

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.

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 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.

TIME LIMIT TO RESPOND

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 several requests. In this case, we will notify you and keep you updated.

CONTACTING THE REGULATOR

If you feel that your data has not been handled correctly, or you are unhappy with our response to any requests you have made to us regarding the use of your personal data, you have the right to lodge a complaint with the Information Commissioner’s Office.

You can contact them by calling 0303 123 1113.
Or go online to www.ico.org.uk/concerns (opens in a new window; please note we are not responsible for the content of external websites)

If you are based outside the UK, you have the right to lodge your complaint with the relevant data protection regulator in your country of residence.