1. Introduction
1.1 We are committed to safeguarding the privacy of our website visitors and ourcustomers.
1.2 This policy applies where we are acting as a data controller with respect tothe personal data of our website visitors and customers; in other words, wherewe determine the purposes and means of the processing of that personal data.
1.3 In this policy, "we", "us" and "our" refer toOverseas Trading Ltd. For more information about us, see Section 13.
2. Credit
2.1 This document was created using a template from SEQ Legal (https://seqlegal.com).
3. How we use your personal data
3.1 In this Section 3 we have set out:
(a) the general categories of personal data that we may process;
(b) the purposes for which we may process personal data; and
(c) the legal bases of the processing.
3.2 We may process data about your use of our website and services] ("usage data"). The usage data mayinclude your IP address, geographical location, browser type and version,operating system, referral source, length of visit, page views and websitenavigation paths, as well as information about the timing, frequency andpattern of your service use. The source of the usage data is our analyticstracking system. This usage data may be processed for the purposes of analysingthe use of the website and services. The legal basis for this processing is ourlegitimate interests, namely monitoring and improving our website and services.
3.3 We may process your account data ("accountdata"). The account data may include your Company Name, CompanyRegistration Number, Company VAT number. Your title, name, address, telephonenumber and email address. The source of the account data is you or youremployer. The account data may be processed for the purposes of operating ourwebsite, providing our services, ensuring the security of our website andservices, maintaining back-ups of our databases and communicating with you. Thelegal basis for this processing is our legitimate interests, namely the properadministration of our website and business and the performance of a contract betweenyou and us and/or taking steps, at your request, to enter into such a contract.
3.4 We may process your information included in your personal profile on ourwebsite ("profile data"). Theprofile data may include your title, name, address, telephone number, emailaddress. The profile data may be processed for the purposes of enabling andmonitoring your use of our website and services. The legal basis for thisprocessing is our legitimate interests, namely the proper administration of ourwebsite and business and the performance of a contract between you and usand/or taking steps, at you request, to enter into such a contract.
3.5 We may process information relating to our customer relationships, includingcustomer contact information ("customerrelationship data"). The customer relationship data may include yourname, your employer, your job title or role, your contact details, andinformation contained in communications between us and you or your employer.The source of the customer relationship data is you or your employer. Thecustomer relationship data may be processed for the purposes of managing ourrelationships with customers, communicating with customers, keeping records ofthose communications and promoting our products and services to customers. Thelegal basis for this processing is our legitimate interests, namely the propermanagement of our customer relationships.
3.6 We may process information relating to transactions, including purchases ofgoods and services that you enter into with us and/or through our website ("transaction data"). The transactiondata may include your contact details, and the transaction details. Thetransaction data may be processed for the purpose of supplying the purchasedgoods and services and keeping proper records of those transactions. The legalbasis for this processing is the performance of a contract between you and usand/or taking steps, at your request, to enter into such a contract and ourlegitimate interests, namely the proper administration of our website andbusiness.
3.7 We may process information contained in or relating to any communication thatyou send to us ("correspondence data").The correspondence data may include the communication content and metadataassociated with the communication. The correspondence data may be processed forthe purposes of communicating with you and record-keeping. The legal basis forthis processing is our legitimate interests, namely the proper administrationof our website and business and communications with users.
3.8 We may process any of your personal data identified in this policy wherenecessary for the establishment, exercise or defence of legal claims, whetherin court proceedings or in an administrative or out-of-court procedure. Thelegal basis for this processing is our legitimate interests, namely theprotection and assertion of our legal rights, your legal rights and the legalrights of others.
3.9 We may process any of your personal data identified in this policy wherenecessary for the purposes of obtaining or maintaining insurance coverage,managing risks, or obtaining professional advice. The legal basis for thisprocessing is our legitimate interests, namely the proper protection of ourbusiness against risks.
3.10 Inaddition to the specific purposes for which we may process your personal dataset out in this Section 3, we may also process any of your personal data wheresuch processing is necessary for compliance with a legal obligation to which weare subject, or in order to protect your vital interests or the vital interestsof another natural person.
3.11 Pleasedo not supply any other person's personal data to us, unless we prompt you todo so.
4. Providing your personal data to others
4.1 We may disclose your personal data to our insurers and/or professional advisersinsofar as reasonably necessary for the purposes of obtaining or maintaininginsurance coverage, managing risks, obtaining professional advice, or theestablishment, exercise or defence of legal claims, whether in courtproceedings or in an administrative or out-of-court procedure.
4.2 We may disclose your personal data to our suppliers or subcontractors insofaras reasonably necessary for the proper administration of our website andbusiness.
4.3 Financial transactions relating to our website and services may be handled byour payment services providers. We will share transaction data with our paymentservices providers only to the extent necessary for the purposes of processingyour payments, refunding such payments and dealing with complaints and queriesrelating to such payments and refunds.
4.4 In addition to the specific disclosures of personal data set out in thisSection 4, we may disclose your personal data where such disclosure isnecessary for compliance with a legal obligation to which we are subject, or inorder to protect your vital interests or the vital interests of another naturalperson. We may also disclose your personal data where such disclosure isnecessary for the establishment, exercise or defence of legal claims, whetherin court proceedings or in an administrative or out-of-court procedure.
5. International transfers of your personal data
5.1 In this Section 5, we provide information about the circumstances in which yourpersonal data may be transferred to countries outside the European Economic Area(EEA).
5.2 We have offices and facilities in China. The European Commission has made an"adequacy decision" with respect to the data protection laws ofChina. Transfers to China will be protected by appropriate safeguards, namelythe use of standard data protection clauses adopted or approved by the EuropeanCommission.
6. Retaining and deleting personal data
6.1 This Section 6 sets out our data retention policies and procedure, which aredesigned to help ensure that we comply with our legal obligations in relationto the retention and deletion of personal data.
6.2 Personal data that we process for any purpose or purposes shall not be kept forlonger than is necessary for that purpose or those purposes.
6.3 We will retain your personal data as follows:
(a) personal data will be retained for aminimum period of three months and for a maximum period of five years. As anongoing customer we will work with you to ensure that your data is updatedwhenever necessary in order to maintain proper administration of our websiteand business and the performance of a contract between you and us.
6.4 Notwithstanding the other provisions of this Section 6, we may retain yourpersonal data where such retention is necessary for compliance with a legalobligation to which we are subject, or in order to protect your vital interestsor the vital interests of another natural person.
7. Amendments
7.1 We may update this policy from time to time by publishing a new version on ourwebsite.
7.2 You should check this page occasionally to ensure you are happy with anychanges to this policy.
8. Your rights
8.1 In this Section 8, we have summarised the rights that you have under dataprotection law. Some of the rights are complex, and not all of the details havebeen included in our summaries. Accordingly, you should read the relevant lawsand guidance from the regulatory authorities for a full explanation of theserights.
8.2 Your principal rights under data protection law are:
(a) the right to access;
(b) the right to rectification;
(c) the right to erasure;
(d) the right to restrict processing;
(e) the right to object to processing;
(f) the right to data portability;
(g) the right to complain to a supervisory authority; and
(h) the right to withdraw consent.
8.3 You have the right to confirmation as to whether or not we process yourpersonal data and, where we do, access to the personal data, together withcertain additional information. That additional information includes details ofthe purposes of the processing, the categories of personal data concerned andthe recipients of the personal data. Providing the rights and freedoms ofothers are not affected, we will supply to you a copy of your personal data.The first copy will be provided free of charge, but additional copies may besubject to a reasonable fee
8.4 You have the right to have any inaccurate personal data about you rectifiedand, taking into account the purposes of the processing, to have any incompletepersonal data about you completed.
8.5 In some circumstances you have the right to the erasure of your personal datawithout undue delay. Those circumstances include the personal data are no longernecessary in relation to the purposes for which they were collected orotherwise processed; you withdraw consent to consent-based processing; youobject to the processing under certain rules of applicable data protection law;the processing is for direct marketing purposes; and the personal data havebeen unlawfully processed. However, there are exclusions of the right toerasure. The general exclusions include where processing is necessary: forcompliance with a legal obligation; or for the establishment, exercise ordefence of legal claims.
8.6 In some circumstances you have the right to restrict the processing of yourpersonal data. Those circumstances are: you contest the accuracy of thepersonal data; processing is unlawful but you oppose erasure; we no longer needthe personal data for the purposes of our processing, but you require personaldata for the establishment, exercise or defence of legal claims; and you haveobjected to processing, pending the verification of that objection. Whereprocessing has been restricted on this basis, we may continue to store yourpersonal data. However, we will only otherwise process it: with your consent;for the establishment, exercise or defence of legal claims; for the protectionof the rights of another natural or legal person; or for reasons of importantpublic interest.
8.7 You have the right to object to our processing of your personal data on groundsrelating to your particular situation, but only to the extent that the legalbasis for the processing is that the processing is necessary for: theperformance of a task carried out in the public interest or in the exercise ofany official authority vested in us; or the purposes of the legitimateinterests pursued by us or by a third party. If you make such an objection, wewill cease to process the personal information unless we can demonstratecompelling legitimate grounds for the processing which override your interests,rights and freedoms, or the processing is for the establishment, exercise ordefence of legal claims.
8.8 You have the right to object to our processing of your personal data for directmarketing purposes (including profiling for direct marketing purposes). If youmake such an objection, we will cease to process your personal data for this purpose.
8.9 If you consider that our processing of your personal information infringes dataprotection laws, you have a legal right to lodge a complaint with a supervisoryauthority responsible for data protection. You may do so in the EU member stateof your habitual residence, your place of work or the place of the allegedinfringement.
8.10 To theextent that the legal basis for our processing of your personal information isconsent, you have the right to withdraw that consent at any time. Withdrawal willnot affect the lawfulness of processing before the withdrawal.
8.11 Youmay exercise any of your rights in relation to your personal data by writtennotice to us, in addition to the other methods specified in this Section 8].
9. About cookies
9.1 A cookie is a file containing an identifier (a string of letters and numbers)that is sent by a web server to a web browser and is stored by the browser. Theidentifier is then sent back to the server each time the browser requests apage from the server.
10. Cookies that we use
10.1 We usecookies for the following purposes:
(a) authentication - we use cookies to identify you when you visit our website andas you navigate our website
(b) status - we use cookies to help us to determine if you are logged into ourwebsite.
(c) personalisation - we use cookies to store information about your preferencesand to personalise the website for you.
(d) security - we use cookies as an element of the security measures used toprotect user accounts, including preventing fraudulent use of logincredentials, and to protect our website and services generally.
(f) analysis - we use cookies to help us to analyse the use and performance of ourwebsite and services.
11. Cookies used by our service providers
11.1 Ourservice providers may use cookies and those cookies may be stored on yourcomputer when you visit our website.
11.2 We useGoogle Translate to provide a translation service to our users. This serviceuses cookies.
12. Our details
12.1 Thiswebsite is owned and operated by Overseas Trading Ltd
12.2 We areregistered in England and Wales under registration number 4442532, and our registeredoffice is at; OTL House, Methley Road, Castleford, West Yorkshire, WF10 1PA
12.3 Ourprincipal place of business is at;
OTL House, Methley Road, Castleford, West Yorkshire, WF10 1PA
12.4 Youcan contact us:
(a) by post, to above address
(b) using our website contact form;
(c) by telephone, on the contact number published on our website
(d) by email, using the email address published on our website