Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data). We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:
- Identity Data includes first name, last name, username or similar identifier, title.
- Contact Data includes billing address, delivery address, email address and telephone numbers.
- Profile Data includes your username and password, purchases or orders made by you, your interests, preferences, feedback and survey responses.
- Technical Data 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 this website.
- Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.
In general, a person can browse our websites without giving TXO any personal information. Some parts of our website may require a person or organisation to be registered with us, for example, to be able to login and use our i-TRAC asset management portal.
As part of the registration process, we ask for a creation of an account where we collect additional personal data. We use your personal data for several purposes which include: to tell individuals or organisations about products and services if requested; to fulfil requests; to contact an individual if we need to obtain or provide additional information; to verify the accuracy of our records; to contact an individual regarding customer satisfaction surveys. Further information about how we use your personal data is set out below.
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.
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 Identity Data and Contact Data by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you: apply for our products or services; create an account on our website; subscribe to our service or publications; request marketing to be sent to you; promotion or survey; give us feedback or contact us.
- Third parties or publicly available sources. We will receive personal data about you from various third parties and public sources as set out below: Technical Data from the following parties: (a) analytics providers such as Google based outside the UK;
From time to time, we may offer you the opportunity to opt in to receive TXO newsletters, mailings or other promotions. An individual or organisation will be provided with an opportunity to indicate whether they wish to participate in these activities in accordance with relevant notice and consent requirements under applicable local laws.
How information collected is used
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 as set out in the table below.
Generally, we do not rely on consent as a legal basis for processing your personal data although we will get your consent before sending third party direct marketing communications to you via email or text message. You have the right to withdraw consent to marketing at any time by contacting us.
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.
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 including basis of legitimate interest|
|To register you as a new customer||(a) Identity (b) Contact||(a) Performance of a contract with you (b) Necessary for our legitimate interests|
|To process and deliver your orders for goods and services including: (a) providing you with a quote; (b) emailing you with order confirmation and updates on the status of your order;||(a) Identity (b) Contact (c) Financial (d) Transaction||(a) Performance of a contract with you (b) Necessary for our legitimate interests (to recover debts due to us)|
|To administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)||(a) Identity (b) Contact (c) Technical||(a) 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) (b) Necessary to comply with a legal obligation|
|To deliver relevant website content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you||(a) Identity (b) Contact (c) Profile (d) Usage (e) Marketing and Communications (f) Technical||Necessary for our legitimate interests (to study how customers use our products/services, to develop them, to grow our business and to inform our marketing strategy)|
|To use data analytics to improve our website, products/services, marketing, customer relationships and experiences||(a) Technical (b) Usage||Necessary for our legitimate interests (to define types of customers for our products and services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy)|
|To make suggestions and recommendations to you about goods or services that may be of interest to you and to tell you about our latest events and promotions.||(a) Identity (b) Contact (c) Technical (d) Usage (e) Profile (f) Marketing and Communications||Necessary for our legitimate interests (to develop our products/services and grow our business)|
Sharing information with third parties
We may share personal information with our trusted third-party service providers to help us manage and operate our websites, such as processing orders, performing statistical analysis, sending emails or postal mail, providing customer support and performing other important services.
Although these partners may not be affiliated with us, they are required to maintain the confidentiality of information and are not authorised to discuss, disclose or make any use of personal information except as necessary to provide such services.
If an alternative payment process is required, the personal and financial information needed to process your application or purchase will be sent directly to each provider. The companies that administer these programs are independent of TXO and have their own privacy policies.
Personal data will be held by us for so long as is necessary for the purposes for which it was collected, for the settlement of any potential disputes which may be raised or otherwise in accordance with legal requirements.
Unsubscribing or changing your information
We want to communicate with individuals only if they want to hear from us. Individuals have the right to request confirmation of what information we hold about them and to correct, update or change such information. If they would prefer not to receive information from us or would like to correct, update or change personal information or preferences, they are asked to follow the instructions below. It is noted that objecting to our holding and using information may prevent us from providing some products or services.
Requests to be removed from our communications might take up to three (3) business days to become effective (regular mailing lists may take up to 1 week). Individuals may receive emails or regular mail that is already in process even though they may have been removed. Even if removed from a list, if an order is placed online, we will send an email to confirm the order and may need to contact the client by phone, email or regular mail if we have questions about their order.
- You can unsubscribe, at any time, from our communications via the link in the emails or by emailing [email protected].
- Alternatively requests can be made in writing to: TXO Systems Ltd, Attn: Marketing/Privacy, TXO Systems Ltd, Unit 3, Newhouse Farm Industrial Estate, Chepstow, NP16 6UP, UK.
- Requests must be sure to include the full name of the individual, the username and account email address.
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.
Website links to other sites
This website 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 encourage individuals to review the privacy policies of any websites they choose to link to from our websites so that they understand how those websites collect, use and share their personal information.
TXO is not responsible for the privacy policies or other content on third-party websites.
Location and transfers of information
Information may be held or accessed by TXO entities in Europe, the United States, Brazil and Australia in the course of providing our websites, products and services to individuals or organisations.
As previously stated, we may use third-party service providers when performing our services. These third-party service providers may be located in countries in Europe, the United States, Brazil or Australia.
We share your personal data with the TXO entities and third party service providers in Europe, the United States and Brazil and Australia, this means that we will transfer your personal data outside of the UK. In terms of any such transfers, we ensure that personal information is transferred with relevant and appropriate contractual and other safeguards in place to ensure that it is kept secure and handled in accordance with relevant privacy laws, this includes but is not limited to ensuring that:
- we will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data; and/or
- where we use certain service providers, we may use specific contracts approved for use in the UK which give personal data the same protection it has in the UK.
Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the UK.
Information security measures
We use the latest encryption technology (Secure Sockets Layer or SSL) to secure personal information. The personal information provided when purchases are made is encrypted (or coded) using a secure server for maximum security. This coding makes it extremely difficult for anyone to reach personal information as it moves through our system.
To use our websites, you must use an SSL-enabled browser such as Firefox or Chrome. This protects the confidentiality of personal information while it is transmitted over the Internet.
We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.
We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.
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, regulatory, tax, accounting or other requirements.
What are your rights?
Under the GDPR (General Data Protection Regulation), you have rights under data protection laws in relation to your personal data. If you’d like to learn more about your rights, please see the website of the Information Commissioner’s Office.
You generally have the following rights, which you can usually exercise free of charge:
- Request access to your personal data.
- Request correction of your personal data.
- Request erasure of your personal data.
- Object to processing of your personal data.
- Request restriction of processing your personal data.
- Request personal data in an accessible and machine-readable format.
- Right not to be subject to decisions without human involvement.
If you have provided us with a consent to use your personal data, you have a right to withdraw that consent easily at any time. Withdrawing a consent will not affect the lawfulness of our use of your personal data in reliance on that consent before it was withdrawn.
If you wish to exercise any of the rights set out above or have any other queries or concerns, please don’t hesitate to contact us at [email protected]
If you believe that any information we are holding on you is incorrect or incomplete, please contact us as soon as possible. We will promptly correct any information found to be incorrect.
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 could refuse to comply with your request in these circumstances.
We try to respond to all legitimate requests within one month. Occasionally it could 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.
You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK regulator for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.
For questions, concerns or a copy of your personal information held by us (reasonable photocopying fees may apply) please contact us at: TXO Systems Ltd Attn: Marketing/Privacy Unit 3, Newhouse Farm Industrial Estate Chepstow NP16 6UP, UK Email: [email protected]
* Affiliates include TXO Systems Inc; TXO Systems Pty Ltd; MMX Communications Services Ltd and other companies that may be added from time to time and that are controlled by or under common control with one of the foregoing that are engaged or involved in the operation of our websites.
Policy version: 3
Last reviewed: Nov-2022