Rowan International Limited, is a company registered in England and referred to as “Rowan”, “we”, “our” or “us” in this policy.
Personal data relates to a living individual who can be identified from that data. Identification can be the information alone or in conjunction with any other information in the data controller’s possession or likely to come into such possession. The processing of personal data is governed by the General Data Protection Regulation 2016/679 GDPR” and the Data Protection Act 2018.
The owner of that personal data is referenced in the legislation as the Data Subject. Rowan are the Data Controllers and determine how your personal data is processed and for what purposes. Rowan comply with their obligations under GDPR by keeping personal data up to date; by storing and destroying it securely; by not collecting or retaining excessive amounts of data; by protecting personal data from loss, misuse, unauthorised access and disclosure and by ensuring that appropriate technical measures are in place to protect personal data.
We process the data we collect based on our legitimate interests in selling and securing our products, running our business and direct marketing our products and services. We also collect data to comply with legal and compliance obligations, maintain accurate business records and generally to enable the proper administration of our business.
How we use your data
Under the GDPR, we must always have a lawful basis for using personal data. This may be because the data is necessary for our performance of a contract with you, or because it is in our legitimate business interests to use it. Your personal data may be used for one of the following purposes:
- Providing and managing your account
- The receipt and supply of products and services. Your personal details are required in order for us to enter into a contract with you
- Personalising and tailoring our products and services for you
- Communicating with you. This may include responding to emails or calls from you
- Supplying you with information by email about our products and services
We will also hold customer and prospective customer data for marketing and promotional activities. As our main area of work is providing FMCG to both retail and wholesale channels we will use your data as follows to help us achieve this:
- Storing your details and updating them when necessary on our database, so that we can contact you in relation to the sale and purchase of stock
- Keeping records of our conversations and meetings, so that we can provide targeted services to you
- Processing your data for targeting appropriate marketing campaigns
As already stated, we may process the data of our customers and prospective customers for these purposes if we deem this to be necessary for our legitimate interests. Article 6(1)(f) of the GDPR provides that we can process your data where it “is necessary for the purposes of the legitimate interests pursued by us, except where such interests are overridden by the interests or fundamental rights or freedoms of you which require protection of personal data.”
What personal data do we collect?
We may collect the following information:
- Name and job title.
- Contact information including email address, telephone number and postal address.
- Your correspondence and communications with Rowan.
- This list is not exhaustive and, in specific circumstances, we may need to collect additional data as set out in this policy from other third Parties who have your consent or from publicly available sources.
- Publicly available personal data, includes any you have shared via a public platform such as Twitter, LinkedIn or Companies House.
- Our website and services are for businesses and not intended for use by children and we do not knowingly collect data relating to children.
- CCTV footage if you attend our premises.
We are committed to ensuring that your information is secure. In order to prevent unauthorized access or disclosure, we have put in place suitable physical, electronic and managerial procedures to safeguard and secure the information we collect.
Sharing Data with Third Parties
We will only disclose information about you to third parties if we are legally obliged to do so or to fulfil our contractual duties to you, for instance we may need to pass on certain information to an external provider to enable the delivery of goods and services.
Rowan only allows the service providers to handle your personal data when we have confirmed that they apply appropriate data protection and security controls. Aside from these service providers, Rowan will not disclose your personal data to third parties.
Retention of Data
Personal data will not be stored or held for more than six years plus the current year unless there is a specific reason for doing so. The definition of current will vary according to the personal data.
- The current plus six years’ rule is the usual maximum period of retention. If there is no need to keep personal data longer than that period it should be disposed of securely before the six years limit. Exemptions from the rule of 6 years’ retentions are the following categories:
- Contractors Records will be retained for seven years plus the current year;
- Financial Records will be retained for ten years plus the current year;
- Data Protection Requests are retained for seven years plus the current year;
- Personnel Records are retained for ten years plus the current year;
- Health and Safety Records are retained for ten years plus the current year;
Once the above period of each data category has expired, Rowan International Ltd has the right to erase or destroy the personal data without any impact.
Controlling your personal information
You may request details of personal information that we hold about you and/or you may choose to restrict the collection or use of your personal information by contacting us in the following ways:
Telephone: 01268 592000
Write to: Data Protection Officer, Rowan International Ltd, Endeavour House, Endeavour Drive, Basildon, Essex, SS14 3WF
We accept the following forms of ID when we receive a Subject Access Request:
A Photo Driving License, Valid Passport, Proof of Age Card or Birth Certificate.
A cookie is a small file which asks permission to be placed on your computer's hard drive. Once you agree, the file is added and the cookie helps analyze web traffic or lets you know when you visit a particular site. Cookies allow web applications to respond to you as an individual. The web application can tailor its operations to your needs, likes and dislikes by gathering and remembering information about your preferences.
We use traffic log cookies to identify which pages are being used. This helps us analyze data about web page traffic and improve our website in order to tailor it to customer needs. We only use this information for statistical analysis purposes and then the data is removed from the system.
Overall, cookies help us provide you with a better website, by enabling us to monitor which pages you find useful and which you do not. A cookie in no way gives us access to your computer or any information about you, other than the data you choose to share with us.
You can choose to accept or decline cookies. Most web browsers automatically accept cookies, but you can usually modify your browser setting to decline cookies if you prefer. This may prevent you from taking full advantage of the website.
Links to other websites
Our website may contain links to other websites of interest. However, once you have used these links to leave our site, you should note that we do not have any control over that other website. Therefore, we cannot be responsible for the protection and privacy of any information which you provide whilst visiting such sites and such sites are not governed by this privacy statement. You should exercise caution and look at the privacy statement applicable to the website in question.
The information we hold regarding our employees may include disabilities, medical records, origin, religion, date of birth, nationality, bank account number, social security number, personal tax number, criminal record, credit history check, driving license and checks, family details, disciplinary records, working visa, photos, visual identifiers, performance plan progress, or gender identifiers.
Where necessary we may keep information relating to your health, which could include reasons for absence and reports and notes. This information will be used to comply with our health and safety and occupational health obligations – to consider how your health affects your ability to do your job and whether any adjustments to your job might be appropriate. Where we may process special categories of information relating to your racial or ethnic origin, political opinions, religious and philosophical beliefs, criminal record, credit history check, family details, disciplinary records, working visa, photo, visual identifiers, performance plan progress, gender identifiers etc. we will always obtain your explicit consent to those activities, unless this is not required by law or the information is required to protect your health in an emergency.
Any changes we may make to our Privacy Statement in the future will be posted to our website.