Triolo Commercial Services (TCS), (“we“) are committed to protecting and respecting your privacy in accordance with the European General Data Protection Regulations.
For the purpose of the Data Protection Act 1998 (“the Act”) and this policy, the data controller is Triolo Commercial Services, whose registered offices are at Kemp House, 152-160 City Road, London EC1V 2NX
Information We May Collect From You
We may collect and process the following data about you:
- Information you give us. You may give us personal information about you by filling in forms on our site or by corresponding with us by telephone, e-mail or otherwise. The information you give us may include your name (including business name), address, e-mail address and phone number, financial and credit card information, personal description and photograph, information regarding your shipment such as the details and nature of the products being delivered, their source and their destination.
- Information we collect about you. With regard to each of your visits to our site we may automatically collect the following information:
- technical information, including the Internet protocol (IP) address used to connect your computer to the Internet, browser type and version, time zone setting, browser plug-in types and versions, operating system and platform;
- information about your visit, including the full Uniform Resource Locators (URL) clickstream to, through and from our site (including date and time); page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs), and methods used to browse away from the page and any phone number used to call us.
- Information we receive from other sources. We may receive information about you if you use any of the other websites we operate or the other services we provide. In this case we will have informed you when we collected that data that it may be shared internally and combined with data collected on this site. We are also working closely with third parties (including, for example, business partners, sub-contractors, payment and delivery services, advertising networks, analytics providers, search information providers, credit reference agencies) and may receive information about you from them.
The internet pages partly use so-called cookies. Cookies do not harm your computer and do not contain viruses. Cookies serve to make our offer more user-friendly, effective and secure. Cookies are small text files that are stored on your computer and stored by your browser.
Most of the cookies we use are so-called “session cookies”. They are automatically deleted after your visit. Other cookies remain stored on your device until you delete them. These cookies allow us to recognize your browser the next time you visit.
Uses Made Of the Information
We use information held about you in the following ways:
- Information you give to us. We will use this information:
- to carry out our obligations arising from any contracts entered into between you and us and to provide you with the information and services that you request from us;
- to provide you with information about other goods and services we offer that are similar to those that you have already purchased or enquired about;
- to notify you about changes to our services;
- to process any application for employment you might make to us;
- to ensure that content from our site is presented in the most effective manner for you and for your computer;
- to process any enquiry that you may submit to us via electronic means, including any online forms.
- Information we collect about you. We will use this information:
- to administer our site and for internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes;
- to improve our site to ensure that content is presented in the most effective manner for you and for your computer;
- to allow you to participate in any interactive features of our service;
- as part of our efforts to keep our site safe and secure;
- to measure or understand the effectiveness of advertising we serve to you and others, and to deliver relevant advertising to you;
- detect, prevent, investigate or remediate, crime, illegal or prohibited activities or to otherwise protect our legal rights (including liaison with regulators and law enforcement agencies for these purposes);
- to establish whether any of the services we may offer from time to time may be of interest to you.
- Information we may receive from other sources. We may combine this information with information you give to us and information we collect about you. We may use this information and the combined information for the purposes set out above (depending on the types of information we receive).
When performing direct marketing, Triolo Group will only use your name and email address and this information will only be shared with our network partners. Direct marketing will only be performed on the basis of legitimate interest and will be conducted by the use of segmentation by sector and customer status to ensure our messaging is relevant and of interest.
The personal data we collect will be used for the following purposes:
- Sending direct marketing regarding our services
- Tracking when emails have been opened, how often, and whether links have been clicked within the email (and also when unsubscribing)
- Initiating contact on the basis of tracking this information
- Sharing this information, when necessary, internally and with network members
- Law enforcement agencies so that they may prevent or detect crime or prosecute offenders;
- Regulators to meet Triolo Group’s legal and regulatory obligations;
- Government departments where reporting is mandatory under applicable law.
Our legal basis for processing the personal data:
- Consent (where granted)
- Legitimate Interest (where consent has not been granted nor refused)
- In order to perform our contractual obligations to you
Any legitimate interests pursued by us, or third parties, are as follows:
- A legitimate interest assessment has been completed on your data, and we believe that you have an interest in the service we are communicating
- Our segmentation process has highlighted your industry as one which can benefit from the service we are communicating to
- We will only process your data if we believe that the message we are communicating will be of interest to your organisation,
We will only collect, store and process the personal data we need to perform these direct marketing actions:
- Email address
If you send us enquiries via the contact form, your details from the enquiry form, including the contact details you provided there, will be stored in order to process the request and in case of follow-up questions. We will not share this information without your consent.
The processing of the data entered into the contact form is therefore exclusively based on your consent (Art. 6 (1) lit. DSGVO). You can revoke this consent at any time. An informal message by e-mail to us is sufficient. The legality of the data processing operations carried out until the revocation remains unaffected by the revocation.
The information you provide in the contact form will remain with us until you ask us to delete it, revoke your consent to storage or delete the purpose for data storage (for example, after your request has been processed). Mandatory statutory provisions – especially retention periods – remain unaffected.
Applications For Employment
We collect and process the personal data of applicants for the purpose of processing the application process. The processing can also be done electronically. This is especially the case if an applicant submits the relevant application documents to us electronically, for example by e-mail or via a web form located on the website.
If a contract of employment results from the application, the transmitted data will be stored for the purpose of executing the employment relationship in compliance with the statutory provisions.
If the application does not result in a contract of employment, the application documents will be deleted six months after the appointment has been completed, provided that deletion does not prejudice any other legitimate interests of the controller. Other legitimate interest in this sense, for example, a burden of proof in a procedure under the General Equal Treatment Act (AGG). After approval by the applicant, the data can also be stored longer.
Social Media Tools
You can change your privacy settings on Twitter in the account settings at: https://twitter.com/account/settings.
Our website uses features of the LinkedIn network. Providers are LinkedIn Corporation, 2029 Stierlin Court, Mountain View, CA 94043, United States. Each time you visit one of our pages that contains LinkedIn features, it will connect to LinkedIn servers. LinkedIn is informed that you have visited our website with your IP address. If you click LinkedIn’s “Recommend Button” and are logged in to your LinkedIn account, LinkedIn will be able to associate your visit to our website with you and your user account. We point out that we as the provider of the pages have no knowledge of the content of the transmitted data and their use by LinkedIn. For more information, see the LinkedIn privacy statement at: https://www.linkedin.com/legal/privacy-policy
On our pages plugins of the social network Facebook, provider Facebook Inc., 1 Hacker Way, Menlo Park, California 94025, USA, are integrated. The Facebook plugins can be recognized by the Facebook logo or the “Like-Button” (“Like”) on our site. An overview of the Facebook plugins can be found here: https://developers.facebook.com/docs/plugins/.
If you do not wish Facebook to associate your visit to our pages with your Facebook user account, please log out of your Facebook user account.
Our website uses plugins from the Google-powered YouTube page. Site operator is YouTube, LLC, 901 Cherry Ave., San Bruno, CA 94066, USA.
When you visit one of our YouTube plug-in-enabled sites, you will be connected to the servers of YouTube. It tells the YouTube server which of our pages you’ve visited.
If you’re logged into your YouTube account, YouTube will allow you to associate your browsing behaviour directly with your personal profile. You can prevent this by logging out of your YouTube account.
The use of YouTube is in the interest of an attractive presentation of our online offers. This constitutes a legitimate interest within the meaning of Art. 6 para. 1 lit. f DSGVO.
This website uses the “Google Analytics” service provided by Google Inc. (1600 Amphitheater Parkway Mountain View, CA 94043, USA) to analyse users’ website usage. The service uses “cookies” – text files stored on your device. The information collected by the cookies is usually sent to a Google server in the US and stored there. On this website accesses the IP anonymization. The IP address of users is shortened within the member states of the EU and the European Economic Area. This reduction eliminates the personal reference of your IP address. Under the terms of the agreement, which website operators have entered into with Google Inc., they use the information collected to compile an evaluation of website activity and site activity, and provide Internet-related services.
You have the option to prevent the storage of cookies on your device by making the appropriate settings in your browser. There is no guarantee that you will be able to access all features of this website without restriction if your browser does not allow cookies.
Furthermore, you can use a browser plug-in to prevent the information collected by cookies (including your IP address) from being sent to Google Inc. and used by Google Inc.
Here’s more information on Google Inc’s data usage: https://support.google.com/analytics/answer/6004245?hl=en
This site uses the mapping service Google Maps via an API. Provider is Google Inc., 1600
Amphitheater Parkway, Mountain View, CA 94043, USA.
To use the features of Google Maps, it is necessary to save your IP address. This information is usually transmitted to and stored on a Google server in the United States. The provider of this site has no influence on this data transfer.
The use of Google Maps is in the interest of an attractive presentation of our online offers and an easy findability of the places we have indicated on the website. This constitutes a legitimate interest within the meaning of Art. 6 para. 1 lit. f DSGVO.
Disclosure of Your Information
We may share your personal information with your consent with any member of our group, which means our subsidiaries, any holding company of us and its subsidiaries, in each case as defined in section 1159 of the UK Companies Act 2006.
We may share your information with selected third parties including:
- Business partners, suppliers and sub-contractors for the performance of any contract we enter into with them or you;
- Analytics and search engine providers that assist us in the improvement and optimisation of our site;
- Credit reference agencies for the purpose of assessing your credit score where this is a condition of us entering into a contract with you.
We may disclose your personal information to third parties:
- In the event that we sell any of our group’s business or assets, in which case we may disclose your personal data to the prospective buyer of such business or assets.
- If any company in our group is, or substantially all of its assets are, acquired by a third party, in which case personal data gathered from you may be one of the transferred assets.
Where We Store Your Personal Data
All information you provide to us is stored on our secure servers. Any payment transactions will be encrypted using SSL technology.
Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted to our site; any transmission is at your own risk. Once we have received your information, we will use appropriate procedures and security features to try to prevent unauthorised access.
You have the right to ask us not to process your personal data for marketing purposes. We will usually inform you (before collecting your data) if we intend to use your data 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 data. You can also exercise the right at any time by contacting us at email@example.com
Our site may, from time to time, contain links to and from the websites of third parties. 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 or how such third parties may process your personal information. Please check these policies before you submit any personal data to these websites.
Protection of Your Data
If you use this website, various personal data will be collected. Personal information is information that personally identifies you.
Please note that data transmission over the Internet (for example, when communicating via e-mail) may have security vulnerabilities. A complete protection of the data from access by third parties is not possible.
Revocation of Your Consent to Data Processing
Many data processing operations are only possible with your express consent. You can revoke an existing consent at any time. Please email this request to firstname.lastname@example.org – an informal message to us is sufficient. The legality of the data processing carried out until the revocation remains unaffected by the revocation.
Right to Data Portability
You have the right to have data, which we process automatically on the basis of your consent or in fulfilment of a contract, handed out to you or to a third party in a standard, machine-readable format. If you require the direct transfer of data to another person in charge, this will only be done to the extent technically feasible.
Information, Blocking, Deletion
You have the right to free information on your stored personal data, their origin and recipient and the purpose of the data processing and, if necessary, a right to rectification, blocking or deletion of this data. Please direct any such request to email@example.com
Any changes we may make to this policy in the future will be posted on this page. Please check back frequently to see any updates or changes to this policy.
Updated 22nd May 2018