P&O Ferrymasters is one of the leading European providers of tailor-made transportation and logistics services. We are registered in UK with company number NI004115 and registered office at 2a Redlands Crescent, Port of Larne Business Park, Redlands Crescent, LARNE, BT40 1FF [the “Company” or “we” or “us”]. We are committed to protecting and respecting the personal data of all those whose data we handle in connection with the services we provide.
This policy provides information about how and why personal data is collected from the websites www.poferrymasters.com and www.pofm.com [“Our Websites”], email via Contact Us, any other online services, letters or telephone calls. It also explains how you can exercise your rights and how you can contact us if you have any concerns or questions about data protection.
For the purpose of the Data Protection Act 2018 (the "Act") and the General Data Protection Regulation (Regulation [EU] 2016/679 of the European Parliament and of the Council) (the “GDPR”), P&O Ferrymasters is the controller, and determines the purposes and means of processing of your personal data.
We have appointed a Privacy Officer who is responsible for helping us to comply with our legal obligations set out in the Act and the GDPR. The Privacy Officer monitors our data protection compliance and provides advice and guidance as to how we can improve our data handling practices. The contact details of our Privacy Officer are:
Information we collect from or about you
We collect and process the following types of personal data:
- Personal identifiers such as name, address, company, position, country, email, industry sector which you provide to us through our enquiry or contact forms or if you correspond with us via email and which we use: a) to fulfil any request you make (e.g. submitting a query on Our Websites, subscribing to a communications service, fulfilling requests for information etc.); b) to create a database of people who have expressed interest in our companies, products or services; and c) to allow you to participate in any interactive features of our service, when you choose to do so.
- Feedback and opinions which you provide to us through our enquiry or contact forms is processed to allow us to answer queries and complaints you may have and to help us evaluate the quality and consistency of our services.
- Usage data: details of your visits to Our Websites including your information about your visit, including the full Uniform Resource Locators (URL), clickstream to, through and from Our Websites (including date and time), products or services you viewed or searched for, page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs), methods used to browse away from the page and any phone number used to call our customer service number which we collect from your browser to enable us to monitor the performance and relevance of Our Websites, to ensure that content from Our Websites is presented in the most effective manner for you and for your computer, and to keep Our Websites safe and secure. The source of usage data is Google Analytics.
- Details of any correspondence with you by email, letter or telephone.
- Your marketing preferences so that we know whether and how we should contact you.
- Open and clickthrough information which measures how you interact with any emails we may send to you.
Purposes of Processing (how we use your personal data)
Most of the personal data we process is used for the following purposes:
- To service any enquiry you may submit to us (as a prospective customer).
- To perform a contract to provide you with services (as a customer).
- To enter into a contract to purchase goods or services from you (as a supplier).
We use the information we collect to create profiles and to segment our database of customers and prospective customers for analytical and direct marketing purposes including sending marketing and promotional materials. We may combine information we obtain from you with information from other sources to improve our business analysis and customer understanding.
We do not perform any profiling or automated decision making as defined in the Act and the GDPR.
We may undertake additional data processing activities but will ensure they are compatible with the purposes above.
If we choose to process your personal data for any purpose incompatible with the purposes above, we will provide you with appropriate information at the point where you come across those additional purposes and prior to commencing any such additional processing activities.
Legal basis for Processing
The legal bases for processing personal data described above are:
- Performance of a contract to supply you with our services or to purchase goods or services from you;
- Our legitimate interests of seeking to promote, develop and grow our businesses and to provide excellent customer service;
- Compliance with a legal or regulatory obligation;
- Consent for direct marketing.
Use of Processors
The table below indicates organisations or categories of organisations we employ to provide high quality specialist services to us. We may disclose your personal data to these processors but they are bound by a legal contract to confidentiality, a guarantee of the security of processing and compliance with data protection legislation. In other words we insist that they look after your personal data as carefully as we do.
|Organisation or category of organisation||Purpose||Location|
|Email broadcaster (MailChimp)||To fulfil our CRM and email programme.||United States of America*|
*United States of America The European Union has not endorsed the privacy laws of the United States but has approved a framework for the transfer of personal data called the EU:US Privacy Shield under which MailChimp has a valid certificate enabling us to lawfully transfer your personal data to the MailChimp email platform. This arrangement will remain in force after the United Kingdom leaves the European Union. You may review MailChimp’s Privacy Shield certificate here (www.privacyshield.gov).
If it is appropriate to have your enquiry addressed by one of our companies in the European Union, Turkey or Ukraine, we may share your personal data with another company within the POFM group. These companies have offices in UK, France, Republic of Ireland, Belgium, Netherlands, Germany, Spain, Italy, Rumania, Poland, Hungary, Ukraine and Turkey. We undertake such data sharing on the lawful basis of our legitimate interests to promote our products and services.
We may also disclose your personal data to other third parties from time to time:
- If we are under a duty to disclose or share your personal data to comply with any legal obligation;
- To protect the rights, property or safety of our company, our customers or others.
As described above we may transfer your personal data to UK, France, Republic of Ireland, Belgium, Netherlands, Germany, Spain, Italy, Rumania, Poland, Hungary, Ukraine or Turkey, but only ever within the P&O Ferrymasters group of companies under an intra-group agreement for data transfers of personal data.
We do not transfer personal data to any other organisations outside of the United Kingdom and the European Economic Area other than those described above.
We shall not keep your personal data for longer than is necessary for the purpose for which we process it.
We shall retain your personal data as follows:
|Type of Personal Data||Retention period|
|Personal identifiers such as name, address, company, position, country, email, industry sector which you provide to us through our enquiry or contact forms or if you correspond with us via email.||6 years after your company ceases to be our customer or supplier|
|Feedback and opinions which you provide to us through our enquiry or contact forms.||6 years after your company ceases to be our customer or supplier|
|Usage data: details of your visits to Our Websites including your information about your visit.||6 years after your company ceases to be our customer or supplier|
|Details of any correspondence||10 years after your company ceases to be our customer or supplier|
Notwithstanding the above we may retain your data where such retention is necessary for compliance with a legal obligation.
Data protection law grants you certain rights (‘information rights’) which provide you with:
|Right of access||You have the right to obtain confirmation from us as to whether or not personal data concerning you are being processed, and, where that is the case, access to that personal data.|
|Right to rectification||If you feel that any data that we hold about you is inaccurate you have the right to ask us to correct or rectify it. You also have the right to have incomplete personal data completed by providing a supplementary statement.|
|Right to erasure||You have a right to ask us to erase information about you where you can demonstrate that the data we hold is no longer needed by us, or if you withdraw the consent upon which our processing is based, or if you feel that we are unlawfully processing your data.|
|Right to restrict processing||You have a right to request that we refrain from processing your data where you contest its accuracy, or the processing is unlawful and you have opposed its erasure, or where we don’t need to hold your data anymore but you need us to in order to establish, exercise or defend any legal claims, or we are in dispute about the legality of our processing your personal data.|
|Right to object to processing||You have a right to object to our processing of your personal data where the basis of the processing is our legitimate interests including but not limited to direct marketing and profiling.|
|Right to withdraw consent||You have the right to withdraw your consent for the processing of your personal data where the processing is based on consent. To withdraw consent please select the unsubscribe option in the most recent electronic marketing communication you have received or alternatively you can write to us at email@example.com.|
|Right to object to direct marketing||Where your personal data are processed for direct marketing purposes, you have the right to object at any time to processing of your personal data for marketing.|
|Right to data portability||You have the right to have your personal data transferred to another controller in some circumstances.|
Right to complain to a Supervisory Authority
If you wish to exercise any of your rights concerning your personal data, you should contact our Privacy Officer at the address shown above. If you are not satisfied with the response you receive you have the right to complain to a supervisory authority. In the United Kingdom this is:
Information Commissioner's Office
(T) +44 (0) 303 123 1113
We respect your privacy. If you have any questions, please get in touch with us at: firstname.lastname@example.org