Introduction

Welcome to CW Smiths & Sons privacy notice (referred to as “we”, “us” or “our” in this privacy notice). We trade under the name “EXACT Moves.”

We recognises the importance of protecting individual’s privacy and personal data and processing it in accordance with the applicable privacy laws. It is the purpose of this Privacy Notice to communicate the ways in which we process personal data in our business activities. We respect and value the privacy of all of our clients and will only collect and use personal data in ways that are described here, and in a way that is consistent with our obligations and your rights under the law.

If you have any questions or inquiries concerning this Privacy Notice and/or your personal data, please contact our current data privacy manager Michelle Jones.

Email address of current data privacy manager: Michelle.jones@exactmoves.co.uk
Postal address: EXACT Moves, Unit C2, Queensbridge Industrial Park, London Road, West Thurrock, Essex RM20 3LH

Information about us

Limited Company registered in England and Wales under company number: 1091590
Registered Address: 10 Western Road, Romford, Essex RM1 3JT
VAT number: 246 8481 32
Telephone number: 01708 771290

What does this notice cover?

This Privacy Information explains how we use your personal data: how it is collected, how it is held and how it is processed. It also explains your rights under the law relating to your personal data.

What is Personal Data?

Personal data is defined by the General Data Protection Regulation (EU Regulation 2016/679) (the “GDPR”) as ‘any information relating to an identifiable person who can be directly or indirectly identified in particular reference to an identifier’.

Personal data is, in simpler terms, any information about you that enables you to be identified. Personal data covers obvious information such as your name and contact details, but it also covers less obvious information such as identification numbers, electronic data and other online identifiers.

Who is the data controller of personal data?

Data controller, and therefore the legal entity responsible for collection and use of personal data under this privacy policy is CW Smith & Sons (t/a EXACT Moves).

What are my rights?

Under the GDPR, you have the following rights, which we will always work to uphold:
a) The right to be informed about our collection and use of your personal data. This Privacy Notice tell you everything you need to know, but you can always contact us to find out more or to ask us any questions.
b) The right to access the personal data we hold about you.
c) The right to have your personal data rectified if any of your personal data held by us is inaccurate or incomplete.
d) The right to be forgotten i.e. the right to ask us to delete or otherwise dispose of any of your of any of your personal data that we have, please see contact details under the how do I contact you section.
This may be subject to applicable laws and our retention criteria;
e) The right to restrict (i.e. prevent) the processing of your personal data;
f) The right to object to us using your personal data for a particular purpose or purposes.
g) The right to data portability. This means, you request us to move your personal data over to you or to another data controller in accordance with the European Data Protection Regulation;
(h) If we have requested and you have given us your consent to process your personal data, you have the right to withdraw that consent in accordance with applicable laws; and
(i) Lodge a complaint with a relevant data protection authority if you deem that we have processed your personal data in violation of the applicable data protection laws.

Further information about your rights can be obtained from the Information Commissioners Office or your local Citizens Advice Bureau. If you have any cause for complaint about our use of your personal data, you have the right to lodge a complaint with the Information Commissioners Office.

What personal data do you collect?

We may collect some or all of the following personal data (this may vary according to your relationship with us):
• Name
• Address
• Email address
• Telephone number
• Mobile number
• Business name
• Job title
• Payment information including bank details
• Accounts department contact information
• Company registration number
• VAT number

Why do we collect personal data?

Our primary purpose is to collect information about our clients because; the data is necessary for the performance of a contract with you, you have consented to our use of your personal data, or because it is in our legitimate business interest to use it.

What is the legal basis for the processing of personal data?

We collect and process your personal data based on a necessity to fulfil contractual obligations and with legitimate interests related to the above explained purposes and our operations. In some instances we may also request for your consent.

Please see below the types of data we store, its use and the legal basis for processing it.

Your personal data will be used for or may be used for one of the following purposes:
• Providing and managing your account
• Supplying our services to you. Your personal details are required in order for us to enter into a contract with you
• Personalising and tailoring our services for you
• Communicating with you. This may include responding to emails or calls to and from you
• Emailing copies of certificates and/or invoices/statements/quotations.

Who do we share data with?

As a service provider who on occasion will use subcontractors to carry out a job we will share a limited amount of your personal data with a trusted list of sub-contractors. Data is limited to vehicle registrations, breakdown locations name and contact phone number(s).

It has never been practice for CW Smith & Sons (t/a EXACT Moves) to use data for marketing purposes, either electronically or by post, nor is there any intention for this to change.

How long do we retain personal data?

We will not keep your personal data for any longer than is necessary in light of the reason(s) for which it was first collected.

Your personal data will therefore be kept for the following periods:
• We keep all invoice and account records for at least six years after the end of the accounting period or tax year
• If the above is not applicable personal data will be held until the end of the contract between us

How and where do you store of transfer my personal data?

We will only store or transfer personal data in the UK. This means that it will be fully protected under GDPR.

Personal data may be stored either in hardcopy or electronic form. We recognise our obligation to safeguard the sensitive nature of all personal data. Data stored as an electronic form is stored securely within our servers and internet banking which is protected using current, up to date security software together with an additional firewall protection. Any hardcopy personal data, is kept in a locked cupboard with access restricted to the accounts department for which they may need this
information to carry out their relevant tasks.

We are, therefore, committed to applying protective measures to secure against the unauthorised access, modification, collection, copying, use, and disclosure of any personal data. These measures include:
(i) Limiting the access and uses of information to those tail lift services personnel, contractors and
suppliers and persons who, for in order to be able to perform their relevant tasks need to have, on a
fair and lawful basis, access to personal data;
(ii) Use of physical and electronic access codes and passwords to control and restrict access;
(iii) Training and raising awareness on relevant Employees and other personnel about data protection and privacy;
(iv) Applying updates and at-minimum-industry standard technical security measures.

How can I access my personal data?

If you want to know what personal data we have about you, you can ask us for details of that personal data and for a copy of it (where any such personal data is held). This is known as a “subject access request”.

All subject access requests should be made in writing and sent to the following email address:
Michelle.jones@exactmoves.co.uk

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 may refuse to comply with your request in these circumstances.

We try to respond to all legitimate requests within one month. Occasionally it may 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.

What we may need from you

We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

What is a data breach?

A personal data breach is a breach of security leading to the destruction, loss, alteration, unauthorised disclosure of, or access to, personal data.

Who does it have to be reported to?

In the event of a data breach, the point of contact from CW Smith & Sons Limited (t/a EXACT Moves) is Michelle Jones, who is also our Data Protection Officer. They will invoke the data control procedure with the Finance Director, as required. EXACT Moves will report the breach to the relevant supervisory authority within 72 hours of the organisation becoming aware of it. We will notify affected individual data subjects within 48 hours of becoming aware of the breach.

How do I contact you?

To contact us about anything to do with your personal data and data protection including making a subject access request, please use the following details (for the attention of Michelle Jones):

Email address: michelle.jones@exactmoves.co.uk
Telephone number: 01708 771290
Postal Address:
Unit C2, Queensbridge Industrial Park
795 London Road
West Thurrock
Essex RM20 3LH

Changes to this Privacy Notice

EXACT Moves shall periodically review this Privacy Notice and its data protection procedures to ensure they continue to beappropriate to its activities and up to date and relevant with any applicable law changes and/or business activity changes.