Privacy Policy
Background
HRN Tractors Limited understands that your privacy is important to you and that you care about how your personal data is used. We respect and value the privacy of all of our customers, suppliers and employees 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.
1. Information About Us
HRN Tractors Limited.
Limited Company registered in Scotland under company number SC072669.
Registered address: South Road, Insch, Aberdeenshire. AB52 6XF.
Main trading address: HRN Tractors, West Rossburn Lane, Stirling. FK9 4AH.
VAT number: 297 4441 23.
Data Protection Officer: Karen Gerrard.
Email address: karen.gerrard@hrntractors.com.
Telephone number: 03450 543210.
Postal address: HRN Tractors, South Road, Insch. AB52 6XF.
We are regulated by the Information Commissioners office.
2. 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.
3. What Is Personal Data?
Personal data is defined by the UK GDPR and the Data Protection Act 2018 (collectively, “the Data Protection Legislation”) as ‘any information relating to an identifiable person who can be directly or indirectly identified in particular by 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 location data, and other online identifiers.
The personal data that we use is set out in Part 5, below.
4. What Are My Rights?
Under the Data Protection Legislation, you have the following rights, which we will always work to uphold:
- The right to be informed about our collection and use of your personal data. This Privacy Notice should tell you everything you need to know, but you can always contact us to find out more or to ask any questions using the details in
© HRN | Privacy Policy | Rev 1 | September 2021 | Review September 2022 2 Part 11. - The right to access the personal data we hold about you. Part 10 will tell you how to do this.
- The right to have your personal data rectified if any of your personal data held by us is inaccurate or incomplete. Please contact us using the details in Part 11 to find out more.
- The right to be forgotten, i.e. the right to ask us to delete or otherwise dispose of any of your personal data that we hold. Please contact us using the details in Part 11 to find out more.
- The right to restrict (i.e. prevent) the processing of your personal data.
- The right to object to us using your personal data for a particular purpose or purposes.
- The right to withdraw consent. This means that, if we are relying on your consent as the legal basis for using your personal data, you are free to withdraw that consent at any time.
- The right to data portability. This means that, if you have provided personal data to us directly, we are using it with your consent or for the performance of a contract, and that data is processed using automated means, you can ask us for a copy of that personal data to re-use with another service or business in many cases.
- Rights relating to automated decision-making and profiling. we do not use your personal data in this way.
For more information about our use of your personal data or exercising your rights as outlined above, please contact us using the details provided in Part 11.
It is important that your personal data is kept accurate and up-to-date. If any of the personal data we hold about you changes, please keep us informed as long as we have that data.
Further information about your rights can also be obtained from the Information Commissioner’s 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 Commissioner’s Office. We would
welcome the opportunity to resolve your concerns ourselves, however, so please contact us first, using the details in Part 11.
5. What Personal Data Do You Collect and How?
We may collect and hold some or all of the personal and non-personal data set out in the table below, using the methods also set out in the table. We do not collect any ‘special category’ or ‘sensitive’ personal data and/or personal data relating to children
and/or data relating to criminal convictions and/or offences.
6. Do You Use My Personal Data?
Under the Data Protection Legislation, we must always have a lawful basis for using personal data. The following table describes how we will use your personal data, and our lawful bases for doing so:
| What We Do | What Date We Use | Our Lawful Basis |
| Administering our business. | Typically but not limited to; Personal details, correspondence details, financial details. | This will be through consent, contractual obligations, legal obligations or legitimate business interests. |
| Supplying our products and/or services to you. | Typically but not limited to; Personal details, correspondence details, financial details | This will be through consent, contractual obligations, legal obligations or legitimate business interests |
| Managing payments for our products and/or services. | Typically but not limited to; Personal details, correspondence details, financial details. | This will be through consent, contractual obligations, legal obligations or legitimate business interests. |
| Personalising and tailoring our products and/or services for you | Typically but not limited to; Personal details, correspondence details, financial details. | This will be through consent, contractual obligations, legal obligations or legitimate business interests. |
| Communicating with you. | Typically but not limited to; correspondence details. | This will be through consent, contractual obligations, legal obligations or legitimate business interests. |
| Supplying you with information by email and/or post that you have opted-in-to (you may opt-out at any time by writing to Karen Gerrard | Typically but not limited to; Personal details, correspondence details, and marketing preferences. | This will be through consent, contractual obligations, legal obligations or legitimate business interests. |
With your permission and/or where permitted by law, we may also use your personal data for marketing purposes, which may include contacting you by email and/or telephone and/or text message and/or post with information, news, and offers on our products and/or services. You will not be sent any unlawful marketing or spam. We will always work to fully protect your rights and comply with our obligations under the Data Protection Legislation and the Privacy and Electronic Communications (EC
Directive) Regulations 2003, and you will always have the opportunity to opt out. We will always obtain your express opt-in consent before sharing your personal data with third parties for marketing purposes and you will be able to opt-out at any time.
We will only use your personal data for the purpose(s) for which it was originally collected unless we reasonably believe that another purpose is compatible with that © HRN | Privacy Policy | Rev 1 | September 2021 | Review September 2022 4
or those original purposes (s) and need to use your personal data for that purpose. If we do use your personal data in this way and you wish us to explain how the new purpose is compatible with the original, please contact us using the details in Part 11.
If we need to use your personal data for a purpose that is unrelated to, or incompatible with, the purpose(s) for which it was originally collected, we will inform you and explain the legal basis which allows us to do so.
In some circumstances, where permitted or required by law, we may process your personal data without your knowledge or consent. This will only be done within the bounds of the Data Protection Legislation and your legal rights
7. How Long Will You Keep My 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 (or, where there is no fixed period, the following factors will be
used to determine how long it is kept):
| Types of Data | How Long We Keep It |
| Identity Information including name, title, date of birth, gender. | Data shall be kept in the form which permits identification of the data subjects for no longer than is necessary for the purposes for which the personal data are processed; personal data may be stored for longer periods insofar as the personal data will be processed solely for archiving purposes in the public interest, scientific or historical research purposes or statistical purposes in accordance with Article 89(1) subject to implementation of the appropriate technical and organisational measures required by this Regulation in order to safeguard the rights and freedoms of the data subject (‘storage limitation’) |
| Contact information including address, email address, phone number. | Data shall be kept in the form which permits identification of the data subjects for no longer than is necessary for the purposes for which the personal data are processed; personal data may be stored for longer periods insofar as the personal data will be processed solely for archiving purposes in the public interest, scientific or historical research purposes or statistical purposes in accordance with Article 89(1) subject to implementation of the appropriate technical and organisational measures required by this Regulation in order to safeguard the rights and freedoms of the data subject (‘storage limitation’). |
| Business information including business name, job title, trading history, company number, VAT details, financial records. | Data shall be kept in the form which permits identification of the data subjects for no longer than is necessary for the purposes for which the personal data are processed; personal data may be stored for longer periods insofar as the personal data will be processed solely for archiving purposes in the public interest, scientific or historical research purposes or statistical purposes in accordance with Article 89(1) subject to implementation of the appropriate technical and organisational measures required by this Regulation in order to safeguard the rights and freedoms of the data subject (‘storage limitation’). |
| Payment information including card details, bank details, finance details, financial records. | Data shall be kept in the form which permits identification of the data subjects for no longer than is necessary for the purposes for which the personal data are processed; personal data may be stored for longer periods insofar as the personal data will be processed solely for archiving purposes in the public interest, scientific or historical research purposes or statistical purposes in accordance with Article 89(1) subject to implementation of the appropriate technical and organisational measures required by this Regulation in order to safeguard the rights and freedoms of the data subject (‘storage limitation’). |
| Profile information including preferences and history, items bought. | Data shall be kept in the form which permits identification of the data subjects for no longer than is necessary for the purposes for which the personal data are processed; personal data may be stored for longer periods insofar as the personal data will be processed solely for archiving purposes in the public interest, scientific or historical research purposes or statistical purposes in accordance with Article 89(1) subject to implementation of the appropriate technical and organisational measures required by this Regulation in order to safeguard the rights and freedoms of the data subject (‘storage limitation’). |
8. How and Where Do You Store or Transfer My Personal Data?
We will only store your personal data or store some of your personal data in the UK. This means that it will be fully protected under the Data Protection Legislation.
And/or
We will only store your personal data or store some of your personal data within the European Economic Area (the “EEA”). The EEA consists of all EU member states, plus Norway, Iceland, and Liechtenstein. This means that your personal data will be © HRN | Privacy Policy | Rev 1 | September 2021 | Review September 2022 6 fully protected under the EU GDPR and/or to equivalent standards by law. Transfers of personal data to the EEA from the UK are permitted without additional safeguards.
And/or
We may store some or all of your personal data in countries outside of the UK. These are known as “third countries”. We will take additional steps in order to ensure that your personal data is treated just as safely and securely as it would be within the UK and under the Data Protection Legislation as follows:
We ensure that your personal data is protected under binding corporate rules. Binding corporate rules are a set of common rules which all our group companies are required to follow when processing personal data. For further information, please refer to the
Information Commissioner’s Office.
9. Do You Share My Personal Data?
We will not share any of your personal data with any third parties for any purposes, subject to the following exceptions.
If we sell, transfer, or merge parts of our business or assets, your personal data may be transferred to a third party. Any new owner of our business may continue to use your personal data in the same way(s) that we have used it, as specified in this Privacy Policy.
In some limited circumstances, we may be legally required to share certain personal data, which might include yours, if we ar involved in legal proceedings or complying with legal obligations, a court order, or the instructions of a government authority.
OR
We may share your personal data with other companies in our group for marketing or financial awareness purposes. This includes subsidiaries
| Recipient | Activity Carried Out | Sector | Location |
| Agritrac Exports Limited | Export, sale and purchase of plant and equipment, both new and used. |
Construction and Agriculture. | Rossburn Lane, Stirling. FK9 4AH. |
| R & N Barclay | Agricultural activities, such as but not limited to farming. | Agriculture | South Road, Insch, Aberdeenshire. AB52 6XF |
10. 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 email or postal addresses shown in Part 11. To make this as easy as possible for you, a Subject Access Request Form is available for you to use. You do not have to use this form, but it is the easiest way to tell us everything we need to know to respond to your request as quickly as possible.
There is not normally any charge for a subject access request. If your request is ‘manifestly unfounded or excessive (for example, if you make repetitive requests) a fee may be charged to cover our administrative costs in responding.
We will respond to your subject access request within 28 days and, in any case, not more than one month of receiving it. Normally, we aim to provide a complete response, including a copy of your personal data within that time. In some cases, however, articularly if your request is more complex, more time may be required up to a maximum of three months from the date we receive your request. You will be kept fully informed of our progress.
11. How Do I Contact You?
To contact us about anything to do with your personal data and data protection, including to make a subject access request, please use the following details (for the attention of Karen Gerrard):
Email address: karen.gerrard@hrntractors.com
Telephone number: 03450 543 210
Postal Address
HRN Tractors
South Road
Insch
Aberdeenshire
AB52 6XF
© HRN | Privacy Policy | Rev 1 September 2021 | Review September 2022