At Peel Ports we are committed to respecting your privacy. This Privacy Notice sets out how we comply with data protection legislation and aims to give you information on how we collect and process your personal data, including any data you may provide to us when you utilise our services or sign up to receiving news and updates from us.

Data Controller

This Privacy Notice is issued on behalf of the Clydeport Operations Limited so when we mention “we”, “us” or “our” in this Privacy Notice, we are referring to Clydeport Operations Limited

We have appointed a Group Data Protection Officer (contact details below), who is responsible for overseeing questions in relation to this Privacy Notice.

You have the right to make a complaint at any time to the Information Commissioner’s Office, which is the UK’s supervisory authority for data protection issues.  We would however appreciate the opportunity to deal with any concerns you may have before you approach the ICO and would ask that you contact the Group Data Protection Officer in the first instance.

Third Party Links on Our Website

Our website may include links to third party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow those third parties to collect or share data about you. We do not control these third party websites and are not responsible for their privacy notices. When you leave our website, we encourage you to read the privacy notice of every website you visit.

Principles of Data Protection

We will process your personal data in accordance with data protection law which states that information that we hold about you must be:

• Used lawfully, fairly and in a transparent way
• Collected only for valid purposes that we have clearly explained to you and not used in any way that is incompatible with those purposes
• Relevant to the purposes we have told you about and limited only to those purposes
• Accurate and kept up to date
• Kept only as long as necessary for the purposes we have told you about
• Kept securely

Information We Hold About You

We may collect, store and use various categories of personal information about you, including:

• Identity Data (e.g. your name and title)
• Contact Data (e.g. your address, phone number and email address)
• Financial Data (e.g. bank account and payment details)
• Transaction Data (e.g. details about payments to and receipts from you and other details of products and services you have purchased from us)
• Website Usage Data (e.g. information about how you use our website, interests, preferences, etc.)

Aggregated Data

We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data may be derived from your personal data but is not considered personal data in law as this data does not directly or indirectly reveal your identity. For example, we may aggregate your Website Usage Data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect Aggregated Data with our personal data so that it can directly or indirectly identify you, we treat the combined data as personal data, which will be used in accordance with this Privacy Notice.

Special Categories of Personal Data

Some of our customers provide us with biometric data in the form of an electronic copy of a thumb or finger print in order to gain access to specific areas of our premises.

Biometric data, as a special category of sensitive personal data, will be processed on the basis that it is in the substantial public interest for us to do so, given that the processing of this data is necessary for the prevention or detection of an unlawful act. Moreover and alternatively, we will obtain this data with the explicit consent of those customers. We will store the biometric data securely using appropriate pseudonymisation techniques to protect the identities of the individuals concerned. At the end of our contract with those customers, this data is permanently deleted from our records.

No other Special Categories of Personal Data (including details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, health records and genetic data) are collected or processed in any way by us, nor do we collect any information about criminal convictions or offences unless we have obtained your consent or there is a legal requirement to do so.

How Your Personal Data Is Collected

We use different methods to collect data from you and about you including through:

• Direct Interactions: You may give us your identity and contact data by filling in forms or by corresponding with us by post, phone, email, in person or otherwise. This includes personal data you provide when you:
  • Enquire about our products and services
  • Subscribe to our service or publications
  • Request marketing information to be sent to you
  • Enter a promotion or survey
  • Provide us with feedback

• Automated Technologies or Interactions: As you interact with our website, we may automatically collect Website Usage Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies and other similar technologies.

A cookie is a piece of text, which asks permission to be placed on your computer’s hard drive. Once you agree, your browser adds that text in a small file.

We use traffic log cookies to identify which pages are being used. This helps us analyse data about web page traffic and improve our website in order to tailor it to customer needs. Denial of a traffic log cookie should not prevent you from using our site, however it may restrict the use of certain features.

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 may set your web browser to notify you of cookie placement requests or decline cookies completely. You can delete the files that contain cookies - those files are stored as part of your Internet browser.

You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of this website may become inaccessible or not function properly.

For more information on cookies please see https://ico.org.uk/for-organisations/guide-to-pecr/cookies-and-similar-technologies/

• Third Parties or Publicly Available Sources: We may receive personal data about you from various third parties and public sources as set out below:
  • Website Usage Data from analytics providers such as Google
  • Identity and Contact data from contact brokers or aggregators
  • Identity and Contact data from publicly available sources such as Companies House, credit reference agencies and LinkedIn.

How We Use Your Personal Data

We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:

• Where we need to perform the contract we are about to enter into or have entered into with you.
• Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
• Where we need to comply with a legal or regulatory obligation.

Generally we do not rely on consent as a legal basis for processing your personal data other than in relation to processing Special Categories of Personal Data (see above) and sending third party direct marketing communication to you. You have the right to withdraw consent to marketing at any time by contacting us here.

Marketing

We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising. We have established a preference centre where you can view and make certain decisions about your personal data use. Click here.

We may use your Identity, Contact, Transaction and Website Usage Data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which products, services and offers may be relevant for you.

You will receive marketing communications from us if you have requested information from us or purchased products or services from us, or if you have provided us with your information when you have enquired about our products or services, or corresponded with us by post, phone, email, in person or otherwise and, in each case, you have not opted out of receiving that marketing.

Change of Purpose

We will only use your personal information for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose.

Please note that we may process your personal data without your knowledge or consent where this is required or permitted by law.

Sharing Your Personal Data

In some circumstances we may share your personal data with the parties set out below:

• Companies within Peel Ports Group that act as joint controllers or processors and are based in the European Economic Area in order to provide IT, administration and support services.
• Third parties (including service providers and professional advisers acting as processors who provide administration and support services).

We require all third parties to respect the security of your personal data and to treat it in accordance with the law.  We do not allow our third party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.

We only transfer personal data outside the European Economic Area where the processor of the data provides protection in line with the data protection obligations that apply in the European Union.  The Group Data Protection Officer is notified of any data processor that is outside of the European Economic Area.

Storage of Your Personal Data

We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.

We have put in place procedures to deal with any suspected personal data breach and will notify you any applicable regulator of a breach where we are legally required to do so.

Data Retention

We will only retain your personal data for as long as necessary to fulfill the purposes we collected it for, including for the purposes of satisfying any legal, accounting or reporting requirements.

Your Rights

You have the right to request access to, and transfer, rectification or erasure of, your personal data. You may object to the processing of your personal data or request a restriction to the way it is processed. You also have the right to lodge a complaint with a supervisory authority.

In the limited circumstances where you may have provided your consent to the processing of your personal data for a specific purpose, you have the right to withdraw your consent for that specific processing at any time.

You can ask us to stop sending you marketing messages at any time by logging into the website and checking or unchecking relevant boxes to adjust your marketing preferences or by following the opt-out links on any marketing message sent to you, or by contacting us at any time. Click here.

Changes to This Privacy Notice

We reserve the right to update this Privacy Notice at any time, and will publish any updates on our website. We may also notify you in other ways from time to time about the processing of your personal data.

Group Data Protection Officer

The Group Data Protection Officer (DPO) is based at Maritime Centre, Port of Liverpool, Liverpool, L21 1LA and can be contacted by email at GroupDataProtectionOfficer@peelports.com or in writing to:

Andrew Langfeld
Group Data Protection Officer
Peel Ports Group Limited
Maritime Centre
Port of Liverpool
L21 1LA

If you have any questions about this Privacy Notice, including any request to exercise your legal rights, please contact the DPO.