Privacy Policy 1 — Hero's Camino

Privacy Policy

Welcome to heroscamino.com, the internet marketing arm of El Camino Ltd. (“Hero’s Camino,” “we,” “our,” and “us”). This privacy policy sets out how Hero’s Camino uses and protects any information that you give us when you use this website.

Hero’s Camino takes your privacy very seriously. Please read this privacy policy carefully as it contains important information on who we are and how and why we collect, store, use and share your personal information. It also explains your rights in relation to your personal information and how to contact us or supervisory authorities in the event you have a complaint.

We collect, use and are responsible for certain personal information about you and we are responsible as ‘controller’ of that personal information.

Key terms

It would be helpful to start by explaining some key terms used in this policy:

We, us, our:

El Camino Ltd, registered in England and Wales with Company number 04420641.

Personal information:

Any information relating to an identified or identifiable individual

Special category personal information

Personal information revealing racial or ethnic origin, political opinions, religious beliefs, philosophical beliefs or trade union membership
Genetic and biometric data
Data concerning health, sex life or sexual orientation

Personal information we collect about you

You are not required to provide any personal information on the public areas of our website. However, should you choose to contact us with a query or register for mailings from our website, you may be asked to provide personal contact details, and other details such as the services in which you are interested.

We may collect and use the following personal information about you:

your name and contact information, including email address and telephone number, company details, job titles and responsibilities
Information to enable us to check and verify your identity or the identity of the company’s staff or suppliers e.g. identification documents, utility bills
location data
your billing information, transaction and payment card information e.g. bank statements and debit/credit card statements
your personal or professional interests
relevant personal information in connection with the provision of the services to you
your professional online presence, e.g. LinkedIn profile
information to enable us to undertake credit or other financial checks on you
Information about how you use our website, IT, communication and other systems
your responses to events, specific updates and mailing list preferences

This personal information is required to provide services to you. If you do not provide personal information we ask for, it may delay or prevent us from providing to you. Please refer to the section “How and why we use your personal information” for further details.

How your personal information is collected

The information we hold about you may come from your submission via our website or when you communicate or correspond with us by phone, e-mail, in person or in any other communication with us.

We collect most of this personal information directly from you—in person, by telephone, text or email and/or via our website.

However, we may also collect or receive information:

from publicly accessible sources, e.g. social media sites and government registers, Companies House or HM Land Registry;
directly from a third party, e.g. credit reference agencies, business partners, sub-contractors in technical, payment and delivery services, analytics providers;
from social media webpages we may link to including (but not limited to) Twitter, LinkedIn, YouTube and Instagram;
from cookies on our website—for more information on our use of cookies, please see our cookies policy;
from automated technologies or interactions used, for example as you interact with our website, we may automatically collect technical data about your equipment, browsing actions and patterns via our website or IT systems; and
from analysis and management of our services for you – information we learn from the way in which your details with us are administered and managed

How and why we use your personal information

Under data protection law, we can only use your personal information if we have a proper reason for doing so, e.g.:

to comply with our legal and regulatory obligations;
for the performance of our contract with you or to take steps at your request before entering into a contract;
for our legitimate interests or those of a third party; or
where you have given consent.

A legitimate interest is when we have a business or commercial reason to use your information, so long as this is not overridden by your own rights and interests.

We have set out below, a description of the ways we use your information, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.

Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data.

What we use your personal information for

To provide our services to you, including ensuring that the services are provided in the most effective manner
- Our reasons
  - For the performance of our contract with you or to take steps at your request before entering into a contract
  - For our legitimate interests or those of a third party, i.e. to be as efficient as we can so we can deliver the best service for you at the best price
The administration and maintenance of our accounts and records, including updating and enhancing customer records
- Our reasons
  - To comply with our legal and regulatory obligations
  - For our legitimate interests or those of a third party, e.g. making sure that we can keep in touch with our customers about existing services and/or new services
To respond to queries raised by you or by a third party in relation to the performance of services for you
- Our reasons
  - For our legitimate interests or those of a third party, i.e. (i) to make sure we are following our own internal procedures so we can deliver the best service to you, and (ii) to be as efficient as we can so we can deliver the best service for you at the best price
Conducting checks to identify our customers and verify their identity and their eligibility for the provision of our services (Other processing necessary to comply with professional, legal and regulatory obligations that apply to our business, e.g. under health and safety regulation or rules issued by our professional regulator)
- Our reasons
  - For the performance of our contract with you or to take steps at your request before entering into a contract (To comply with our legal and regulatory obligations)
For research and statistical analysis in order to help us develop the website and our services
- Our reasons
  - For our legitimate interests or those of a third party, i.e. to define types of customers for our services, to keep our website updated and relevant, for running our business, provision of administration and IT services, to develop our business and to inform our marketing strategy
Gathering and providing information required by or relating to audits, enquiries or investigations by regulatory bodies or professional regulators
- Our reasons
  - To comply with our legal and regulatory obligations
Ensuring business policies are adhered to, e.g. policies covering security and internet use
- Our reasons
  - For our legitimate interests or those of a third party, i.e. to make sure we are following our own internal procedures so we can deliver the best service to you
Operational reasons, such as improving efficiency, training and quality control
- Our reasons
  - For our legitimate interests or those of a third party, i.e. to be as efficient as we can so we can deliver the best service for you at the best price
Ensuring the confidentiality of commercially sensitive information
- Our reasons
  - For our legitimate interests or those of a third party, i.e. to protect trade secrets and other commercially valuable information
  - To comply with our legal and regulatory obligations
Statistical analysis to help us manage our business, e.g. in relation to our financial performance, customer base, services range or other efficiency measures
- Our reasons
  - For our legitimate interests or those of a third party, i.e. to be as efficient as we can so we can deliver the best service for you at the best price
Preventing unauthorised access and modifications to systems
- Our reasons
  - For our legitimate interests or those of a third party, i.e. to prevent and detect criminal activity that could be damaging for us and for you
  - To comply with our legal and regulatory obligations
Statutory returns
- Our reasons
  - To comply with our legal and regulatory obligations
Ensuring safe working practices, staff administration and assessments
- Our reasons
  - To comply with our legal and regulatory obligations
  - For our legitimate interests or those of a third party, e.g. to make sure we are following our own internal procedures and working efficiently so we can deliver the best service to you
To process payment of fees for the provision of services to you and other fees, including:

• to manage payments, fees and charges

• to collect and recover money owed to us

Our reasons

For the performance of our contract with you or to take steps at your request before entering into a contract
To comply with our legal and regulatory obligations
For our legitimate interests or those of a third party, e.g. for running our business, to provide you with the information, products and services that you request from us, to recover debts due to us
To comply with our legal and regulatory obligations

To keep you informed about relevant services, events and specific updates from us, including marketing our services to:
- existing and former customers;
- third parties who have previously expressed an interest in our services;
- third parties with whom we have had no previous dealings.
- Our reasons
  - For our legitimate interests or those of a third party, i.e. to promote our business to existing and former customers
External audits and quality checks and to seek professional advice e.g. for the audit of our accounts
- Our reasons
  - For our legitimate interests or a those of a third party, i.e. so we can demonstrate we operate in accordance with applicable law and standards
  - To comply with our legal and regulatory obligations

Promotional communications

We may use your personal information to send you updates (by email, text message, telephone or post) about our services, including events, specific updates from us or new services.

We have a legitimate interest in processing your personal information for promotional purposes (see above ‘How and why we use your personal information’). This means we do not usually need your consent to send you promotional communications. However, where consent is needed, we will ask for this consent separately and clearly.

We will always treat your personal information with the utmost respect and never sell or share it with other organisations for marketing purposes without your express consent.

We will get your express opt-in consent before we share your personal data with any companies for marketing purposes.

You have the right to opt out of receiving promotional communications at any time. You may ask us to remove you from our mailing list at any time by writing to: enews@heroscamino.com

We may ask you to confirm or update your marketing preferences if you instruct us to provide further services in the future, or if there are changes in the law, regulation, or the structure of our business.

Who we share your personal information with

We may share your personal information with third parties including:

our service providers (including payment service providers and providers of IT services), suppliers, contractors, sub-contractors, or any other related parties for the performance of any contract we enter into with them for the performance of services to you;
analytics and search engine providers that assist us in the improvement and optimisation of our website;
third parties we use to process your information on our behalf, for example, third parties used to host our website and to maintain our IT systems. Where we use third parties to process your information on our behalf we will ensure that they have provided appropriate safeguards required in relation to the processing of your information; and
our insurers and brokers, professional advisers, auditors and bank, if we are required to.

In addition, we may disclosure your information to third parties:

If we are under a duty to disclose or share your personal data with government, regulatory or law enforcement agencies in connection with the investigation of unlawful activities or in order to: (i) comply with any legal obligation, or (ii) enforce or apply our agreement with you; or (iii) protect the rights, property, or safety of our business or others. This includes exchanging information with other companies and organisations for the purposes of fraud protection and credit risk reduction, insurance purposes or legal advice.
If this business is sold or integrated with another business your details may be disclosed to our advisers and any prospective purchasers and their advisers, and your details will be passed on to the new owners of the business. The recipient of the information will be bound by confidentiality obligations.

We only allow our service providers to handle your personal information if we are satisfied they take appropriate measures to protect your personal information.

Where your personal information is held

Information may be held at our offices and those of our service providers, representatives and relevant third parties as described above (see above: ‘Who we share your personal information with’).

Some of these third parties may be based outside the European Economic Area. For more information, including on how we safeguard your personal information when this occurs, see below: ‘Transferring your personal information out of the EEA’.

How long your personal information will be kept

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

We will generally keep your personal information while we are providing services to you. Thereafter, we will keep your personal information for as long as is necessary:

to respond to any questions, complaints or claims made by you or on your behalf;
to show that we treated you fairly;
to keep records required by law.

We will not retain your personal information for longer than necessary for the purposes set out in this policy. Different retention periods apply for different types of personal information.

To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.

When it is no longer necessary to retain your personal information, we will delete or anonymise it. In some circumstances we may anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes in which case we may use this information for longer periods without further notice to you.

Transferring your personal information out of the EEA

Some of our external third parties are based outside the UK so their processing of your personal data will involve a transfer of data outside the UK.

Whenever we transfer your personal data out of the UK, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:

We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data by the UK.
Where we use certain service providers, we may use specific contracts approved by the Secretary of State which give personal data the same protection it has in the UK.

Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the UK.

You acknowledge that personal data that you submit for publication through our website or services may be available, via the internet, around the world. The internet is not a secure medium. All publicly accessible websites are susceptible to unlawful interception by third parties and we accept no liability if security is breached. However, we have put in place various security procedures at a level appropriate to the nature of the data held and the risk of security being breached.

If you want detailed information from Get Safe Online on how to protect your information and your computers and devices against fraud, identity theft, viruses and many other online problems, please visit www.getsafeonline.org. Get Safe Online is supported by HM Government and leading businesses.

Your rights

You have the following rights, which you can exercise free of charge:

Access

The right to be provided with a copy of your personal information (the right of access)

Rectification

The right to require us to correct any mistakes in your personal information

To be forgotten

The right to require us to delete your personal information—in certain situations

Restriction of processing

The right to require us to restrict processing of your personal information—in certain circumstances, e.g. if you contest the accuracy of the data

Data portability

The right to receive the personal information you provided to us, in a structured, commonly used and machine-readable format and/or transmit that data to a third party—in certain situations

To object

The right to object:

at any time to your personal information being processed for direct marketing (including profiling);
in certain other situations to our continued processing of your personal information, e.g. processing carried out for the purpose of our legitimate interests.

Not to be subject to automated individual decision-making

The right not to be subject to a decision based solely on automated processing (including profiling) that produces legal effects concerning you or similarly significantly affects you

For further information on each of those rights, including the circumstances in which they apply, please contact us or see the Guidance from the UK Information Commissioner’s Office (ICO) on individuals’ rights under the General Data Protection Regulation.

If you would like to exercise any of those rights, please:

• email, call or write to [us OR our Data Protection Officer]—see below: ‘How to contact us’; and

• let us have enough information to identify you [(eg your full name, address and customer or matter reference number)];

• let us have proof of your identity and address (a copy of your driving licence or passport and a recent utility or credit card bill); and

• let us know what right you want to exercise and the information to which your request relates.]

Keeping your personal information secure

The internet is not a secure medium. All publicly accessible websites are susceptible to unlawful interception by third parties and we accept no liability if security is breached. However, we have put in place various security procedures at a level appropriate to the nature of the data held and the risk of security being breached.

We also keep your information confidential. Our internal procedures cover the storage, access and disclosure of your information.

We have appropriate security measures to prevent personal information from being accidentally lost, or used or accessed unlawfully. We limit access to your personal information to those who have a genuine business need to access it. Those processing your information will do so only in an authorised manner and are subject to a duty of confidentiality.

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

Updating your details

If any of the information that you have provided to us changes, for example if you change your name or contact details, please let us know the correct details by sending an e-mail to info@metalreg.com . This will help us to ensure that the information we hold about you remains accurate and up to date.

How to complain

We hope that we can resolve any query or concern you may raise about our use of your information. You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues (https://ico.org.uk/concerns or telephone: 0303 123 1113). We would, however, appreciate the chance to deal with your concerns before you approach the supervisory authority, so please contact us in the first instance.

Status of this privacy policy and consent

We will only use your personal data 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 refer to the section “How and why we use your personal information” for more information on the purposes for which we may collect your personal data.

By submitting your information to us you consent to the use of that information as set out in this privacy policy.

If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.

Please note that we may process your personal data without your knowledge or consent, in compliance with the rules in this privacy policy, where this is required or permitted by law.

Where consent is required for our use of your information, we will seek your consent.

Changes to this privacy policy

We may change this Privacy Policy from time to time by updating this page and, where appropriate, notifying you by email. If we change our privacy policy we will post the changes on this page, and we may place notices on other pages of the website where appropriate. Please check this page regularly to see any updates or changes to our policy. Any change will take effect immediately the revised policy is available online. Continued use of the service will signify that you agree to any such changes.

How to contact us

Please contact us by post, email or telephone if you have any questions about this privacy policy or the information we hold about you.

Our contact details are shown below:

Our contact details

El Camino Ltd

Office address: 3 Claire Court, London, N128TD, UK

Telephone: + 44 (0)20 3700 9144

Email address: enews@heroscamino.com

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