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Southern Cross Packaging Privacy Policy

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This privacy policy sets out how Southern Cross Packaging Limited uses and protects your personal data.

1. Important information and who we are

The privacy of our website users is very important to us and therefore we encourage all users to read this very carefully because it contains important information regarding:

  • who we are;
  • why we collect, store, use and share personal information;
  • your rights in relation to your personal information; and
  • how to contact use and supervisory authorities in the event you have a complaint.

Southern Cross Packaging Limited is the controller and responsible for your personal data (collectively referred to as "Southern Cross Packaging", "we", "us" or "our" in this privacy policy).

This website is not intended for children and we do not knowingly collect data relating to children.

If you have any questions about this privacy policy, including any requests to exercise your legal rights (59), please contact us using the information set out in the contact details section (610).

2. The types of personal data we collect about you

Personal data means any information about an individual from which that person can be identified.

We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:

  • Identity Data includes first name, last name, title and gender.
  • Contact Data includes company billing address, company delivery address, company email address and company telephone numbers (landline and mobile).
  • Financial Data includes bank account and payment card details of our customers and suppliers.
  • Transaction Data includes details about payments to and from you and other details of products and services you have purchased from us.
  • Technical Data includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions,
    • operating system and platform, device ID and other technology on the devices you use to access this website.
  • Usage Data includes information about how you interact with and use our website, products and services.
  • Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.

3. How is your personal data collected?

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

  • You may give us your personal data by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:
    • place an order for our products;
    • request information on our products;
    • request marketing to be sent to you; or
    • give us feedback.
  • As you interact with our website, we will automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies and other similar technologies.

4. How we use your personal data

Legal basis

The law requires us to have a legal basis for collecting and using your personal data. We rely on one or more of the following legal bases:

  • Performance of a contract with you: Where we need to perform the contract we are about to enter into or have entered into with you.
  • Legitimate interests: We may use your personal data where it is necessary to conduct our business and pursue our legitimate interests. We make sure we consider and balance any potential impact on you and your rights (both positive and negative) before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). Examples of where we may rely on this legal basis are:
    • to ensure network and information security;
    • to communicate with you regarding the products including to provide you important notices regarding changes to our terms and to address and respond to your requests, inquiries, and complaints;
    • to enforce our terms or this Privacy Policy, or agreements with third parties; and
    • to assist in the investigation of suspected illegal or wrongful activity, and to protect and defend our rights and property, or the rights or safety of third parties.
  • Legal obligation: We may use your personal data where it is necessary for compliance with a legal obligation that we are subject to. We will identify the relevant legal obligation when we rely on this legal basis.
  • Consent: We rely on consent only where we have obtained your active agreement to use your personal data for a specified purpose. Where we rely on consent to use your information, you have the right to withdraw that consent at any time by contacting our Data Protection Officer, provided that we are not required by applicable law or professional standards to retain such information.

Purposes for which we will use your personal data

We have set out below, in a table format, examples of the ways we may use the various categories of your personal data, and which of the legal bases we would rely on to do so. We have also identified what our legitimate interests are where appropriate.

Purpose/Use Type of data Legal basis
To register you as a new customer (a) Identity
(b) Contact 		Performance of a contract with you
To process and deliver your order including:
(a) Manage payments, fees and charges
(b) Collect and recover money owed to us 		(a) Identity
(b) Contact
(c) Financial
(d) Transaction
(e) Marketing and Communications
 (a) Performance of a contract with you
(b) Necessary for our legitimate interests (to recover debts due to us)
To manage our relationship with you which will include:
(a) Notifying you about changes to our terms or privacy policy
(b) Dealing with your requests, complaints and queries
 (a) Identity
(b) Contact
(c) Profile
(d) Marketing and Communications
 (a) Performance of a contract with you
(b) Necessary to comply with a legal obligation
(c) Necessary for our legitimate interests (to keep our records updated and manage our relationship with you
To administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data) (a) Identity
(b) Contact
(c) Technical
 (a) Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise)
(b) Necessary to comply with a legal obligation
To use data analytics to improve our website, products/services, customer relationships and experiences and to measure the effectiveness of our communications and marketing (a) Technical
(b) Usage 		Necessary for our legitimate interests (to define types of customers for our products and services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy)
To send you relevant marketing communications and make personalised suggestions and recommendations to you about goods or services that may be of interest to you based on your Profile Data (a) Identity
(b) Contact
(c) Technical
(d) Usage
(e) Profile
(f) Marketing and Communications
 Necessary for our legitimate interests (to carry out direct marketing, develop our products/services and grow our business) or Consent, having obtained your prior consent to receiving direct marketing communications

Direct marketing

You will receive marketing communications from us if you have requested information from us or purchased goods or services from us and you have not opted out of receiving the marketing.

We may also analyse your Identity, Contact, Technical, Usage and Profile Data to form a view which products, services and offers may be of interest to you so that we can then send you relevant marketing communications.

Third-party marketing

We will get your express consent before we share your personal data with any third party for their own direct marketing purposes.

Opting out of marketing

You can ask to stop sending you marketing communications at any time. If you opt out of receiving marketing communications, you will still receive service-related communications that are essential for administrative or customer service purposes for example relating to order confirmations.

5. Disclosures of your personal data

We may share your personal data where necessary with the parties set out below:

  • >law enforcement or other authorities if required by applicable law;
  • credit reference and fraud prevention agencies;
  • regulators to meet our legal and regulatory obligations;
  • any third party in the context of actual or threatened legal proceedings, provided we can do so lawfully (for example in response to a court order);
  • our own professional advisors and auditors for the purpose of seeking professional advice or to meet our audit responsibilities; and
  • third party IT suppliers where needed to maintain our electronic IT systems (only were we have a GDPR agreement already in place with the IT supplier in question)

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 will not share your personal information with any other third party.

6. International Transfers

We may transfer your personal data to service providers that carry out certain functions on our behalf. This may involve transferring personal data outside the UK to countries which have laws that do not provide the same level of data protection as the UK law.

Whenever we transfer your personal data out of the UK to service providers, we ensure a similar degree of protection is afforded to it by ensuring that appropriate contractual arrangements are made which give the transferred personal data the same protection as it has in the UK and that the service providers are bound to take appropriate security measures to keep the transferred personal data secure.

7. Data Security

We have appropriate security measures in place to prevent personal information from being accidentally lost, or used or accessed in an unauthorised way. We limit access to your personal information to those who have a genuine business need to know 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.

8. Data Retention

How long will you use my personal data for?

We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.

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, regulatory, tax, accounting or other requirements.

By law we have to keep basic information about our customers (including Contact, Identity, Financial and Transaction Data) for six years after they cease being customers. In some circumstances you can ask us to delete your data: see 59 below for further information.

9. Your Legal Rights

You have a number of rights under data protection laws in relation to your personal data.

You have the right to:

  • Request access to your personal data (commonly known as a "subject access request"). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
  • Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
  • Request erasure of your personal data in certain circumstances. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
  • Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) as the legal basis for that particular use of your data (including carrying out profiling based on our legitimate interests). In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your right to object.
  • You also have the absolute right to object any time to the processing of your personal data for direct marketing purposes (see 24 for details of how to object to receiving direct marketing communications).
  • Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
  • Withdraw consent at any time where we are relying on consent to process your personal data (see the table in section 4 for details of when we rely on your consent as the legal basis for using your data). However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.
  • Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in one of the following scenarios:
    • If you want us to establish the data's accuracy;
    • Where our use of the data is unlawful but you do not want us to erase it;
    • Where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or
    • You have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.

If you wish to exercise any of the rights set out above, please contact our Data Protection Officer (see Contact details at 610) and provide us with enough information to identify you and let us know the information to which your request relates.

No fee usually required

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 could refuse to comply with your request in these circumstances.

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.

Time limit to respond

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

10. Contact details

If you have any questions about this privacy policy or about the use of your personal data or you want to exercise your privacy rights, please contact us in the following ways:

  • Email address: sales@southerncrosspackaging.com
  • Postal address: Southern Cross Packaging Limited, 1 The Meadows, Waterberry Drive, Waterlooville, PO7 7XX
  • Telephone number: (+44) 02392 240 660

11. Complaints

You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK regulator for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO and we hope that our Data Protection Officer can resolve any query or concern you raise about our use of your information, so please contact us in the first instance.

12. Changes to the privacy policy and your duty to inform us of changes

We keep our privacy policy under regular review and we may make changes to it from time to time.

It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us, for example a new address or email address.

13. Third-party links

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