Privacy Policy

Introduction

• This Privacy Policy explains what we at Solo Rail Solutions Ltd (“Solo Rail”) do with your personal data; whether we are in the process of dealing with an enquiry, processing an order, continuing our ongoing customer relationship with you, receiving a service from you, requesting your feedback, or you are visiting our website.
• It describes how we collect, use and process your personal data, and how, in doing so, we comply with our legal obligations to you. Your privacy is important to us, and we are committed to protecting and safeguarding your data privacy rights.
• This Privacy Policy applies to the personal data of our Customers, Potential Customers, Suppliers, Sub-Contractors and Employees. If you are a Solo Rail Employee you should refer to your contract of employment and our Employee Privacy Notice found in the company handbook for specific information regarding the handling of your personal data.
• It is important to note that that any amendments to our Privacy Policy will be posted to this page; for updates to our policy please navigate to this page.

What kind of personal data do we collect?

• Customer Data:

In order to provide the best possible products and services to our customers we need to process certain information. Solo Rail only ask for details that will genuinely help us to deliver these products and services, such as your name, job role, and contact details; including but not limited to: telephone number, email address, first and last name, job title.  Where Solo Rail are required by you to process payments for goods and services by way of debit or credit card we will also process these details, but only for this purpose.

We may also collect information regarding your website activity and visits in order to further enhance your customer experience.

• Supplier Data:

We collect a minimum amount of data from our suppliers to ensure that we can easily process transactions. Solo Rail will collect contact details for the main contact and any associate contacts within the business that assist us in processing any number of transactions.  We also need other information such as your bank details so that we can pay for the services you provide (if this is part of the contractual arrangements between us).

• Sub-contractor Data

We collect and store information required so that we can process contractual obligations between us.  These details include personal and business email addresses, telephone numbers, address details, bank account details, qualifications and insurances.

• End-user data

Where we are obligated to carry out work for a third-party contractor, we reserve the right to obtain and process data, including site addresses, email addresses and telephone numbers.  This enables Solo Rail to fulfil our contractual obligations to you and our customer.

How do we collect your personal data?

• Customer Data

We collect customer data in the following ways:

1. Directly from you
2. From third-party software detailing ongoing project data
3. From websites
4. From social media platforms
5. From your work colleagues
6. From exhibitions or events attended by Solo Rail employees

When viewing or interacting with data and information on our websites or in an email from us, we may also collect certain data automatically or through you providing it to us.

• Supplier Data

We collect supplier data in the following ways:

1. Directly from you
2. From your work colleagues
3. Your website

• Sub-contractor Data

1. Directly from you
2. From your work colleagues
3. Your website
4. End-user Data

• End-user data

We collect end-user data via third-party contractors or suppliers who are using the services of Solo Rail to fulfil a project.

• Website Users

We collect your data automatically via cookies when you visit our website, in line with cookie settings in your browser. We will also collect data from you when you contact us via the website, for example by using the contact forms.

How do we use your personal data?

• Customer Data:

There are two main reasons for using your personal details.  Firstly, details will be used to help Solo Rail process ongoing requests that you have made of us, i.e. raising a quote or processing an order, through to delivery of that order and potentially requesting feedback (in the form of a survey).  Solo Rail will also store and process data for the purposes of direct marketing via email, telephone and post. Review the section below: “How can I unsubscribe from all or individual types of direct marketing” should you wish to opt out of any form of direct marketing from Solo Rail.

• Supplier Data:

The main reasons for storing and processing your personal data is to ensure that we can complete the contractual arrangements between us and comply with any legal and binding requirements.

• Sub-contractor Data:

The main reasons for storing and processing your personal data is to ensure that we can complete the contractual arrangements between us and comply with any legal and binding requirements.

• End-user Data:

The main reason that we process end user data is to ensure that we can contractually deliver on products and services which have been requested via a third party

• Website Users:

We use data collected via our website to help us to improve your experience when using our website, for example by analysing your recent search trends to help us present recently viewed products. If you are a customer, we may use data from your use of our websites to enhance other aspects of our communications with you, for example email communications.

Who do we share your personal data with?

• Customer Data:

We may share your personal data with suppliers or sub-contractors but only where it is necessary for them to deliver a contractual obligation such as delivery or installation of our products or service.  Customer details that are being used for the purposes of e-marketing will be uploaded to a secure external system which is provided by a third-party organisation.  If prior agreement is provided by you we will pass your details on to alternative companies who we believe will be able to fulfil your requirement when Solo Rail cannot.

• Supplier Data:

By way of a referral we may share your personal data with potential customers who would also benefit from your products and services.

• Sub-contractor Data:

Where a contractual agreement has been agreed for you to carry out work on behalf of Solo Rail at a customer’s site, Solo Rail will provide your personal data to the customer, in order for them to complete their internal processes.

• End-user Data:

When entering in to a contractual agreement with Solo Rail we will pass on the minimum amount of your personal data as deemed appropriate for a supplier or subcontractor of Solo Rail to carry out their contractual obligations to us.

• Website User Data:

No details obtained from our website will be processed outside of Solo Rail.  Any data used to process and target specific information to you will be done so using a Solo Rail managed system.

How do we safeguard your personal data?

• We care about protecting your information. That’s why we put in place appropriate measures that are designed to prevent unauthorised access to, and misuse of, your personal data.

Those processes include, but are not limited to; encrypted server access, encrypted laptop devices, plus all antivirus and gateway security settings are up to date and monitored.

How long do we keep your personal data for?

• Data stored and processed in our CRM system

If we have not had meaningful contact with you for a period of five years, we will remove your personal data from our systems unless we believe another processing requirement, such as legal or contractual regulation, requires us to retain it.

• Printed and digital archived project information

Due to the nature of our products we deem it appropriate to store project information for up to 20 years; this allows us the ability to recall previous project information should you, the customer, require it.

How can you access, amend or take back the personal data that you have given to us?

• If we are holding or using your personal information, you may change your mind at any time by writing to Sales Department at Solo Rail Solutions Limited, Unit 8 Long Acre Trading Estate, Long Acre, Nechells, Birmingham, B7 5JD or emailing us at datacontroller@solorail.com. We will process the restriction of use in our marketing communications or removal of your personal information within 10 working days, sometimes sooner.Please note that we may keep a record of your communications to help us resolve any issues which you raise.
• Right to object

If we are using your data because we deem it necessary for our legitimate interests to do so, and you do not agree, you have the right to object. We will respond to your written request within 30 days (although we may be allowed to extend this period in certain cases). Generally, we will only disagree with you if certain limited conditions apply.

• Right to erasure

In certain situations, you have the right to request us to “erase” your personal data. We will respond to your request within 30 days (although we may be allowed to extend this period in certain cases) and will only disagree with you if certain limited conditions apply. If we do agree to your request, we will remove your data. We will assume that you would prefer us to keep a note of your name on our system as a person who would prefer not to be contacted by Solo Rail, as this will ensure that we can minimise the future risk of your data being resubmitted and used in the future.  If you would prefer that this is not the case, please let us know.

Any data within the e-marketing system will be moved to a suppressed list and be unable to be resubmitted for direct marketing use without prior agreement from you.

• Right to lodge a complaint

You have the right to lodge a complaint; details of which can be found here.

How can I unsubscribe from all or individual types of direct marketing?

• Email Marketing

All e-marketing communications sent by Solo Rail using our third-party e-marketing software will contain an unsubscribe button, on clicking to unsubscribe you will be requested to submit your email address in order to authenticate your permission to suppress the email address.  Any emails sent to you using one of our outlook email addresses can be directly replied to or you can forward the email to datacontroller@solorail.com in order to request you are removed from future direct marketing email communications.

• Telephone Marketing

A request can be made with the person whom you are directly on the phone with at the time, and they will process this request in our centralised CRM system.  If you are unsure as to whether you are registered on our systems for telephone marketing and wish to remove your details you can contact us either on email; datacontroller@solorail.com or by telephone on 0121 328 6785 and press 1 for the Commercial Department.  Your details will be updated within 5 working days or sooner.

• Postal Marketing

If you would like to remove your personal details to prevent receiving postal marketing communications you can email your request to datacontroller@solorail.com or telephone 0121 328 6785 and press 1 for the Commercial Department. Your details will be updated within 5 working days or sooner.

What are cookies, how do we use them and how to opt out?

• A “cookie” is a bite-sized piece of data that is stored on your computer’s hard drive. They are used by nearly all websites and do not harm your system.
• Solo Rail use cookies to track your activity and help us to improve your experience when visiting our website. We can also use the information from cookies to tailor other forms of direct marketing, to ensure that you see information relevant to you and any current requirements. We can also use cookies to analyse traffic and for advertising purposes.
• If you want to check or change what types of cookies you accept, or opt-out from cookies being used in the ways mentioned above, this can usually be altered within your browser settings.
• Most web browsers will automatically accept cookies but, if you would rather we didn’t collect data in this way, you can choose to reject some or all cookies in your browser’s privacy settings. Please be advised that rejecting all cookies means that you may not be able to use all functions of our website.

OUR LEGAL BASES FOR PROCESSING YOUR DATA

LEGITIMATE INTERESTS

• Article 6(1)(f) of the GDPR states that we can process your data where it “is necessary for the purposes of the legitimate interests pursued by us or by a third party, except where such interests are overridden by the interests or fundamental rights or freedoms of you which require protection of personal data.”

Customer data:

• We think it is reasonable that, if you have communicated with us in the past or we have had meaningful contact with you within the past 5 years, there is a legitimate interest that you will continue to benefit from our range of solutions, and thus we will keep you updated via forms of direct marketing.
• We want to provide potential customers with the opportunity to hear about our products and services and request additional information.  We therefore think it is reasonable that, if you operate in a sector that regularly benefits from our products and services and your information has been made available in the public domain, we can contact you to advise you of our products and services.  We will have an upfront and honest approach to this and provide you with the opportunity to opt-out of any further communications from us.
• Where we subscribe to third-party services who collate and enter data relating to ongoing projects in our industry, we will deem it reasonable that you are in a position where you wish to be contacted regarding suitable products and services.  We will therefore process your data for the purposes of direct marketing in order to establish if you have a requirement.
• Where you have made contact with us, we will process your request in line with our business processes and in order to provide you with the requested products and services.  This will include processes such as: arranging and attending your site and processing information that will enable us to design, manufacture and install your solution. Information obtained will be stored on our systems now and in the future to further enable us to process your requests and to keep you updated on product, service and company updates via forms of direct marketing.
• Personal details may be used for administrative purposes including invoicing and project management.

Supplier data:

• We store and process the personal data of individuals within your organisation in order to facilitate the receipt of services from you as one of our suppliers. We also hold your financial details so that we can pay you for your services. We deem all such activities to be necessary within legitimate interests.

CONTRACTUAL

• Article 6(1)(b) gives us lawful basis for processing personal data where; “processing is necessary for the performance of a contract to which the data subject is party or in order to take steps at the request of the data subject prior to entering into a contract”
• In this context, a contract does not have to be a formal signed document or even written down, as long as there is an agreement which meets the requirements of contract law. Broadly speaking, this means that the terms have been offered and accepted, you both intend them to be legally binding, and there is an element of exchange (usually an exchange of goods or services for money, but this can be anything of value).

Customer data:

• Where we and you have entered in a contractual agreement to deliver products and services, we will process the appropriate and required information in order to do so; i.e. address details of the company and installation site. In order to provide a smooth and seamless service, we will also deem it reasonable to process such information as appropriate to send updates on the progress of your contract with us.  Some of these updates and notifications will be automated and sent from a third-party e-marketing system.

End user:

• Where Solo Rail has been requested to act as a sub-contractor to supply products and services to you as an end-user, we deem it appropriate to process any personal details provided to us in order to fulfil our contractual obligations to your supplier. We will also collect, directly from you, additional personal data in order to fulfil our processes and ensure a seamless service.  We may also store and process personal data in order to provide additional services such as collections, deliveries and maintenance. Finally, data may be used on job completion to request feedback in the form of a survey; this enables Solo Rail to confirm satisfaction or dissatisfaction with the work we have carried out, and action accordingly.

GLOSSARY

• Customer(s) – refers to companies that have previously been supplied with products or services from Solo Rail and companies that are considered potential customers if they have previously made contact with Solo Rail to enquire about products and services. Customers in the context of this privacy policy also refer to the companies that Solo Rail deem appropriate to directly market with information about our products and services, but may not have had previous communication.
• Supplier(s)– refers to partnerships, companies (including sole traders), independent contractors and freelance workers who provide services to Solo Rail.
• End-user data– refers to the personal data of individuals within a business where Solo Rail have been requested to carry out contractual services, as requested by the end-user via a third-party supplier.
• Sub-contractors – refers to independent limited companies or sole traders who are contracted by Solo Rail to carry out services on behalf of end-users.     
• General Data Protection Regulation (GDPR)– a European Union statutory instrument which aims to harmonise European data protection laws. It has an effective date of 25 May 2018, and any references to it should be construed accordingly to include any national legislation implementing it.
• Website Users – any individual who accesses the Solo Rail website.
• Other terms– “We” refers to Solo Rail the controller and processor of personal data; “You” refers to the customer, supplier, end-user, employee and individual who is protected by the rights and freedoms of GDPR and data protection.

David Hunt, Managing Director

Data Controller for Solo Rail Solutions Ltd

21 May 2018