Privacy Policy

1. Introduction
We, TRS Group (UK) Limited and all associated group companies (“TRS”) of 29 Welbeck Street, London, W1G 8DA, the Data Controller, are committed to respecting the privacy of individuals. This notice outlines how we collect and use your personal information, 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.
We have provided this Privacy Notice to help you understand how we collect, use and protect your information when you visit http://www.trs.co.uk/ and any other TRS website on which this Privacy Notice is posted (each, a “Website” and, collectively the “Websites”), or otherwise communicate with us, for example by phone or in writing by mail or e-mail. We wish to help you make informed decisions, so please take a few moments to read the sections below and learn how we may use your personal information.

If you have any queries in relation to this notice, or need more information please do not hesitate to contact us at:
TRS Head Office
Southbridge Way
The Green
Southall
Middlesex
UB2 4AX

Or email us at mail@trs.co.uk

2. What personal information may we collect about you?

Most of the information we collect about you is obtained directly from you when you enter it via a website or write to us. However, we may also collect information we observe about you, for example via cookies when you visit one of our websites, or CCTV footage if you visit one of our offices or one of our Cash & Carry facilities. We may also collect information about you from public sources.

We will collect the following information:

• Your full name, address, email address and contact details when you submit an enquiry via the Contact Us page on TRS website;
• [Your TRS account passwords and customer numbers];
• Your financial, bank and credit card information;
• Information about your business, business partners, beneficial owners or directors, particularly when you become a customer for our wholesale business or when you become a supplier;
• If you are a customer or supplier of TRS, we will obtain information from any credit checks or other checks we are required to carry out for legal and regulatory purposes;
• Information on your purchases and account balance, as well as your login information, and products you have viewed or searched; and
• Information collected using CCTV surveillance in our offices, depots or Cash & Carry facilities.

3. How do we use your personal information?

We collect and use information about you if you visit one our websites, utilise our services, make customer enquiries or send other communications, apply for jobs at TRS, register for information or when you respond to communications by us.
Your relationship with us will determine why we collect particular information about you. We may be required by law to collect certain information; require it in order to perform a contract, or prior to entering into a contact with you; or use it for our legitimate business interests where these do not override your rights or interest.
We may collect and use your information to:
• Effectively respond to your queries;
• To manage any customer trading account with us and update the records we hold about you from time to time;
• For customers who hold credit accounts, to carry out credit checks;
• To provide you with your goods and information about your goods and our services and to provide you with information about other goods and services we offer that are similar to those you have already purchased or enquired about and that may be of interest to you, to make suggestions and recommendations to you about goods or services that may interest you;
• We may anonymise the data we hold about you or your business and share it with our suppliers for their own reporting or marketing activities;
• Where orders are placed directly with us using an electronic ordering system we may automatically collect and use sales and purchase data to analyse sales of our products;
• Aggregate/process personal data for research, statistical and/or scientific purposes;
• In relation to CCTV, for the prevention of crime and for security purposes;
• Processing audio, video recordings, live stream footage and/or videography or other image(s) for advertising, marketing and/or promotional purposes, if your consent has been provided to do so;
• Any other processing for which you have given your consent, for example receiving marketing information or surveys.

4. Special categories of personal information

Special protection is given to certain kinds of personal data that is particularly sensitive. This is information about your health status, racial or ethnic origin, political views, religious or similar beliefs, sex life or sexual orientation, genetic or biometric identifiers, trade union membership (‘special categories of personal data’) or about your criminal convictions or offences.

Where we collect any special categories of personal data, we will take appropriate technical and security measures to ensure that we have explicit consent or another legal basis to hold, use and retain the sensitive personal information.

5. Who has access to your personal information?

Your information will be processed by employees of TRS in order to fulfil our obligations to you as outlined in this notice. We may also share your details with third parties including:

• Contractors working on behalf of or in partnership with TRS;
• Our third-party suppliers/service providers who perform functions on our behalf under contract, support our systems, operations and/or processes;
• Sub-contractors we may use in technical, payment and delivery services;
• Credit reference agencies and other background check providers;
• Tax, audit, or other authorities, when we believe in good faith that the law or other regulation requires us to share this information, for example where processes and systems are being compliance assessed by TRS’s corporate audit or their representatives;
• Law enforcement or other regulatory bodies who can legally request access to information about you for prevention and detection of crime, the apprehension or prosecution of offenders, and the assessment or collection of tax;

We may also share personal information with relevant third parties where we sell or buy any business or assets, or to enforce or apply our Terms of Use or Terms and Conditions of Sale.

6. Information security and International Transfers

TRS is committed to being transparent and taking all reasonable and appropriate steps to keep your personal information secure and to protect it from misuse, loss, or unauthorised access. We do this by having in place a range of appropriate technical and organisational measures.

We are also obliged to tell you where we use services that transfer your information internationally. At TRS we have a strict selection process when it comes to our suppliers/ service providers and we enforce strict requirements within our contracts to ensure your personal information is stored and transferred in a way which is secure.

In the event that TRS transfers personal information to service providers outside the EEA in the future, we will take all reasonable steps to ensure that your personal data is processed securely. We will only transfer personal information outside the EEA where it is compliant with applicable data protection legislation and the means of transfer provides adequate safeguards in relation to your personal information.
If personal information is transferred outside the EEA, we will ensure that we have entered into contracts with all our suppliers and service providers which include the current EU Commission approved model clauses concerning the protection of the data transferred.

7. How long will you keep my personal information?

We will not retain your personal information for any longer than is necessary for our purposes, including for the purposes of satisfying any legal, accounting or reporting requirements. If you have any questions about data retention then please email mail@trs.co.uk

Where we have been using your personal information to provide you with marketing, we will remove you from our marketing list if you ask us to do so, but we may still need to keep some of your information for ongoing contractual purposes if you continue to be our customer and for legal, accounting and regulatory reporting reasons.

8. Changes to this notice

Just as our business changes constantly, this notice may also change. To assist you, this notice has an effective date set out at the end of this notice.

9. What rights do I have with regards to my personal data?

To exercise your privacy rights please send your request in writing. We may be required to verify your identity for security purposes. Your rights are outlined below:

o The right to access information we hold about you, why we have that information, who has access to the information and where we obtained the information from.
o The right to correct and update the information we hold about you. If the data we hold about you is out of date, incomplete or incorrect you can inform us and your data will be updated.
o The right to have your information erased. If you feel we should no longer be using your data you can request that we erase the data that we hold. Upon receiving a request for erasure we will confirm whether it has been deleted or a reason why it cannot be deleted (for example because we have a legal obligation to keep the information or we need it for a legitimate business interest).
o The right to object to processing of your data. You may request that we stop processing information about you. Upon receiving your request we will contact you and let you know if we are able to comply or if we have legitimate grounds to continue to process your data. Even after you exercise your right to object, we may continue to hold your data to comply with your other rights or bring or defend legal claims.
o The right to data portability. You have the right to request that we transfer your data to another controller.
o The right to request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data: (a) if you want us to establish the data’s accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) 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 (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
o The right to withdraw consent at any time where we are relying on consent to process your personal data.

We will comply with your request where it is feasible to do so, within 30 days of receiving your request. There are no fees or charges for the first request. However additional requests for the same data may be subject to an administrative fee of £25 per request.

To exercise your rights please do so by writing to:

TRS Head Office
Southbridge Way
The Green
Southall
Middlesex
UB2 4AX

Or e-mail mail@trs.co.uk

10. Consent

Where we need your consent to hold your information we will ask you to confirm your consent in writing and we will inform you why we are collecting the information, how we will use it, how long we keep it for, who else will have access to it and what your rights are as a data subject.. Where we do rely on consent you have the right to change your mind and withdraw that consent at any time by writing to us. If you withdraw your consent we will immediately cease using any personal information obtained and processed under that consent unless we have some other legal obligation to continue to use it.

11. Use of Cookies

TRS utilises cookies to enhance your browsing experience.

12. What can I do if I am not satisfied with how my personal information is processed?

At TRS we aim to ensure all information collected about you is done so fairly and lawfully, whilst implementing robust measures to keep your information secure. If you are not satisfied with the information provided in this notice, please contact us in the first instance so we can resolve your queries or provide you with any additional information required.

Alternatively it is your right to contact your local Data Protection Authority and lodge a complaint. In the UK the lead Data Protection Authority is the Information Commissioner. For more information please visit the Information Commissioner’s office at www.ico.org.uk/concerns, call them on 0303 123 1113, or write to them at Information Commissioner’s Office, Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF.

If you have any queries in relation to this notice, or need more information please do not hesitate to contact us at:
TRS Head Office
Southbridge Way
The Green
Southall
Middlesex
UB2 4AX

Or email us at mail@trs.co.uk

Effective date: 1st June 2018