Last updated: [•] 2018
However, if you do not have time to read it in full we have summarised the key points for you in our 'speed read' section below.
- Gas-Trak Online (“GTO”) is a trading name of A-Gas (UK) Limited (we, our or us). We are registered as a data controller with the Information Commissioner's Office and our registration number is Z4822906.
- We process (i.e. handle) your personal data to provide our services to you. Under data protection laws, we are only permitted to process your personal data where we have a legal basis for doing so. We will only ever process your personal data in compliance with applicable law.
- We will keep your personal data for as long as we need it. How long we need your personal data depends on what we are using it for, whether that is to provide services to you, for our own legitimate interests (described below) or so that we can comply with the law. We will actively review the information we hold and when there is no longer a customer, legal or business need for us to hold it, we will either delete it securely or in some cases anonymise it.
- We may transfer your personal data to a recipient located outside of the European Economic Area (EEA). If we do this, we will ensure that the transfer mechanism provides an adequate level of protection, which has been recognised by the European Commission.
- ABOUT GTO
- WHAT PERSONAL DATA DO WE COLLECT ABOUT YOU?
- HOW IS YOUR PERSONAL DATA COLLECTED?
- PURPOSES FOR WHICH WE WILL USE YOUR PERSONAL DATA
- WHO WILL HAVE ACCESS TO YOUR PERSONAL DATA?
- WHO ELSE MIGHT WE SHARE YOUR PERSONAL DATA WITH?
- HOW DO WE PROTECT YOUR PERSONAL DATA?
- HOW LONG DO WE KEEP YOUR PERSONAL DATA?
- WHAT ARE YOUR RIGHTS?
- WHO CAN YOU ASK FOR MORE INFORMATION?
1. About GTO
1.1 Gas-Trak Online (“GTO”) (we, our or us) is a trading name of A-Gas (UK) Limited, a company registered in England and Wales under company number 02752249 whose registered office is at Banyard Road, Portbury, Bristol, BS20 7XH.
1.2 We are registered as a data controller with the Information Commissioner's Office and our registration number is Z4822906.
(a) the GTO App, once you have downloaded or streamed a copy of the GTO App onto your mobile telephone or handheld device (Device);
(b) the Website; and
(c) your use of the Reports,
(together, the Services).
3. What personal data do we collect about you?
3.1 This section tells you about the information we collect about you and why. Personal data means any information about an individual from which that individual can be identified.
3.2 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, surname and photographs.
- Contact Data includes email address and telephone numbers.
- Financial Data includes payment card details.
- Transaction Data includes details about payments.
- Technical Data includes internet protocol (IP) address, your login data, browser type and version, information about your Device, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access the GTO App and the Website.
- Profile Data includes your username and password.
- Service Data includes information about usage of cylinders, customer data, equipment date and job date.
- Marketing and Communications Data includes your preferences in receiving marketing from us and your communication preferences.
4. How is your personal data collected?
We use different methods to collect data from and about you including through:
4.1 Direct interactions:
We collect personal data about you if you fill in forms on the GTO app, our Website or correspond with us by telephone, email or otherwise. This includes information you provide when you:
- register to use the GTO App, log-in to the Website or through your use of any of our Services, or when you report an issue with an any of our Services;
- fill in forms on the GTO App and the Website;
- report a problem with the GTO App or our Website or give us feedback; and
- if you contact us directly with any query, or correspond with us (for example, by e-mail or telephone), we may keep a record of that correspondence.
We may also ask you to share your personal data with us if it is necessary for us to provide our services to you.
4.2 Automated technologies or interactions:
When you use our Services, a Device may automatically collect and send the following information: technical information, including the type of Device you use, a unique device identifier (for example, your Device's IMEI number, the MAC address of the Device's wireless network interface, or the mobile phone number used by the Device), unique application numbers, network information, Device operating system.
We automatically collect the following information:
- details of your use of any of the GTO App or your visits to the Website (including, but not limited to, traffic data) and the resources that you access in the Services may be sent to us automatically;
- other technical information we may receive, includes the Internet protocol (IP) address used to connect your computer to the internet, plug-in types and versions, operating system and platform, the type and version of browser you use and time zone setting; and
- information about your visit, including the full Uniform Resource Locators (URLs) clickstream to, through and from our Website (including date and time); time on page, page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks and mouse-overs).
Where we collect information about you in the ways described above, we do so on the basis that it is in our legitimate interests to collect and process this data. In most situations this will be anonymised but we collect and process this data to ensure that our site is functioning properly and that our customer experience is to the standard that you and we expect.
Some of our location-enabled Services require your personal data for the feature to work. If you wish to use the particular feature, you will be asked to consent to your data being used for this purpose. You can withdraw your consent at any time by changing the settings on your Device or de-activating the setting on your browser.
The GTO App and the Website may, from time to time, contain links to and from the websites of advertisers and affiliates. If you follow a link to any of these websites, please note that these websites have their own privacy policies and that we do not accept any responsibility or liability for these policies. Please check these policies before you submit any personal data to these websites.
No automated decision-making or profiling will take place using your personal data.
4.3 Information we receive from other sources:
We may receive information about you if you use any other website we operate or the other services we provide. We are also working closely with third parties, (including, for example, business partners, sub-contractors in technical, payment and delivery services, advertising networks, analytics providers, search information providers, credit reference agencies) and may receive information about you from them, in particular where you purchase any of our products or services through such third parties. In addition, we may receive information about you from third parties who provide it to us (e.g. your employer, our customers and law enforcement authorities).
When we receive information from other sources, we rely on them having the appropriate provisions in place telling you how they collect data and who they may share it with. We carefully check our sources to ensure that we only receive your information when it is lawful for us to do so.
5. Purposes for which we will use your personal data
This section explains how we will use personal data you provide to us in order to carry out the activities relevant to the provision of our Services to you.
We must have a legal basis for processing your personal data. We consider that we have a legal basis where:
- you have given us consent to do so for the specific purposes which we have told you about;
- it is necessary for us to do so to enable us to provide you with the services that you have requested from us;
- it is necessary in order to fulfil our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests; or
- the law otherwise permits or requires it.
Where we process your personal data on the basis of our legitimate interests, these are our (or our third party’s) interests in providing our services to you in an efficient and secure manner.
We have set out below a list of all the ways we may use your personal data and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are, where appropriate.
In some cases we may use more than one legal basis for processing your personal data; this will depend on the specific purpose for which we are using your personal data. Please contact us using the contact details in section 14 if you have any queries about the specific legal basis that we rely on for processing your personal data.
What we use your personal data for (purpose)
Type of data
Legal basis for processing (including basis of legitimate interest)
To register you as a new customer
Performance of a contract with you
To carry out our obligations arising from any contracts entered into between you and us including:
(a) managing payments or charges;
(b) collecting and recovering money owed to us;
(c) running fraud checks if we have reasonable suspicions;
(d) provide you with the information, products and services that you request from us.
(a) Performance of a contract with you
(b) Necessary for our legitimate interests (to recover debts due to us and to help us prevent fraud
To respond to your enquiries or to process your requests in relation to your information.
Performance of a contract with you
To maintain a suppression list should you opt-out of receiving communications
Necessary for our legitimate interests (to ensure that we are not at risk of breaching data protection laws by communicating with you where you have asked us not to.)
To manage our relationship with you which will include:
b) asking you to leave a review or take a survey
(d) Marketing Communications
(a) Performance of a contract with you
(b) Necessary to comply with a legal obligation
(c) Necessary for our legitimate interests
To administer and protect our business, the GTO App and the Website (including training our employees, troubleshooting, data analysis, testing, system maintenance, security audits, support, reporting and hosting of data).
(a) Necessary for our legitimate interest (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)
To use data analytics to improve the GTO App, the Website, products/services, marketing, customer relationships and experiences
Necessary for our legitimate interests (to define types of customers for our products and services, to keep the GTO App and the Website updated and relevant, to develop our business and to inform our marketing strategy)
To establish, exercise and defend our legal rights
All types of data referred to in paragraph 3.2
(a) Necessary for compliance with a legal obligation
(b) Necessary for our legitimate interest (for the purpose of establishing, exercising or defending our legal rights)
This section is to explain how we will ensure that you only receive communications that you wish to receive.
6.1 Marketing communications:
We can only use your personal information to send you marketing messages if we have either your consent or a ‘legitimate interest’. A ‘legitimate interest’ is when we have a business or commercial reason to use your information. It must not unfairly go against what is right and best for you.
The personal data we have for you is made up of what you tell us, and the data we collect about you when you use our Services, or data provided to us from third parties we work with.
If you have provided your consent to receive marketing communications from us and you change your mind, you can change your preferences and unsubscribe at any time by unsubscribing from the relevant communication channel, or by contacting us using the contact details in section 14. If you choose not to receive this information we will be unable to keep you informed of new products, services and promotions that may interest you.
6.2 Service communications
As detailed in the table at section 5, we may send you communications such as those which relate to any service updates relating to the GTO App. We consider that we can lawfully send these communications to you as we have a legitimate interest to do so, namely to effectively provide you with the best service we can and to grow our business.
7. Who will have access to your personal data
We take your privacy seriously and have implemented appropriate physical, technical and organisational security measures designed to secure your personal data against accidental loss, destruction or damage and unauthorised access, use, alteration or disclosure.
8. Who else might we share your personal data with
We may share your personal data with you, and where appropriate, your associates and your representatives.
We may share your personal data with any member of our group which means our subsidiaries, our ultimate holding company and its subsidiaries as defined in section 1159 of the UK Companies Act 2006.
We may share your personal data with the following third-parties who assist us with administering the provision of our services to you:
- business partners, suppliers and sub-contractors for the performance of any contract we enter into with them or you;
- analytics and search engine providers that assist us in the improvement and optimisation of our Website;
- agents we engage to perform functions on our behalf including sending customer communications, analysing data, providing marketing assistance and processing payments. They have access to personal data needed to perform their functions, but may not use it for other purposes.
We may also disclose your personal data to third parties for the following purposes:
- to enforce or apply the Terms and Conditions or investigate potential breaches; or
- to a law enforcement agency or court to the extent necessary for purposes including preventing, investigating, detecting, and prosecuting criminal offences; preventing threats to public security in accordance with applicable law; or validating a claim; or
- to protect the rights, property or safety of A-Gas (UK) Limited, our customers, or others (including exchanging information for the purposes of fraud protection and credit risk reduction); or
- if A-Gas (UK) Limited or substantially all of its assets are sold to or acquired by a third party, in which case we may disclose or transfer your personal data to the prospective buyer. If this happens, you will be informed of this transfer.
We may also pass Aggregated Data on the usage of the GTO App and our Website (e.g. we might disclose the median ages of visitors, or the numbers of visitors that come from different geographic areas) to third parties but this will not include information that can be used to identify you personally.
9. How do we protect your personal data?
This section explains how we keep your personal data safe and where it will be held.
We take your privacy seriously and are committed to maintaining the privacy and security of the personal data you provide to us, and the choices you have regarding our collection and use of your personal data.
Once we have received your personal data, we follow strict security procedures as to how your personal data is stored and used, and who sees it, to help stop any unauthorised access.
Any payment transactions will be encrypted. Where we have given you (or where you have chosen) a password which enables you to access certain parts of our site, you are responsible for keeping this password confidential. You should not share this information with anyone.
The information that we collect from you may be transferred to, and stored at, a destination outside the European Economic Area (EEA). When we transfer and store your personal data outside of the EEA we will ensure that it is adequately protected by using appropriate safeguards as further detailed below.
Staff operating outside the EEA who work for us, or one of our suppliers, may process the information. Such staff may be engaged in, among other things, the processing of your payment details and the provision of support services;
Where your personal data is transferred from the EEA to a recipient outside the EEA in a country not recognised by the European Commission as providing an adequate level of protection for personal data, such transfer shall be covered by a framework recognised by the relevant authorities or courts as providing an adequate level of protection for personal data including but not limited to:
- Standard Contractual Clauses (the agreement in the form annexed to the European Commission's decision of 5 February 2010 on Standard Contractual Clauses for the transfer of personal data to processors established in third countries which can be found here); or
- The EU-US Privacy Shield Framework.
Unfortunately, the transmission of your personal data via the internet is not completely secure and although we do our best to protect your personal data, we cannot guarantee the security of your data transmitted to the GTO App or our Website and you acknowledge that any transmission is at your own risk.
10. How long do we keep your personal data?
This section explains the length of time that we will retain your personal data.
We will keep your personal data for no longer than is necessary for the purposes for which it was obtained. The criteria for determining the duration for which we will retain your personal data are as follows:
(1) we will retain your personal data in a form that permits identification only for as long as:
(i) we maintain an ongoing relationship with you; or
(ii) your personal data is necessary in connection with the lawful purposes set out in this policy for which we have a valid legal basis.
(2) the duration of:
(iii) any applicable limitation period under applicable law (i.e. any period during which any person could bring a legal claim against us in connection with your personal data, or to which your personal data may be relevant); or
(iv) an additional reasonable period following the end of such applicable limitation period.
(3) in addition, if any relevant legal claims are brought, we may continue to process your personal data for such additional periods as are necessary in connection with that claim.
During the periods in paragraphs (2)(i) and (2)(ii) above, we will restrict our processing of your personal data to the storage of, and maintaining the security of, those data, except to the extent that those data need to be reviewed in connection with any legal claim or obligation under applicable law.
After this period your personal data will be anonymised so that you are no longer identified or identifiable from such information, or securely deleted/destroyed.
Any third parties that we engage will keep your data stored on their systems for as long as is necessary to provide the relevant services to you or us. If we end our relationship with any third party providers, we will make sure that they securely delete or return your personal data to us.
We may retain personal data about you for statistical purposes (for example, to help us better advertise our services). Where data is retained for statistical purposes it will always be anonymised, meaning that you will not be identifiable from that data.
11. What are Your rights
This section explains that you have a number of rights in relation to your personal data. There are circumstances in which your rights may not apply. You have the right to request that we:
- provide you with a copy of the information we hold about you;
- update any of your personal information if it is inaccurate or out of date;
- delete the personal data we hold about you - if we are providing services to you and you ask us to delete personal data we hold about you then we may be unable to continue providing those services to you;
- restrict the way in which we process your personal data;
- stop processing your data if you have valid objections to such processing; and
- transfer your personal data to a third party.
For more information on your rights and how to use them, or if you would like to make any of the requests set out above, please contact us using the details provided in section 14. We will respond to all such requests within the time period required by law. Occasionally it may take us longer, if your request is particularly complex, you have made a number of requests or you have not supplied the information we need to respond to you. In this case, we will notify you and keep you updated.
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.
As explained in the section on Communications, even if you consented to the processing of your personal data for marketing purposes (by ticking the relevant box or by requesting information about services), you have the right to ask us to stop processing your personal data for such purposes. You can exercise this right at any time by unsubscribing from the relevant communication channel, changing your preferences in the preference centre or by contacting us at firstname.lastname@example.org.
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 may refuse to comply with your request in these circumstances.
12.2 A cookie is a small file of letters and numbers that we store on your browser or the hard drive of your computer if you agree. Cookies contain information that is transferred to your computer's hard drive.
12.3 We use the following cookies:
(a) Strictly necessary cookies. These are cookies that are required for the operation of our website. They include, for example, cookies that enable you to log into secure areas of our website, use a shopping cart or make use of e-billing services.
(b) Analytical/performance cookies. They allow us to recognise and count the number of visitors and to see how visitors move around our website when they are using it. This helps us to improve the way our website works, for example, by ensuring that users are finding what they are looking for easily.
(c) Functionality cookies. These are used to recognise you when you return to our website. This enables us to personalise our content for you, greet you by name and remember your preferences (for example, your choice of language or region).
(d) Targeting cookies. These cookies record your visit to our website, the pages you have visited and the links you have followed. We will use this information to make our website and the advertising displayed on it more relevant to your interests. We may also share this information with third parties for this purpose.
12.4 You can find more information about the individual cookies we use and the purposes for which we use them in the table below:
Expiry Period for cookie
Used to distinguish users
Checks for whether the fonts have been loaded by this browser already (so as not to load them again on page reloads).
Agree to Cookies
Used to determine whether the user has agreed to cookie usage.
30 days and auto-renews every time the user visits the site
Various cookies used by Google Analytics to track page views, visits and traffic sources.
Varies between 30mins and 2 years
Used to distinguish users
Used to throttle request rate
12.5 You may block cookies by activating the setting on your browser that allows you to refuse the setting of all or some cookies. However, if you use your browser settings to block all cookies (including essential cookies) you may not be able to access all or parts of our site.
14. Who can you ask for more information?
Alternatively, you can contact us through the Contact Us section of the Website.
If you are unsatisfied with our response to any data protection issues you raise with us or our DPO, you have the right to make a complaint to the Information Commissioner’s Office (ICO). The ICO is the authority in the UK which is tasked with the protection of personal data and privacy.