INEOS AUTOMOTIVE
LEARNING MANAGEMENT SYSTEM (“LMS”)
PRIVACY NOTICE
INEOS Automotive Limited (“INEOS Automotive”) respects your privacy and is committed to protecting your personal data. This privacy notice will inform you as to how we look after your personal data when you visit our website (regardless of where you visit it from) and tell you about your privacy rights and how the law protects you.
This privacy notice is provided in a layered format so you can click through to the specific areas set out below. Please also use the Glossary to understand the meaning of some of the terms used in this privacy notice.
1. IMPORTANT INFORMATION AND WHO WE ARE
Purpose of this privacy notice
This privacy notice aims to give you information on how INEOS Automotive collects and processes your personal data through your use of this website, including any data you may provide through this website when you sign up to our newsletter, take a survey, purchase a product or service, indicate an interest in purchasing a product or service or take part in a competition
This website is not intended for children and we do not knowingly collect data relating to children.
It is important that you read this privacy notice together with any other privacy notice or fair processing notice we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. This privacy notice supplements the other notices and is not intended to override them.
INEOS Automotive
INEOS Automotive is part of the INEOS group of companies (the “INEOS Group”), details of which can be found here https://www.ineos.com/
INEOS Automotive has appointed a data protection officer (“DPO”) who is responsible for overseeing questions in relation to this privacy notice. If you have any questions about this privacy notice, including any requests to exercise your legal rights, please contact the DPO using the details set out below.
Contact details
Full name of legal entity: INEOS Automotive Limited, an English limited liability company (Company number 11201576)
Name or title of DPO: Head of Legal
Email address: dataprotection@ineosgrenadier.com
Postal address: Anchor House, 15 – 19 Britten Street, London, SW3 3TY, United Kingdom
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 (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.
Changes to the privacy notice and your duty to inform us of changes
This version of the privacy notice was last updated on 22 July 2022.
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.
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 notice of every website you visit.
2. THE DATA WE COLLECT ABOUT YOU
Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous or anonymised data).
INEOS Automotive may at various times collect, use, store and transfer different kinds of personal data about you which we have grouped together follows, as well as any other data that you may give to us/selected third party as a result of enrolling and attending the training:
§ Training Data: assigned learning plan, assigned courses, scheduled courses, enrollments, achieved results/completion, training location, course date of completion, qualification status, assessment information, survey and feedback, training records (course names, participation dates, training enrolments, training completions)
When we mention “INEOS Automotive”, in this privacy notice, we are referring to the relevant company in the INEOS Group responsible for processing your data. INEOS Automotive is one of the controllers and is jointly responsible for this website.
We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data may be derived from your personal data but is not considered personal data in law as this data does not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy notice.
We do not collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data). Nor do we collect any information about criminal convictions and offences.
Throughout this privacy notice, references to “we”, “us” or “our” are to INEOS Automotive as controller of your personal data as set out above.
If you fail to provide personal data
Where we need to collect personal data by law, or under the terms of a contract we have with you and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with goods or services). In this case, we may have to cancel a product or service you have with us but we will notify you if this is the case at the time.
3. HOW IS YOUR PERSONAL DATA COLLECTED
We use different methods to collect data from and about you including through:
4. HOW WE USE YOUR PERSONAL DATA
We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:
If we rely on consent as a legal basis for processing your personal data (for example, in relation to sending third party direct marketing communications to you via email or text message), you have the right to withdraw consent to marketing at any time by contacting us at dataprotection@ineosgrenadier.com.
Purposes for which we will use your personal data
We have set out in a table format (accessible via the link below) a description of all the ways we plan to 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.
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. Please contact us at dataprotection@ineosgrenadier.com if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below.
(See Table A below)
Third-party marketing
We will get your express opt-in consent before we share your personal data with any company outside the INEOS group of companies for marketing purposes.
Opting out
You can ask us or third parties to stop sending you marketing messages at any time by following the opt-out links on any marketing message sent to you or by contacting us at any time at dataprotection@ineosgrenadier.com.
Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of a product/service purchase, warranty registration, product/service experience or other transactions.
Cookies
You can set your browser to refuse browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies which are necessary for the operation of the website, please note that some parts of this website may become inaccessible or not function properly. For more information about the cookies we use, please see our cookie policy.
What kind of cookies does this Site use?
Two cookies are used by this site:
The essential one is the session cookie, usually called TotaraSession. You must allow this cookie into your browser to provide continuity and maintain your login from page to page. When you log out or close the browser this cookie is destroyed (in your browser and on the server).
The other cookie is purely for convenience, usually called something like TOTARAID. It just remembers your username within the browser. This means when you return to this site the username field on the login page will be already filled out for you. It is safe to refuse this cookie - you will just have to retype your username every time you log in.
Change of purpose
We will only use your personal data for the purposes for which we originally collected it. If we need to use your data for another purpose, we may do so as long as it is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us at dataprotection@ineosgrenadier.com.
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 above rules, where this is required or permitted by law.
5. DISCLOSURES OF YOUR PERSONAL DATA
We may have to share your personal data with the parties set out below for the purposes set out in the table in paragraph 4 above.
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 may share your personal data within the INEOS Group and with our third party provider of training services Vertex Professional Services, a trading name of Vertex Company UK 1 Limited (“Vertex”). This will involve transferring your data outside the UK and the European Economic Area (the “EEA”). It should also be noted that INEOS Automotive itself is based in the UK.
In addition, if you seek to use our training services when you are located outside the EEA, your information may be transferred outside the EEA in order to provide you with those products or services.
Our external third-party service provider (Vertex) is based outside the EEA so their processing of your personal data will involve a transfer of data outside the EEA.
Whenever we transfer your personal data out of the EEA, we ensure a similar degree of protection is afforded to it, including by ensuring that there is a legal agreement in place which covers such transfer of personal data (which may include using specific contracts approved by the European Commission which give personal data the same protection it has in the EEA).
Please contact dataprotection@ineosgrenadier.com if you want further information on the specific mechanism used by us when transferring your personal data out of the EEA.
We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.
We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.
How long will you use my personal data for?
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.
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 for tax purposes.
In some circumstances you can ask us to delete your data – please contact us for further information.
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, as such information would cease to be personal data, we may use this information indefinitely without further notice to you.
Under certain circumstances, you have rights under data protection laws in relation to your personal data. Please click on the links below to find out more about these rights:
If you wish to exercise any of the rights set out above, please contact us at dataprotection@ineosgrenadier.com.
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 may 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 may 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. GLOSSARY
Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give you the best service/product and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights 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). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us at dataprotection@ineosgrenadier.com.
Performance of Contract means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.
Comply with a legal or regulatory obligation means processing your personal data where it is necessary for compliance with a legal or regulatory obligation that we are subject to.
Other companies in the INEOS Group acting as joint controllers or processors and who are based the EU and/or UK. This may include INEOS Group companies whose products we feel may be of interest to you.
You have the right to:
to your personal data (commonly known as a “data 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.
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.
of your personal data. 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.
of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
Request restriction of processing
of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios: (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.
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.
at any time where we are relying on consent to process your personal 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.
|
Purpose/Activity |
Type of data |
Lawful basis for processing including basis of legitimate interest |
|
To register you as a new user of the website |
(a) Identity (b) Contact (c) Organisation |
Performance of a contract with you or provision of training in connection with performance of a contract |
|
To ensure delivery of appropriate training in relation to INEOS products and services |
(a) Identity (b) Contact (c) Marketing and Communications (d) Organisation (e) Training |
(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) Asking you to leave a review or take a survey |
(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 to study how customers use our products/services) |
|
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 deliver relevant website content and training to you and measure or understand the effectiveness of the training we provide to you |
(a) Identity (b) Contact (c) Profile (d) Usage (e) Marketing and Communications (f) Technical |
Necessary for our legitimate interests (to ensure efficient delivery of effective and appropriate training in relation to INEOS products and services) |
|
To use data analytics to improve our website, training services, marketing, partner relationships and customer experiences |
(a) Technical (b) Usage (c) Organisation (d) Training |
Necessary for our legitimate interests (to define training needs for our products and services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy) |
|
To enable us to administer messages or contributions you make via the website |
(a) Identity (b) Contact (c) Profile |
Necessary for our legitimate interests (to handle and respond to the content posted) |