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Privacy and Data Protection Policy

Last Update:  11 November 2023

Privacy notice

Troy (UK) Ltd is aware of its obligations under the General Data Protection Regulation (GDPR) and is committed to processing your data securely and transparently. This privacy notice sets out, in line with GDPR, the types of data that we hold on you as a customer, member or supplier of Troy (UK) Ltd. It also sets out how we use that information, how long we keep it for and other relevant information about your data.


This notice applies to data controlled by the Troy Group on behalf of current and former customers, members, and suppliers.

Data controller details

Troy (UK) Ltd is a data controller, meaning that it determines the processes to be used when using your personal data.


Data protection principles

In relation to your personal data, we will:


  • process it fairly, lawfully and in a clear, transparent way

  • collect your data only for reasons that we find proper for the course of your contract in ways that have been explained to you

  • only use it in the way that we have told you about

  • ensure it is correct and up to date

  • keep your data for only as long as we need it

  • process it in a way that ensures it will not be used for anything that you are not aware of or have consented to (as appropriate), lost or destroyed


Types of data we process

We hold many types of data about you, including some of the following:


  • name, business address, contact numbers, email address, comments, reviews, survey responses

  • interactions/information collected through social media, activity on Troy Group websites

  • company credit history, purchasing and payment history

  • terms and conditions of engagement


How we collect your data

We collect data about you in a variety of ways and this will usually start when we undergo a contract where we will collect the data from you directly.


We collect further data when you register online, place an order for a product or service, complete a survey, provide feedback on social media, message boards or via email, and through your interaction with our websites using cookies.

In some cases, we will collect data about you from third parties, such as credit reference agencies.  We will not collect this data without your consent.


Personal data is kept in company files or within the Company’s IT systems.

Why we process your data

The law on data protection allows us to process your data for certain reasons only:


  • in order to perform a contract that we are party to

  • in order to carry out legally required duties

  • in order for us to carry out our legitimate interests

  • to protect your interests and 

  • where something is done in the public interest.

All of the processing carried out by us falls into one of these permitted reasons. Generally, we will rely on the first three reasons set out above to process your data. For example, we need to collect your personal data in order to:


  • carry out the contract that we have entered into with you and

  • to ensure the appropriate credit checks are performed.


We also collect data so that we can carry out activities which are in the legitimate interests of the Company. We have set these out below:


  • making decisions about rebates and other benefits

  • providing contractual benefits to you

  • maintaining comprehensive up to date records about you to ensure, amongst other things, effective correspondence can be achieved

  • business planning and forecasting exercises

  • dealing with legal claims made against us

  • preventing fraud ensuring our administrative and IT systems are secure and robust against unauthorised access

If you do not provide your data to us

One of the reasons for processing your data is to allow us to carry out our duties in line with your contract. If you do not provide us with the data needed to do this, we will be unable to perform those duties. We may also be prevented from confirming, or continuing with, your contract with us in relation to our legal obligations if you do not provide us with this information.


Sharing your data

Your data will be shared with colleagues within Troy (UK) Ltd where it is necessary for them to undertake their duties. This includes, for example, the Marketing Team to make you aware of offers and trade events, and the Accounts department for maintaining records and administering payments.


We share your data with third parties to undertake the following:


  • Insurers and/or credit bureaus – for the provision of credit facilities.


We may also share your data with third parties as part of a Company sale or restructure, or for other reasons to comply with a legal obligation upon us.


We do not share your data with third parties that are not directly associated with the Troy Group.


Protecting your data

We are aware of the requirement to ensure your data is protected against accidental loss or disclosure, destruction and abuse. We have implemented processes to guard against such.


  • Data is held on a secure IT drive centrally which has restricted access.

  • Data sent via e-mail will be, wherever possible, encrypted and deleted on receipt.


Where we share your data with third parties, we provide written instructions to them to ensure that your data is held securely and in line with GDPR requirements. Third parties must implement appropriate technical and organisational measures to ensure the security of your data.


Whenever personal information is held in a country that does not provide an adequate level of protection for personal information, we will ensure our data processors take adequate measures designed to protect the personal information, such as ensuring that any such transfers or processing are subject to the terms of the Data Protection Act (2018) or other adequate transfer mechanisms as required under relevant data protection laws.


How long we keep your data for

In line with data protection principles, we only keep your data for as long as we need it for, which will be at least for the duration of your contract with us though in some cases we will keep your data for a period after your contract has ended. Retention periods can vary depending on why we need your data.


Your rights in relation to your data

The law on data protection gives you certain rights in relation to the data we hold on you. These are:


  • the right to be informed. This means that we must tell you how we use your data, and this is the purpose of this privacy notice

  • the right of access. You have the right to access the data that we hold on you. To do so, you should make an enquiry on the web forms available

  • the right for any inaccuracies to be corrected. If any data that we hold about you is incomplete or inaccurate, you are able to require us to correct it

  • the right to have information deleted. If you would like us to stop processing your data, you have the right to ask us to delete it from our systems where you believe there is no reason for us to continue processing it

  • the right to restrict the processing of the data. For example, if you believe the data we hold is incorrect, we will stop processing the data (whilst still holding it) until we have ensured that the data is correct

  • the right to portability. You may transfer the data that we hold on you for your own purposes

  • the right to object to the inclusion of any information. You have the right to object to the way we use your data where we are using it for our legitimate interests

  • the right to regulate any automated decision-making and profiling of personal data. You have a right not to be subject to automated decision making in a way that adversely affects your legal rights.

Where you have provided consent to our use of your data, you also have the unrestricted right to withdraw that consent at any time. Withdrawing your consent means that we will stop processing the data that you had previously given us consent to use. There will be no consequences for withdrawing your consent. However, in some cases, we may continue to use the data where so permitted by having a legitimate reason for doing so.


If you wish to exercise any of the rights explained above, please contact us using the web contact us forms.


Making a complaint

The supervisory authority in the UK for data protection matters is the Information Commissioner's Office (ICO). If you think your data protection rights have been breached in any way by us, you are able to make a complaint to the ICO.

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