Trailnet CIC – Privacy Policy & Notice
About this Policy
This privacy policy and general privacy notice applies to Trailnet CIC. We at Trailnet
CIC take your privacy seriously, and this policy and notice has been drafted in
accordance with the requirements of the General Data Protection Regulations
(“GDPR”), with the support of the legal team at www.legalo.co.uk.
This privacy notice explains how we look after your personal data (in all situations
where we collect your data), sets out your privacy rights and explains how the law,
and our approach to privacy and personal data, protects you.
This privacy notice supplements any other privacy notices that we may provide to
you at the point that we collect data from you, and should be read in conjunction
with those notices.
Our status and details
For the purpose of the GDPR, we are the data controller and any enquiry regarding
the collection or processing of your data should be addressed to our [Data Protection
Officer OR Privacy Manager] using the contact details below:
Name or title: Bernadette Lawson
Email address: office@trailnet.org.uk
Postal address: Thorndon Cycle Centre, Thorndon Country Park, The Avenue,
Brentwood CM13 3RZ
By using this Website, you consent to this policy. We are registered with the
Information Commissioner’s Office for this purpose.
Information we collect
We will collect, process and store personal data only if it is directly provided to us by
you. You may do this in your capacity as the user of this Website, by enquiring in
relation to our goods or services, becoming a customer or supplier, or potential
supplier.
Personal information covers any information which relates to you as an identifiable
person. Below are examples of the type of data that this may include:
(a) Identity Data including forenames, last name, maiden name, date of birth,
gender, marital status, and username or similar identifier.
(b) Contact Data may include invoicing; purchase order; home or work address,
email address and telephone numbers, personal or job title and position.
(c) Financial Data may include bank account and payment card details.
(d) Special Category Data for example health or medical data, details about your
race, religion, sex and political opinions.
(e) Transaction Data may include payments made for products and services you
have purchased from us, or in relation to payments that we have made to
you.
(f) Technical Data may include internet protocol (IP) address, browser type and
version, time zone setting and location, browser plug-in types and versions,
operating system and platform and other technology on the devices used to
access this Website.
(g) Profile and Usage Data may include enquiries submitted by you, purchases
information, feedback and survey responses, and how you use our website,
products and services.
(h) Marketing Data may include details of any preference that you have advised
us of in relation to marketing communications from us.
We may also collect non-personal data such as aggregated data, which is data that
may be obtained from your personal data, but which does not directly or indirectly
identify you. This may include usage data detailing how you use our website and the
features and areas that you have interacted with.
How do we collect your personal data?
A range of different methods may be used to collect data, which may include the
following methods:
(a) Direct interactions with us in person, by post, phone, email or otherwise. For
example, you might give us your Identity, Contact and Financial Information in
this way.
(b) Automated technologies or interactions with our website, by using the web
enquiry form [or the shopping cart on this website]. For example, you might
give us your Identity, Contact and Financial Information in this way.
(c) Third parties or publicly available sources (third parties may be used in
processing Identity, Contact and Financial categories of personal data).
Data accuracy
It is important that the data that we hold about you is accurate and up-to-date. In the event
that your data changes, please notify us, so that we can update our records.
Use of your information
We may hold and process personal data that you provide to us in accordance with the GDPR.
The information that we collect and store relating to you is primarily used:
(a) To enable us to provide our goods or services to you, to communicate with you and
to meet our contractual commitments to you. This may include Identity, Contact,
Financial and Transactional data.
To notify you about any changes to our business, such as improvements to our Website or
service/product changes, that may affect our service or relationship with you. This may
include Identity and Contact data.
If you are an existing customer, we may contact you with information about goods and
services similar to those that were the subject of a previous sale to you. This may include
Identity and Contact data.
Where you have consented to receive such information, to provide information on other
parties’ products or services that we feel may be of interest to you. This may include Identity,
Contact and Marketing data.
Where you have consented to receive our e-newsletters to provide that to you. This may
include Identity and Contact data.
Where we need to comply with a legal obligation. This may include Identity, Contact and
Transactional data.
Where it is necessary for our legitimate interests (or those of a third party) and your interests
and fundamental rights do not override those interests. This may include all types of data.
Where we collect your data for marketing purposes, we will always request your consent at
the point the data is collected, to use your data for that purpose.
We will always obtain your consent prior to sharing your personal data with any third party
for their marketing purposes. This may be to enable relevant third parties to advise you of
products or services that may be of interest to you.
We will only use your personal data for a reason other than the purpose for which it was
originally obtained if we consider that we need to use it for that other purpose and have a
legitimate interest in doing so.
Disclosure of your information
There are a range of circumstances where we may disclose your data to third parties. These
include:
(a) Regulatory bodies. We may disclose your data to regulatory bodies to enable us to
comply with the law, to assist fraud protection and to minimise credit risk. This may
include Identity, Contact and Transactional data.
(b) Our suppliers. We may disclose your data to third parties that are involved in the
fulfilment of our services to you. This may include Identity, Contact and Transactional
data.
(c) Third party marketing. Where you have consented for us to do so, we may provide
your data to selected third parties who may contact you about their goods or
services that you may be interested in. This may include Identity, Contact and
Marketing data.
(d) Business sale. We may disclose your personal data outside of our organisation: (a) in
the event that we sell or buy any business or assets, in which case we may disclose
your personal data to the prospective seller or buyer of such business or assets; and
(b) if Trailnet CIC’s business is bought by a third party, in which case personal data
held by it about its customers will be one of the assets to transfer to the buyer.
However, any such transfer will only be on terms that the confidentiality of your
personal data is protected and that the terms of this privacy policy will continue to
be complied with by the recipient.
Please be advised that we do not reveal information about identifiable individuals to our
advertisers, but we may, on occasion, provide them with aggregated data about our Website
visitors and customers.
If you do not want us to share your data with third parties, you will have the opportunity to
withhold your consent to this when you provide your details to us on the form on which we
collect your data, or you can do so by writing to us at the address detailed above or sending
us an email to office@trailnet.org.uk at any time.
Controlling the use of your data
Where we rely on consent as the lawful basis for processing your data, you can revoke or
vary that consent at any time.
If you do not want us to use your data or want to vary the consent that you have provided,
you can write to us at the address detailed above or email us at office@trailnet.org.ukat any
time.
Data storage and the transfer your data
As part of the services offered to you, for example through our Website, the information you
provide to us may be transferred to and stored in countries outside of the European
Economic Area (EEA), as we use remote website server hosts to provide the website and
some aspects of our service, which may be based outside of the EEA, or use servers based
outside of the EEA – this is generally the nature of data stored in “the Cloud”. It may also be
processed by staff operating outside the EEA who work for one of our suppliers, e.g. our
website server host, payment processing provider, or work for us when temporarily outside
of the EEA.
A transfer of your personal data may happen if any of our servers are located in a country
outside of the EEA or one of our service providers is located in a country outside of the EEA.
If you use our service while you are outside the EEA, your personal data may be transferred
outside the EEA in order to provide you with these services.
If we transfer or store your personal data outside the EEA in this way, we will take steps with
the aim of ensuring that your privacy rights continue to be protected, as outlined in this
privacy policy. Where we use suppliers based in the US, we may transfer data to them if they
are part of the Privacy Shield, which requires them to provide similar protection to personal
data shared between the EEA and the US.
Security
The transmission of information via the Internet or email is not completely secure. Although
we will do our best to protect your personal data, we cannot guarantee the security of data
while you are transmitting it to our site: any such transmission is at your own risk.
We have put in place security measures to prevent your data from accidental, loss or
disclosure. Once we have received your personal data, we will use strict procedures and
security features to try to prevent unauthorised access.
Where we have given you (or where you have chosen) a password, so that you can access
certain parts of our site, you are responsible for keeping this password confidential. You
should choose a password that it is not easy for someone to guess.
In the event of a data breach, we will notify the ICO and you in the event that the breach
results in any likelihood of loss or damage to you.
Data retention
The length of time that we retain and store data depends on the purpose for which it was
collected. We will only store data for as long as is required to fulfil that purpose, or for the
purpose of satisfying legal requirements.
It is a legal requirement that we keep certain data about our customers and suppliers for at
least six years. The type of data includes Contact, Identity, Financial and Transaction data.
Where you have requested that we provide you with marketing materials, we will retain your
data until such time as consent is withdrawn by you.
Use of cookies & tracking pixels
Our Website does not use cookies or tracking pixels.
Your rights
The GDPR gives you a range of rights in relation to the personal data that we collect from.
You have the right to:
(a) Access your personal data. This right is commonly known as the ‘data subject access
request’ and enables you to receive a copy of the personal data we hold about you.
You will not need to pay a fee to access your personal data unless we can justifiably
demonstrate that the request is repetitive or excessive. We will respond to all
legitimate data access requests within one month, but we may need to obtain
further information from you in order to confirm your identity and the legitimacy of
the request.
(b) Request update of the personal data. This enables you to have any incomplete or
inaccurate data corrected.
(c) Erasure of your personal data. This enables you to ask us to delete personal data
where there is no justifiable reason for us continuing to retain and process it. We
may not always be able to delete the data, such as if there is an ongoing contractual
relationship between us or if we are legally required to retain the data.
(d) Object to processing of your personal data where we are relying on consent or our
legitimate interests (or those of a third party) as the justification for processing the
data.
(e) Restrict the processing of your personal data. This enables you to ask us to change
the processing of your personal data. For example, you may wish to vary the basis on
which we contact you.
(f) Request the transfer 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,
machine-readable format.
(g) Withdraw consent. Where we are relying on consent to process your personal data,
you may withdraw that 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.
You can exercise these rights at any time by writing to us at the address detailed above, or by
email to office@trailnet.org.uk
Third party links
You might find links to third party websites on our website. If you click a link to a third-party
website and visit that site, you may be allowing that site to collect and share certain data
about you. These websites should have their own privacy policies, which you should check.
We do not accept any responsibility or liability for their policies whatsoever, as we have no
control over them.
Complaints
If you wish to raise a complaint regarding our use of your personal data, then you can contact
the Information Commissioner’s Office (ICO), which is the UK supervisory authority for data
protection issues (www.ico.org.uk).
If you do wish to raise a complaint, then we would welcome the opportunity to discuss your
concerns before you contact the ICO, to see if we can resolve the issue for you.
Changes to this policy
We may update these policies to reflect changes to the website and customer feedback.
Please regularly review these policies to be informed of how we are protecting your personal
data.
We welcome any queries, comments or requests you may have regarding this Privacy Policy.
Please do not hesitate to contact us.
Version: September 2025
