We ask that you read this privacy notice carefully as it contains important information on who we are, how and why we collect, store, use and share personal information, your rights in relation to your privacy and personal information and on how to contact us and supervisory authorities in the event you have a complaint.

Atom Logistics, which is part of UBT (EU) Limited (“UBT”) collects, uses and is responsible for certain personal information about you. When we do so we are regulated under the General Data Protection Regulation which applies across the European Union (including in the United Kingdom) and we are responsible as ‘controller’ of that personal information for the purposes of those laws.

We provide logistics services to businesses operating in the UK and Europe. In the course of our business we collect the following personal information when you provide it to us:

Personal information such as your name, contact details (including postal address, email address and telephone number(s)) and occupation when you:

• Register on our website;
• Contact us directly via our website, by email or by telephone to use our products or services;
• Personal information including bank details for direct debit payments and credit card information provided to us only through our secure pay website page

We also obtain personal information from other sources as follows:

• Personal information that you have provided to our suppliers and business partners and which you have authorised them to share with us so that we can contact you about our services;

We use your personal information to:

• Provide you with products or services you have requested;
• Provide you with ongoing information about Atom Logistics that we believe you may be interested in;
• To provide you with information about related goods or services provided by others that we believe will be of interest to you;
• To notify you about changes to our service.

We routinely share the contact details of our customers and potential customers with our third party suppliers and affiliated UBT companies overseas. This data sharing enables them to supply you with the goods and services that you have ordered and/or to contact you about their goods and services that you might be interested in. We will only give your details to suppliers you have chosen and the information we have will be limited to the contact details you have provided in order that the supplier you have chosen can contact you about your order/enquiry. Our affiliated UBT companies and some of those third party recipients are based outside the European Economic Area — for further information including on how we safeguard your personal data when this occurs, see ‘Transfer of your information out of the EEA’.

We will share personal information with law enforcement or other authorities if required by applicable law.

We will not share your personal information with any other third party.

The provision of your personal information e.g. name and contact details is required to enable us to provide you with the goods and services that you have ordered from us or that you are interested in receiving information about. We will inform you at the point of collecting information from you, whether you are required to provide the information to us.

• We will hold personal information about our customers for 6 years from when we last supply you with goods or services.
• We will hold contact details about our previous customers or potential customers only for so long as we reasonably consider that the information about products and services that we might provide to you is relevant to and of interest to you and we will delete your contact details if you ask us not to continue to send such information to you or at any time if we have reason to think that the information is out of date, and in any case no later than 6 years after you last contacted us.

• If we supply goods and services to you we rely on the fact that it is necessary for us to have and to use your personal information for the performance of our contract with you as the lawful basis on which we collect and use your personal data;
• If you are a customer or a previous customer to whom we send information about goods and services provided by us or by others that we think is of interest to you, we rely on our legitimate business interests as the lawful basis on which we retain and use the personal data that you have given to us. Our legitimate interests are to keep you informed of those goods and services and other information about our business. This will be limited to information sent to the contact details that you have provided to us and with every communication you will be given a clear and straightforward option to opt out of further communications and to ask us to delete the personal information that we hold about you. We have considered the risk of harm to your privacy rights and to your data security and have concluded that the risk is minimal given (i) the type of data (your contact details) that we process for this purpose, (ii) the method, volume and content of the communications that we might send to you (emails, including daily offers (not every day but several a week) not more often than monthly, related to the goods and services that you have previously ordered from us or expressed an interest in), (iii) your right to opt out of further communications and to ask us to delete your information from our records at any time and (iv) the ability for you to select your preferences through the marketing preferences portal on our website.
• Any contact by electronic communication will respect your e-privacy rights by being restricted to the use of e-contact details that you provided to us in the original supply process and limited to the same or similar goods and services.

We do not believe that there are likely to be any serious consequences to you of our use of your personal information. The potential consequences that we have identified are:

• Your data security:The risk of the personal information that we hold about you being accidentally lost, or used or accessed in an unauthorised way.We have taken steps to protect against this (please see further information under the heading “Keeping your personal information secure” below).
• Your privacy rights:You may, from time to time, receive communications from us or from our third party suppliers.However, we do not believe that the frequency, content or manner of these communications will risk any breach of your privacy rights and with every communication you will be given a clear and straightforward option to opt out of further communications and to ask us to delete the personal information that we and/or our third party suppliers hold about you.

We may transfer your personal information to the following which are located outside the European Economic Area (EEA) as follows:

• To our own centres of operation in Australia, Argentina, Caribbean, New Zealand, Canada and USA in order to process your order/s for goods and services or to send relevant communications covered by this Privacy Notice to you;
• To our third party suppliers in Australia, Non-EU European countries, New Zealand, Canada and USA in order that they can process your order(s) for goods and services or to send relevant communications covered by this Privacy Notice to you.

Some of those countries have been recognised by an adequacy decision of the European Commission which determines that they offer an adequate level of data protection. Currently, the relevant recognised countries are Canada, Faroe Islands, Guernsey, Israel, Isle of Man, Jersey, New Zealand, Switzerland, Uruguay and the US (where the US Privacy Shield applies). Whilst the European Commission has not given a formal decision that other countries provide an adequate level of data protection similar to those which apply in the United Kingdom and EEA, any transfer of your personal information to such countries will be limited to transfers that are necessary for the performance or conclusion of our contract with you or at your request for the performance or conclusion of your contract with a third party or where we have assessed that the country or destination offers sufficient protection to the data protection rights that you have in the UK and having regard to:

• the personal data being transferred;
• where the personal data has originated from and where it is being sent to;
• how the data will be used and how long it will be retained for; and
• the security measures that will apply to the personal data in the country that it is being sent to.If you would like further information please contact our Data Protection Officer (see ‘How to contact us’ below). We will not otherwise transfer your personal data outside of the EEA or to any organisation (or subordinate bodies) governed by public international law or which is set up under any agreement between two or more countries.

Under the General Data Protection Regulation you have a number of important rights free of charge. In summary, those include rights to:

• fair processing of information and transparency over how we use your use personal information;
• access to your personal information and to certain other supplementary information that this Privacy Notice is already designed to address;
• require us to correct any mistakes in your information which we hold;
• require the erasure of personal information concerning you in certain situations;
• receive the personal information concerning you which you have provided to us, in a structured, commonly used and machine-readable format and have the right to transmit those data to a third party in certain situations;
• object at any time to processing of personal information concerning you for direct marketing
• object to decisions being taken by automated means which produce legal effects concerning you or similarly significantly affect you;
• object in certain other situations to our continued processing of your personal information;
• otherwise restrict our processing of your personal information in certain circumstances;
• claim compensation for damages caused by our breach of any data protection law.

For further information on each of those rights, including the circumstances in which they apply, see the Guidance from the UK Information Commissioner’s Office (ICO) on individuals rights under the General Data Protection Regulation.

If you would like to exercise any of those rights, please:

• email, call or write to
• let us have enough information to identify you;
• let us have proof of your identity and address (a copy of your driving licence or passport and a recent utility or credit card bill), and
• let us know the information to which your request relates.

We have appropriate security measures in place to prevent personal information from being accidentally lost, or used or accessed in an unauthorised way. We limit access to your personal information to those who have a genuine business need to know it. Those processing your information will do so only in an authorised manner and are subject to a duty of confidentiality.

We also have procedures in place to deal with any suspected data security breach. We will notify you and any applicable regulator of a suspected data security breach where we are legally required to do so.

We hope that our Data Manager can resolve any query or concern you raise about our use of your information.

The General Data Protection Regulation also gives you right to lodge a complaint with a supervisory authority, in particular in the European Union (or European Economic Area) state where you work, normally live or where any alleged infringement of data protection laws occurred. The supervisory authority in the UK is the Information Commissioner who may be contacted at https://ico.org.uk/concerns/ or telephone their helpline: 0303 123 1113.

This privacy notice was published on 23/05/2018 Version: v1.0

We may change this privacy notice from time to time, when we do we will inform you via our Website and a link in our next email communication to you.

Please contact our Data Manager, if you have any questions about this privacy notice or the information we hold about you:

Matthew Gardner
UBT UK Regional Office
Exchange Place
Poseidon Way
Warwick
CV34 6BY

T: 0203 301 7929
E: [email protected]