Traqa Privacy Policy

1. Introduction

1.1. Traqa Ltd is committed to safeguarding the privacy of our employees, customers and website visitors.

1.2. This policy applies where we are acting as a data controller with respect to the personal data of employees, customers and website visitors; in other words, where we determine the purposes and means of the processing of that personal data.

1.3. In this policy, "we", "us" and "our" refer to Traqa Ltd. For more information about us, see Section 11.

2. Traqa Online

2.1. Website

2.1.1. We use cookies on our website. Insofar as those cookies are not strictly necessary for the provision of our website, we will ask you to consent to our use of cookies when you first visit our website.

2.1.2. Our website incorporates privacy controls which affect how we will process your personal data. By using the privacy controls, you can specify whether you would like to receive direct marketing communications.

2.1.3. We may process data about your use of our website. The usage data may include your IP address, geographical location, browser type and version, operating system, referral source, length of visit, page views and website navigation paths, as well as information about the timing, frequency and pattern of your service use. The source of the usage data is Google Analytics, which is GDPR compliant. This usage data may be processed for the purposes of analyzing the use of the website and services. The legal basis for this processing is our legitimate interests, namely monitoring and improving our website and services.

2.1.4. Our website may link to other websites. We are not responsible for their data policies, procedures or content.

2.1.5. We endeavour to take all reasonable steps to protect your personal data but cannot guarantee the security of any Data you disclose online. You accept the inherent security implications of dealing on-line and will not hold us responsible for any breach of security unless we have been negligent or in wilful default.

2.1.6. We cannot predict, control or be responsible for information you choose to tell us or others in a publicly available fashion such as via bulletin boards or chat rooms. Therefore, this Privacy Policy does not apply to any information that you voluntarily disclose to us, our partners, our customers or any other third party via chat rooms, bulletin boards or otherwise, where we did not expressly ask you for such information.

2.2. Social Media

2.2.1. We will not publish any personal data on any of our Social Media pages.

2.2.2. We may share links to selected business partners on our Social Media, but can accept no responsibility of liability for any data on their sites or pages.

2.2.3. We accept no liability for any comments made or personal data left on any of our Social Media pages by persons outside of the company.

3. How we use your personal data

3.1. All personal data held by us will be held in electronic format only. Any hard copies of documents containing personal data will be shredded and disposed of with confidential waste.

3.2. If we receive any personal data about you from an external source, i.e. not obtained directly from you, the content and source of said data will be disclosed to you and your permission sought to for us to use and retain said data where applicable.

3.3. Your personal data may be passed on to other companies (our Service Providers) only with your express consent. When placing orders for the purchase of goods from us, you give us permission to share such personal data with our Service Providers (Couriers) as is required to deliver said goods.

When purchasing Services from us, you give us your permission to use your personal data as is required to provide said Services.

All providers of our Service Providers have provided to us evidence of their compliance to GDPR. The legal basis for this processing is your consent to use said data to communicate to fulfill your purchase.

3.4. We may process information contained in any enquiry you submit to us regarding goods and/or services. The enquiry data may be processed for the purposes of offering, marketing and selling relevant goods and/or services to you. The legal basis for this processing is your consent to use said data to communicate with you.

3.5. We may process your account data this may include your name and email address. The source of the account data is you or your employer. The account data may be processed for providing our services, maintaining back-ups of our databases and communicating with you. The legal basis for this processing is our legitimate interests, namely the performance of a contract between you and us and/or taking steps, at your request, to enter into such a contract.

3.6. We may process your personal data that are provided in the course of the use of our services. The service data may include your name. The source of the service data is you or your employer. The service data may be processed for the purposes of providing our services, ensuring the security of our website and services, maintaining back-ups of our databases and communicating with you. The legal basis for this processing is our legitimate interests, namely the proper administration of our services provided to you.

3.7. We may process information relating to transactions, including purchases of goods and services that you enter into with us. The data may include your contact details, your card details and the transaction details. The transaction data may be processed for the purpose of supplying the purchased goods and services and keeping proper records of those transactions. The legal basis for this processing is the performance of a contract between you and us and/or taking steps, at your request, to enter into such a contract and our legitimate interests, namely the proper administration of our business.

3.8. We may process information that you provide to us for the purpose of subscribing to our email notifications and/or newsletters. The data may be processed for the purposes of sending you the relevant notifications and/or newsletters. The legal basis for this processing is your consent, unless you have specifically requested to unsubscribe from such communications.

3.9. We may process information contained in or relating to any communication that you send to us by email or written communication. The data may include the communication content associated with the communication. The data may be processed for the purposes of communicating with you and record-keeping. The legal basis for this processing is our legitimate interests, namely the proper administration of our business and communications with you.

4. General

4.1. We may process any of your personal data identified in this policy where necessary for the establishment, exercise or defence of legal claims, whether in court proceedings or in an administrative or out-of-court procedure. The legal basis for this processing is our legitimate interests, namely the protection and assertion of our legal rights, your legal rights and the legal rights of others.

4.2. We may process any of your personal data identified in this policy where necessary for the purposes of obtaining or maintaining insurance coverage, managing risks, or obtaining professional advice. The legal basis for this processing is our legitimate interests, namely the proper protection of our business against risks.

4.3. In addition to the specific purposes for which we may process your personal data set out in Section 3, we may also process any of your personal data where such processing is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person.

4.4. Please do not supply any other person's personal data to us, unless we prompt you to do so. Any information you provide us will be communicated to that person, as well as the source.

5. Providing your personal data to others

5.1. We may disclose your name, address and telephone number to our Service Providers as per Section 3.3 insofar as reasonably necessary for the purpose of delivering items or services you have ordered from us.

5.2. We may disclose your personal data to our insurers and/or professional advisers as per Section 3.3 insofar as reasonably necessary for the purposes of obtaining or maintaining insurance coverage, managing risks, obtaining professional advice, or the establishment, exercise or defence of legal claims, whether in court proceedings or in an administrative or out-of-court procedure.

5.3. Financial transactions via Credit Card relating to products and services are handled by our payment services provider, Worldpay. We will share transaction data with our payment services provider only to the extent necessary for the purposes of processing your payments, refunding such payments and dealing with complaints and queries relating to such payments and refunds. We have confirmed that our payment services provider is GDPR compliant. You can find information about the payment services providers' privacy policies and practices at https://www.worldpay.com/uk/privacy-policy.

5.4. We may disclose your personal data to one or more selected companies for the purpose of enabling them to contact you so that they can offer, market and sell to you relevant goods and/or services, only with your explicit permission. You must inform us if you do not wish this information to be shared. Each such third party will act as a data controller in relation to the personal data that we supply to it. Upon contacting you, each such third party will supply to you a copy of its own privacy policy, which will govern that third party's use of your personal data.

5.5. In addition to the specific disclosures of personal data set out in Section 3 we may disclose your personal data where such disclosure is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person. We may also disclose your personal data where such disclosure is necessary for the establishment, exercise or defence of legal claims, whether in court proceedings or in an administrative or out-of-court procedure.

6. Retaining and deleting personal data

6.1. Personal data relating to employees will be kept for the duration of your employment with us.

6.2. We will retain your personal data in our CRM database while you purchase products from us.

Personal data will be held on our CRM database until it is updated by you, or you request that it be removed.

6.3. Any personal data supplied in hard copy will be converted to electronic format and kept securely off-site and the hard copy shredded and disposed of with confidential waste.

6.4. Notwithstanding the other provisions of this section, we may retain your personal data where such retention is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person.

7. Amendments

7.1. We may update this policy from time to time by publishing a new version on our website.

7.2. You should check this page occasionally to ensure you are happy with any changes to this policy.

7.3. We may notify you of significant changes to this policy by email.

8. Your rights

8.1. You have the legal rights under GDPR In this Section 8, we have summarised the rights that you have under data protection law. Some of the rights are complex, and not all of the details have been included in our summaries. Accordingly, you should read the relevant laws and guidance from the regulatory authorities for a full explanation of these rights.

8.2. Your principal rights under data protection law are:

8.2.1. The right to access.

You have the right to confirmation as to whether or not we process your personal data and, where we do, access to the personal data, together with certain additional information. That additional information includes details of the purposes of the processing, the categories of personal data concerned and the recipients of the personal data. Providing the rights and freedoms of others are not affected, we will supply to you a copy of your personal data. This request must be made to our Data Protection Officers.

8.2.2. The right to rectification.

You have the right to have any inaccurate personal data about you rectified and, taking into account the purposes of the processing, to have any incomplete personal data about you completed.

8.2.3. The right to erasure.

In some circumstances you have the right to the erasure of your personal data without undue delay. Those circumstances include: the personal data are no longer necessary in relation to the purposes for which they were collected or otherwise processed; you withdraw consent to consent-based processing; you object to the processing under certain rules of applicable data protection law; the processing is for direct marketing purposes; and the personal data have been unlawfully processed. However, there are exclusions of the right to erasure. The general exclusions include where processing is necessary for exercising the right of freedom of expression and information; for compliance with a legal obligation; or for the establishment, exercise or defence of legal claims.

8.2.4. The right to restrict processing.

In some circumstances you have the right to restrict the processing of your personal data. Those circumstances are: you contest the accuracy of the personal data; processing is unlawful but you oppose erasure; we no longer need the personal data for the purposes of our processing, but you require personal data for the establishment, exercise or defence of legal claims; and you have objected to processing, pending the verification of that objection. Where processing has been restricted on this basis, we may continue to store your personal data. However, we will only otherwise process it: with your consent; for the establishment, exercise or defence of legal claims; for the protection of the rights of another natural or legal person; or for reasons of important public interest.

8.2.5. The right to object to processing.

You have the right to object to our processing of your personal data on grounds relating to your particular situation, but only to the extent that the legal basis for the processing is that the processing is necessary for: the performance of a task carried out in the public interest or in the exercise of any official authority vested in us; or the purposes of the legitimate interests pursued by us or by a third party. If you make such an objection, we will cease to process the personal information unless we can demonstrate compelling legitimate grounds for the processing which override your interests, rights and freedoms, or the processing is for the establishment, exercise or defence of legal claims.

8.2.6. The right to decline marketing.

You have the right to object to our processing of your personal data for direct marketing purposes. If you make such an objection, we will cease to process your personal data for this purpose.

8.2.7. The right to data portability.

To the extent that the legal basis for our processing of your personal data is consent, or that the processing is necessary for the performance of a contract to which you are party or in order to take steps at your request prior to entering into a contract. You have the right to receive your personal data from us in a structured, commonly used and machine-readable format. However, this right does not apply where it would adversely affect the rights and freedoms of others.

8.2.8. The right to complain to a supervisory authority.

If you consider that our processing of your personal information infringes data protection laws, you have a legal right to lodge a complaint with a supervisory authority responsible for data protection. You may do so in the EU member state of your habitual residence, your place of work or the place of the alleged infringement.

8.2.9. The right to withdraw consent.

To the extent that the legal basis for our processing of your personal information is consent, you have the right to withdraw that consent at any time. Withdrawal will not affect the lawfulness of processing before the withdrawal.

8.3. You may exercise any of your rights in relation to your personal data by written notice to us or by email, enquiries@traqa.com, marked for the attention of the Data Protection Officer, in addition to the other methods specified in this Section 8].

9. Cookies

9.1. A cookie is a file containing an identifier (a string of letters and numbers) that is sent by a web server to a web browser and is stored by the browser. The identifier is then sent back to the server each time the browser requests a page from the server.

9.2. Cookies may be either "persistent" cookies or "session" cookies: a persistent cookie will be stored by a web browser and will remain valid until its set expiry date, unless deleted by the user before the expiry date; a session cookie, on the other hand, will expire at the end of the user session, when the web browser is closed.

9.3. Cookies do not typically contain any information that personally identifies a user, but personal information that we store about you may be linked to the information stored in and obtained from cookies.

9.4. We use cookies for the following purposes:

9.4.1. Preferences – we use preference cookies to enable our website to remember your language preference to personalise the website for you. Cookies used for this purpose are:

lang (cdn.syndication.twing.com)

9.4.2. Statistics - we use cookies to help us to analyze the use and performance of our website and services, no personal data is collected. Cookies used for this purpose are:

_ga (traqa.com)

_gat (traqa.com)

_gid (traqa.com)

9.4.3. Marketing - we use cookies to help us to analyze the use of our website and to link to our Social Media pages. Cookies used for this purpose are:

collect (google-analytics.com)

i/jot/syndication (twitter.com)

impression.php/# (facebook.com)

UUID#[abcdef0123456789]{32} (traqa.com)

9.4.4. Cookie consent - we use cookies to store your preferences in relation to the use of cookies more generally. Cookies used for this purpose are:

EU e-privacy Directive (V3.7.1) (extensions.joomla.org)

9.5. Cookies used by our service providers

9.5.1. Our service providers use cookies and those cookies may be stored on your computer when you visit our website.

9.5.2. We use Google Analytics to analyse the use of our website. Google Analytics gathers information about website use by means of cookies. The information gathered relating to our website is used to create reports about the use of our website. Google's privacy policy is available at: https://www.google.com/policies/privacy/. The relevant cookies are:

_ga (traqa.com)

_gat (traqa.com)

_gid (traqa.com)

collect (google-analytics.com)

10. Managing cookies

10.1. Most browsers allow you to refuse to accept cookies and to delete cookies. The methods for doing so vary from browser to browser, and from version to version. You can however obtain up-to-date information about blocking and deleting cookies via these links:

(a) https://support.google.com/chrome/answer/95647?hl=en (Chrome);

(b) https://support.mozilla.org/en-US/kb/enable-and-disable-cookies-website-preferences (Firefox);

(c) http://www.opera.com/help/tutorials/security/cookies/ (Opera);

(d) https://support.microsoft.com/en-gb/help/17442/windows-internet-explorer-delete-manage-cookies (Internet Explorer);

(e) https://support.apple.com/kb/PH21411 (Safari); and

(f) https://privacy.microsoft.com/en-us/windows-10-microsoft-edge-and-privacy (Edge).

10.2. Blocking all cookies will have a negative impact upon the usability of many websites.

10.3. If you block cookies, you may not be able to use all the features on our website.

11. Our details

11.1. The website is owned and operated by Traqa Ltd.

11.2. We are registered in England and Wales under registration number 3440555, and our registered office is at: Traqa Ltd, 1st Floor, 1 Centrus, Mead Lane, Hertford, Hertfordshire, SG13 7GX, United Kingdom.

11.3. Our principal place of business is at the address above.

11.4. You can contact us:

By post, to the postal address given above

By telephone, on the contact number published on our website

By email, using the email address published on our website.

12. Data protection officers

12.1. Our data protection officer's contact details are:

Catherine Pegna Catherine.Pegna@gvhealth.com

Clive Naden Clive.Naden@gvhealth.com

Both can be contacted at the phone number shown on our website.