Your privacy is important to GTAccess. This Privacy Notice explains how GTAccess processes personal information (meaning any information about you which is personally identifiable (such as your name, address, telephone number or email address) collected through the use of our websites and applications.

COOKIE POLICY

For the purposes of these policies, GTAccess defines the term “User” as an entity with which GTAccess has an established relationship, the term “Visitor” as an individual that visits our front-end website (for example www.gtaccess.co.uk).

Any information stored on GTAccess systems is treated as confidential. All information is stored securely and is accessed by authorised personnel only. GTAccess implements and maintains appropriate technical, security and organisational measures to protect Personal Data against unauthorised or unlawful processing and use, and against accidental loss, destruction, damage, theft or disclosure.

By using our website, you acknowledge your acceptance of the provisions in our privacy policy.

PRIVACY POLICY

1. COLLECTION AND USE OF PERSONAL INFORMATION

1.1 GENERAL
We are committed to protecting the privacy of any personal data that you may submit to the Website. Generally you can visitthe Website without revealing who you are, or disclosing any personal data. If you are a Visitor to our website only, and not a user of our platform, then this section is relevant for you. Your personal information will be treated in accordance with the General Data Protection Regulation (GDPR) (Regulation (EU) 2016/679).

From time to time, we may use your personal information to send important notices, such as communications about pur-chases and changes to our terms, conditions, and policies. Because this information is important to your interaction with GTAccess, you may not opt out of receiving these communications.

1.2 WEBSITE VISITORS
By visiting this website, you consent to the collection and use of your Personal Data as described herein. If you do not agree with the terms set out herein, please do not visit this website. However, there may be times when we require personal dataabout you or when you wish to disclose such personal data to us. Such personal data is obtained only when voluntarily sub-mitted by you and is subject to the provisions set out in this policy. If you do not grant the requested consent to the process-ing of your Personal Data, the use of this website may not be possible.

GTAccess may collect, record and analyze information of Visitors to its website. We may record your IP address and use cookies. GTAccess may add information collected by way of pageview activity. Furthermore, GTAccess may collect and process any Personal Data that you volunteer to us in our website’s forms, such as when you sign up for information and newsletters. If you provide GTAccess with your social media details, GTAccess may retrieve publicly available information about you from social media. GTAccess gathers data about visits to the website, including numbers of Visitors and visits, Geo-location data, length of time spent on the site, pages clicked on or where Visitors have come from.

Such Personal Data may comprise your IP address, first and last name, your postal and email address, your telephone number, your job title, data for social networks, your areas of interest, interest in GTAccess products, and certain information about the company you are working for (company name and address), as well as information as to the type of relationshipthat exists between GTAccess and yourself.

When you create a GTA ID, apply for a commercial credit account, purchase a product, contact us or participate in an online survey, we may collect a variety of information, including your name, mailing address, phone number, email address, contact preferences, and credit card information.

1.2.1 PURPOSE OF PROCESSING PERSONAL DATA
GTAccess uses the collected data to communicate with Visitors, to customize content for Visitors, to show advertise-ments on other websites to Visitors, and to improve its website by analyzing how Visitors navigate the site.

1.2.2 SHARING PERSONAL DATA
GTAccess may also share such information with our suppliers, affiliated businesses or other service providers in order to provide a requested service or transaction or in order to analyze the Visitor behavior on its website. In certain circum- stances we may need to disclose your information should you breach this privacy policy or any Terms and Conditions.We may also disclose or access your account if required to do so by law or by any Governmental body.

1.2.3 COLLECTION OF NON-PERSONAL INFORMATION
We also collect data in a form that does not, on its own, permit direct association with any specific individual. We may collect, use, transfer, and disclose non-personal information for any purpose. We may collect information such as occu-pation, language, unique device identifier, referrer URL, location, and the time zone.

1.2.4 COOKIES AND IP ADDRESSES
We may use cookies and other technologies such as pixel tags to collect information about your behavior, your computer, including where available your IP address, operating system and browser type, for system administration purposes. Thisis statistical data about our users’ browsing actions and patterns and does not identify you as an individual. By continuingto visit the website, you agree to the placement of cookies on your device. If you choose not to accept our cookies, we cannot guarantee that your experience will be as fulfilling as it would otherwise be. We may also place cookies from third parties for functional and marketing purposes. More information about our use of Cookies can be found in the GTAccess Cookie Policy Document (GTA-084)

1.2.5 LOCATION-BASED SERVICES
To provide location-based services, GTAccess may collect, use, and share precise location data. Where available, location-based services may use GPS, Bluetooth, and your IP Address, along with crowd-sourced Wi-Fi hotspot and cell tower locations, and other technologies to determine your devices’ approximate location. Unless you provide consent,this location data is collected anonymously in a form that does not personally identify you and is used by GTAccess to provide and improve location-based services.

1.2.6 LINKS TO OTHER SITES
Our website may contain links to other websites of interest. However, once you have used these links to leave our site, you should note that we do not have any control over that other website. Therefore, we cannot be responsible for theprotection and privacy of any information which you provide whilst visiting such sites and such sites are not governed bythis privacy policy. You should exercise caution and look at the privacy policy applicable to the website in question.

1.2.7 CUSTOMER LOGIN PORTAL
Certain features or services offered on or through the Site may require you to open an account (including setting up a GTA ID and password). You are entirely responsible for maintaining the confidentiality of the information you hold for your account, including your password, and for any and all activity that occurs under your account as a result of your failing to keep this information secure and confidential. You agree to notify GTAccess immediately of any unauthorized use of your account or password, or any other breach of security. You may be held liable for losses incurred by GTAccess or any other user of or visitor to the Site due to someone else using your GTA ID, password or account as a result of your failing to keep your account information secure and confidential.

You may not use anyone else’s GTA ID, password or account at any time without the express permission and consent of the holder of that GTA ID, password or account. GTAccess cannot and will not be liable for any loss or damage arising from your failure to comply with these obligations. We have the right to disable any GTA ID or password, whether chosen by you or allocated by us, at any time, if in our opinion, you have failed to comply with any of the provisions of theseterms or the Terms and Conditions of use of the Website.

You agree to notify us immediately by emailing our Data Protection Officer or by phone on 01527 871123 of any unauthorised use of your GTA ID password or user name of which you become aware.

1.2.8 CONTROLLER
GTAccess processes Personal Data both as a Processor and as a Controller, as defined in the Directive and the GDPR: The GTAccess entity which you as a User entered an agreement with when using the GTAccess platform, will be the Controller for User data, as outlined above in “Collection of User data” section.

2. RETENTION AND DELETION

GTAccess will not retain data longer than is necessary to fulfill the purposes for which it was collected or as required by applica-ble laws or regulations. Users with an active GTA ID account will therefore have the responsibility to delete data when required. When a users’s account is terminated or expired, all Personal Data collected through the platform will be deleted, as required byapplicable law.

2.1 DATA STORAGE AND RETENTION
If a User contacts us, in writing, by email or other electronic means, We may keep a record of that correspondence; and details of the Users visits to the Website including, but not limited to, traffic data, location data, weblogs and other communication data and the resources that you access in accordance with our cookie policy.

2.1.1 ACCESS TO PERSONAL INFORMATION
You can help ensure that your contact information and preferences are accurate, complete, and up to date by logging in to your account at https://www.gtaccess.co.uk/gtalogin/. For other personal information we hold, we will provide you with access for any purpose including to request that we correct the data if it is inaccurate or delete the data if GTAccess is not required to retain it by law or for legitimate business purposes. We may decline to process requests that are frivolous/vex-atious, jeopardize the privacy of others, are extremely impractical, or for which access is not otherwise required by UK law. Access, correction, or deletion requests can be made by emailing dpo@gtaccess.co.uk.

2.1.2 STORAGE AND SECURITY
GTAccess have stringent security procedures covering the storage and disclosure of your personal data in order to prevent unauthorised access and to comply with the UK Data Protection Act 1998. All information we collect is stored either on our secured servers or our trusted partners within the EEA (European Economic Area). It is never transferred out of the EEA and you will be notified if this should ever change. While we take all reasonable efforts to protect such personal data, you acknowledge that we cannot ensure or warrant the security of any personal data provided by these means and you provide it to us at your own risk. If, despite our security precautions, personal data is inadvertently disclosed, we shall use all reason-able endeavours to limit and remedy the disclosure but, to the extent permitted by law, we accept no liability for unintentional disclosure of personal data.

2.2 THE RIGHT TO BE FORGOTTEN
Under the General Data Protection Regulations 2018 a user has the right to request that we correct the data if it is inaccurate or delete the data if GTAccess is not required to retain it by law or for legitimate business purposes. We may decline to process requests that are frivolous/vexatious, jeopardize the privacy of others, are extremely impractical, or for which access is not other-wise required by UK law. Access, correction, or deletion requests can be made by emailing our Data Protection Officer

3. DATA PROTECTION OFFICER

If you want to contact us with any questions, comments or complaints about how we collect, use or retain a Users personal data, please email our Data Protection Officer

COOKIE POLICY

A cookie is a small file which asks permission to be placed on your computer’s hard drive. Once you agree, the file is added and the cookie helps analyse web traffic or lets you know when you visit a particular site. Cookies allow web applications to respond to you as an individual. The web application can tailor its operations to your needs, likes and dislikes by gathering and remem-bering information about your preferences.

1. HOW WE USE COOKIES

We use traffic log cookies to identify which pages are being used. This helps us analyse data about web page traffic and im-prove our website. We only use this information for statistical analysis purposes and then the data is removed from the system.

Overall, cookies help us provide you with a better website, by enabling us to monitor which pages you find useful and which you do not. A cookie in no way gives us access to your computer or any information about you, other than the data you choose to share with us. You can choose to accept or decline cookies. Most web browsers automatically accept cookies, but you can usu-ally modify your browser setting to decline cookies if you prefer. This may prevent you from taking full advantage of the website.

1.1 COOKIES SET BY GOOGLE ANALYTICS
We use Google Analytics to track how people use this website in order to manage and improve the site. This information is collected anonymously and cannot be used to identify you.

Like many services, Google Analytics uses first-party cookies to track visitor interactions. These cookies are used to store information, such as what time a visit occurred, whether the visitor has been to the site before, and what site referred the visitor to the web page. Browsers do not share first-party cookies across domains.

We also use Google Analytics Demographics and Interest Reporting which is based upon data from Google Display Adver-tising. We use aggregate data provided by this service (such as age, gender and interests) to better understand our website audience and adjust our communications appropriately whilst also improving the site.

2. LINKS TO OTHER WEBSITES

Our website may contain links to other websites of interest. However, once you have used these links to leave our site, you should note that we do not have any control over that other website. Therefore, we cannot be responsible for the protection and privacy of any information which you provide whilst visiting such sites and such sites are not governed by this cookie policy. You should exercise caution and look at the policies applicable to the website in question.

TERMS OF USE

These terms and conditions govern your use of the GTAccess website. Please read the terms in full before you use this Website. If you do not accept these terms, please do not use this Website. Using the Website implies that you accept these terms. We do occasionally update these terms so please refer back to them in the future.

1. SITE ACCESS

You will be able to access the majority of this Website without having to register any details with us. However, particular areas of this Website will only be accessible with a GTA ID.

2. USE OF WEBSITE

You are permitted to use our website for your own purposes and to print and download material from this Website provided that you do not modify any content without our consent. Material on this website must not be republished online or offline without our permission.

The copyright and other intellectual property rights in all material on this Website are owned by us and must not be reproduced without our prior consent. All product and company names are trademarks or registered trademarks of their respective holders.

2.1 SITE UP-TIME
We take all reasonable steps to ensure that this Website is available 24 hours every day, 365 days per year. However, websites do sometimes encounter downtime due to server and, other technical issues. Therefore we will not be liable if this website is unavailable at any time.

This Website may be temporarily unavailable due to issues such as system failure, maintenance or repair or for reasons beyond our control. Where possible we will try to give our visitors advance warning of maintenance issues but shall not be obliged to do so.

2.2 VISITOR CONDUCT
With the exception of personally identifiable information, the use of which is covered under our Privacy Policy, any material you send or post to this Website shall be considered non-proprietary and not confidential. Unless you advise to the contrary we will be free to copy, disclose, distribute, incorporate and otherwise use such material for any and all purposes.

2.3 LINKS TO AND FROM OTHER WEBSITES
Any links to third party websites located on this Website are provided for your convenience only. We have not reviewed each third party website and have no responsibility for such third party websites or their content. We do not endorse the third party websites or make representations about them or any material contained in them. If you choose to access a third party website linked to from this Website, it is at your own risk.

3. COPYRIGHT

The information on the Site, including but not limited to, text, graphics, images, audio clips and software is the property of GTAccess and is protected by UK and international copyright laws. Unauthorised use or distribution of any material on the Site may violate copyright, trademark, and other laws and is subject to civil as well as criminal sanctions.

The Site or any proportion of it may not, except where otherwise indicated, be reproduced, duplicated, copied, transferred, distributed, stored or otherwise exploited for any commercial use without prior written permission by GTAccess. Modifications to the contents of the Site are expressly prohibited. You agree to prevent any unauthorised copying of the materials and to ensure that all employees, where applicable, of your organisation adheres to these limitations.

3.1 TRADEMARK INFORMATION
Unless otherwise indicated, all trademarks, brand names, corporate logos and emblems displayed on the Site are the property of GTAccess or its affiliates. GTAccess's trademarks, brand names, corporate logos and emblems may not be used any way without the prior written permission from GTAccess. The Site may contain images that are subject to the copyright rights of their providers.

4. NO WARRANTIES OR REPRESENTATIONS

INFORMATION ON THE SITE IS PROVIDED "AS IS" WITHOUT ANY EXPRESS OR IMPLIED WARRANTY OF ANY KIND. IN NO EVENT WILL GTACCESS BE LIABLE TO ANY PARTY FOR ANY DIRECT, INDIRECT, SPECIAL OR OTHER CONSEQUENTIAL DAMAGES FOR ANY USE OF THE SITE, OR ON ANY OTHER HYPERLINKED WEB SITE INCLUDING, WITHOUT LIMITATION, ANY LOST PROFITS, BUSINESS INTERRUPTION, LOSS OF PROGRAMS OR OTHER DATA ON YOUR HANDLING SYSTEM OR OTHERWISE, ARISING OUT OF THE USE OF OR INABILITY TO USE THE INFORMATION, EVEN IF GTACCESS ARE ADVISED OF THE POSSIBILITY OF SUCH DAMAGES.

GTAccess makes no warranties or representations whatsoever about any other web site which you may access through the Site. Such are provided only as a convenience and does not mean that GTAccess endorses or accepts any responsibilities for the contents or the use of such web sites. In addition, it is up to you to take precautions and to ensure that whatever you select for your use is free of such items as viruses, worms, Trojan horses and other items of a destructive nature.

Further, GTAccess does not warrant the accuracy or completeness of the information, text, graphics, links or other items that may be contained on the Site. The information contained on the Site may be changed at any time without prior notification. However, GTAccess makes no commitment to update the information or other material contained on the Site.

5. DISCLAIMER

We take all reasonable steps to ensure that the information on this Website is correct. However, we do not guarantee the correctness or completeness of material on this Website. We may make changes to the material on this Website at any time and without notice. The material on this Website may be out of date, or on rare occasions incorrect and we make no commitment to ensure that such material is correct or up to date.

The material at this Website is provided without any conditions or warranties of any kind. To the maximum extent permitted by law, we provide access and use of this website on the basis that we exclude all representations, warranties and conditions which but for these Terms may have effect in relation to this Website.

5.1 EXCLUSION OF LIABILITY
Neither we nor any other party (whether or not involved in producing, maintaining or delivering this Website), shall be liable or responsible for any kind of loss or damage that may result to you or a third party as a result of your or their use of our website. This exclusion shall include servicing or repair costs and, without limitation, any other direct, indirect or consequential loss, and whether in tort or contract or otherwise in connection with this Website.

5.2 GOVERNING JURISDICTION
This Legal Notice shall be governed by and construed in accordance with English law. Any dispute(s) arising in connection with this Legal Notice are subject to the exclusive jurisdiction of England and Wales.

If You want to contact us with any questions, comments or complaints about how we collect, use or retain Your personal data sent to this Website, please email our Data Protection Officer or call 01527 871123

These policy statements are dated April 2019.