Privacy Policy and GDPR Compliance Information

This document refers to personal data, which is defined as information concerning any living person (a natural person who hereafter will be called the Data Subject) that is not already in the public domain.

The General Data Protection Regulation (GDPR) seeks to protect and enhance the rights of data subjects. These rights cover the safeguarding of personal data, protection against the unlawful processing of personal data, and the unrestricted movement of personal data within the EU. It should be noted that GDPR does not apply to information already in the public domain.

Hawthorn Logistics Solutions Ltd is pleased to provide the following Privacy Notice:

Personal Data

Hawthorn Logistics Solutions Ltd uses the information collected from you to provide quotations, make telephone contact, and email you marketing information which Hawthorn Logistics Solutions Ltd believes may be of interest to you and your business. By making initial contact, you consent to Hawthorn Logistics Solutions Ltd maintaining a marketing dialogue with you until you either opt out (which you can do at any stage) or we decide to desist in promoting our services.

Hawthorn Logistics Solutions Ltd also acts on behalf of its clients in the capacity of data processor. When working exclusively as a data processor, Hawthorn Logistics Solutions Ltd will be acting on the instruction of its client and will work hard to ensure that the client is fully GDPR compliant.

Some personal data may be collected about you from the forms and surveys you complete, from records of our correspondence and phone calls, and from details of your visits to our website, including but not limited to personally identifying information such as Internet Protocol (IP) addresses. Hawthorn Logistics Solutions Ltd may from time to time use such information to identify its visitors. Hawthorn Logistics Solutions Ltd may also collect statistics about the behaviour of visitors to its website.

Hawthorn Logistics Solutions Ltd website uses cookies, which are small pieces of information stored on a visitor’s computer and provided to the website each time the visitor returns. Hawthorn Logistics Solutions Ltd uses cookies to help identify and track visitors and their website access preferences. Website visitors who do not wish to have cookies placed on their computers should set their browsers to refuse cookies before using Hawthorn Logistics Solutions Ltd website.

Any information Hawthorn Logistics Solutions Ltd holds about you and your business encompasses all the details we hold about you and any sales transactions, including any third-party information we have obtained about you from public sources and our own suppliers, such as credit referencing agencies.

Hawthorn Logistics Solutions Ltd will only collect the information needed so that it can provide you with marketing and consulting services. Hawthorn Logistics Solutions Ltd does not sell or broker your data, although there may be occasions when your information is contained within data that Hawthorn Logistics Solutions Ltd has purchased from a third-party list broker on behalf of a client.

Legal Basis for Processing Personal Data

To meet Hawthorn Logistics Solutions Ltd contractual obligations to clients and to respond to marketing enquiries.

Legitimate interests:
To promote the marketing and consulting services offered by Hawthorn Logistics Solutions Ltd and/or to market the services and/or products offered by Hawthorn Logistics Solutions Ltd’s existing clients.

Consent

Through agreeing to this privacy notice, you are consenting to Hawthorn Logistics Solutions Ltd processing your personal data for the purposes outlined. You can withdraw consent at any time by emailing compliance@hawthornlogistics.ie or writing to us. Please see the last section for full contact details.

Disclosure

Hawthorn Logistics Solutions Ltd may on occasion pass your personal information to third parties exclusively to process work on its behalf. Hawthorn Logistics Solutions Ltd requires these parties to agree to process this information based on our instructions and requirements consistent with this Privacy Notice and GDPR.

Hawthorn Logistics Solutions Ltd does not broker or pass on information gained from your engagement with the company without your consent. However, Hawthorn Logistics Solutions Ltd may disclose your personal information to meet legal obligations, regulations, or valid governmental requests. The company may also enforce its Terms and Conditions, including investigating potential violations of those Terms and Conditions, detecting, preventing, or mitigating fraud, security, or technical issues, or protecting against imminent harm to the rights, property, or safety of Hawthorn Logistics Solutions Ltd, its clients, and/or the wider community.

Retention Policy

Hawthorn Logistics Solutions Ltd will process personal data during the duration of any contract and will continue to store only the personal data needed for five years after the contract has expired in order to meet any legal obligations. After five years, any personal data not needed will be deleted.

Data Storage

Data is held in Ireland using multiple servers. Hawthorn Logistics Solutions Ltd does not store personal data outside the EEA.

Your Rights as a Data Subject

At any point whilst Hawthorn Logistics Solutions Ltd is in possession of or processing your personal data, all data subjects have the following rights:

• Right of access – you have the right to request a copy of the information that we hold about you.
• Right of rectification – you have the right to correct data that we hold about you that is inaccurate or incomplete.
• Right to be forgotten – in certain circumstances you can ask for the data we hold about you to be erased from our records.
• Right to restriction of processing – where certain conditions apply, you have a right to restrict the processing.
• Right of portability – you have the right to have the data we hold about you transferred to another organisation.
• Right to object – you have the right to object to certain types of processing, such as direct marketing.
• Right to object to automated processing, including profiling – you also have the right not to be subject to the legal effects of automated processing or profiling.

In the event that Hawthorn Logistics Solutions Ltd refuses your request under rights of access, we will provide you with a reason as to why, and you have the right to challenge that decision.

Hawthorn Logistics Solutions Ltd can, at your request, confirm what information it holds about you and how it is processed.

You Can Request the Following Information

Identity and the contact details of the person or organisation (Hawthorn Logistics Solutions Ltd) that has determined how and why to process your data.

Contact details of the data protection officer, where applicable.

The purpose of the processing, as well as the legal basis for processing.

If the processing is based on the legitimate interests of Hawthorn Logistics Solutions Ltd or a third party such as one of its clients, information about those interests.

The categories of personal data collected, stored, and processed.

Recipient(s) or categories of recipients that the data is or will be disclosed to.

How long the data will be stored.

Details of your rights to correct, erase, restrict, or object to such processing.

Information about your right to withdraw consent at any time.

How to lodge a complaint with the supervisory authority.

• Whether the provision of personal data is a statutory or contractual requirement, or a requirement necessary to enter into a contract, as well as whether you are obliged to provide the personal data and the possible consequences of failing to provide such data.
• The source of personal data if it was not collected directly from you.
• Any details and information regarding automated decision making, such as profiling, and any meaningful information about the logic involved, as well as the significance and expected consequences of such processing.

Identification Required to Access Personal Data

Hawthorn Logistics Solutions Ltd will accept the following forms of ID when information on your personal data is requested: a copy of your national ID card, driving licence, passport, birth certificate, and a utility bill not older than three months. A minimum of one piece of photographic ID listed above and one supporting document is required. If Hawthorn Logistics Solutions Ltd is dissatisfied with the quality of the documents provided, further information may be sought before personal data can be released.

All requests should be made to compliance@hawthornlogistics.ie, by phoning +353 1899 1101, or by writing to us at the address further below.

Complaints

In the event that you wish to make a complaint about how your personal data is being processed by Hawthorn Logistics Solutions Ltd or its partners, you have the right to complain to the Managing Director of Hawthorn Logistics Solutions Ltd. If you do not receive a response within 30 days, you may complain to the Data Protection Commission.

The details for each of these contacts are:
Hawthorn Logistics Solutions Ltd, FAO The Managing Director
Unit 1 Northwest Business Park
Ballycoolin
Dublin D15 NYH4
Ireland
Telephone +353 1899 1101 or email compliance@hawthornlogistics.ie

Data Protection Commission
Canal House
Station Road
Portarlington, Co. Laois, R32 AP23
Ireland
Telephone +353 5786 84800 or email: info@dataprotection.ie