Please read the following carefully to understand our views and practices regarding personal data and how we will treat it. By using our website or purchasing our products, you consent to the collection, use, storage and disclosure of personal information as set out in this policy.
Our full details are:
Name of legal entity: Moove Lubricants Limited
Name: Rudi Trevisani
Postal Address: 30 Tower View, Kings Hill, West Malling, Kent ME19 4UY
Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).
We may collect, use, store and transfer different kinds of personal data about you which we have grouped together follows:
“Identity Data” includes first name, last name, username or similar identifier, marital status, title, date of birth, gender and in some instances, passport details and photograph.
“Contact Data” includes billing address, delivery address, email address and telephone numbers.
“Financial Data” includes bank account and payment card details.
“Marketing and Communications Data” includes your preferences in receiving marketing from us and our third parties and your communication preferences.
“Profile Data” includes your username and password, membership details in relation to our membership programmes, purchases or orders made by you, your interests, preferences, feedback and survey responses.
“Technical Data” includes internet protocol (IP) address, your login data, 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 you use to access this website.
“Transaction Data” includes details about payments to and from you and other details of products you have purchased from us.
“Usage Data” includes information about how you use our website (including our membership programmes) and products.
Where we need to collect personal data by law, or under the terms of a contract we have with you and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with products). In this case, we may have to cancel a product or service you have with us but we will notify you if this is the case at the time.
We use different methods to collect data from and about you including through:
Direct interactions. You may give us your Identity, Contact and Financial Data by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:
Please note that we may monitor, record, store and use any telephone, email or other communication with you in order to check any instructions given to us, for training purposes, for crime prevention and to improve the quality of our customer service.
Automated technologies or interactions. As you interact with our website, we may automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies, server logs and other similar technologies. We may also receive Technical Data about you if you visit other websites employing our cookies.
Third parties or publicly available sources. We may receive personal data about you from various third parties and public sources as set out below:
We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:
We have set out below, in a table format, a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.
Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data.
|Purpose/Activity||Type of data||Lawful basis for processing including basis of legitimate interest|
|To register you as a new customer or as a member to our loyalty and reward scheme||
||Performance of a contract with you.|
|To process and deliver our products including:
|To manage our relationship with you which will include:
|To enable you to partake in our loyalty and reward scheme, surveys or competitions||
|To administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)||
|To deliver relevant website content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you||
||Necessary for our legitimate interests (to study how customers use our products, loyalty and reward scheme and website, to develop them, to grow our business and to inform our marketing strategy).|
|To use data analytics to improve our website, products, marketing, loyalty and reward scheme, customer relationships and experiences||
||Necessary for our legitimate interests (to define types of customers for our products, loyalty and reward scheme, to keep our website updated and relevant, to develop our business and to inform our marketing strategy).|
|To make suggestions and recommendations to you about products or services that may be of interest to you||
||Necessary for our legitimate interests (to develop our products / services and grow our business).|
We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising. For PPP (our loyalty and reward scheme), we have established a privacy centre where you can view and make certain decisions about your personal data use https://www.commaoil.com/ppp/account. For all other data enquiries please contact us via MARKETING@uk.moovelub.com.
We may use your Identity, Contact, Technical, Usage and Profile Data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which products and services and offers may be relevant for you (we call this marketing).
You will receive marketing communications from us if you have requested information from us or purchased products from us and, in each case, you have not opted out of receiving that marketing.
We will get your express opt-in consent before we share your personal data with any company outside the Moove Lubricants group of companies for marketing purposes.
You can ask us or third parties to stop sending you marketing messages at any time by following the opt-out links on any marketing message sent to you or by contacting us at MARKETING@uk.moovelub.com.
Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of a product purchase, membership programme, product experience or other transactions.
We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us at firstname.lastname@example.org.
If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.
Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.
We may have to share your personal data with the parties set out below for the purposes set out in the table in paragraph 5 above.
You agree that we have the right to share your personal information with the recipients referred to below for the purposes set out in the table in paragraph 5 above (under the heading ‘Purposes for which we will use your personal data’).
|Recipient||Category of data||Purpose|
|Banks and payment providers services||
||Processing of payments in the performance of our contract with you|
|Business partners, suppliers or sub-contractors such as [Logistic and Marketing companies.||
||Performance of any contract we enter into with you or our customer or for the taking of steps at your or our customer’s request with a view to entering into a contract|
|Credit reference agencies||
||Assessing your credit score which may be a condition of us entering into a contract with you, for fraud prevention and/or to pursue debtors which is necessary for our legitimate interests|
|Analytics and search engine providers||Aggregate anonymised information about users of our products and website||Improvement and optimisation of our business which is necessary:
|Professional advisers such as insurers, accountants, lawyers, business advisers, pension advisers and financial advisors||
||Supporting Moove Lubricants investigations which is necessary for:
|Software development companies, cloud and infrastructure companies and web designers||
||Our legitimate interests (for running our business, provision of administration and IT services).|
Where it is necessary for us to share your personal information:
We will also disclose your personal information to third parties:
We may also share your personal data with other companies in the Moove Lubricants group which means our subsidiaries, our ultimate holding company and its subsidiaries, as defined in section 1159 of the UK Companies Act 2006. This is necessary for our legitimate interests for running our business, to study how customers use our products/services, to develop them, to grow our business and to inform our marketing strategy.
We store your personal data within the Moove Lubricants Group. This will involve transferring your data outside of the European Economic Area (“EEA”).
Many of our external third parties are also based outside the EEA so their processing of your personal data will involve a transfer of data outside the EEA.
Whenever we transfer your personal data out of the EEA, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:
Please contact us at email@example.com if you want further information on the specific mechanism used by us when transferring your personal data out of the EEA.
We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.
We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.
We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.
To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.
Where we have to keep basic information about our customers by law (including Contact, Identity, Financial and Transaction Data), we shall retain such personal data for six years after they cease being customers for tax purposes.
In some circumstances you can ask us to delete your data: see Request erasure below for further information.
In some circumstances we may anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes in which case we may use this information indefinitely without further notice to you.
Under certain circumstances, you have the following rights under data protection laws in relation to your personal data:
If you wish to exercise any of the rights set out above, please contact us at firstname.lastname@example.org.
You have the right to make a complaint at any time to the Information Commissioner's Office (“ICO”), the UK supervisory authority for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.
You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.
We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.
We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.
Our website may, from time to time, contain links to and from the websites of our partner networks, advertisers and affiliates (including, but not limited to, websites on which our products are advertised). If you follow a link to any of these websites, please note that these websites and any services that may be accessible through them have their own privacy policies and that we do not accept any responsibility or liability for these policies or for any personal data that may be collected through these websites or services, such as contact and location data. Please check these policies before you submit any personal data to these websites or use these services.
Our products and website are not directed to children. If a parent or guardian becomes aware that his or her child has provided us with personal data without their consent, please contact us. If we become aware that a child has registered for a product or service and has provided us with personal data, we will delete such information from our files.
It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.