Welcome to the Toro Shelters’s privacy notice.
Toro Shelters respects your privacy and is committed to protecting your personal data. This privacy
notice will inform you as to how we look after your personal data when you visit our website
(regardless of where you visit it from) and tell you about your privacy rights and how the law protects you
Please also use the Glossary to understand the meaning of some of the terms used in this privacy notice.
1. Important information and who we are
Purpose of this privacy notice
This privacy notice aims to give you information on how Toro Shelters collects and processes your
personal data through your use of this website.
This website is not intended for children and we do not knowingly collect data relating to children.
It is important that you read this privacy notice together with any other privacy notice or fair
processing notice we may provide on specific occasions when we are collecting or processing
personal data about you so that you are fully aware of how and why we are using your data. This
privacy notice supplements the other notices and is not intended to override them.
notice is issued on behalf of the Toro Shelters so when we mention Toro Shelters, “we”, “us” or
“our” in this privacy notice, we are referring to the relevant company in the Toro Shelters Ltd
responsible for processing your data. Tom Hallam-Eames is the controller and responsible for this website.
We have appointed a data privacy manager who is responsible for overseeing questions in relation
to this privacy notice. If you have any questions about this privacy notice, including any requests to
exercise your legal rights, please contact the data privacy manager using the details set out below.
Our full details are:
Full name of legal entity: Toro Corporation Ltd
Name or title of data privacy manager or Data controller: Tom Hallam-Eames
Email address: firstname.lastname@example.org
Postal address: Unit A, Berkely Court Business Park, Bristol, BS5 0BX
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.
Changes to the privacy notice and your duty to inform us of changes
This version was last updated on 27/02/19
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.
This website may include links to third-party websites, plug-ins and applications. Clicking on those
links or enabling those connections may allow third parties to collect or share data about you. We
do not control these third-party websites and are not responsible for their privacy statements. When
you leave our website, we encourage you to read the privacy notice of every website you visit.
2. The data we collect about you
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
We may collect, use, store and transfer different kinds of personal data about you which we have
grouped together follows:
• Information that you provide by filling in various forms on our web site e.g. to request
information on products and services. We may also ask you for information if you report a
problem with our web site.
• If you contact us, we may keep a record of that correspondence.
• Details of your visits to our web site and the resources that you access.
• IP addresses. We may collect information about your computer, including your IP address, for
the purposes described below.
We do not collect any Special Categories of Personal Data about you (this includes details about
your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions,
trade union membership, information about your health and genetic and biometric data). Nor do we
collect any information about criminal convictions and offences.
If you fail to provide personal data
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 goods or services). 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.
3. How is your personal data collected?
We use different methods to collect data from and about you including through:
4. How we use your personal data
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:
• Where we need to perform the contract we are about to enter into or have entered into with you.
• Where it is necessary for our legitimate interests (or those of a third party) and your interests
and fundamental rights do not override those interests.
• Where we need to comply with a legal or regulatory obligation.
Generally we do not rely on consent as a legal basis for processing your personal data and we will
not contact you unless you have specifically requested it. You have the right to withdraw consent to
marketing at any time by contacting us.
Purposes for which we will use your personal data
We have set out below 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
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. Please contact us if you need details about the
specific legal ground we are relying on to process your personal data where more than one ground
has been set out in the table below.
Purpose/Activity Type of data Lawful basis for processing including
basis of legitimate interest
To manage our relationship with
you, which will include sending
you information about Henry
Boot/marketing mailings where
you have requested this, or other
contact where you may have
requested us to contact you.
(d) Marketing and
(a) Performance of a contract with you
(b) Necessary to comply with a legal
(c) Necessary for our legitimate interests
(to keep our records updated and to study
how customers use our products/services)
To use data analytics to improve
our website, products/services,
marketing, customer relationships
Necessary for our legitimate interests (to
define types of customers for our products
and services, to keep our website updated
and relevant, to develop our business and
to inform our marketing strategy)
We will get your express opt-in consent before we share your personal data with any company
outside the Toro Shelters group of companies for marketing purposes.
Cookies are small text files stored on your device when you access most websites on the Internet.
Toro Shelters uses Analytics cookies on numerous pages of its website. These allow us to use Google
Analytics software to see various data regarding visits to our website. This data comprises:
• Date of visit
• Duration of visit (time)
• Page views per visit
• Country of visitor
• Browser used
No personal or identifiable information is collected or used.
By analysing this data Toro Shelters hopes to monitor the general use and consequently the success
of our website.
You can set your browser to refuse all or some browser cookies, or to alert you when websites set
become inaccessible or not function properly.
For further information about Google Analytics please visit –
You can prevent tracking by Google Analytics by going to –
For general information about cookies go to – http://www.allaboutcookies.org/
By using our website, you agree to the use of the cookies as outlined.
Change of purpose
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.
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.
5. Disclosures of your personal data
We may have to share your personal data with the parties set out below for the purposes set out in
the table in paragraph 4 above.
• Internal Third Parties as set out in the Glossary
• Third parties to whom we may choose to sell, transfer, or merge parts of our business or our
assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change
happens to our business, then the new owners may use your personal data in the same way as
set out in this privacy notice.
We require all third parties to respect the security of your personal data and to treat it in accordance
with the law. We do not allow our third-party service providers to use your personal data for their
own purposes and only permit them to process your personal data for specified purposes and in
accordance with our instructions.
We do not transfer your personal data outside the European Economic Area (EEA).
6. Data security
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.
7. Data retention
How long will you use my personal data for?
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.
In some circumstances you can ask us to delete your data, see section 8 below.
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.
Your legal rights
Under certain circumstances, you have rights under data protection laws in relation to your personal
data, such as:
• Request access to your personal data
• Request correction of your personal data
• Request erasure of your personal data
• Object to processing of your personal data
• Request restriction of processing your personal data
• Request transfer of your personal data
• Right to withdraw consent
If you wish to exercise any of the rights set out above, please contact the data privacy manager as
highlighted in section 1 above.
No fee usually required
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.
What we may need from you
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
Time limit to respond
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.
Legitimate Interest means the interest of our business in conducting and managing our business
to enable us to give you the best service/product and the best and most secure experience. We
make sure we consider and balance any potential impact on you (both positive and negative) and
your rights before we process your personal data for our legitimate interests. We do not use your
personal data for activities where our interests are overridden by the impact on you (unless we have
your consent or are otherwise required or permitted to by law). You can obtain further information
about how we assess our legitimate interests against any potential impact on you in respect of
specific activities by contacting us.
Performance of Contract means processing your data where it is necessary for the performance of
a contract to which you are a party or to take steps at your request before entering into such a
Comply with a legal or regulatory obligation means processing your personal data where it is
necessary for compliance with a legal or regulatory obligation that we are subject to.