Introduction

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.

Controller

This privacy

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.

Contact details

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: structures@torocorp.co.uk

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,

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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.

Third-party links

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

data).

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.

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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

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. 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.

(a) Identity

(b) Contact

(c) Profile

(d) Marketing and

Communications

(a) Performance of a contract with you

(b) Necessary to comply with a legal

obligation

(c) Necessary for our legitimate interests

(to keep our records updated and to study

how customers use our products/services)

(d) Consent

To use data analytics to improve

our website, products/services,

marketing, customer relationships

and experiences

(a) Technical

(b) Usage

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)

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Third-party marketing

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

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

or access cookies. If you disable or refuse cookies, please note that some parts of this website may

become inaccessible or not function properly.

For further information about Google Analytics please visit –

http://www.google.com/intl/en/policies/privacy/

You can prevent tracking by Google Analytics by going to –

https://tools.google.com/dlpage/gaoptout?hl=en

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

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• 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.

International transfers

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.

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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

our response.

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.

9. Glossary

LAWFUL BASIS

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

contract.

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.