Privacy Policy

This privacy policy (together with our terms of use and any other documents referenced) sets out the basis on which any personal data we collect from you, or that you provide to us, will be processed by us. This privacy policy also sets out your rights in relation to the personal data which CNG Services Ltd (CSL) hold about you.

Please read the following carefully to understand our views and practices regarding your personal data and how we will use it.

For the purpose of data protection law, including the UK Data Protection Act 1998 (DPA) and the General Data Protection Regulation (GDPR), CSL is the data controller.

1) Purpose of this Privacy Notice

This privacy notice aims to give you information on how CSL collects and processes your personal data through interactions you may have with the business.

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.

1.1 Controller

CSL is the controller and responsible for your personal data (collectively referred to as CSL, “we”, “us” or “our” in this privacy notice).

We have appointed Julie Lazenby as our Data Protection Manager (DPM) who is responsible for overseeing questions in relation to this privacy notice. If you have any questions, including any requests to exercise your legal rights, please contact the DPM using the details set out below.

1.1.1 Contact Details

Our full details are:

• Full name of legal entity: CNG Services Limited
• Name of contact: Julie Lazenby
• Email address: julie.lazenby@cngservices.co.uk or info@cngservices.co.uk
• Postal address: Virginia House, 56 Warwick Road, Olton, Solihull, United Kingdom, B92 7HX
  Third-party links

1.1.2 Third-party links

CSL’s website may include links to third-party websites, plugs-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) Data Collected Personal Data

2.1 Personal data
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). All electronic content is subject to the GDPR.

We may collect, use, store and transfer different kinds of personal data about you which we have grouped together below:

• Identity Data includes first name, last name, company and job title.
• Contact Data includes contact numbers, all relevant company and residential addresses and
  email address.
• Transaction Data includes details about payments to and from you and other details of
  products and services you have purchased or supplied.
• Marketing and Communications data includes your preferences in receiving marketing from
  us and our third parties and your communication preferences.

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 options, trade union membership, criminal convictions/offences, information about your genetic and biometric data).

2.1.1 Failure 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. 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.

2.2 How Your Personal Data is Collected
We use different methods to collect data from and about you including through:

• Direct interactions – you may give us your Identity, Contact and Marketing and Communications Data by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:
  • become a CSL employee
  • become a CSL customer/supplier
  • are referred by a common connection/third party
  • request marketing to be sent to you
  • give us some feedback.

2.3 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.

Occasionally, we are going to send marketing communications to you via email. You have the right to withdraw consent to marketing at any time by contacting us at info@cngservices.co.uk

2.3.1 Purposes for which we will use Your Personal Data

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. Information that will be sent to external recipients has to go through document control. 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.

Note, do not send other peoples’ personal details by email unless the recipient is verifiably the correct person and you have the correct permissions.

2.3.2 Marketing

We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising.

We may store your personal data on our Customer Relationship Management (CRM) software, named ‘Insightly’, and it may pass through our newsletter software, named ‘MailChimp’ when sending out e- letters. If you receive any correspondence from us through ‘MailChimp’ you will be given the option to unsubscribe.

2.3.3 Promotional Offers from us

We may use your Identity, Contact, Technical and Marketing and Communications 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, services and offers may be relevant for you.

You may/will receive marketing communications from us if you have requested information or purchased goods/services from us and, in each case, you have not opted out of receiving marketing information.

2.3.4 Third Party Marketing

We do not share personal data with third parties for marketing. Should this ever change, we will get your consent before we share your personal data for marketing purposes with anyone outside CSL.

2.3.5 Opting Out

You can ask us to stop sending you marketing emails at any time by following the opt-out links on any marketing emails set to you or by contacting us at any time.

Where you opt out of receiving these marketing emails this will not apply to personal data provided to us as a result of a product/ service purchase, warranty registration, product/ service experience or other transaction.

2.3.6 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 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.

2.4 Disclosures of Your Personal Data

We may have to share your personal data with third parties for the purposes set out in table 1 above.

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. Examples of changes are to sell, transfer, or merge parts of our business or our assets with third parties whom we have chosen. Alternatively, we may seek to acquire other businesses or merge with them.

We require all third parties to respect the security of your personal data and to treat it in accordance with the law.

2.4.1 CSL Employee Rights Under GDPR

All CSL employees retain the following rights regarding their personnel details under GDPR including:

• The right to be informed
• The right of access
• The right to rectification
• The right to erasure
• The right to restrict processing
• The right to data portability
• The right to object
• The right not to be subject to automated decision-making including profiling.

If an employee wants to access their data, this must be done through the HR department.

2.5 Internal Transfers

We may need to share your personal data with parties outside of England if we do business internationally.

2.6 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 (CNG-HUM-POL- 613_IT System Security Policy and CNG Services Employee Handbook_CNG-HUM-MSC-015) and will notify you and any applicable regulator of a breach where we are legally required to do so. All data breaches will be subject to further investigation at Senior Management level.

2.7 Data Retention

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 following:

• the amount,
• nature,
• 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 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.

2.7.1 No Fee Usually Required

You will not have to pay a fee to access your personal data (or to exercise any of your other rights in section 3.4.1). 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.

2.7.2 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

3) Glossary

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.

4) Your Legal Rights

You have rights under data protection laws in relation to your personal data. You have the right to:

Request access to your personal data (commonly known as a “data subject access request”). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.

Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.

Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.

Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.

Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios:

a) if you want us to establish the data’s accuracy

b) where our use of the data is unlawful, but you do not want us to erase it

c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims

d) you have objected to our use of your data, but we need to verify whether we have overriding legitimate grounds to use it.

Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.

Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.

Complain to the regulator. 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.

If you wish to exercise any of the rights set out above, please contact us. All requests by a data owner for their data will be dealt with promptly and in line with the time periods set by legislation.

Document valid until: 16/11/2026.