1 Westgate Street, London E8 3RL ("**POWSTER**", "**we**", "**us**" or "**our**") collects, uses, maintains,
discloses and processes the personal information collected from visitors of the www.trailered.com website
("**Site**") prospective customers and customers who use any of our services or products ("**Services**")
(together referred to as "**you**" or "**your**").
Our Site is targeted at adults. We never knowingly collect personal information via our Site from those we
know are under 13, and no part of our Site is structured to attract anyone under 13.
At POWSTER, we're committed to keeping your personal information safe and secure, and handling it in
accordance with applicable data protection laws. This Policy contains important information and we ask
that you read it carefully. In this Policy, you can find more about:
[**What personal information we collect and when and why we use it**](#personal-info) .
[**How we protect and store personal information**](#protect) .
[**How we share personal information within the Company and with our service providers, regulators and
other third parties**](#sharing-personal-info) .
[**Explaining more about Direct Marketing**](#direct-marketing) .
[**Transferring personal information globally**](#transferring-personal-info) .
[**Legal rights available to help manage your privacy**](#legal-rights) .
[**Contacting us**](#contact-us) .
**What is a cookie?
A cookie is a small text file containing small amounts of information which is downloaded to/stored on
your computer (or other internet enabled devices, such as a smartphone or tablet) when you visit a website.
Cookies help us remember information about your visit to our Site, like your country, language and other
settings. They can also help us to operate our Site more efficiently and make your next visit easier.
Cookies can also allow us to do various other things, as we further explain below.
**What cookies do we use?**
When you visit our Site, the following cookies may be downloaded to your device:
These cookies allow us to recognise and count the number of visitors/users of our Site and to see how such
visitors/users move around our Site when they are using it. This helps us to improve the way our Site
works, for example, by ensuring that users are finding what they are looking for easily.
These cookies are used to recognise you when you return to our Site. This enables us to personalise our
content for you, greet you by name and remember your preferences.
While we do not use targeting cookies for advertising purposes, we use Google Analytics on our Site for
analytical/performance purposes. Google Analytics allows us to track anonymous user movement and
interaction on our Site, as well as monitoring how our Site works under high volume or stressed conditions. The types of aggregated events we track using Google Analytics include:
* Site user activity (which includes new users/returning users/length of visit/pages reviewed/bounce
* Demographics (such as age/gender)
* Geo Location data/language
* Platform (such as browser/network/device)
To enrich our content, we sometimes embed social options, photos and video content from websites such
as Facebook, Twitter and YouTube. As a result, when you visit a page with content embedded from, for
example, YouTube, YouTube may set a cookie. Please note that we do not control the dissemination of
these cookies and you should check the relevant third party website, such as Facebook, Twitter or
YouTube, for more information about their cookies.
How can you turn off cookies?
If you do not want us to install cookies or you don’t agree to how we use them in any way, you can change
the settings on your internet browser or reject cookies. The "Help" section of the toolbar on most browsers
will tell you how to prevent your device from accepting new cookies, how to have the browser notify you
when you receive a new cookie, or how to disable cookies altogether. However, if you use your browser
settings to block all cookies (including those cookies that are strictly necessary for the administration and
operation of our Site) you may experience reduced functionality or not be able to access all or parts of our
Site. Further information may be found at www.allaboutcookies.org.
What personal information and when and why we use it
We collect personal information from you if you:
* visit our site
* purchase one of our Services
* work with us as a business partner or service provider
If you visit our Site, we collect the following personal information from you:
- your name, email address and your query if you "Sign up" for any relevant notifications
- your name email address if you would like to receive our newsletters
- via the cookies we use on our Site. Furthermore, information about our cookie usage, please click
POWSTER uses this personal information to:
- personalize your experience of our Site. We may use information in the aggregate to understand
how users of our Site, as a group, use the Services and resources provided on our Site
- improve our Site. We may use feedback from you to improve our Services
- send periodic emails and newsletters. For example, we may use your email address to respond to
your inquiries, questions, and/or other requests, arrange a demo of our Services or send you
newsletters (as applicable)
If you purchase one of our Services, we collect the following personal information from you:
- full name
- job title
- email address
- company name and address
- company telephone
- (as applicable) transaction information
POWSTER uses this personal information to facilitate the delivery of the requested Services, and (where
applicable) provide Trailered updates and/or newsletters.
If you work with us as a business partner or service provider, we collect the following personal
information from you:
- full name
- job title
- email address
- company address
- company telephone
- transaction information
POWSTER uses this personal information to:
- review/assess your suitability as a business partner or service provider
- provide/use services as required
Legal basis for using your personal information
We will only collect, use and share your personal information where we are satisfied that we have an
appropriate legal basis to do this. This is because:
* we need to use your personal information to perform a contract or take steps to enter into a
contract with you. For example, to take payment for the Service you ordered, and to provide you
with, and to inform you of any technical issues concerning, the Service you ordered;
* we need to use your personal information for our legitimate interest as a commercial organisation.
For example, for good governance, accounting, and managing and auditing our business
operations. In all such cases, we will look after your information at all times in a way that is
proportionate and respects your privacy rights and you have a right to object to processing as
explained in [**Your legal rights**](#legal-rights);
* we need to use your personal information to comply with a relevant legal or regulatory obligation
that we have. For example, for activities relating to the prevention, detection and investigation of
crime and for compliance with legal and regulatory requirements and related disclosures;
* we have your consent to using your personal information for a particular activity. For example,
where relevant, to send certain direct marketing to you.
If you would like to find out more about the legal basis for which we process personal information, please
How we protect and store your personal information
We have adopted appropriate data collection, storage and processing practices, technical, organisational
and security measures designed to protect against unauthorized access, alteration, disclosure or destruction
of the personal information that you share with us. For example, such measures include:
* placing confidentiality requirements on our staff members and service providers;
* destroying or permanently anonymising personal information if it is no longer needed for the
purposes for which it was collected;
* following security procedures in the storage and disclosure of your personal information to
prevent unauthorised access to it; and
* using secure communication channels such as SSL ("secure sockets layer") for transmitting data
that is sent to us. SSL is an industry standard encryption protocol used to protect online
As the security of information depends in part on the security of the computer you use to communicate
with us and the security you use to protect user IDs and passwords, please take appropriate measures to
protect this information.
We will store your personal information for as long as is reasonably necessary for the purposes for which it
was collected, as explained in this Policy. Where your information is no longer needed, we will ensure that
it is disposed of in a secure manner. In some circumstances we may store your personal information for
longer periods of time, for instance where we are required to do so in accordance with legal, regulatory, tax
and accounting requirements. In specific circumstances we may store your personal information for longer
periods of time so that we have an accurate record of your dealings with us in the event of any complaints
or challenges, or if we reasonably believe there is a prospect of litigation relating to your personal
information or dealings. If you have any questions about how we store your personal information, please
contact us via the contact details set out below.
Sharing your personal information with others
We share your personal information in the manner and for the purposes described below:
* **with other companies within our group** where such disclosure is necessary to provide you with
our Services or to manage our business. [**Click here for a list of our group companies**](http://www.vistagroup.co.nz/vista-group-businesses.html);
* **with third parties who help manage our business and deliver services**. These third parties have
agreed to confidentiality restrictions and use any personal information we share with them or
which they collect on our behalf solely for the purpose of providing the contracted service to us.
These include Amazon Web Services, Google Cloud Platform, Cloudflare, Ubiquiti, Synology,
Apple, Jazz HR, Asana, SalesForce, Slack, Sentry, Eat Work Art and Verisure;
* **with government organisations and agencies, law enforcement, regulators**, to comply with all
applicable laws, regulations and rules, and requests of law enforcement, regulatory and other
* **banks and payment providers** to authorize and complete payments;
* **with credit reference agencies and organisations** working to prevent fraud in financial services;
* we may share in aggregate, statistical form, non-personal information regarding the visitors to our
Site, traffic patterns, and Site usage with our partners, affiliates or advertisers.
If, in the future, we sell or transfer some or all of our business or assets to a third party, we may disclose
information to a potential or actual third party purchaser of our business or assets.
Third party websites
You may find there is advertising or other content on our Site that link to the sites and services of our
partners, suppliers, advertisers, sponsors, licensors and other third parties. We do not control the content or
links that appear on these sites and are not responsible for the practices employed by websites linked to, or
from our Site. In addition, these sites or services, including their content and links, may be constantly
changing. These sites and services may have their own privacy policies and customer service policies.
Browsing and interaction on any other website, including websites which have a link to our Site, is subject
to that website's own terms and policies. This Policy does not apply to your use of any third party websites.
Explaining more about direct marketing
**How we use personal information to keep you up to date with our Services**
We may use personal information to let you know about Services that we believe will be of interest to you
and/or provide you with our newsletter. We may contact you by email, post, or telephone or through other
communication channels that we think you may find helpful. In all cases, we will respect your preferences
for how you would like us to manage marketing activity with you.
**How you can manage your marketing preferences**
To protect privacy rights and to ensure you have control over how we manage marketing with you:
* we will take steps to limit direct marketing to a reasonable and proportionate level and only send
you communications which we believe may be of interest or relevance to you;
* you can ask us to stop direct marketing at any time - you can ask us to stop sending email
marketing, by following the "unsubscribe" link you will find on all the email marketing messages
we send you. Alternatively, you can contact us via our [**Contact Us**](#contact-us) page. Please specify whether
you would like us to stop all forms of marketing or just a particular type (e.g. email); and
* you can change the way your browser manages cookies, which may be used to deliver online
We recommend you routinely review the privacy notices and preference settings that are available to you
on any social media platforms as well as your preferences within your account with us.
Transferring personal information globally
We operate on a global basis. Accordingly, as part of our business activities, your personal information
may be transferred and stored in countries outside of Europe, including the United States and New
Zealand, that are subject to different standards of data protection.
We will take appropriate steps ensure that transfers of personal information are in accordance with
applicable law and carefully managed to protect your privacy rights and interests and transfers are limited
to countries which are recognized as providing an adequate level of legal protection or where we can be
satisfied that alternative arrangement are in place to protect your privacy rights. To this end:
* we ensure transfers within our group of companies will be covered by an agreement entered into
by members of our group of companies (an intra-group agreement) which contractually obliges
each member to ensure that personal information receives an adequate and consistent level of
protection wherever it is transferred within our group of companies;
* where we transfer your personal information outside our group of companies or to third parties
who help provide our Services, we obtain contractual commitments from them to protect your
personal information. Some of these assurances are well recognized certification schemes like the
EU - US Privacy Shield for the protection of personal information transferred from within the EU
to the United States; or
* where we receive requests for information from law enforcement or regulators, we carefully
validate these requests before any personal information are disclosed.
You have a right to Contact Us for more information about the safeguards we have put in place (including
a copy of relevant contractual commitments) to ensure the adequate protection of your personal
information when this is transferred as mentioned above.
Your legal rights
Subject to certain exemptions, and in some cases dependent upon the processing activity we are
undertaking, you have certain rights in relation to your personal information. Click on the links below to
learn more about each right you may have:
* [**To access personal information**](#access-personal-info)
* [**To rectify / erase personal information**](#rectify)
* [**To restrict the processing of your personal information**](#restrict)
* [**To transfer your personal information**](#transfer)
* [**To object to the processing of personal information**](#right-to-object)
* [**To object to how we use your personal information for direct marketing purposes**](#object-marketing)
* [**To obtain a copy of personal information safeguards used for transfers outside your jurisdiction**](#obtain-copy)
* [**To lodge a complaint with your local supervisory authority**](#complaint)
If you wish to access any of the above-mentioned rights, we may ask you for additional information to
confirm your identity and for security purposes, in particular before disclosing personal information to you.
We reserve the right to charge a fee where permitted by law, for instance, if your request is manifestly
unfounded or excessive.
You can exercise your rights by Contacting Us. Subject to legal and other permissible considerations, we
will make every reasonable effort to honour your request promptly or inform you if we require further
information in order to fulfil your request.
We may not always be able to fully address your request, for example, if it would impact the duty of
confidentiality we owe to others, or if we are legally entitled to deal with the request in a different way.
Right to access personal information
You have a right to request that we provide you with a copy of your personal information that we hold and
you have the right to be informed of: (a) the source of your personal information; (b) the purposes, legal
basis and methods of processing; (c) the data controller’s identity; and (d) the entities or categories of
entities to whom your personal information may be transferred.
Right to rectify or erase personal information
You have a right to request that we rectify inaccurate personal information. We may seek to verify the
accuracy of the personal information before rectifying it.
You can also request that we erase your personal information in limited circumstances where:
- it is no longer needed for the purposes for which it was collected; or
- you have withdrawn your consent (where the data processing was based on consent); or
- following a successful right to object (see Right to object); or
- it has been processed unlawfully; or
- to comply with a legal obligation to which POWSTER is subject.
We are not required to comply with your request to erase personal information if the processing of your
personal information is necessary:
- for compliance with a legal obligation; or
- for the establishment, exercise or defence of legal claims.
Right to restrict the processing of your personal information
You can ask us to restrict your personal information, but only where:
- its accuracy is contested, to allow us to verify its accuracy; or
- the processing is unlawful, but you do not want it erased; or
- it is no longer needed for the purposes for which it was collected, but we still need it to establish,
exercise or defend legal claims; or
- you have exercised the right to object, and verification of overriding grounds is pending.
We can continue to use your personal information following a request for restriction, where:
- we have your consent; or
- to establish, exercise or defend legal claims; or
- to protect the rights of another natural or legal person.
Right to transfer your personal information
You can ask us to provide your personal information to you in a structured, commonly used,
machine-readable format, or you can ask to have it transferred directly to another data controller, but in
each case only where:
- the processing is based on your consent or on the performance of a contract with you; and
- the processing is carried out by automated means.
Right to object to the processing of your personal information
You can object to any processing of your personal information which has our legitimate interests as its
legal basis, if you believe your fundamental rights and freedoms outweigh our legitimate interests.
If you raise an objection, we have an opportunity to demonstrate that we have compelling legitimate
interests which override your rights and freedoms.
Right to object to how we use your personal information for direct marketing purposes
You can request that we change the manner in which we contact you for marketing purposes.
You can request that we not transfer your personal information to unaffiliated third parties for the purposes
of direct marketing or any other purposes.
Right to obtain a copy of personal information safeguards used for transfers outside your
You can ask to obtain a copy of, or reference to, the safeguards under which your personal information is
transferred outside of the European Union.
We may redact data transfer agreements to protect commercial terms.
Right to lodge a complaint with your local supervisory authority
You have a right to lodge a complaint with your local supervisory authority if you have concerns about
how we are processing your personal information.
We ask that you please attempt to resolve any issues with us first, although you have a right to contact your
supervisory authority at any time.
POWSTER may update this Policy at any time. When we do, we will revise the updated date at the bottom
of this page. We encourage you to frequently check this page for any changes to stay informed about how
we may use and protect the personal information we collect. If we make fundamental changes to this
Policy, we will seek to inform you by notice on our Site or by email.
Our Head of Information Security and Compliance has ultimate responsibility for making sure that
POWSTER Policy and any applicable laws are complied with. Our Head of Information Security and
Compliance can be contacted by emailing: firstname.lastname@example.org or Yann.Teboul@vista.co
If you have any questions, concerns or complaints regarding our compliance with this Policy, the
information we hold about you or if you wish to exercise your rights, we encourage you to first contact us.
We will investigate and attempt to resolve complaints and disputes and make every reasonable effort to
honour your wish to exercise your rights as quickly as possible and in any event, within the timescales
provided by data protection laws.
You have a right to lodge a complaint with your local data protection supervisory authority (i.e. your place
of habitual residence, place or work or place of alleged infringement), which in the UK is the Information
Commissioner's Office at any time. We ask that you please attempt to resolve any issues with us before
your local supervisory authority.
Issue Date of Privacy Notice: 31 October 2018