Privacy Policy Statement
At Dalytrading, we respect the rights of every individual regarding how their personal data is collected, used, and protected. In the course of our operations, we may collect, store, and process personal information relating to our customers, suppliers, employees, and other third parties. We are committed to handling all such data responsibly, lawfully, and transparently.
Protecting personal data is essential to maintaining trust in our business and ensuring the smooth and successful delivery of our services. We expect all employees and authorised users who handle data on behalf of Dalytrading to follow this policy and comply with applicable data protection regulations at all times. Any misuse or breach of this policy will be treated seriously and may result in disciplinary action.
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About This Policy
At Dalytrading, we handle a variety of personal data relating to our employees, applicants, customers, suppliers, and other business partners. This information may be collected and stored in different formats, whether electronically, on paper, or through other secure systems.
We are committed to managing personal data in line with applicable laws and regulations, including the UK General Data Protection Regulation (UK GDPR) and the Data Protection Act 2018. These frameworks provide important safeguards to ensure that personal information is processed fairly, lawfully, and transparently.
This policy sets out the principles and standards that guide how Dalytrading obtains, uses, stores, transfers, and protects personal data. It also outlines the legal conditions that must be met whenever personal data is handled by us or on our behalf.
Dalytrading is responsible for ensuring compliance with data protection legislation and with this policy. Any questions or concerns regarding its operation, or if you believe the policy has not been followed, should be directed to our Data Protection Representative in the first instance.
We are committed to managing personal data in line with applicable laws and regulations, including the UK General Data Protection Regulation (UK GDPR) and the Data Protection Act 2018. These frameworks provide important safeguards to ensure that personal information is processed fairly, lawfully, and transparently.
This policy sets out the principles and standards that guide how Dalytrading obtains, uses, stores, transfers, and protects personal data. It also outlines the legal conditions that must be met whenever personal data is handled by us or on our behalf.
Dalytrading is responsible for ensuring compliance with data protection legislation and with this policy. Any questions or concerns regarding its operation, or if you believe the policy has not been followed, should be directed to our Data Protection Representative in the first instance.
Definitions of Data Protection Terms
To ensure clarity and consistency, Dalytrading uses the following key terms in relation to data protection:
Data:
Information that is stored electronically (for example, on a computer system), or maintained in certain.
Data Subject:
Any living individual whose personal data is held or processed by Dalytrading. A data subject does not need to be a UK national or resident. All data subjects are entitled to specific legal rights concerning the handling of their personal information.
Data Subject:
Any living individual whose personal data is held or processed by Dalytrading. A data subject does not need to be a UK national or resident. All data subjects are entitled to specific legal rights concerning the handling of their personal information.
Personal Data:
Any information relating to an identifiable individual. This may include factual details (such as a name, address, or date of birth) or opinions and assessments relating to that person’s actions, conduct, or characteristics.
Data Controller:
The organisation or individual responsible for determining how and why personal data is processed. As the controller of personal data for our business operations, Dalytrading is responsible for ensuring that appropriate practices, policies, and safeguards are in place.
Data Users:
Employees of Dalytrading whose roles involve accessing, handling, or processing personal data. All data users are required to manage this data securely and in full compliance with this policy and applicable data protection regulations.
Data Processors:
External individuals or organisations (other than employees of the data controller) who process personal data on behalf of Dalytrading, and strictly in line with our instructions. This may include third-party service providers or suppliers entrusted to handle certain data securely.
Processing:
Any action performed on personal data, whether automated or manual. This includes collecting, recording, storing, organising, adapting, retrieving, using, disclosing, transferring, erasing, or destroying data.
Special Category Data:
Certain types of personal information are considered particularly sensitive and require extra protection. This includes information about a person’s racial or ethnic background, political views, religious or philosophical beliefs, trade union membership, physical or mental health, sexual orientation, or records of criminal convictions and offences. Processing this type of data is strictly controlled and, in most cases, can only occur with the individual’s explicit consent or where permitted by law.
Data:
Information that is stored electronically (for example, on a computer system), or maintained in certain.
Data Subject:
Any living individual whose personal data is held or processed by Dalytrading. A data subject does not need to be a UK national or resident. All data subjects are entitled to specific legal rights concerning the handling of their personal information.
Data Subject:
Any living individual whose personal data is held or processed by Dalytrading. A data subject does not need to be a UK national or resident. All data subjects are entitled to specific legal rights concerning the handling of their personal information.
Personal Data:
Any information relating to an identifiable individual. This may include factual details (such as a name, address, or date of birth) or opinions and assessments relating to that person’s actions, conduct, or characteristics.
Data Controller:
The organisation or individual responsible for determining how and why personal data is processed. As the controller of personal data for our business operations, Dalytrading is responsible for ensuring that appropriate practices, policies, and safeguards are in place.
Data Users:
Employees of Dalytrading whose roles involve accessing, handling, or processing personal data. All data users are required to manage this data securely and in full compliance with this policy and applicable data protection regulations.
Data Processors:
External individuals or organisations (other than employees of the data controller) who process personal data on behalf of Dalytrading, and strictly in line with our instructions. This may include third-party service providers or suppliers entrusted to handle certain data securely.
Processing:
Any action performed on personal data, whether automated or manual. This includes collecting, recording, storing, organising, adapting, retrieving, using, disclosing, transferring, erasing, or destroying data.
Special Category Data:
Certain types of personal information are considered particularly sensitive and require extra protection. This includes information about a person’s racial or ethnic background, political views, religious or philosophical beliefs, trade union membership, physical or mental health, sexual orientation, or records of criminal convictions and offences. Processing this type of data is strictly controlled and, in most cases, can only occur with the individual’s explicit consent or where permitted by law.
Principles of Data Management
At Dalytrading, we ensure that all personal data is handled fairly, transparently, and in a manner that respects the rights of the individual. Our approach is designed to maintain trust while enabling the smooth operation of our business.
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Collected and processed fairly and lawfully, with respect for the individual’s rights.
Used only for specified, legitimate purposes, and handled appropriately to achieve those objectives.
Relevant, adequate, and limited to what is necessary for the intended purpose.
Accurate and kept up to date, with reasonable steps taken to correct any inaccuracies.
Retained only for as long as necessary, in line with business, legal, and regulatory requirements.
Managed in accordance with data subject rights, including access, correction, and deletion where applicable.
Protected against unauthorised or unlawful processing, accidental loss, destruction, or damage.
Not transferred outside the UK or countries lacking adequate data protection, unless appropriate safeguards are in place.
By adhering to these principles, Dalytrading ensures that personal data is managed responsibly, maintains trust with employees, clients, and suppliers, and supports the smooth operation of our business globally.
Lawful and Transparent Data Use
At Dalytrading, all personal data must be handled in accordance with key data protection principles designed to ensure legal compliance, transparency, and responsible use. These principles require that personal data is:
Personal data is processed only when there is a valid lawful basis, such as:
Personal data is processed only when there is a valid lawful basis, such as:
The individual’s consent for a specific purpose.
The processing being necessary to perform a contract with the individual.
Compliance with a legal or regulatory obligation.
The pursuit of a legitimate business interest, provided it does not override the rights of the data subject.
When handling special category data (sensitive personal data), we ensure that additional legal requirements are met, including obtaining explicit consent or satisfying other conditions permitted under law.
As the data controller for personal data used in our business operations, Dalytrading is committed to ensuring that all processing is lawful, justified, and conducted responsibly.
As the data controller for personal data used in our business operations, Dalytrading is committed to ensuring that all processing is lawful, justified, and conducted responsibly.
Purpose-Limited Data Processing
At Dalytrading, personal data is collected and processed only for clearly defined and legitimate business purposes. This includes information we receive directly from individuals — for example, through forms, correspondence, telephone, email, or other communication channels — as well as data obtained from trusted third-party sources, such as business partners, service providers, credit reference agencies, or logistics partners.
We commit to using personal data solely for the purposes outlined in our internal data schedule or for other purposes permitted under applicable law. Individuals are informed of these purposes at the point of data collection or as soon as reasonably possible thereafter.
By limiting the use of personal data to specific, legitimate objectives, Dalytrading ensures compliance with legal obligations, protects individual rights, and maintains the trust of our employees, clients, and partners.
We commit to using personal data solely for the purposes outlined in our internal data schedule or for other purposes permitted under applicable law. Individuals are informed of these purposes at the point of data collection or as soon as reasonably possible thereafter.
By limiting the use of personal data to specific, legitimate objectives, Dalytrading ensures compliance with legal obligations, protects individual rights, and maintains the trust of our employees, clients, and partners.
Data Subject Notification
At Dalytrading, we are committed to being transparent and accountable when handling personal data. When we collect personal information directly from individuals, we ensure they are informed about:
Personal data is processed only when there is a valid lawful basis, such as:
Personal data is processed only when there is a valid lawful basis, such as:
The specific purposes for which their personal data will be processed.
Any third parties with whom the data may be shared or disclosed.
How individuals can exercise control over the use and disclosure of their personal information.
When personal data is obtained from other sources, we provide this information to the relevant individual as soon as reasonably possible.
In all cases, we clearly communicate that Dalytrading is the data controller, and we identify the contact details of our Data Protection Officer or responsible point of contact for any questions or concerns.
By proactively notifying data subjects, Dalytrading ensures compliance with legal requirements while fostering trust, transparency, and confidence in the way we manage personal data.
In all cases, we clearly communicate that Dalytrading is the data controller, and we identify the contact details of our Data Protection Officer or responsible point of contact for any questions or concerns.
By proactively notifying data subjects, Dalytrading ensures compliance with legal requirements while fostering trust, transparency, and confidence in the way we manage personal data.
Proportional and Purpose-Driven Data Collection
At Dalytrading, we ensure that personal data is collected only to the extent necessary to achieve the specific purposes communicated to the individual. We are committed to gathering information that is relevant, sufficient, and proportionate, avoiding any collection of data beyond what is required for legitimate business or regulatory purposes.
This approach helps Dalytrading maintain compliance, operational efficiency, and trust with employees, clients, and partners.
This approach helps Dalytrading maintain compliance, operational efficiency, and trust with employees, clients, and partners.
Data Accuracy
At Dalytrading, we are committed to maintaining high standards of accuracy for all personal data we process. We verify the correctness of information at the point of collection and conduct regular reviews to ensure it remains up to date.
Where we identify inaccuracies or outdated information, we take prompt and appropriate action to correct, update, or securely dispose of the data. This approach ensures that our operations remain reliable, compliant, and that we maintain the trust of our employees, clients, and partners.
Where we identify inaccuracies or outdated information, we take prompt and appropriate action to correct, update, or securely dispose of the data. This approach ensures that our operations remain reliable, compliant, and that we maintain the trust of our employees, clients, and partners.
Data Retention
At Dalytrading, personal data is retained only for as long as necessary to fulfil the purposes for which it was collected, or to meet legal, regulatory, or contractual obligations.
Once data is no longer required, we take all reasonable steps to securely delete, anonymise, or dispose of it from our systems. This ensures that personal information is handled responsibly, mitigates risk, and maintains the confidence of our employees, clients, and partners.
Once data is no longer required, we take all reasonable steps to securely delete, anonymise, or dispose of it from our systems. This ensures that personal information is handled responsibly, mitigates risk, and maintains the confidence of our employees, clients, and partners.
Respecting Data Subject Rights
At Dalytrading, we are committed to processing personal data in a way that fully respects the rights of the individuals it concerns. Data subjects are entitled to exercise the following rights:
Access – the right to request details of the personal data we hold about them.
Correction – the right to have inaccurate or incomplete information amended promptly.
Objection to Direct Marketing – the right to prevent their personal data from being used for marketing purposes.
Restriction of Processing – the right to request that processing which could cause harm, distress, or detriment to themselves or others is limited.
By upholding these rights, Dalytrading ensures transparency, accountability, and trust in the way we manage personal data across all our business operations.
Data Security
At Dalytrading, we are committed to protecting personal data against unauthorised access, unlawful processing, accidental loss, or damage. We implement robust procedures and technologies to safeguard data from the moment it is collected until it is securely disposed of.
Personal data may only be shared with external processors who adhere to our security standards or have equivalent measures in place to protect the information.
We maintain security by safeguarding the confidentiality, integrity, and availability of all personal data:
Personal data may only be shared with external processors who adhere to our security standards or have equivalent measures in place to protect the information.
We maintain security by safeguarding the confidentiality, integrity, and availability of all personal data:
Confidentiality – only authorised personnel may access personal data.
Integrity – data must remain accurate, complete, and suitable for its intended purpose.
Availability – authorised users must be able to access the data when needed for legitimate business purposes.
To support these objectives, we follow practical security measures, including:
Access Controls – monitoring and restricting entry to areas where personal data is stored.
Secure Storage – confidential information, whether physical or digital, is securely locked when not in use.
Data Disposal – paper records are shredded, and digital storage devices are destroyed when no longer required.
Equipment and Workstation Security – screens should not display personal data to unauthorised individuals, and PCs must be locked or logged off when unattended.
By adhering to these practices, Dalytrading ensures that personal data is handled safely and responsibly, protecting the trust of our employees, clients, and partners.
International Data Transfers
At Dalytrading, personal data may occasionally be transferred to countries outside the European Economic Area (EEA). Such transfers are conducted only under strict safeguards to ensure that the rights and freedoms of data subjects are fully protected.
The destination country provides an adequate level of data protection in line with international standards.
The data subject has given explicit consent for the transfer.
The transfer is necessary for the performance of a contract with the data subject, or to protect the individual’s vital interests.
The transfer is required for important public interest purposes, or for the establishment, exercise, or defence of legal claims.
Appropriate safeguards have been put in place, and the transfer is authorised by relevant data protection authorities.
In some cases, personal data may also be processed by staff located outside the EEA who work for Dalytrading or for authorised suppliers. Such staff may be involved in contract fulfilment, payment processing, customer support, or other legitimate business activities, all under strict data protection protocols.
By applying these measures, Dalytrading ensures that personal data remains secure and compliant, even when transferred internationally, protecting the trust of our employees, clients, and partners.
By applying these measures, Dalytrading ensures that personal data remains secure and compliant, even when transferred internationally, protecting the trust of our employees, clients, and partners.
Disclosure and Sharing of Personal Data
At Dalytrading, we treat personal data with the highest level of care. However, there are circumstances where information may be shared responsibly and lawfully:
Within our Group – personal data may be shared with our subsidiaries, parent company, or other group entities to support legitimate business operations.
Business Transactions – if Dalytrading is involved in a merger, acquisition, sale, or restructuring, personal data may form part of the assets transferred to relevant parties.
Legal and Regulatory Requirements – we may disclose information where required to comply with the law, to enforce contracts, or to protect the rights, property, and safety of Dalytrading, our employees, clients, or partners.
Fraud Prevention and Risk Management – information may be exchanged with trusted organisations to support fraud prevention and credit risk reduction.
Authorised Third Parties – on occasion, we may share personal data with carefully selected external partners where it is necessary to deliver services or for other purposes clearly set out in this policy.
In every instance, Dalytrading ensures that data sharing is conducted securely, proportionately, and in line with applicable data protection laws, maintaining the trust of all individuals whose data we manage.
Handling Data Subject Access Requests
At Dalytrading, we respect the rights of individuals to access the personal data we hold about them. To ensure requests are handled correctly and securely:
Formal Requests – data subjects must submit access requests in writing. Any employee receiving such a request must forward it without delay to our designated Data Protection Representative.
Telephone Enquiries – personal data will only be disclosed over the phone if the caller’s identity can be verified beyond doubt. Where identity cannot be confirmed, callers will be asked to submit their request in writing.
Support and Escalation – in complex or uncertain situations, employees must seek guidance from the Data Protection Representative rather than disclosing information themselves.
Safeguarding Information – staff must never feel pressured to release personal information and are expected to prioritise confidentiality and compliance at all times.
By following these procedures, Dalytrading ensures that access requests are managed lawfully, securely, and with respect for the rights of individuals.
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