For the purposes of data protection legislation in force from time to time, the data controller is Rowe Hankins Ltd., Power House, Mason Street, Bury, Lancashire, BL9 0RH, UK.
Our nominated Data Controller is Jennifer Tottey.
Who We Are And What We Do
Rowe Hankins Ltd. specialises in innovative trainborne and wayside products for the world’s railways. Rowe Hankins Ltd. work closely with rolling stock manufacturers, fleet operators, track owners and infrastructure contractors for Light and Heavy Rail Vehicle projects.
Information You Give To Us Or We Collect About You
This is the information you give us by filling in forms on our site – www.rowehankins.com – or by corresponding with us by phone, e-mail or otherwise. It includes information you provide when you register to use our site, subscribe to our services, other social media functions on our site, or when you report a problem with our site.
The information you give us or we collect about you may include your name, address, private or business email address.
What Information Do We Collect?
a) Anonymous browsing
You can visit this site without telling us who you are or revealing any information about yourself, including your email address. In this case, our Web server may collect the name, address, the IP address and domain you used to access this site, the type and version of browser and operating system you are using, and the web site you came from and visit next. This information is used by us to measure the number of visits, average time spent, page views, and other statistics about visitors to this Site in general. We may also use this data to monitor site performance for systems administration purposes, to make this Site easier and more convenient to use and to report information in aggregate form to our advisers (e.g. how many visitors log in to this site).
Cookies are small pieces of data stored by your Internet browser on your computer’s hard drive, which permits us to recognize you when you access this site. If you are browsing, a cookie is used to help us measure the number of visits, average time spent, page views, and other statistics relating to your use of this site. If you are searching, a cookie is used to carry the search request data from the request page to the results page. This cookie, by itself, doesn’t tell us your email address or who you are.
Our Legitimate Business Interests
Our legitimate interests in collecting and retaining your personal data is described below:
a) Marketing purposes: New and future final products / offers
b) Offers / Special and Seasonal Offers Consent
c) Selling purposes
Should we want or need to rely on consent to lawfully process your data we will request your consent orally, by email or by an online process for the specific activity we require consent for and record your response on our system. Where consent is the lawful basis for our processing you have the right to withdraw your consent to this processing at any time.
How Is Your Personal Information Secured And Protected?
We are committed to taking all reasonable and appropriate steps to protect the personal information that we hold from misuse, loss, or unauthorised access. We do this by having in place a range of appropriate technical and organisational measures. These include measures to deal with any suspected data breach.
This site may contain links to other sites, including those of our business partners. While we try to link only to sites that share our high standards and respect for privacy, please understand that we are not responsible for the content of, or the privacy practices employed by, other sites.
Social Media Platforms
Communication, engagement and actions taken through external social media platforms that this website and its owners participate on are custom to the terms and conditions as well as the privacy policies held with each social media platform respectively.
Users are advised to use social media platforms wisely and communicate / engage upon them with due care and caution in regard to their own privacy and personal details. This website nor its owners will ever ask for personal or sensitive information through social media platforms and encourage users wishing to discuss sensitive details to contact them through primary communication channels such as by telephone or email.
This website may use social sharing buttons which help share web content directly from web pages to the social media platform in question. Users are advised before using such social sharing buttons that they do so at their own discretion and note that the social media platform may track and save your request to share a web page respectively through your social media platform account.
Shortened Links in Social Media
This website and its owners through their social media platform accounts may share web links to relevant web pages. By default, some social media platforms shorten lengthy URLs [web addresses].
Users are advised to take caution and good judgement before clicking any shortened URLs published on social media platforms by this website and its owners. Despite the best efforts to ensure only genuine URLs are published many social media platforms are prone to spam and hacking and therefore this website and its owners cannot be held liable for any damages or implications caused by visiting any shortened links.
Right To Object
This right enables you to object to us processing your personal data where we do so for one of the following four reasons:
our legitimate business interests;
to enable us to perform a task in the public interest or exercise official authority;
to send you direct marketing materials;
for scientific, historical, research, or statistical purposes.
If your objection relates to us processing your personal data because we deem it necessary for your legitimate interests, we must act on your objection by ceasing the activity in question unless:
We can show that we have compelling legitimate grounds for the processing which overrides your interests.
If your objection relates to direct marketing, we must act on your objection by ceasing this activity.
Right To Withdraw Consent
Where we have obtained your consent to process your personal data for certain activities (for example, marketing arrangements or profiling), you may withdraw consent at any time and we will cease to carry out the particular activity that you previously consented to unless we consider that there is an alternative reason to justify our continued processing of your data for this purpose in which case we will inform you of this condition.
Subject Access Request
You may ask us to confirm what information we hold about you at any time, and request us to modify, update or delete such information. We may ask you to verify your identity and for more information about your request. If we provide you with access to the information, we hold about you, we will not charge you for this unless your request is “manifestly unfounded or excessive”. If you request further copies of this information from us, we may charge you a reasonable administrative cost where legally permissible. Where we are legally permitted to do so, we may refuse your request. If we refuse your request, we will always tell you the reasons for doing so.
Right To Erasure
You have the right to request that we erase your personal data in certain circumstances.
Normally, the information must meet one of the following criteria:
the data is no longer necessary for the purpose for which we originally collected and/or processed them;
where previously given, you have withdrawn your consent to us processing your data, and there is no other valid reason for us to continue processing;
the data has been processed unlawfully (i.e. in a manner which does not comply with the GDPR);
it is necessary for the data to be erased in order for us to comply with our legal obligations as a data controller; or
if we process the data because we believe it necessary to do so for our legitimate interests, you object to the processing and we are unable to demonstrate overriding legitimate grounds for our continued processing.
We would only be entitled to refuse to comply with your request for one of the following reasons:
to exercise the right of freedom of expression and information;
to comply with legal obligations or for the performance of a public interest task or exercise of official authority;
for public health reasons in the public interest;
for archival, research or statistical purposes; or
to exercise or defend a legal claim.
When complying with a valid request for the erasure of data we will take all reasonably practicable steps to delete the relevant data.
Right To Restrict Processing
You have the right to request that we restrict our processing of your personal data in certain circumstances. This means that we can only continue to store your data and will not be able to carry out any further processing activities with it until either:
one of the circumstances listed below is resolved;
you consent; or
further processing is necessary for either the establishment, exercise or defence of legal claims, the protection of the rights of another individual, or reasons of important EU or Member State public interest.
The circumstances in which you are entitled to request that we restrict the processing of your personal data are:
where you dispute the accuracy of the personal data that we are processing about you. In this case, our processing of your personal data will be restricted for the period during which the accuracy of the data is verified;
where you object to our processing of your personal data for our legitimate interests. Here, you can request that the data be restricted while we verify our grounds for processing your personal data;
where our processing of your data is unlawful, but you would prefer us to restrict our processing of it rather than erasing it; and
where we have no further need to process your personal data, but you require the data to establish, exercise, or defend legal claims.
If we have shared your personal data with third parties, we will notify them about the restricted processing unless this is impossible or involves disproportionate effort. We will, of course, notify you before lifting any restriction on processing your personal data.
Right To Rectification
You have the right to request that we rectify any inaccurate or incomplete personal data that we hold about you. If we have shared this personal data with third parties, we will notify them about the rectification unless this is impossible or involves disproportionate effort. Where appropriate, we will also tell you which third parties we have disclosed inaccurate or incomplete personal data to. Where we think that it is reasonable for us not to comply with your request, we will explain our reasons for this decision.
Right To Lodge A Complaint With A Supervisory Authority
You also have the right to lodge a complaint with your local supervisory authority. If you would like to exercise any of these rights or withdraw your consent to the processing of your personal data (where consent is our legal basis for processing your personal data), you can contact us here.
We may keep a record of your communications to help us resolve any issues which you raise.
Article 4(11) of the GDPR states that (opt-in) consent is “any freely given, specific, informed and unambiguous indication of the data subject’s wishes by which he or she, by a statement or by a clear affirmative action, signifies agreement to the processing of personal data relating to him or her.” In plain language, this means that:
you must give us your consent freely, without us putting you under any type of pressure;
you must know what you are consenting to – so we’ll make sure we give you enough information;
you should have control over which processing activities you consent to and which you don’t. We provide these finer controls within our privacy preference centre; and
you need to take positive and affirmative action in giving us your consent – we’re likely to provide a tick box for you to check so that this requirement is met in a clear and unambiguous fashion.
We will keep records of the consents that you have given in this way.
Resources & Further Information
Data Protection Act 2018
Privacy and Electronic Communications Regulations 2003
Privacy and Electronic Communications Regulations 2003 – The Guide