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Data Privacy Policy

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This Data Privacy Policy explains what we do with your personal data, whether we are in the process of detailing with an enquiry, processing an order, continuing our ongoing customer relationship with you, requesting your feedback, or for when you visit our website.

This document describes how we collect, use and process your personal data and how we comply with our legal obligations to you, in line with the data protection law GDPR.

This Privacy Policy applies to the personal data of our customers and potential customers and suppliers.

Personal data collected

Customer Data

In order to provide the best possible products suitable for your particular operation, and service to meet your individual customer needs, we need to process certain information. Activate Lubricants Ltd only ask for details that will genuinely help us to deliver our products and services. Data collection includes name, job title and contact details. This includes, but is not limited to: telephone number, email address, first and last name, site/company address. Where Activate Lubricants are required by you to process payments for foodgrade lubricants and/or equipment by way of debit or credit cards we will also process these details, but only for this purpose.

Supplier Data

We collect a minimum amount of data from our suppliers to ensure we can easily process transactions. Activate Lubricants will collect contact details for the main contact and any associate contacts within the business that assist us in processing any number of transactions. We also need other information such as your bank details so that we can pay for the services you provide (if this is part of the business arrangements between us).

How do we collect your personal data?

Customer Data

We collect customer data directly from you.

Supplier Data

We collect supplier data directly from you.

How do we use your personal data?

The main reason for using your personal details is to help Activate Lubricants Ltd process ongoing requests you have made of us e.g. raising a quote, processing an order, arranging a delivery of a particular order.

Website Users

If you send us a query or request via our website, your information will be used to answer your query, satisfy your request and/or communicate with you about Activate products and services. We retain to this data until such time as you request to ‘opt out’ of communications, either by using the various ‘unsubscribe’ options we provide within communication media or by pro-active request via the contact details given further down this document. We do not share your information with third parties.

We may collect technical data about the type of Internet Browser and computer operating system that you use. This information does not identify you as an individual and is uses only for tracking of site use. This is a technology called ‘cookies’ which can be used to provide you with tailored information from a website. A cookie is an element of data, a file which is nothing but a line of text that a website can send to your browser, which may then store it on your system. This will help us to identify you when you return to the site and allow us to tailor content to your personal preferences. For more information about cookies, please see our separate Cookie Policy.

You can set your browser to notify you when you receive a cookie, giving you the chance to decide whether to accept it. However, in a few cases some of our website features may not function as a result.

How do we safeguard your personal data?

We care about the protection of your information. That’s why we put in place appropriate measures that are designed to prevent unauthorised access to, and misuse of, your personal data.

Those processes include, but are not limited to: encrypted server access, laptop devices are password protected, all anti-virus and gateway security settings are up to date and monitored.

How long do we keep your personal data for?

Data stored and processed in our system. If we have not had meaningful contact with you for a period of seven years, we will remove your personal data from our systems, unless there is a processing requirement that requires us to retain it.

How can you access, amend or take back the personal data you have given to us?

If we are holding or using your personal information, you may change your mind at any time by writing to The Data Protection Officer, Activate Lubricants Ltd, Furthermore Hall, Little Bardfield, Braintree. CM7 4TX or emailing We will process the removal of your personal information within 10 working days. Please note we may keep a record of your communications to help us resolve any issues which you raise.

Right to object

If we are using your data because we deem it necessary and there are legitimate interests to do so, and you do not agree, you have the right to object. We will respond to your request within 30 days (although we may be allowed to extend this period in certain cases). Generally, we will only disagree with you if certain limited conditions apply.

Right to erase

In certain situations, you have the right to request us to ‘erase’ your personal data. We will respond to your request within a maximum of 30 days and will only disagree with you if certain limited conditions apply. If we do agree with your request, we will remove your data. We will assume that you would prefer us to keep a note of your name on our system as a person who would prefer not to be contacted by Activate Lubricants Ltd as this will ensure that we minimise the risk of your data being resubmitted and used in the future. If you would prefer that this is not the case please let us know.

Our legal basis for processing your data

Legitimate interests

Article 6(1)(f) of the GDPR states what we can process your data where it “is necessary for the purposes of the legitimate interests persued by (us) or a third party, except where such interests are overridden by the interests or fundamental rights or freedoms of (you) which require protection of personal data”.

Customer data

We think it reasonable that if you have communicated with Activate Lubricants Ltd in the past or we have had meaningful contact with you within the past 5 years that this is a legitimate interest that you will continue to benefit from our continued communication.

We want to provide potential customers with the opportunity to hear about our products and services and request additional information. We therefore deem it that if you operate in a sector that regularly benefits from our products and technical expertise regarding foodgrade lubrication, compliance and relevant equipment, and your information has been made available in the public domain, that we can contact you to advise you of our products and services. We will have an upfront and honest approach to this and will always provide you with the opportunity to opt out of any further communications from us, whether by post, email or telephone or via our website.

Supplier data

We store and process personal data of individuals within your organisation in order to facilitate the receipt of services from you as one of our suppliers. We also hold your financial details, so that we can pay you for your services. We deem all such activities to be necessary within legitimate interests.


Article6(1)(b) gives us lawful basis for processing personal data where, “processing is necessary for the performance of a contract to which the data subject is part or in order to take steps at the request of the data subject prior to entering a contract”.

In this context, a contract does not have to be a formal signed document, or even written down, as long as there is an agreement which meets the requirements of contract law. Broadly speaking, this means that the terms have been offered and accepted, you both intend them to be legally binding, and there is an element of exchange (usually an exchange of goods or services for money, but this can be anything of value).

Contract Customer Data

Where we and you have entered a contract agreement to delivery products and services we will process the appropriate and required information in order to do so. For example, email address and address of the company.

Third Party Processors

Our carefully selected partners and service providers may process personal information about you on our behalf as described below:

“Digital Marketing Service Providers

We periodically appoint digital marketing agents to conduct marketing activity on our behalf, such activity may result in the compliant processing of personal information. Our appointed data processors include:

(i)Prospect Global Ltd (trading as Sopro) Reg. UK Co. 09648733. You can contact Sopro and view their privacy policy here: Sopro are registered with the ICO Reg: ZA346877 their Data Protection Officer can be emailed at:”

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