1. Introduction

GAP GROUP NORTH EAST LIMITED(“GAP Group”, “we”, “us”, or “our”) is committed to protecting your personaldata and respecting your privacy. This Privacy Policy explains how we collect,use, store, and share your personal information when you visit or interact withour website at gapgroupuk.com, request a quote, sign up to our communications,or otherwise engage with us.

GAP Group operates as a group ofcompanies. This policy applies to the following entities within the group:

• GAP GROUP NORTH EAST LIMITED (the main data controllerfor this website)

• P A MOODY RECYCLING LIMITED

• GAP ALBA LTD

• GAP ICE LTD

• GAP HAULAGE LIMITED

This policy is written incompliance with the UK General Data Protection Regulation (UK GDPR) and theData Protection Act 2018.

2. Who We Are (Data Controller)

The data controller responsiblefor your personal information is:

GAP GROUP NORTH EAST LIMITED

Gap House, Nest Road, Gateshead,Tyne & Wear, NE10 0ES

Companies House Number: 09903046

Email: media@gapgroupuk.com

Phone: 0191 438 6438

If you have any questions aboutthis policy or how we handle your data, please contact us atmedia@gapgroupuk.com.

3. What Personal Data We Collect

We may collect and process thefollowing categories of personal data about you:

3.1 Data you provide to us directly

• Name, job title, and company name

• Email address and telephone number

• Postal address or site address (for collection quotesand logistics)

• Information submitted through contact forms, quoterequest forms, or audit request forms

• Account login credentials if you register for ouronline portal

• Communications you send us via email, live chat, orenquiry forms

3.2 Data collected automatically

• IP address and browser type

• Pages visited, time spent on site, and referring URLs

• Cookie identifiers and tracking data (see Section 9 forour Cookie Policy)

3.3 Data from third parties

• Information from analytics providers such as GoogleAnalytics

• Information from marketing and CRM platforms we use tomanage communications

4. How We Use Your Personal Data

We use your personal data forthe following purposes, relying on the legal bases indicated:

Responding to enquiries andproviding quotes

Legal basis: Legitimateinterests / Pre-contractual necessity. We use your contact details to respondto quote requests, service enquiries, or audit requests you submit through ourwebsite.

Delivering our services

Legal basis: Performance of acontract. When you become a customer, we use your data to arrange collections,manage logistics, issue compliance documentation, and provide licensedtreatment services.

Sending marketingcommunications

Legal basis: Consent (fornewsletter sign-ups) / Legitimate interests (for existing customers). We maysend you updates, industry news, service information, and promotional content.You can opt out at any time by clicking ‘unsubscribe’ in any email or bycontacting us at media@gapgroupuk.com.

Running and improving ourwebsite

Legal basis: Legitimateinterests. We use analytics data to understand how visitors use our website andto improve functionality, content, and user experience.

Managing customer accountsand portals

Legal basis: Performance of acontract / Legitimate interests. We use login and account data to provideaccess to our online customer portal and to manage service records.

Complying with legalobligations

Legal basis: Legal obligation.We may need to retain or share certain data to comply with WEEE regulations,Environment Agency requirements, HMRC obligations, or other applicable law.

5. Who We Share Your Data With

We do not sell your personaldata. We may share your information with trusted third parties in the followingcircumstances:

• CRM and email marketing platforms - to manage ourcontact database and send communications (e.g. HubSpot, Mailchimp, orequivalent). These providers act as data processors on our behalf.

• Payment processors - to securely handle any financialtransactions. Payment data is processed directly by our payment provider and wedo not store full card details.

• Logistics and haulage partners - where deliveries orcollections involve partner operators, limited data (such as site address andcontact name) may be shared to fulfil the service.

• Analytics providers - such as Google Analytics, whichprocesses anonymised website usage data on our behalf.

• IT and software service providers - who support oursystems under strict data processing agreements.

• Regulatory bodies and legal authorities - where we arerequired by law to disclose information (e.g. the Environment Agency, HMRC, orlaw enforcement).

All third parties we work withare required to handle your data in accordance with UK GDPR and are bound byappropriate data processing agreements.

6. International Data Transfers

Some of our third-party serviceproviders (such as analytics and CRM platforms) may process data outside the UKor European Economic Area (EEA). Where this occurs, we ensure appropriatesafeguards are in place, such as the UK International Data Transfer Agreement(IDTA) or equivalent standard contractual clauses, to protect your data to thesame standard required under UK GDPR.

7. How Long We Keep Your Data

We retain personal data only foras long as necessary for the purposes it was collected, or as required by law.Our standard retention periods are:

• Customer and contract records: 6 years from the end ofthe contract (in line with the Limitation Act 1980)

• Enquiry and quote form data: 6 years from the date ofsubmission, unless a contract is entered into

• Marketing contact data: Until you unsubscribe orwithdraw consent, after which we retain a suppression record to honour yourpreference

• Portal account data: For the duration of your accountand up to 6 years after closure

• Website analytics data: In accordance with theretention settings of the relevant analytics provider (typically 26 months forGoogle Analytics)

Where data is no longerrequired, we securely delete or anonymise it.

8. Your Rights Under UK GDPR

You have the following rights inrelation to your personal data:

• Right of access - to request a copy of the personaldata we hold about you

• Right to rectification - to ask us to correctinaccurate or incomplete data

• Right to erasure - to request deletion of your data incertain circumstances

• Right to restrict processing - to ask us to limit howwe use your data

• Right to data portability - to receive your data in astructured, machine-readable format

• Right to object - to object to processing based onlegitimate interests or for direct marketing

• Rights related to automated decision-making - we do notmake solely automated decisions that significantly affect you

To exercise any of these rights,please contact us at media@gapgroupuk.com. We will respond within one calendarmonth. We may need to verify your identity before processing your request.

If you are not satisfied withhow we handle your request or your data, you have the right to lodge acomplaint with the UK’s supervisory authority:

Information Commissioner’sOffice (ICO)

Website: www.ico.org.uk |Helpline: 0303 123 1113

9. Cookies

Our website uses cookies andsimilar technologies to improve your experience and to analyse how the site isused. Cookies are small text files stored on your device when you visit awebsite.

We use the following types ofcookies:

• Essential cookies - necessary for the website tofunction correctly (e.g. session management, security)

• Analytics cookies - to understand how visitors interactwith our website (e.g. Google Analytics). These cookies collect anonymiseddata.

• Marketing cookies - used to track visitors and deliverrelevant content or advertising

You can control and managecookies through your browser settings or via our cookie consent tool when youfirst visit our site. Please note that disabling certain cookies may affect thefunctionality of our website.

For more information, pleaserefer to our separate Cookie Policy, which is available on our website.

10. Data Security

We take the security of yourpersonal data seriously. We implement appropriate technical and organisationalmeasures to protect your data against unauthorised access, accidental loss,alteration, or disclosure. These measures include secure servers, accesscontrols, and encrypted communications where appropriate.

Whilst we take all reasonablesteps to protect your data, no method of transmission over the internet is 100%secure. If you believe your data has been compromised, please contact usimmediately at media@gapgroupuk.com.

11. Children’s Privacy

Our website and services aredirected at businesses and professionals and are not intended for use byindividuals under the age of 18. We do not knowingly collect personal data fromchildren. If you believe we have inadvertently collected such data, pleasecontact us and we will delete it promptly.

12. Links to Third-Party Websites

Our website may contain links toexternal websites operated by third parties, including our partnerorganisations. This Privacy Policy does not apply to those websites, and we arenot responsible for their privacy practices. We encourage you to read the privacypolicies of any third-party sites you visit.

13. Changes to This Privacy Policy

We may update this PrivacyPolicy from time to time to reflect changes in our practices, services, orapplicable law. The “Last updated” date at the top of this page will be revisedaccordingly. We encourage you to review this policy periodically. Where changesare significant, we will notify you by email or by a prominent notice on ourwebsite.

14. Contact Us

If you have any questions,concerns, or requests regarding this Privacy Policy or the way we handle yourpersonal data, please contact us: