1. INTRODUCTION AND SCOPE
Community Network Services Ltd is a company registered in England No: 2084279 and we have our registered
office located at 16 Palace Street, London SW1E 5JQ (the “Company” or “we” or
“us”). Our main trading address is Western Docks, Southampton, SO15 1DA, VAT registration
We are committed to protecting and respecting personal data that we handle in connection with the services we provide to our users, particularly in compliance with data protection law.
The Company is a wholly owned subsidiary of DP World Southampton.
Please ensure you read the CNS System terms and conditions for further detail as to the terms that apply in relation to your access and use of the Services.
You have legal rights to access and to know how we use the personal data that we hold about you.
You can read, print, and save this whole policy. We use sub-headings to help you find specific information that you may be looking for more easily.
2. DATA CONTROLLER
The CNS System is operated under the legal jurisdiction of England. For the purpose of the General Data Protection Regulation (Regulation EU 2016/679 of the European Parliament and of the Council) (the “GDPR”), the Company is the data controller.
3. FURTHER INFORMATION
4. INFORMATION WE COLLECT FROM OR ABOUT YOU
The type of personal data we may process about you as a result of your use of the CNS System will depend on the type of user you are as well as the Services and access required. The personal data we may process therefore include:
- user name
- user type
- business address
- job title
- email address
- phone number (including any phone number you use to call our enquiry services)
- licence plate and trailer number of vehicle that driver is operating
- planned and actual movement of driver through border locations
- identification number
- IP address
information on your use of the CNS System, including:
- your browser type and version
- time zone setting
- language preferences
- location set by user
- user permissions (as set by Admin User)
- browser plug-in types and versions
- operating system and platform and information about your visit, including the full Uniform Resource Locators (URL)
- clickstream to, through and from the CNS System (including date and time)
- products or services you viewed or searched for
- page response times
- download errors
- length of visits to certain pages
- page interaction information (such as scrolling, clicks, and mouse-overs)
- methods used to browse away from the page
The personal data that we process about you may be provided directly by you, by someone (such as an Admin User) on your behalf and / or as a result of your use of the Services.
Information provided by you or on your behalf
We will collect personal data about you when you (or someone on your behalf):
- register with us
- sign up for any of our modules of the CNS System
- contact us through the CNS System or make an enquiry with us
- email us
- complete customer feedback or surveys.
We may also collect personal data about you when someone provides us with this information, such as if an Admin User registers you on the CNS System on your behalf. Please make sure that the information that has been provided on your behalf is accurate and up to date. Please see below as to how you can update your information.
If you join our communications program we collect information about each email we have sent to you and your interaction with them, including, without limitation, the number of times opened, deliverability, which sections you clicked on etc. which we use to measure the effectiveness of our email campaigns, to plan marketing campaigns and to segment our database.
If you are an existing customer and / or user of the products and services of the Company and / or
members of the DP World Group, we may use information and personal data already provided to assist in
your registration in the CNS System (so you so don’t have to provide this again). We will also
liaise with other members of the DP World Group from whom you receive services in order to ensure that
we accurately reflect these services as and when such become available on the CNS System. With this in
mind, please make sure you regularly check and to the extent necessary update your account information
to ensure the information we hold on you remains accurate. Please see below as to how you can update
Information provided by third parties
We may receive information about you from other sources (such as credit reference agencies), which we will add to the information we already hold about you in order to help us provide our products and services in accordance with your requirements and to improve and personalise our service to you.
Information about other individuals
If you give us information on behalf of someone else (for example to enable us to provide information on
the operational or regulatory status of a consignment, or as an Admin User registering another user),
you confirm that the other person has agreed that you may act on his/her behalf and is aware his/ her
personal data may be processed as set out in this policy (including in relation to marketing and the
transfer of personal data abroad).
By providing personal data of another individual to us, you agree that a copy of this policy has been provided to him / her prior to such information being shared and that you will immediately notify us of any issues or concerns that such individual has in relation to the processing of their personal data by the CNS System (including the extent to which they no longer wish to receive marketing from us).
5. HOW WE USE PERSONAL DATA
We use the personal data we collect to:
- identify you and manage any accounts you hold with us;
- provide our Services;
- communicate with you, your organisation and relevant third parties in relation to such Services;
- fulfil any request you make (e.g. submitting a query on the CNS System, subscribing to a communications service, fulfilling requests for information, entering into a competition, promotion, survey etc.);
- allow you to participate in any interactive features of our Services, when you choose to do so;
- carry out customer profiling and analyse your purchasing preferences to create a database for analytical and direct marketing purposes including sending marketing and promotional materials (see more information on this below);
- monitor the performance and relevance of the CNS System, to ensure that content from the CNS System is presented in the most effective manner for you and for your computer and help us to evaluate the quality and consistency of our Services,
- keep the CNS System safe and secure;
- create a database of people who have expressed interest in our companies (subsidiaries or affiliates, including those within the DP World Group), products or services or who have told us they do not want to hear from us. This includes creating and maintaining a mailing list of people who receive or conversely have expressed a preference not to receive electronic marketing communications from us;
- notify you of any changes to the CNS Software, CNS System and / or our Services that may affect you.
We may combine information we obtain from other sources with information we collect from the CNS System to improve our business analysis and customer understanding.
We may use your information to contact you with marketing messages on our business and potential products and services we think may be of interest to you.
We only want to provide you with information of interest to you and in your preferred channel of communication. As such, you can ask us to only send you marketing communications by particular methods (for example, you may be happy to receive emails from us but not telephone calls), about specific subjects or you may ask us not to send you any marketing communications at all.
We will only market the products and services of the Company, DP World Group and thirdparty products to you in accordance with your marketing preferences. We will ask you to consider and indicate your marketing preferences when you first register an account on the CNS System, which you may change later on by emailing us on: email@example.com or by indicating your preferences on your account.. We will keep up to date suppression lists to reflect the extent to which you have informed us that you do not want to receive any marketing messages.
In accordance with your preferences, we will share your details with the other members of the DP World Group who may also send you similar marketing messages. If you have consented to such receive marketing from us you can opt out at any time by clicking the unsubscribe link in the communication and / or contacting us (or the relevant party) directly.
Please note that if you have unsubscribed from marketing messages, we may still send you service communications which we are contractually obliged to send, such as port alerts (where applicable) or updated tariff fees, as may be relevant to you. These are not marketing messages, but communication we are required to send them in order to enable us to provide our services to you.
We may do a credit check on you:
- so that we can make credit decisions about you; and
- to prevent and detect fraud and money laundering.
Our search will be recorded on the files of the credit reference agency.
We may also disclose information about how you conduct your account to credit reference agencies and your
information may be linked to records relating to other people living at the same address with whom you
are financially linked.
Other credit businesses may use your information to:
- make credit decisions about you and the people with whom you are financially associated;
- trace debtors; and
- prevent and detect fraud and money laundering.
If you provide false or inaccurate information to us and we suspect fraud, we will record this.
For further information please contact us on firstname.lastname@example.org.
6. LAWFUL BASES FOR PROCESSING
We will only use your personal data in accordance with relevant data protection law.
In the day to day running of our business we may use your personal data in accordance with the following lawful bases:
- in order to provide the Services and as a result of our obligations under a contract with you;
- in accordance with our own legitimate interest purposes (such as the administration and management of our business and the improvement of our product and services). When handling your personal data for these purposes, we will remain mindful of, and ensure such processing shall not be overridden by, your fundamental rights and freedoms in relation to your personal data;
- in order to comply with a legal or regulatory obligation; and
- to the extent required (e.g. in relation to marketing as described above), on the basis of your consent.
If we choose to process your personal data for any additional purpose than those described in this
policy, prior to commencing any such additional processing activities we will provide you with
appropriate information at such time in order to satisfy our legal obligations (and if required to
obtain your consent).
You are not under a legal obligation to provide us with any of your personal data but please note that if you elect not to provide us with your personal data we may be unable to provide our products or services to you.
7. RELATED WEBSITES
The Company as well as other members of the DP World Group operate several other websites which can be
accessed via the CNS System, each of which has separate terms and privacy information informing you how
the services and personal data are handled through that website. These other websites include DP World
London Gateway Customer Portal used to provide vehicle booking, driver registration and accessed via the
“Vehicle Booking System” icon and links.
The CNS System may include links to third party websites, plus-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share personal data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave the CNS System, we encourage you to read the privacy notice of every website you visit.
8. DISCLOSING, SHARING AND TRANSFERRING PERSONAL DATA
The table below indicates categories of organisations to whom we may disclose information about you in the day to day running of our business and which includes suppliers processing personal data on our behalf to help us to provide services to you. We disclose personal data in this manner to procure high-quality, cost-effective services which we believe to be in our legitimate interests.
|Categories of Organisation||Purpose||Location|
|Marketing agencies, database hosting companies, data cleansing companies, and mailing houses.||To provide marketing services and fulfil our CRM and email program.||UK or European Economic Area|
|Email broadcasters (DotDigital)||To fulfil our CRM and email program||United Kingdom|
We may also disclose your personal data to other third parties from time to time:
- if we are under a duty to disclose or share your personal data to comply with any legal obligation;
- to protect the rights, property, or safety of the Company, our customers, or others including exchanging information with other companies and organisations for the purposes of fraud protection and credit risk reduction;
- business partners, suppliers and sub-contractors for the performance of any contract we enter into with them or you (including the customs authorities);
- analytics and search engine providers that assist us in the improvement and optimisation of the CNS System;
- advertisers and advertising networks that require the personal data to select and serve relevant adverts to you and others for the purposes of the third parties commercial interests and/or to enable us to comply with our advertisers’ wishes by displaying their advertisement to that target audience; and
- to interested parties in the event of a share or asset purchase or merger of our business in whole or part, in bankruptcy or reorganization proceeding or in an attempt to recover debt owed.
In order to provide the Services, we may collect, transfer and store your personal data within any member
of the DP World Group including those outside the European Economic Area (“EEA”), including
the United Arab Emirates.
If we share your personal data with any members of the DP World Group outside of the European Economic Area (e.g. in relation to customer support as part of our Services to you), we will ensure that suitable mechanisms are in place to safeguard your rights and your personal data including, without limitation, adequacy decisions made by the European Commission or model contractual clauses between terminals in the EU and those not in the EU.
9. DATA RETENTION
We will hold information about you in our data systems only for as long as we need to hold it in accordance with our retention policy, which generally is as follows:
- we will retain and process information about you for as long as you continue to use or express an interest in our Services, log into the CNS System, use the CNS Software or any of our interactive services, or for as long as we feel that our business, products and services may be of interest to you where you have not indicated otherwise;
- we will hold information about how you interact with our electronic communications for as long as they are relevant to helping us analyse the performance of the CNS System, our Services, digital marketing activities or to better understand our customers and prospects; and
- if your application is rejected, we will keep a limited record of your application and the reason for your rejection. We will without delay remove any financial information provided to us as part of the registration process.
Please note that we may anonymise your personal data or use it for statistical purposes. We exercise the
right to keep anonymised and statistical data indefinitely, but we take care to ensure that such data
can no longer identify or be connected to any individual.
For further information in relation to our retention of your personal data, please contact us on email@example.com.
10. YOUR RIGHTS
Data protection law grants you certain rights (“information rights”) which are set out below. If you would like to exercise this right, you should contact us as outlined above.
Right of access and of data portability.
You have the right of access to information we hold about or concerning you and/or to have it transferred to another data controller in some circumstances.
Right of rectification or erasure.
If you feel that any personal data that we hold about you is inaccurate you have the right to ask us to
correct or rectify it. You also have a right to ask us to erase information about you where the personal
data we hold is no longer needed (e.g. to perform the Services), you withdraw the consent upon which our
processing is based, or you feel that we are unlawfully processing your personal data.
Your right of rectification and erasure extends to anyone with whom we have disclosed your personal data. To the extent the information to be erased is held by a third party as a result of the Services provided to you, we will take all reasonable steps to inform those with whom we have shared your personal data about your request for erasure.
Right to restriction of processing.
You have a right to request that we refrain from processing your personal data where you contest its accuracy, deem the processing is unlawful and oppose its erasure, where we no longer need to hold your personal data, but you need us to in order to establish, exercise or defend any legal claims, or we are in dispute about the legality of our processing your personal data.
Right to object.
You have a right to object to our processing of your personal data where the basis of the processing is our legitimate interests including but not limited to direct marketing.
Right to Withdraw Consent.
You have the right to withdraw your consent for the processing of your personal data where the processing is based on consent. To withdraw consent, please specify what you wish to withdraw consent for, by emailing firstname.lastname@example.org.
Right of Complaint.
If you are unhappy with the way we have used or are handling your personal data you have the right to
lodge a complaint with the Information Commissioner’s Office (ICO), the UK supervisory authority for
data protection issues. We would, however, appreciate the chance to deal with your concerns before you
approach the ICO so we ask that you kindly contact us in the first instance by emailing: email@example.com.
You can find full details of your personal data rights on the Information Commissioner’s Office
12. DATA SECURITY
We take every care to ensure that your personal data is kept secure. We have put in place appropriate
security measures to prevent your personal data from being accidentally lost, used, or accessed in an
unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those
employees, agents, contractors and other third parties who have a business need to know. They will only
process your personal data on our instructions, and they are subject to a duty of confidentiality.
We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.
Please remember that you have specific obligations under the CNS System terms and conditions which if adhered to, further protect your personal data. For example, you are responsible for keeping your passwords secure. If we have given you (or you have chosen) a password which enables you to access certain parts of the CNS System, you are responsible for keeping this password confidential. Please do not to share your passwords with anyone.
Unfortunately, sending information via the internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of personal data sent to the CNS System and / or our Services; you send us personal data at your own risk. Once we have received your personal data, we will use strict procedures and security features to try to prevent unauthorised access.
13. HOW WE KEEP THIS POLICY UP TO DATE
products or services we offer or to our internal procedures or it may be to reflect a change in the law.
The easiest way to check for updates is by looking for the latest version of this policy on the CNS System or you can contact us by emailing firstname.lastname@example.org
End of Policy.
Last Updated: 10 December 2020
Last Refreshed: 16 September 2022