(WasteAction Resource Efficiency Ltd and Warp It updated for GDPR compliance 25th May 2018)
- reviewed 20th May 2019
WasteAction Resource Efficiency Ltd must gather, store and use “personal data” as defined by
the European Union Regulation (EU) 2016/679 in order to market our products and services to
you. The collection and processing of personal data is subject to restrictions aimed at protecting
the privacy of individuals.
Where the policy discusses the processing of data for the necessary performance of the
contract - i.e - registered customers to the Warp It portal, it will include data processor from both
WasteAction Resource Efficiency Ltd and our software developers at Eightlegged.com who we
have worked with since 2011 and who are also GDPR compliant.
We are registered with the Information Commissioner Office and we adhere to good practice in
our data protection policy, including adherence to the General Data Protection Regulations and
the PECR guidelines for records retention. A copy of our data protection certificate can be
obtained from our website.
This privacy statement will describe the reasons why personal data is needed, how it will be
used, who will be able to access the information and when it will be deleted from our records. It
also explains your rights to access your data under data protection laws or seek to have it
rectified or deleted. We will at all times comply with the provisions of the European Union
General Data Protection Regulations (“GDPR”)
2. Personal data which we hold about you
We request very little identifying information from you which is not deemed sensitive data and is
only used for specific set of purposes. The personal data we hold on you is:
● Full name
● Work email address
Other data we hold is:
● Company name
● Job role
● Company address, including postcode
● Company telephone and mobile number
● IP address
● Email marketing preferences
The above personal data is held for the following reasons:
● Processing is necessary for the performance of the contract with the data subject and maintenance of the site.
● For registration to certain areas of the Website including added value resources and newsletters.
● To allow us to consider your comments, queries and suggestions and respond if necessary.
● To allow us to respond to your enquiries for further information.
● To distribute requested materials.
● Marketing to potential customers under the terms of legitimate interest.
Sometimes, we may ask questions where you are not personally identifiable from your response
although we may post responses on the Website. These instances will be highlighted to you but
in all other instances, you should assume that we track any information you provide on a personally identifiable basis.
3. Purposes of processing
We will process your personal data for the purposes of:
● Sending you marketing information or;
● performing our obligations and exercising our rights under your registration to the Warp It site (if registered as a customer)
We will only process your personal data where one of the following apply:
● you have provided your consent for us to do so.
● processing is necessary for the performance of a contract [or to make preliminary arrangements for the creation of a contract]
● there is a legal obligation to do so; or
● processing is necessary for the purposes of the legitimate interests pursued by Waste
Action Resource Efficiency Ltd or by a third party (specifically vetted and compliant
telephone marketing staff), except where such interests are overridden by the interests
or fundamental rights and freedoms of the data subject which require protection of personal data.
4. Third parties
To complete transactions with third parties, in this case, other approved Warp It institutions for
the express purpose of reusing surplus assets, we will share personal data. Notably this will
only include collected data of Full Name and works email address.
We do not pass any personal data to Third Parties other than outlined above. However we want
your experience of the Warp It website and its available resources to be as informative and
useful as possible, we provide a number of links to Third Party Websites. Always be aware of
where you end up. Third Party Websites may send their own cookies to users, or otherwise
collect data or solicit personal information. We assume no responsibility for the information
gathering practices of websites that you are able to access through ours, and we encourage you
5. Transfers of your personal data outside the EEA
No customer data is transferred outside of EEA
WasteAction Resource Efficiency Ltd is an international business and, from time to time, we
may transfer your personal data outside the EEA as follows:
● If you have signed up to our newsletter; Your personal data will be stored on a CRM
cloud system, currently Hubspot, which is headquartered in USA
● If you are not a customer and we communicate with you for legitimate purposes.
● If you have registered for an Warp It event, Your personal data may be stored in an
Event Technology platform, currently Eventbrite, which is headquartered in USA,
6. Retention of your personal data
We will retain your personal data only so long as we reasonably require in light of the purposes
for which we are holding it and all relevant legal, commercial and operational considerations.
Where we hold your data for the performance of a contract, your data will be held until the
completion of the contact plus 18 months. To cover and questions regarding transactions and
for continuity for re subscriptions
If you choose to unsubscribe from receiving marketing emails from us your email address will be
held on our email suppression list in order to prevent us from contacting you again via email.
This is held under the Legal Obligation basis in order for us to comply with GDPR law.
We frequently review the ICO and PECR guidelines for data retention.
7. Subject Access Rights
You have a right (referred to as the data subject access request, “DSAR”) to access the
personal data that we hold about you. If you would like to exercise that right, you must submit a
request to email@example.com specifying the information that you want us to provide you.
We are obliged to respond to any such request within one month of receiving it (subject to
We will inform you via email following receipt of your request and, if necessary, seek additional
information from you about your request.
8. Accuracy of Information and Corrections
You have a right (referred to as the right to rectification) to have your personal data rectified if it
is inaccurate or incomplete. If you become aware that any of the data that we hold about you is
inaccurate, you can
● update your personal information on our website if you hold an account
● update your preferences at the bottom of any notification, email or newsletter you
receive if you are subscribed to our mailing list or if we are contacting by terms of
● submit a request to firstname.lastname@example.org
Please do this as soon as practical. We are obliged to comply with requests within one month.
This may be extended to 3 months where a rectification request is complex.
9. Storage of Data
Personal data will be stored in password protected software as a service CRM at present
Hubspot, event technology platform and email marketing platform, password protected
documents within electronic folders, which are only accessible to members of the marketing
We do not hold any sensitive personal data.
Data protection policy accessible at www.warp-it.co.uk/policy
You have a right (referred to as the right to erasure) to request the deletion or removal of your
personal data where there is no compelling reason for its continued process. In these instances
your data will be removed within one month apart from where we hold your email address on
our mailing list, where your email address will then be held on email suppression list, which we
must hold for legal reasons. You will be notified if any of your data must continue to be held for
any legal reasons.
If you would like to exercise this right, you can:
● unsubscribe at the end of any marketing email you receive, if you want to unsubscribe.
An unsubscribe link is included in every notification, email or newsletter email by law.
● submit a request to the email@example.com. We will then consider this request
in accordance with obligations under data protection laws.
11. Transferring your personal data
You have a right (referred to as the right to data portability) to obtain and reuse your personal
data for your own purposes across different services. This right allow you to move, copy or
transfer personal data easily from one IT environment to another in a safe and secure way.
If you would like to exercise this right, you must submit a request to
firstname.lastname@example.org, specifying the information that you wish to be transferred.
We are obliged to comply with any such request within one month. This may be extended to 3
months where the rectification request is complex or multiple requests from the same data
subject are received at the same time. We will notify you if an extension is necessary.
12. Restricting use of your personal data
You have a right (referred to the right to restrict processing) to block or suppress the processing
of personal data in certain circumstances.
If you contest the accuracy of the personal data, processing may be restricted until the accuracy
of the personal data has verified. This also applies where you contest that the processing is
If you would like to exercise this right, you must submit a written request to
email@example.com, specifying the information that you wish us to impose a
processing restriction on.
13. Data Protection officer and Complaints Process
We have appointed a Data Protection Officer who has overall day-to-day responsibility for the
processing of personal data.
If you have any questions at all about this privacy notice or would like more information about
any of the issues covered in it, please contact firstname.lastname@example.org.
If you have a concern or complaint about the way we have handled your personal data you have
the right to complain to the information commissioner via the helpline 0303 123 1113 or by
visiting the following website - https://ico.org.uk/concerns/