At the Gregory Group ("Gregory", "we", "us", "our") we understand that privacy and the security of your personal data is extremely important, as is ensuring that you understand how we use it.

This privacy policy explains how we use personal data, including that of visitors to our website, our customers and potential customers, and of any other individuals that get in contact with us, our suppliers, agency partners, affiliates, and those individuals whose personal data we otherwise process in the course of our business. This privacy policy also covers data processing related to job applications and our recruitment activities.

This policy gives effect to our commitment to protect your personal data and has been adopted by all of the companies and businesses in our group. We will only use personal data in ways that are described in this policy and only ways that are consistent with our obligations and your rights under applicable data protection laws.

Who we are

The Gregory Group consists of Gregory Distribution (Holdings) Ltd and four operating companies which are Gregory Distribution Ltd, Hayton Coulthard Transport Ltd (50:50 JV), ARR Craib Transport Ltd and Pollock (Scotrans) Ltd. For the purposes of data protection legislation, we are the data controller and may also use data processors to process your information on our behalf.

Personal data we collect

We may collect and process the following data about you:

Customers/Prospective Customers:

You may give us information about yourself by filling in forms or by corresponding with us by telephone, e-mail or otherwise. The information you give us may include your name, address, email address and phone number, financial and payment card information, information regarding your shipment such as the details and nature of the products being delivered, their source and their destination.

Job Applicants:

The applicant may directly, or through the use of a recruitment agency, provide us with personal details such as name and address, contact information (including email address and telephone number), date of birth, proof of right to work, employment history and reference contact information in the form of a CV, application form or speculative application via email or post.

Website Users:

We may obtain information about your usage of this website using Cookies – information relating to our use of Cookies can be found in our Cookies Policy.

Other Sources:

We may also, from time to time, receive personal data about you from other sources, such as from service delivery partners and other suppliers.

We will only ever ask you to provide us with personal data which we need in order to provide you with the relevant services that you have requested from us.

How we use your personal data

When you contact us by submitting an application, request, enquiry or feedback, or provide us with personal data in any other way, you agree to permit us to use of your personal data to respond to you and facilitate the requirements of your request where necessary. The ways in which we use your personal data may include:

To fulfil your orders and provide refunds where necessary.
To allow you to feedback on our services and for us to respond as required.
To begin the employee recruitment processes.
To provide you with information about us or, where applicable, a member of our group or one of our affiliates.
To help to improve and develop our services.
For direct marketing purposes.

We must always have lawful grounds for processing your personal data, most commonly this will be to perform a contract that we have entered with you or are about to enter into. Alternatively, we will process information where there is a legitimate interest to do so (for example when we are responding to your feedback and enquiries, we will legitimately need to use your personal data in order to correspond with you).

From time to time, we send information relating to the business and our products that we think may be of interest to our customers and former employees. If you do not want to receive this information, you can let us know by emailing [email protected].

What if you fail to provide personal data?

Please make sure you provide us with certain information when requested as if you don't, we may not be able to perform the contract we have entered into with you (such as, to provide you with our services). In this case, we may have to cancel a service you have with us, but we will notify you if this is the case at the time.

Change of purpose

We will only use your personal data for the purposes for which we collected it. If we need to use your personal data for a purpose other than that for which it was collected, we will provide you, prior to that further processing, with information about the new purpose, we will explain our legal justification for doing so and we will provide you with any relevant further information. We may also issue a new privacy policy to you.

How we share your personal data

Third party suppliers and service providers involved in our contractual relationship with you:

Like most businesses, we work with third party suppliers and service providers as part of the day to day operations of our business. Some of these trusted suppliers will process your personal data on our behalf and provide services to us such as the provision of transport services, customer relationship management and/or payment platforms/solutions which enable us to provide and streamline the provision of our services to you.

We will always make sure that these trusted suppliers meet agreed standards for the protection of your personal data, and they will only ever be allowed to use your personal data in order to provide us with services and not for their own commercial purposes. We require all third parties to take appropriate technical and organisational security measures to protect your personal information and to treat it subject to a duty of confidentiality and in accordance with applicable data protection law.

Other scenarios in which we might share your personal data:

In certain situations, we may be required or obliged to share your personal data with third parties, such as with governmental or professional bodies, regulators, law enforcement or fraud prevention agencies or with our professional advisors (including tax, legal or other corporate advisors who provide professional services to us).

We may also share personal data within our group.

In all cases, we will only share your personal data where we have a lawful basis to do so and where appropriate measures are put in place to ensure the safety and security of your personal data.

How do we protect your personal data?

We take the security of your personal data very seriously and have put in place physical, technical, operational and administrative strategies, controls and measures to help protect your personal data from unauthorised access, use or disclosure as required by law and in accordance with accepted good industry practice. We will always keep these under review to make sure that the measures we have implemented remain appropriate. You can obtain further information about these measures using the contact details set out at part 15 of this privacy policy below.

In addition, we limit access to your personal data to those employees and other third parties who have a business need to know in order to perform their job duties and responsibilities. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.

Where your personal data may be processed

Given the international location of some of our suppliers and providers, your personal data may be transferred in and out of the UK and the European Economic Area ("EEA") where local laws may not provide legal protection for personal data in the same way as is applicable in the UK or the EEA. Where your personal data is processed outside of the UK and EEA, we will ensure that we take the necessary steps to protect your personal data as required by data protection laws.

How long do we keep your personal data?

We will retain your personal data for as long as we need it in connection with our relationship with you. This retention period may depend on whether you are visiting our website or utilising our services and on whether we need to retain your personal data in order to comply with applicable laws.

Personal data which is no longer to be retained will be securely and effectively destroyed or permanently erased from our IT systems and we will also require third parties to destroy or erase such personal data where applicable.

In some circumstances we may anonymise your personal data so that it can no longer be associated with you. In this case, we may retain such information for a longer period without further notice to you.

Your rights in relation to your personal data

It is important that the personal data we hold about you is accurate and up to date. Please keep us informed if your personal data changes so that our records can be updated. We cannot be held responsible for any errors in your personal data in this regard unless you have notified us of the relevant change.

Data protection law grants you a number of specific rights in respect of your data in addition to the broad and general right to have your data protected. We have set out some information in respect of each of those specific rights, below:

Right to be informed about how your personal data will be processed. This enables you to receive information about how we use your personal data. We have set this information out in this policy.
Request access to your personal data (commonly known as a "data subject access request"). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate information we hold about you corrected.
Request erasure of your personal data (commonly known as the "right to be forgotten"). This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have exercised your right to object to processing (see below).
Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground. You also have the right to object where we are processing your personal data for direct marketing purposes.
Request the restriction of processing of your personal data. This enables you to ask us to suspend the processing of personal data about you, for example if you want us to establish its accuracy or the reason for processing it.
Request the transfer of your personal data to another party.
Not to be subject to a decision solely based on automated processing. We do not anticipate making decisions about you based solely on automated decision making where that decision would have a significant impact on you. If we ever make a decision about you automatically by a computer or an algorithm without human intervention you can ask us to have that decision reviewed by a human.

If you want to exercise any of the rights set out above, please contact us using the contact details set out at part 15 of this privacy policy below.

Third-party websites

Our website may, from time to time, contain links to third-party websites. If you follow a link to any of these websites, please note that these websites have their own privacy policies and that we do not accept any responsibility or liability for these policies. Please check these policies before you submit any personal data to these websites.

Changes to this privacy policy

We reserve the right to update or amend this privacy policy at any time, including where we intend to further process your personal data for a purpose other than that for which the personal data was collected or where we intend to process new types of personal data. We will place any updates here on this page. This privacy policy was last updated on 24 January 2025.

Complaints

We encourage you to contact us first if you have any queries, comments or concerns about the way we handle your data (our details are in the section immediately below). We will try to put things right.

However, if you are not satisfied with our handling of any request by you in relation to your rights or concerns, you also have the right to make a complaint to a data protection supervisory authority, which, if you are based in:

the UK, is the UK's Information Commissioner's Office ("ICO"). You can contact the ICO at: Information Commissioner's Office, Wycliffe House, Water Lane, Wilmslow, SK9 5AF; 0303 123 1113; or https://ico.org.uk/; or

if you are not based in the UK and are based in Europe, you can contact your local representative, details of which can be found here.

Contact

If you have any questions about this privacy policy or how we handle your personal data, please contact us by emailing [email protected].

Privacy Policy