POLICIES

ECOSSE EV LTD believes that continuous improvement in environmental management is an essential element within its overall business plan – minimising waste, consumption of resources and pollution goes hand in hand with high productivity and quality standards. This policy therefore applies to, and will be integrated with, all business activities, products and services with the potential to adversely affect the environment on a local or global scale. 

We recognise and accept our legal duty of care toward the environment and are committed not only to complying with our legal duties and with other requirements to which we subscribe but to exceed these requirements where reasonably practicable. 

Energy generation and consumption is a major contributor to the production of greenhouse gases and global warming and a significant cost to the business. We commit to actively managing our use of energy, reducing consumption and continuously improving efficiency wherever possible. We will also seek to minimise our direct and indirect consumption of other natural resources, particularly those obtained from non-renewable or non-sustainable reserves. 

We will seek to identify all processes that generate waste – whether from the inefficient use of resources or the production of by-products, emissions or effluent discharges – and will seek to avoid pollution by eliminating, minimising or reusing waste products wherever reasonably practicable or, where this cannot be achieved, identifying and taking advantage of opportunities for recycling and waste recovery. 

The basis of our environmental management system will be an ongoing review of business activities and the identification of aspects of our work that could have an impact upon the environment. This will be followed by the implementation of proactive steps to eliminate, minimise or manage them so that adverse environmental effects are at a minimum. 

To enable us to measure our environmental performance, we will establish and monitor suitable objectives and targets that will promote continuous improvement year on year in our environmental performance. 

Scope 
The scope of the Environmental Management System extends to all products and services of the company. Included within this definition, and in addition to planned operating conditions, are nonroutine activities and foreseeable emergency situationsThe environmental management system will also apply to those aspects of the activities of suppliers and service providers over which we have, or could have, an influence and the environmental performance of our business partners. 

Arrangements for Implementation 

  1. Environmental Aspects 

The identification of those aspects (environmental aspects) of our activities, products and services that could have an impact upon the environment will be fundamental to our environmental management system. This policy will apply to those aspects over which we have control or can exert influence and will also apply to new developments, new or modified activities, products and services. Details of all environmental aspects will be recorded in the Register of Environmental Aspects.  

Having identified our environmental aspects, we will assess those that have the potential to have a significant impact upon the environment (‘significant aspects’) and it is these aspects that will be taken into account in establishing, implementing and maintaining this environmental management system. 

  1. Legal and other requirements 

The initial identification of legal requirements applicable to the business’ environmental aspects is the responsibility of the System Manager. Regular reviews of legal requirements relevant to the business will be carried out on a 6 monthly basis or when changes are made to business activities. The results of legal compliance reviews will be reviewed by top management during regular Management Review meetings.  
 

  1. Objectives, Targets and Programmes 

In order to achieve continuous improvements in the performance of the environmental management system, objectives and targets associated with significant environmental aspects will be set by the Management Board and reviewed on a regular basis at the Management Review meeting. Objectives and Targets will be managed in accordance with Environmental Procedure EP3 (Objectives & Targets). 
 

  1. Competence, Training and Awareness 

Induction training for all new employees will include the importance of conformity with the environmental policy and procedures. This will include information about significant environmental aspects and potential impacts associated with their work, and how their personal performance contributes toward protecting or polluting the environment. 

 Specific tasks or locations which could cause a significant environmental impact are listed in the Register of Significant Environmental Aspects. The company is committed to ensuring that all persons employed either directly or under a temporary contract, in carrying out tasks with the potential to have a significant environmental impact are competent on the basis of appropriate education, training or experience 

The competence of prospective contractors to comply with the terms of this policy will be verified as a part of the tender process, with contractor performance being monitored throughout the life of the contract.  

In order to ensure that skills remain relevant, training records will be maintained and managed on an ongoing basis with refresher training being delivered, where required, at appropriate intervals. 
 

  1. Communication 

In order for the environmental management system to function effectively, and to ensure that it responds proactively to business needs, it is essential that effective lines of communication exist between the various levels and functions of the organisation.  
 

  1. Control of Document 

Where documents are used as part of the environmental management system, it is essential that they are effectively controlled to ensure that they are fit for purpose, that the correct  version is available at the point of use, and is periodically reviewed to ensure that the document continues to meet requirements. In order to achieve this, all documents will be managed in accordance with Standard Procedure QP1 (Document Control). 
 

  1. Operational Control 

The practical effectiveness of the environmental management system depends on processes and procedures associated with the significant environmental aspects, and those contributing to our environmental objectives and targets are carried out under planned conditions. Where deviation from planned conditions could lead to a failure of the aims and objectives of the environmental management system, procedures will be documented along with critical operating conditions that must be maintained.  

Where goods or services supplied by external partners are associated with the control of significant environmental aspects, requirements will be communicated to them by the Aspect Sponsor.  
 

  1. Emergency Preparedness and Response 

It is essential that operational control extends to foreseeable emergency situations. Risk assessments associated with the significant environmental aspects will be carried out to identify and assess the risks associated with the onset of emergency situations, and to plan effective controls to either eliminate the risk or respond effectively to them. Emergency response procedures will be prepared as required, in accordance with Environmental Procedure EP4 (Emergency Preparedness & Response).   

Where emergency response procedures are put in place, they will be reviewed annually by the Aspect Sponsor or after actual emergency events and tested at regular intervals to ensure effectiveness. 
 

  1. Checking 

To ensure that processes associated with significant environmental aspects are being carried out within specified operating limits, suitable monitoring and measurements will be carried out on a regular basis, with the results being recorded in a suitable form. Documentation setting out the required operating conditions will be made available to those responsible for ensuring that compliance is maintained, along with appropriate calibrated equipment to enable them to take accurate measurements. The results of monitoring and measuring will be reviewed on an ongoing basis, so that effective action can be taken to address deviations before hazardous situations develop. The results of monitoring and measurement will be formally evaluated against legal compliance or other standards, to which the business subscribes on an ongoing basis, by the Aspect Sponsor. A record of the findings of these formal reviews will be made and retained by the Aspect Sponsor. 

 
10. Nonconformity, Corrective Action and Preventative Action 

Processes and procedures associated with significant environmental aspects will include details of actions to be taken, to ensure that where deviations from planned operating conditions are detected, effective action can be taken to deal with the non-conformity to correct it or mitigate the environmental impact. 
Nonconformities, Corrective actions and preventative actions will be dealt with in accordance with Standard Procedure QP4 (Nonconformities, Corrective and Preventative Actions). 

  1. Control of Records 

Records required as part of our compliance with statutory obligations, or other standards to which the company subscribes, will be made and retained in accordance with Standard Procedure QP2 (Control of Records).  

  1. Internal Audit 

 
Internal audits of the environmental management system are essential to the business, as they enable us to verify that planned actions are being implemented in the workplace. Audits will be carried out by Competent Internal Auditors. Internal Audits will be planned, carried out and managed in accordance with Standard Procedure QP3 (Internal Audit).  

 
13. Management Review 

 

The effectiveness of the environmental management system will be reviewed on a regular basis to ensure that it continues to be suitable, adequate and effective in managing the impact that the business has upon the environment. The management review process will be managed in accordance with Standard Procedure QP7 (Management Review). 

  1. Introduction

1.1   
We are committed to safeguarding the privacy of our website visitors and
service users.

1.2   
This policy applies where we are acting as a data controller with respect to
the personal data of our website visitors and service users; in other words,
where we determine the purposes and means of the processing of that personal
data.

1.3   
We use cookies on our website. Insofar as those cookies are not strictly
necessary for the provision of our website and services, we will ask you to consent
to our use of cookies when you first visit our website.

1.4   
Our website incorporates privacy controls which affect how we will process your
personal data. By using the privacy controls, you can specify whether you would
like to receive direct marketing communications and limit the publication of
your information.

1.5   
In this policy, “we”, “us” and “our” refer to Ecosse
EV
. For more information about us, see Section 13.

  1. Credit

2.1   
This document was created using a template from SEQ Legal (https://seqlegal.com).

  1. How we use your personal
    data

3.1   
In this Section 3 we have set out:

(a)   
the general categories of personal data that we may process;

(b)   
in the case of personal data that we did not obtain directly from you, the
source and specific categories of that data;

(c)   
the purposes for which we may process personal data; and

(d)   
the legal bases of the processing.

3.2   
We may process data about your use of our website and services (“usage
data
“). The usage data may include your IP address, geographical
location, browser type and version, operating system, referral source, length
of visit, page views and website navigation paths, as well as information about
the timing, frequency and pattern of your service use. The source of the usage
data is Google Analytics. This usage data may be processed for the purposes of
analysing the use of the website and services. The legal basis for this
processing is our legitimate interests, namely monitoring and improving our
website and services.

3.3   
We may process your account data (“account data“). The account
data may include your name and email address. The source of the account data is
you or your employer. The account data may be processed for the purposes of
operating our website, providing our services, ensuring the security of our
website and services, maintaining back-ups of our databases and communicating
with you. The legal basis for this processing is our legitimate interests,
namely the proper administration of our website and business.

3.4   
We may process your information included in your personal profile on our
website (“profile data“). The profile data may include your
name, address, telephone number, email address, profile pictures, gender, date
of birth, relationship status, interests and hobbies, educational details and
employment details. The profile data may be processed for the purposes of
enabling and monitoring your use of our website and services. The legal basis
for this processing is our legitimate interests, namely the proper
administration of our website and business.

3.5   
We may process your personal data that are provided in the course of the use of
our services (“service data“). The service data may include
website usage data.The source of the service data is you or your employer. The
service data may be processed for the purposes of operating our website,
providing our services, ensuring the security of our website and services,
maintaining back-ups of our databases and communicating with you. The legal
basis for this processing is our legitimate interests, namely the proper
administration of our website and business.

3.6   
We may process information that you post for publication on our website or
through our services (“publication data“). The publication
data may be processed for the purposes of enabling such publication and
administering our website and services. The legal basis for this processing our
legitimate interests, namely the proper administration of our website and
business.

3.7   
We may process information contained in any enquiry you submit to us regarding
goods and/or services (“enquiry data“). The enquiry data may
be processed for the purposes of offering, marketing and selling relevant goods
and/or services to you. The legal basis for this processing is your consent (by
placing the enquiry with us), as well as our legitimate interests in responding
to your enquiries/messages and keeping records. Your data may be processed for
the purposes of offering, marketing and selling relevant products and/or
services to you where you have provided your consent.

3.8   
We may process information relating to our customer relationships, including
customer contact information (“customer relationship data“).
The customer relationship data may include your name, your employer, your job
title or role, your contact details, and information contained in
communications between us and you or your employer. The source of the customer
relationship data is you or your employer. The customer relationship data may
be processed for the purposes of managing our relationships with customers,
communicating with customers, keeping records of those communications and
promoting our products and services to customers. The legal basis for this
processing is our legitimate interests, namely the proper management of our
customer relationships

3.9   
We may process information relating to transactions, including purchases of
goods and services, that you enter into with us and/or through our website
(“transaction data“).The transaction data may include your
contact details, your card details and the transaction details. The transaction
data may be processed for the purpose of supplying the purchased goods and
services and keeping proper records of those transactions. The legal basis for
this processing is the performance of a contract between you and us and/or
taking steps, at your request, to enter into such a contract and our legitimate
interests, namely the proper administration of our website and business.

3.10 
We may process information that you provide to us for the purpose of
subscribing to our email notifications and/or newsletters (“notification
data
“). The notification data may be processed for the purposes of
sending you the relevant notifications and/or newsletters.

3.11 
We may process information contained in or relating to any communication that
you send to us (“correspondence data“). The correspondence
data may include the communication content and metadata associated with the
communication.Our website will generate the metadata associated with
communications made using the website contact forms. The correspondence data
may be processed for the purposes of communicating with you and record-keeping.
The legal basis for this processing is our legitimate interests, namely the
proper administration of our website and business and communications with
users.

3.12 
We may process any of your personal data identified in this policy where
necessary for the establishment, exercise or defence of legal claims, whether
in court proceedings or in an administrative or out-of-court procedure. The
legal basis for this processing is our legitimate interests, namely the
protection and assertion of our legal rights, your legal rights and the legal
rights of others.

3.13 
We may process any of your personal data identified in this policy where
necessary for the purposes of obtaining or maintaining insurance coverage,
managing risks, or obtaining professional advice. The legal basis for this
processing is our legitimate interests, namely the proper protection of our
business against risks.

3.14 
In addition to the specific purposes for which we may process your personal
data set out in this Section 3, we may also process any of your personal data
where such processing is necessary for compliance with a legal obligation to
which we are subject, or in order to protect your vital interests or the vital
interests of another natural person.

3.15 
Please do not supply any other person’s personal data to us unless we prompt
you to do so.

  1. Providing your personal data
    to others

4.1   
We may disclose your personal data to our insurers and/or professional advisers
insofar as reasonably necessary for the purposes of obtaining or maintaining
insurance coverage, managing risks, obtaining professional advice, or the
establishment, exercise or defence of legal claims, whether in court
proceedings or in an administrative or out-of-court procedure.

4.2   
We may disclose specify personal data category or categories to our
suppliers or subcontractors insofar as reasonably necessary for carrying out
our contractual obligations to you.

4.3   
Financial transactions relating to our website and services may be handled by
our assigned payment services providers, We will share transaction data with our
payment services providers only to the extent necessary for the purposes of
processing your payments, refunding such payments and dealing with complaints
and queries relating to such payments and refunds.

4.4   
In addition to the specific disclosures of personal data set out in this
Section 4, we may disclose your personal data where such disclosure is
necessary for compliance with a legal obligation to which we are subject, or in
order to protect your vital interests or the vital interests of another natural
person. We may also disclose your personal data where such disclosure is
necessary for the establishment, exercise or defence of legal claims, whether
in court proceedings or in an administrative or out-of-court procedure.

  1. International transfers of
    your personal data

5.1   
In this Section 5, we provide information about the circumstances in which your
personal data may be transferred to countries outside the European Economic
Area (EEA).

5.2   
The hosting facilities for our website are situated in UK. The European
Commission has made an “adequacy decision” with respect to the data
protection laws of each of these countries. Transfers to each of these
countries will be protected by appropriate safeguards, namely the use of
standard data protection clauses adopted or approved by the European
Commission. Please contact us if you would like more information about these
safeguards.

5.3   
Our ground transportation affiliates may be situated within other European
countries, as well as further afield. The European Commission has made an
“adequacy decision” with respect to the data protection laws of each
of these countries. Transfers to each EU countries will be protected by
appropriate safeguards, namely the use of standard data protection clauses
adopted or approved by the European Commission. Please contact us if you would
like more information about these safeguards.

5.4   
You acknowledge that personal data that you submit for publication through our
website or services may be available, via the internet, around the world. We
cannot prevent the use (or misuse) of such personal data by others.

  1. Retaining and deleting
    personal data

6.1   
This Section 6 sets out our data retention policies and procedure, which are
designed to help ensure that we comply with our legal obligations in relation
to the retention and deletion of personal data.

6.2   
Personal data that we process for any purpose or purposes shall not be kept for
longer than is necessary for that purpose or those purposes.

6.3   
We will retain your personal data as follows:

(a)      
personal data category or categories will be retained for a maximum
period of 2 years.

6.4   
In some cases it is not possible for us to specify in advance the periods for
which your personal data will be retained. In such cases, we will continue to
review the necessity of keeping such data and upon a decision that it is no
longer necessary for the processing purposes, we will delete those data.

6.5   
Notwithstanding the other provisions of this Section 6, we may retain your
personal data where such retention is necessary for compliance with a legal
obligation to which we are subject, or in order to protect your vital interests
or the vital interests of another natural person.

  1. Amendments

7.1   
We may update this policy from time to time by publishing a new version on our
website.

7.2   
You should check this page occasionally to ensure you are happy with any
changes to this policy.

7.3   
We may notify you of significant changes to this policy by email.

  1. Your rights

8.1   
In this Section 8, we have summarised the rights that you have under data
protection law. Some of the rights are complex, and not all of the details have
been included in our summaries. Accordingly, you should read the relevant laws
and guidance from the regulatory authorities for a full explanation of these
rights.

8.2   
Your principal rights under data protection law are:

(a)   
the right to access;

(b)   
the right to rectification;

(c)   
the right to erasure;

(d)   
the right to restrict processing;

(e)   
the right to object to processing;

(f)   
the right to data portability;

(g)   
the right to complain to a supervisory authority; and

(h)   
the right to withdraw consent.

8.3   
You have the right to confirmation as to whether or not we process your
personal data and, where we do, access to the personal data, together with
certain additional information. That additional information includes details of
the purposes of the processing, the categories of personal data concerned and
the recipients of the personal data. Providing the rights and freedoms of
others are not affected, we will supply to you a copy of your personal data.
The first copy will be provided free of charge, but additional copies may be
subject to a reasonable fee.

8.4   
You have the right to have any inaccurate personal data about you rectified
and, taking into account the purposes of the processing, to have any incomplete
personal data about you completed.

8.5   
In some circumstances you have the right to the erasure of your personal data
without undue delay. Those circumstances include: the personal data are no
longer necessary in relation to the purposes for which they were collected or
otherwise processed; you withdraw consent to consent-based processing; you
object to the processing under certain rules of applicable data protection law;
the processing is for direct marketing purposes; and the personal data have
been unlawfully processed. However, there are exclusions of the right to
erasure. The general exclusions include where processing is necessary: for
exercising the right of freedom of expression and information; for compliance
with a legal obligation; or for the establishment, exercise or defence of legal
claims.

8.6   
In some circumstances you have the right to restrict the processing of your
personal data. Those circumstances are: you contest the accuracy of the
personal data; processing is unlawful but you oppose erasure; we no longer need
the personal data for the purposes of our processing, but you require personal
data for the establishment, exercise or defence of legal claims; and you have
objected to processing, pending the verification of that objection. Where
processing has been restricted on this basis, we may continue to store your
personal data. However, we will only otherwise process it: with your consent;
for the establishment, exercise or defence of legal claims; for the protection
of the rights of another natural or legal person; or for reasons of important
public interest.

8.7   
You have the right to object to our processing of your personal data on grounds
relating to your particular situation, but only to the extent that the legal
basis for the processing is that the processing is necessary for: the performance
of a task carried out in the public interest or in the exercise of any official
authority vested in us; or the purposes of the legitimate interests pursued by
us or by a third party. If you make such an objection, we will cease to process
the personal information unless we can demonstrate compelling legitimate
grounds for the processing which override your interests, rights and freedoms,
or the processing is for the establishment, exercise or defence of legal
claims.

8.8   
You have the right to object to our processing of your personal data for direct
marketing purposes (including profiling for direct marketing purposes). If you
make such an objection, we will cease to process your personal data for this
purpose.

8.9   
You have the right to object to our processing of your personal data for
scientific or historical research purposes or statistical purposes on grounds
relating to your particular situation, unless the processing is necessary for
the performance of a task carried out for reasons of public interest.

8.10 
To the extent that the legal basis for our processing of your personal data is:

(a)   
consent; or

(b)   
that the processing is necessary for the performance of a contract to which you
are party or in order to take steps at your request prior to entering into a
contract,

and such
processing is carried out by automated means, you have the right to receive
your personal data from us in a structured, commonly used and machine-readable
format. However, this right does not apply where it would adversely affect the
rights and freedoms of others.

8.11 
If you consider that our processing of your personal information infringes data
protection laws, you have a legal right to lodge a complaint with a supervisory
authority responsible for data protection. You may do so in the EU member state
of your habitual residence, your place of work or the place of the alleged
infringement.

8.12 
To the extent that the legal basis for our processing of your personal
information is consent, you have the right to withdraw that consent at any
time. Withdrawal will not affect the lawfulness of processing before the
withdrawal.

8.13 
You may exercise any of your rights in relation to your personal data by
written notice to us

  1. About cookies

9.1   
A cookie is a file containing an identifier (a string of letters and numbers)
that is sent by a web server to a web browser and is stored by the browser. The
identifier is then sent back to the server each time the browser requests a
page from the server.

9.2   
Cookies may be either “persistent” cookies or “session”
cookies: a persistent cookie will be stored by a web browser and will remain
valid until its set expiry date, unless deleted by the user before the expiry
date; a session cookie, on the other hand, will expire at the end of the user
session, when the web browser is closed.

9.3   
Cookies do not typically contain any information that personally identifies a
user, but personal information that we store about you may be linked to the
information stored in and obtained from cookies.

  1. Cookies that we use

10.1 
We use cookies for the following purposes:

(a)   
authentication – we use cookies to identify you when you visit our website and
as you navigate our website

(b)  
status – we use cookies to help us to determine if you are logged into our
website.

(c)   
personalisation – we use cookies to store information about your preferences
and to personalise the website for you.

(d)   
security – we use cookies as an element of the security measures used to
protect user accounts, including preventing fraudulent use of login
credentials, and to protect our website and services generally

(e)   
advertising – we use cookies to help us to display advertisements that will be
relevant to you

(f)   
analysis – we use cookies to help us to analyse the use and performance of our
website and services and

(g)   
cookie consent – we use cookies to store your preferences in relation to the
use of cookies more generally

  1. Cookies used by our service
    providers

11.1 
Our service providers use cookies and those cookies may be stored on your
computer when you visit our website.

11.2 
We use Google Analytics to analyse the use of our website. Google Analytics
gathers information about website use by means of cookies. The information
gathered relating to our website is used to create reports about the use of our
website. Google’s privacy policy is available at: https://www.google.com/policies/privacy/.

The
relevant cookies are:

  1. Managing cookies

12.1 
Most browsers allow you to refuse to accept cookies and to delete cookies. The
methods for doing so vary from browser to browser, and from version to version.
You can however obtain up-to-date information about blocking and deleting
cookies via these links:

(a)   
https://support.google.com/chrome/answer/95647?hl=en
(Chrome);

(b)   
https://support.mozilla.org/en-US/kb/enable-and-disable-cookies-website-preferences
(Firefox);

(c)   
http://www.opera.com/help/tutorials/security/cookies/
(Opera);

(d)   
https://support.microsoft.com/en-gb/help/17442/windows-internet-explorer-delete-manage-cookies
(Internet Explorer);

(e)   
https://support.apple.com/kb/PH21411
(Safari); and

(f)   
https://privacy.microsoft.com/en-us/windows-10-microsoft-edge-and-privacy
(Edge).

12.2 
Blocking all cookies will have a negative impact upon the usability of many
websites.

12.3 
If you block cookies, you will not be able to use all the features on our
website.

  1. Our details

13.1 
This website is owned and operated by Ecosse EV.

13.2 
We are registered in Scotland under registration number SC126306, and our
registered office is at The Rural Centre, West Mains, Ingliston, Edinburgh,
EH28 8LT Scotland.

13.3 
Our principal place of business is as above.

13.4 
You can contact us:

(a)   
by post, to the postal address given above;

(b)   
using our website contact form;

(c)   
by telephone, on the contact number published on our website; or

(d)   
by email, using the email address published on our website

 

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