Alupro Limited’s (Alupro) – Privacy Policy
Introduction
Welcome to Alupro’s privacy policy. In this policy “we”, “us” and “our” refer to Alupro.
Alupro is a not-for-profit trade association funded by the aluminium packaging industry. We provide advice and run communications campaigns to help educate the public about recycling aluminium packaging.
This privacy policy applies to the websites and other online services that we operate (listed below). It explains how we collect, use, share, store and protect personal data about people who visit and use our websites or otherwise interact with us including our partners and stakeholders, industry members, representatives of other organisations such as schools and members of the public.
We use a single privacy policy to cover all of our websites as for the most part our approach to handling of personal data is generally consistent across our websites. However, each website supports a different programme and this mean that we may use personal data in slightly different ways depending on the nature of the programme. For example where the programme is aimed at educating individuals (B2C) rather than organisations (B2B) different rules apply to enable us to supply you with direct marketing as explained further below. We recommend that regardless of which of our websites/programmes you are accessing that you read the policy and that if you have any questions regarding how we handle your information please contact us using the details below.
Websites operated by Alupro to which this policy applies:
Controller
Alupro is the data controller and is responsible for certain personal data about you.
Contact us
If you have any questions about this policy or about how we handle your data, please contact our Data Protection Compliance Lead as follows: JulieM@alupro.org.uk
Complaints
You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK regulator for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.
It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.
International Access and Applicable Laws
Our websites are operated from the United Kingdom and we act as the data controller in accordance with UK data protection law. Although we are generally targeting UK audiences, our websites are accessible globally and may be used by individuals located outside the UK. As a result, personal data may be subject to the data protection and privacy laws of other jurisdictions, depending on where users are located. While we design and manage our websites in line with UK GDPR and applicable UK legislation, users should be aware that local laws and regulatory requirements in their country of residence may also apply when accessing or using our websites.
Third-party links
Our websites may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our websites, we encourage you to read the privacy policy of every website you visit.
Third-party apps, websites and services
If you use any third party apps, websites or services to access our services, your usage is subject to the relevant third party’s terms and conditions, cookies policy, and privacy policy. For example, if you interact with us on social media, your use is subject to the terms and conditions and privacy policies of the relevant social media platform (Facebook, Instagram etc.).
- The data we collect about you
Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).
We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:
- Identity and Contact Data: includes name, title, organisations, job role/position, email address, postal address, telephone number.
- Correspondence and Communications Data: includes your feedback, enquiries, survey responses, and other information you choose to provide when contacting us or interacting with our websites.
- Marketing Data: includes your preferences in receiving marketing communications from us, your opt-ins or consents for newsletters, campaigns, or resources.
- Technical and Usage Data: information about how you use our websites, IT, communication and other systems. Your computer’s Internet Protocol (IP) address, your browser type and version, the pages you visit, the time and date of your visit, the time spent on each page, the device type, operating system, unique device identifiers, device settings, and geo-location data.
We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data could be derived from your personal data but is not considered personal data in law as this data will not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy policy.
We do not intentionally collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health, and genetic and biometric data). Nor do we collect any information about criminal convictions and offences.
If you fail to provide personal data
Where we need to collect personal data by law, or under the terms of a contract we have with you, and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with our products). In this case, we may have to cancel a product you have ordered from us but we will notify you if this is the case at the time.
- How is your personal data collected?
We use different methods to collect data from and about you including through:
- Direct interactions: you may give us your personal data by filling in forms or by corresponding with us by phone, email or otherwise, or submitting survey responses, signing up to our newsletters and publications, or by requesting that marketing be sent to you.
- Indirectly: as you interact with our websites, we will automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies, server logs and other similar technologies. We may also receive Technical Data about you if you visit other websites employing our cookies. Please see our cookie policy for further details.
- Via embedded third party content: we may receive personal data about you from embedded third party content such as videos and social media feeds from providers such as Linkedin / You Tube / Instagram / Facebook, or analytics providers such as Google.
- How we use your personal data
We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:
- Where we need to perform the contract we are about to enter into or have entered into with you.
- Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
- Where we need to comply with a legal obligation.
- In limited circumstances where you have given your consent.
- Purposes for which we will use your personal data
We have set out below, in a table format, a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.
Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below.
|
Purpose/Activity |
Type of data |
Lawful basis for processing including basis of legitimate interest |
|
Website security & operation:
|
Technical and Usage |
Necessary for our legitimate interests (ensuring the security, integrity, and proper functioning of our websites) |
|
Responding to enquiries and communications:
|
Identity and Contact; Correspondence and Communications |
Necessary for our legitimate interests (to communicate with individuals and respond to requests they have initiated) |
|
Setting up an account on alupro.org.uk website |
Identity and Contact; Technical and Usage |
Performance of a contract with you (where you have agreed to our website terms) Necessary for our legitimate interests (managing access to member-only services, maintaining the security of the website) |
|
Provision of downloads and resources:
|
Identity and Contact |
Consent (where marketing or follow-up communications are included) Necessary for our legitimate interests (where data is required solely to fulfil the request) Performance of a contract with you (where you have agreed to our website terms or resource download terms) |
|
Marketing communications and newsletter subscriptions:
|
Identity and Contact; Marketing |
Necessary for our legitimate interests (“B2B” communications, “B2C” where permitted by law, i.e. “soft opt-in) Consent (primary basis for “B2C” communications) |
|
Programme participation campaigns and awards:
|
Identity and Contact |
Necessary for our legitimate interests (to administer programmes fairly and transparently) Consent |
|
Surveys, feedback and research activities:
|
Identity and Contact; Correspondence and Communications
|
Necessary for our legitimate interests (where anonymised or aggregated insights are used to improve services)) Consent. |
|
Analytics, website improvement and user experience:
|
Technical and Usage |
Necessary for our legitimate interests (for strictly necessary functionality) Consent (for non-essential cookies and analytics) |
|
Cookie Management and Preference Storage:
|
Technical and Usage |
Consent Legal Obligation (compliance with PECR and UK GDPR requirements) |
|
Partner and stakeholder relationship management:
|
Identity and Contact: Correspondence and Communications |
Necessary for our legitimate interests (to manage professional relationships and collaborative activities.) |
|
Legal compliance:
|
Any relevant personal data to meet this obligation |
Legal obligation |
|
Incident Management and Record Keeping:
|
Any relevant personal data to meet this obligation |
Legal obligation Necessary for our legitimate interests (to protect the organisation and affected individuals). |
- Account creation on the alupro.org.uk website
Access to the ‘members area’ of the alupro.org.uk (which allows access to certain information such as board meeting summaries and programme updates) requires the creation of a user account. Creating an account is optional, however where a user chooses to register, we collect an email address, a username (which may be the same as the email address), and a password. No additional profile or verification information is collected as part of the registration process. All account registration requests are subject to manual approval to confirm eligibility. Use of the account and access to the restricted areas of this website are governed by our website terms and conditions.
- Direct Marketing
We may use the following channels to send direct marketing to you: email, SMS, post, or telephone, depending on your choices.
If you are an individual (B2C) as opposed to a representative of one of our commercial partners or an organisation (B2B), you may receive marketing communications from us if you have consented for us to send you this information except where a lawful ‘soft opt-in’ applies. In relation to B2B direct marketing we primarily rely on ‘legitimate interests’ as a lawful basis.
Recipients can unsubscribe to marketing updates, or withdraw consent at any time.
- Cookies
All our websites use cookies and analytics tools to enhance functionality, measure performance, and provide personalised content. Consent to install non-essential cookies is obtained via a cookie banner/consent management platform (CookieYes or equivalent).
Website users may manage or withdraw consent at any time.
For more information about the cookies we use, please click here.
- Disclosures of your personal data
We may share your personal data with the parties set out below for the purposes set out in the table above.
- Service providers acting as processors who provide services such as Hosting and IT and system administration services, account creation, email segmentation, Security/CDN services (e.g. Cloudflare), analytics providers (e.g. Google Analytics, Tag Manager).
- Embedded media platforms such as YouTube and LinkedIn.
- Marketing companies and online advertising agencies helping us to manage our electronic communications to you and to help us show you the advertising you are most likely to be interested in.
- Professional advisers including lawyers, bankers, auditors and insurers who provide consultancy, banking, legal, insurance and accounting services.
- HM Revenue & Customs, regulators and other authorities based in the United Kingdom.
- Third parties to whom we may choose to sell, transfer or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy policy.
We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.
- International transfers
It is sometimes necessary for us to transfer your personal data to countries outside the UK. In those cases we will comply with applicable UK laws designed to ensure the privacy of your personal data.
Whenever we transfer your personal data out of the UK, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:
- We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data; or
- Where we use certain service providers, we may use specific contracts approved for use in the UK which give personal data the same protection it has in the UK.
Please contact us: JulieM@alupro.org.uk if you want further information on the specific mechanism used by us when transferring your personal data out of the UK.
- Data security
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.
- Data retention
How long will you use my personal data for?
We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.
To determine the appropriate retention period for personal data, we consider the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements.
Details of retention periods for different aspects of your personal data are available from us by contacting us: JulieM@alupro.org.uk
- Your legal rights
Under certain circumstances, you have rights under data protection laws in relation to your personal data. Please see below to find out more about these rights.
If you wish to exercise any of these rights please contact us: JulieM@alupro.org.uk
No fee usually required
You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we could refuse to comply with your request in these circumstances.
What we may need from you
We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.
Time limit to respond
We try to respond to all legitimate requests within one month. Occasionally it could take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.
YOUR LEGAL RIGHTS
You have the right to:
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 data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
Request erasure of your personal data. 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 successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
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 as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios:
- If you want us to establish the data’s accuracy.
- Where our use of the data is unlawful but you do not want us to erase it.
- Where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims.
- You have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.
Last updated: January 2026