1.2 This policy applies to personal information provided by our customers, clients and suppliers and their authorised users and affiliated individuals. In this notice “you”refers to any individual whose personal data we hold or process.
1.3 In general, our services are limited to the provision of marketing services to business customers and we do not process personal data on a large scale, but we will hold certain data in relation to individuals associated with our clients and suppliers or potential clients (i.e. employees in most cases), and this notice sets out the basis on which we hold that data.
1.4 This notice is governed by the EU General Data Protection Regulation (the“GDPR”) from 25 May 2018.
2. Legal Basis on which we process personal data
2.1 Personal data we hold about you will be processed either because:
2.1.1 the processing is necessary in order for us to comply with our obligations under a contract between you and us, specifically for the provision of our services; or
2.1.2 the processing is necessary in pursuit of a “legitimate interest”, a legitimate interest in this context means a valid interest we have or a third party has in processing your personal data which is not overridden by your interests in data privacy and security.
3. Personal data we collect
3.1 We may collect and process the following personal data (information that can be uniquely identified with you) about you:
3.1.1 for individuals associated with our clients or potential clients we may hold contact information such as names, email addresses, phone numbers, addresses, and job titles and/or specific roles within your organisation (“Client ContactInformation”);
3.1.2 for individuals associated with our suppliers, potential suppliers and other third parties we interact with we may hold contact information such as names, email addresses, phone numbers, addresses, and job titles and/or specific roles within your organisation (“Third Party Contact Information”);
3.1.3 a record of any correspondence or communication between you and us in the delivery of our services and any information we may require from you when you report a problem or submit a complaint (“CommunicationInformation”);
3.1.4 marketing information we may hold about you in order to provide information about our services this may include names, email addresses, phone numbers, addresses, and job titles and/or specific roles within your organisation (“Marketing Information”).
3.2 We will collect information either from you directly or from a third party (for instance your employer or an introducer). If we do obtain your personal data from a third party your privacy rights under this notice are not affected and you are still able to exercise the rights contained within this notice.
3.3 You do not have to supply any personal information to us in practice we may be unable to provide our services to you without personal data (for instance we will need contact information in order to communicate with you). You may withdraw our authority to process your personal data (or request that we restrict our processing)at any time but there are circumstances in which we may need to continue to process personal data (please see below).
4. How we process your personal data
4.1 Please see the table below, which sets out the manner in which we will process the different types of personal data we hold:
For each type of data listed above, definitions are included under clause 3.1.
5. Data Retention
5.1 Our current data retention policy is to delete or destroy (to the extent we are able to) the personal data we hold about you in accordance with the following:
5.2 For any category of personal data not specifically defined in this notice, and unless otherwise specified by applicable law, the required retention period for any personal data will be deemed to be 7 years from the date of receipt by us of that data.
5.3 The retention periods stated in this notice can be prolonged or shortened as maybe required (for example, in the event that legal proceedings apply to the data or if there is an on-going investigation into the data).
5.4 We review the personal data (and the categories of personal data) we are holding on a regular basis to ensure the data we are holding is still relevant to our business and is accurate. If we discover that certain data we are holding is no longer necessary or accurate, we will take reasonable steps to correct or delete this data as may be required.
5.5 If you wish to request that data we hold about you is amended or deleted, please refer to clause 8 below, which explains your privacy rights.
6. Sharing your information
6.1 We do not disclose any information you provide to any third parties other than as follows:
6.1.1 We will share information relating to individuals associated with our clients and suppliers with the relevant client or supplier;
6.1.2 if we are under a duty to disclose or share your personal data in order to comply with any legal obligation (for example, if required to do so by a court order or for the purposes of prevention of fraud or other crime);
6.1.3 in order to enforce any terms and conditions or agreements for our services that may apply;
6.1.4 If we are sub-contracting services to a third party we may provide information to that third party in order to provide the relevant services;
6.1.5 we may transfer your personal information to a third party as part of a sale of some or all of our business and assets to any third party or as part of any business restructuring or reorganisation, but we will take steps with the aim of ensuring that your privacy rights continue to be protected;
6.1.6 to protect our rights, property and safety, or the rights, property and safety of our users or any other third parties. This includes exchanging information with other companies and organisations for the purposes of fraud protection and credit risk reduction.
6.2 Other than as set out above, we will not disclose any of your personal information unless either you give us permission to do so or we have taken steps to ensure that your privacy rights are protected.
7.1 We will take all reasonable steps to ensure that appropriate technical and organisational measures are carried out in order to safeguard the information we collect from you and protect against unlawful access and accidental loss or damage. These measures may include (as necessary):
7.1.1 protecting our servers with software firewalls;
7.1.2 locating our data processing storage facilities in secure locations;
7.1.3 encrypting all data stored on our server with an industry standard encryption method that encrypts the data between your computer and our server so that in the event of your network being insecure no data is passed in a format that could easily be deciphered;
7.1.4 when necessary, disposing of or deleting your data so it is done so securely;
7.1.5 regularly backing up and encrypting data we hold.
7.2 We will ensure that our employees are aware of their privacy and data security obligations. We will take reasonable steps to ensure that the employees of third parties working on our behalf are aware of their privacy and data security obligations.
7.3 This notice and our procedures for handling personal data will be reviewed as necessary.
8. Your privacy rights
8.1 The GDPR gives you the following rights in respect of personal data we hold about you:
8.2 All SARs and other requests or notifications in respect of your above rights must be sent to us in writing to the address at the end of this policy.
8.3 We will endeavour to comply with such requests as soon as possible but in any event we will comply within one month of receipt (unless a longer period of time to respond is reasonable by virtue of the complexity or number of your requests).
9. Cookies and IP Address
9.1 A cookie is a piece of data stored locally on your computer and contains information about your activities on the Internet. The information in a cookie does not contain any personally identifiable information you submit to our website.
9.3 Once you close your browser, our access to the cookie terminates. You have the ability to accept or decline cookies. Most web browsers automatically accept cookies, but you can usually modify your browser setting to decline cookies if you prefer. To change your browse settings you should go to your advanced preferences.
9.4 If you choose not to accept the cookies, this will not affect your access to the majority of information available on our website. However, you will not be able to make full use of our online services.
9.5 An Internet Protocol (IP) address is a number assigned to your computer by yourInternet Service Provider (ISP), so you can access the Internet. We may use your IP address to diagnose problems with our server, report aggregate information, and determine the fastest route for your computer to use in connecting to our website, and to administer and improve the website.
10. Data Breaches
10.1 If personal data we hold about you is subject to a breach or unauthorised disclosure or access, we will report this to the Information Commissioner’s Office(ICO) and/or our data protection manager.
10.2 If a breach is likely to result in a risk to your data rights and freedoms, we will notify you as soon as possible.
11. Other websites
11.1 Our website may contain links and references to other websites. Please be aware that this notice does not apply to those websites.
11.2 We cannot be responsible for the privacy policies and practices of sites that are not operated by us, even if you access them via our website.
11.3 In addition, if you arrive on our website via a third party site, we cannot be responsible for the privacy policies and practices of the owners or operators of that third party site and recommend that you check the policy of that third party site and contact its owner or operator if you have any concerns or questions.
12. Transferring your information outside Europe
12.1 In delivering our services to you information may be transferred to, processed and stored at, countries or international organisations outside of the EEA. For instance if our client or a supplier is based outside of the EEA we will need to communicate with them under our agreement with them.
12.2 If we transfer your information outside of the EEA in a systematic way, and the third country or international organisation in question has not been deemed by the EU Commission to have adequate data protection laws, we will provide appropriate safeguards and we will be responsible for ensuring your privacy rights continue to be protected as outlined in this notice. In particular we will ensure that there is an contract in place with our partners to ensure that your data is processed in accordance with this notice.
12.3 By submitting your personal information to us you agree to the transfer, storing or processing of your information outside the EEA in the manner described above.
13. Notification of changes to the contents of this notice
We will post details of any changes to our policy on [our website] to help ensure you are always aware of the information we collect, how we use it, and in what circumstances if any, we share it with other parties.
14. Contact us
If at any time you would like to contact us with your views about our privacy practices, or with any enquiry or complaint relating to your personal information or how it is handled, you can do so via the following address: Planit LGPM Limited, 130 Shaftesbury Avenue, 2nd Floor, London, United Kingdom, W1D 5EU, firstname.lastname@example.org.
If we are unable to resolve any issues you may have or you would like to make a further complaint, you can contact the Information Commissioner’s Office by visiting http://www.ico.org.uk/ for further assistance.