WHAT IS GDPR
GDPR (also known as the General Data Protection Regulation) is a new European framework for data protection laws. It gives you greater protection and rights and will give you more control over how your data is used.
We respect your privacy and are determined to protect your data. The purpose of this privacy notice is to inform you as to how we look after your personal data when you visit our website (regardless of where you visit it from). Also, to tell you about your privacy rights and how the data protection law protects you.
- WHO WE ARE AND IMPORTANT INFORMATION
- THE PERSONAL DATA WE COLLECT ABOUT YOU
- HOW WE COLLECT YOUR PERSONAL DATA
- HOW WE USE YOUR PERSONAL DATA
- WHO WE SHARE YOUR PERSONAL DATA WITH
- INTERNATIONAL TRANSFERS
- DATA SECURITY
- DATA RETENTION
- YOUR LEGAL RIGHTS
- CHANGES TO THIS NOTICE
- QUERIES, REQUESTS OR CONCERNS
- WHO WE ARE AND IMPORTANT INFORMATION
What is the purpose of this privacy notice?
This privacy notice aims to provide you with information on how we collect and process your personal data through your use of our website, including any data you may provide through this website when you for example, signing up to newsletters or competitions.
This website is not intended for children, and we do not knowingly collect data relating to children.
You must read this privacy notice together with any other privacy notice we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. This privacy notice supplements the other notices and is not intended to override them.
Changes to this privacy notice
We may change this privacy notice from time to time by updating our website in order to reflect changes in the law and /or our privacy practices. We encourage you to check this privacy notice for changes whenever you visit our website.
Pinkfishes Ltd is the controller and responsible for your personal data. Our contact details are
Pinkfishes Ltd, Units 6 & 8 The Bringey, Church Street, Great Baddow, CM2 7JW, email@example.com, 01277 203629. For all data matters please contact Tina Bulley at the above.
Pinkfishes Ltd is the controller and is responsible for this website.
Third-party links outside of our control
This website 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 date about you. We do not control these third-party websites and are not responsible for their privacy statements.
When you leave our website, we encourage you to read the privacy notice of every website you visit.
- The Personal Data We Collect About You
Personal data, or personal information, means any information about an individual from which that person can be identified. You can find out more about personal data from the Information Commissioners Office (http://ico.org.uk/global/contact-us).
Identity Data includes first name/last name/username.
Contact Data Includes home address/delivery address/email address/telephone numbers).
Financial Data includes payment card details.
Transactions Data includes details regarding payments to us and other details of products and services you have purchased from us.
Technical Data includes IP address/your login data/browser type and version/location/operating system and platform/other technology on the devices you use to access this website.
Usage Data includes information about how you use our website, products and services.
Marketing and Communications Data
Includes your preferences in receiving marketing from us and our third parties/your communications preferences.
If you fail to provide personal data
Where we need to collect your 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 goods or services). In this case, we may have to cancel a product or service you have with us, but we well notify you if this is the case at the relevant time.
HOW WE COLLECT YOUR PERSONAL DATA
We use different methods to collect data from and about you are including through:
Directly – You may provide us with your (identity/contact) by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:
Apply for our products or services:
Subscribe to our service or publications:
Request marketing to be sent to you.
- 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.
Performance of Contract; this means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such contract.
Legitimate Interest; this means the interest of our business in conducting and managing our business to enable us to give you the best service/product and the most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests.
We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting Tina Bulley on 01277 203629.
Comply with a legal or regulatory obligation; this means processing your personal data where it is necessary for compliance with a legal or regulatory obligation that we are subject to.
Generally, we do not rely on consent as a legal basis for processing your personal data other than in relation to sending third party direct marketing communication to you via email or text message.
You have the right to withdraw consent to marketing at any time by contacting us (Tina Bulley on either firstname.lastname@example.org or phone 01277 203629).
PURPOSES FOR WHICH WE WILL USE YOUR PERSONAL DATA
We have set out below, in a table format, a description for all the ways we plan to use your personal data, with the legal bases we rely on to do so.
Please 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 Tina Bulley if you require details/information 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
To register you identify (a) Performance of a contact
As a new client with you.
To process and deliver our Identify (a) (a) performance of a contract with
Service including: you (b) Necessary for our legitimate
Confirmation email (a) Financial (c)
Manage payments Transaction (d)
Aggregated data (e)
To manage our relationship, identify (a) (a) Performance of a contract with
With you which will include you (b) Necessary to comply with a
Notifying you about (a) legal obligation (c) Necessary for
Changes to our terms or contact (b) our legitimate interests (to keep
You to leave a review or study how customers use our
Take a survey products/services)
To administer and protect Identify (a) Necessary for our legitimate (a)
Our business and this website interests (for running our business,
(including troubleshooting, provisions of administration and IT
Date, analysis, testing, system contract (b) services, network security, to
Maintenance, support, prevent fraud and in the context of
Reporting and hosting of data) Technical (c) business reorganisation or group
Restructuring exercise) (b)
Necessary to comply with a legal
To deliver relevant website identity (a) Necessary for our legitimate
Content and advertisements interests (to study how customers
To you and measure or contact (b) use our products/services, to
Understand the effectiveness develop them, to grow our
Of the advertising we serve to you profile (c) business and to inform our
To use date analytics to Technical (a) Necessary for our legitimate
Improve our website, interests (to define types of
Products/services, Usage (b) customers for our products
Marketing, customer and services, to keep our website
Relationships and updated and relevant, to develop
Experiences our business and to inform our
To make suggestions and identity (a) Necessary for our legitimate
Recommendations to you interests (to develop our
About goods or services that contact (b) products/services and grow our
May be of interest to you. business)
We strive to provide you with choices regarding certain personal date uses, particularly around marketing and advertising.
Third Party Marketing
We will obtain your express opt-in consent before we share your personal data with any company outside the Pinkfishes Ltd, Company for marketing purposes.
You can request us or third parties to stop sending you marketing messages at any time by following the opt-out links on any marketing message sent to you or by contacting us at email@example.com
Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of product/service purchase, warranty registration, and product or service experience or other transactions.
We may also gather information about your general internet use by using a cookie file. Where used, these cookies are downloaded to your computer automatically. This cookie file is stored on the hard drive of your computer, as cookies contain information that is transferred to your computers hard drive. They help us to improve our Website and the service that we provide to you.
Change of Purpose
We will only use personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to obtain an explanation as to how processing for the new purpose is compatible with the original purpose, please contact Tina Bulley.
Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.
WHO WE SHARE YOUR PERSONAL DATA WITH
We may have to share your personal data with the parties set out below for the purposes set out in the table in paragraph 4 above
External Third Parties Service
Providers STARTPOINT based in the UK who provides IT AND SYSTEM ADMINISTRATION SERVICES
Providers CLIMBING TREES BASED in UK who provides IT AND SYSTEM ADMINISTRATIONS SERVICES
Professional advisers (acting as processors) including lawyers, bankers, auditors and insurers based in the United Kingdom who provide consultancy, banking, legal, insurance and accounting services.
HM Revenue & Customs, regulators and other authorities (acting as processors) based in the United Kingdom who require reporting of processing activities in certain circumstances.
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 such 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 notice.
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.
For the purpose of meeting the requirements of our contract with you, we may transfer your Personal Data outside of the EU. In order to secure your data, we put in place measures and terms of business with such third parties to ensure they treat your Personal Data in a manner consistent with how we expect those within the EU and ourselves to respect data protection legislation.
We are permitted to transfer your Personal Data outside the EEA. In such situations you can expect a broadly similar level of security and protection in regard of that Personal Data as you can expect under UK and EU Law.
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 only permit third parties to process your Personal Data as long as they agree to keep that data both secure and confidential.
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.
We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting or reporting requirements.
To determine the appropriate retention period for personal date, 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 purpose for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.
By law we have to keep basic information about our customers including contact details, financial and transaction data for six years after they cease being customers for tax purposes.
In some circumstances you can ask us to delete your data see your legal rights below for further information.
YOUR LEGAL RIGHTS
Unless subject to an exemption under the data protection laws, you have the following rights with respect to your personal data:
The rights to request a copy of the personal data which we hold about you.
The right to request that we correct any personal data if it is found to be inaccurate or out of date.
The right to request your personal data is erased where it is no longer necessary to retain such data.
The right to withdraw your consent to the processing at any time, where consent was the lawful basis for processing your data.
The right to request that we provide you with your personal data and where possible, to transmit that data directly to another data controller, (known as the right to data portability), where applicable i.e. where our processing is based on consent or is necessary for the performance of our contract with you or where we process your data by automated means.
The right, where there is a dispute in relation to the accuracy of processing of your personal date, to request a restriction is placed on further processing.
The right to object to our processing of personal data, where applicable i.e. where processing is based on our legitimate interests (or in performance of a task in the public interest/exercise of official authority) direct marketing or processing for the purposes of scientific/historical research and statistics.
If you wish to exercise any of the rights set out above, please contact Tina Bulley, Director of Pinkfishes Ltd to access your rights.
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 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 may 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
CHANGES TO THIS NOTICE AND YOUR DUTY TO INFORM US OF CHANGES
From 25th May 2018 there will be changes in data protection laws and we will then be able to respond to some of your requests (for example, a request for the transfer of your personal data).
Please keep us informed if your personal data changes during your relationship with us. It is important that the personal data we hold about you is accurate and current.
QUERIES, REQUESTS OR CONCERNS
To exercise all relevant rights, queries or complaints in relation to this policy or any other data protection matter between you and ourselves, please in the first instance contact Tina Bulley 01277 203629.
If this does not resolve your complaint to your satisfaction you have the right to lodge a complaint with the information Commissioners Office, details will be supplied by pinkfishes.com.