PRIVACY POLICY

We take your privacy very seriously. Please read this privacy policy carefully as it contains important information on who we are and how and why we collect, store, use and share your personal data. It also explains your rights in relation to your personal data and how to contact us or supervisory authorities in the event you have a complaint.

We collect, use and are responsible for certain personal data about you. When we do so we are subject to the UK General Data Protection Regulation (UK GDPR).

Key terms

It would be helpful to start by explaining some key terms used in this policy:

We, us, our

Pro2col Limited

Our data protection officer

Richard Auger

Personal data

Any information relating to an identified or identifiable individual

Special category personal data

Personal data revealing racial or ethnic origin, political opinions, religious beliefs, philosophical beliefs or trade union membership

Genetic and biometric data (when processed to uniquely identify an individual)

Data concerning health, sex life or sexual orientation

Data subject

The individual who the personal data relates to

Personal data we collect about you

We may collect and use the following personal data about you:

  • your name, job title and contact information, including email address and telephone number and company details
  • location data
  • your billing information and transaction records , but we do not collect or use payment card information
  • your professional online presence
  • information to enable us to undertake credit or other financial checks on you
  • Information about how you use our website, IT, communication and other systems
  • your responses to surveys, competitions and promotions
  • cookies data
  • software licence details including how the software is set up and used (not including passwords)
  • technical data including internet protocol address, your log in data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access our website

We collect and use this personal data to provide products and services to you. If you do not provide personal data we ask for, it may delay or prevent us from providing products and services to you.

How your personal data is collected

We collect most of this personal data directly from you—in person, by telephone, text or email and/or via our website. However, we may also collect information:

  • directly from a third party, e.g.:
    • credit reference agencies;
    • customer due diligence providers;
  • from cookies on our website - for more information on our use of cookies, please see our cookie policy below
  • via our IT systems, e.g.:
    • ;
    • through automated monitoring of our websites and other technical systems, such as our computer networks and connections, access control systems, communications systems, email and instant messaging systems;

How and why we use your personal data

Under data protection law, we can only use your personal data if we have a proper reason, eg:

  • where you have given consent;
  • to comply with our legal and regulatory obligations;
  • for the performance of a contract with you or to take steps at your request before entering into a contract; or
  • for our legitimate interests or those of a third party.

A legitimate interest is when we have a business or commercial reason to use your information, so long as this is not overridden by your own rights and interests. We will carry out an assessment when relying on legitimate interests, to balance our interests against your own.

The table below explains what we use your personal data for and why.

 

What we use your personal data for

Our reasons

Providing products and services to you

To perform our contract with you or to take steps at your request before entering into a contract

Preventing and detecting fraud against you or us

For our legitimate interests or those of a third party, ie to minimise fraud that could be damaging for you and/or us

Screening for financial and other sanctions or embargoes

Other activities necessary to comply with professional, legal and regulatory obligations that apply to our business, eg under health and safety law or rules issued by our professional regulator

To comply with our legal and regulatory obligations

Gathering and providing information required by or relating to audits, enquiries or investigations by regulatory bodies

To comply with our legal and regulatory obligations

Ensuring business policies are adhered to, eg policies covering security and internet use

For our legitimate interests or those of a third party, ie to make sure we are following our own internal procedures so we can deliver the best service to you

Operational reasons, such as improving efficiency, training and quality control

For our legitimate interests or those of a third party, ie to be as efficient as we can so we can deliver the best service to you at the best price

Ensuring the confidentiality of commercially sensitive information

For our legitimate interests or those of a third party, ie to protect trade secrets and other commercially valuable information

To comply with our legal and regulatory obligations

Statistical analysis to help us manage our business, e.g. in relation to our financial performance, customer base, product range or other efficiency measures

For our legitimate interests or those of a third party, ie to be as efficient as we can so we can deliver the best service to you at the best price

Preventing unauthorised access and modifications to systems

For our legitimate interests or those of a third party, ie to prevent and detect criminal activity that could be damaging for you and/or us

To comply with our legal and regulatory obligations

Updating and enhancing customer records

To perform our contract with you or to take steps at your request before entering into a contract

To comply with our legal and regulatory obligations

For our legitimate interests or those of a third party, eg making sure that we can keep in touch with our customers about existing orders and new products

Statutory returns

To comply with our legal and regulatory obligations

Ensuring safe working practices, staff administration and assessments

To comply with our legal and regulatory obligations

For our legitimate interests or those of a third party, e.g. to make sure we are following our own internal procedures and working efficiently so we can deliver the best service to you

Marketing our services and those of selected third parties to:

—existing and former customers;

—third parties who have previously expressed an interest in our services;

—third parties with whom we have had no previous dealings.

For our legitimate interests or those of a third party, i.e. to promote our business to existing and former customers

Credit reference checks via external credit reference agencies

For our legitimate interests or those of a third party, i.e. to ensure our customers are likely to be able to pay for our products and services

External audits and quality checks, e.g. for ISO9001 and ISO27001 accreditation and the audit of our accounts

For our legitimate interests or a those of a third party, i.e. to maintain our accreditations so we can demonstrate we operate at the highest standards

To comply with our legal and regulatory obligations

 

Special Category Personal Data

We do not process special category personal data.

Marketing

We may use your personal data to send you updates (by email or telephone) about our products and services, including exclusive offers, promotions or new products and services.

We have a legitimate interest in using your personal data for marketing purposes (see above ‘How and why we use your personal data’). This means we do not usually need your consent to send you marketing information. However, where consent is needed, we will ask for this separately and clearly.

You have the right to opt out of receiving marketing communications at any time by contacting us at info@pro2colgroup.com

  • using the ‘unsubscribe’ link in emails or
  • updating your marketing preferences by contacting us.

We may ask you to confirm or update your marketing preferences if you ask us to provide further products and services in the future, or if there are changes in the law, regulation, or the structure of our business. Who we share your personal data with

We routinely share personal data with:

  • third parties we use to help deliver our products and services to you, e.g. vendors, strategic partners, resellers, payment service providers;
  • other third parties we use to help us run our business, e.g. marketing agencies or website hosts;
  • third parties approved by you, e.g. social media sites you choose to link your account to or third party payment providers;
  • credit reference agencies;
  • our insurers and brokers

We only allow our service providers to handle your personal data if we are satisfied they take appropriate measures to protect your personal data. We also impose contractual obligations on service providers to ensure they can only use your personal data to provide services to us and to you.

We may also need to:

  • share personal data with external auditors, e.g. in relation to ISO accreditation and the audit of our accounts;
  • disclose and exchange information with law enforcement agencies and regulatory bodies to comply with our legal and regulatory obligations;
  • share some personal data with other parties, such as potential buyers of some or all of our business or during a restructuring—usually, information will be anonymised but this may not always be possible, however, the recipient of the information will be bound by confidentiality obligations.

If you would like more information about who we share our data with and why, please contact us (see ‘How to contact us’ below).

We will not share your personal data with any other third party.

Where your personal data is held

Personal data may be held at our offices and those of our third party agencies, service providers (including cloud based service providers), representatives and agents as described above (see above: ‘Who we share your personal data with’).

Some of these third parties may be based outside the UK. For more information, including on how we safeguard your personal data when this happens, see below: ‘Transferring your personal data out of the UK’.

How long your personal data will be kept

We will keep your personal data while you have an account with us or we are providing products and services to you. Thereafter, we will keep your personal data for as long as is necessary:

  • to respond to any questions, complaints or claims made by you or on your behalf;
  • to show that we treated you fairly;
  • to keep records required by law.

We will not keep your personal data for longer than necessary. Different retention periods apply for different types of personal data.

When it is no longer necessary to keep your personal data, we will delete or anonymise it.

Transferring your personal data out of the UK

To deliver services to you, it is sometimes necessary for us to share your personal data outside the UK, e.g.:

  • with your and our service providers located outside the UK;
  • if you are based outside the UK;
  • where there is a European and/or international dimension to the services we are providing to you.

Under data protection law, we can only transfer your personal data to a country or international organisation outside the UK where:

  • the UK government has decided the particular country or international organisation ensures an adequate level of protection of personal data (known as an ‘adequacy decision’);
  • there are appropriate safeguards in place, together with enforceable rights and effective legal remedies for data subjects; or
  • a specific exception applies under data protection law

These are explained below.

Adequacy decision

We may transfer your personal data to certain countries, on the basis of an adequacy decision. These include:

  • all European Union countries, plus Iceland, Liechtenstein and Norway (collectively known as the ‘EEA’);Gibraltar; and
  • Andorra, Argentina, Canada, Faroe Islands, Guernsey, Israel, Isle of Man, Japan, Jersey, New Zealand, Switzerland and Uruguay.

The list of countries that benefit from adequacy decisions will change from time to time. We will always seek to rely on an adequacy decision, where one exists.

Other countries or international organisations we are likely to transfer personal data to do not have the benefit of an adequacy decision. This does not necessarily mean they provide poor protection for personal data, but we must look at alternative grounds for transferring the personal data, such as ensuring appropriate safeguards are in place or relying on an exception, as explained below.

Transfers with appropriate safeguards

Where there is no adequacy decision, we may transfer your personal data to another country or international organisation if we are satisfied the transfer complies with data protection law, appropriate safeguards are in place, and enforceable rights and effective legal remedies are available for data subjects.

The safeguards will usually include using legally-approved standard data protection contract clauses.

To obtain a copy of the standard data protection contract clauses and further information about relevant safeguards, please contact us (see ‘How to contact us’ below).

Transfers under an exception

In the absence of an adequacy decision or appropriate safeguards, we may transfer personal data to a third country or international organisation where an exception applies under relevant data protection law, e.g.:

  • you have explicitly consented to the proposed transfer after having been informed of the possible risks;
  • the transfer is necessary for the performance of a contract between us or to take pre-contract measures at your request;
  • the transfer is necessary for a contract in your interests, between us and another person; or
  • the transfer is necessary to establish, exercise or defend legal claims

We may also transfer information for the purpose of our compelling legitimate interests, so long as those interests are not overridden by your interests, rights and freedoms. Specific conditions apply to such transfers and we will provide relevant information if and when we seek to transfer your personal data on this ground.

Further information

If you would like further information about data transferred outside the UK, please contact our Data Protection Officer (see ‘How to contact us’ below).

Your rights

You have the following rights, which you can exercise free of charge:

Access

The right to be provided with a copy of your personal data

Rectification

The right to require us to correct any mistakes in your personal data

Erasure (also known as the right to be forgotten)

The right to require us to delete your personal data—in certain situations

Restriction of processing

The right to require us to restrict processing of your personal data in certain circumstances, eg if you contest the accuracy of the data

Data portability

The right to receive the personal data you provided to us, in a structured, commonly used and machine-readable format and/or transmit that data to a third party—in certain situations

To object

The right to object:

—at any time to your personal data being processed for direct marketing (including profiling);

—in certain other situations to our continued processing of your personal data, eg processing carried out for the purpose of our legitimate interests.

Not to be subject to automated individual decision making

The right not to be subject to a decision based solely on automated processing (including profiling) that produces legal effects concerning you or similarly significantly affects you

For further information on each of those rights, including the circumstances in which they apply, please contact us (see ‘How to contact us’ below) or see the Guidance from the UK Information Commissioner’s Office (ICO) on individuals’ rights.

If you would like to exercise any of those rights, please:

  • email, call or write to us—see below: ‘How to contact us’; and
  • provide enough information to identify yourself (e.g. your full name, address and customer or matter reference number) and any additional identity information we may reasonably request from you;
  • let us know what right you want to exercise and the information to which your request relates.

Keeping your personal data secure

We have appropriate security measures to prevent personal data from being accidentally lost, or used or accessed unlawfully. We limit access to your personal data to those who have a genuine business need to access it. Those processing your information will do so only in an authorised manner and are subject to a duty of confidentiality. We continually test our systems and are ISO 27001 certified, which means we follow top industry standards for information security.

We also have procedures in place to deal with any suspected data security breach. We will notify you and any applicable regulator of a suspected data security breach where we are legally required to do so.

If you want detailed information from Get Safe Online on how to protect your information and your computers and devices against fraud, identity theft, viruses and many other online problems, please visit www.getsafeonline.org. Get Safe Online is supported by HM Government and leading businesses.

Cookies

Cookies are small files that a site or its service provider transfers to your computer’s hard drive through your Web browser (if you allow) that enables the Website’s or a service provider’s system to recognise your browser and capture and remember certain information. They are also used to help us understand your preferences based on previous or current site activity, which enables us to provide you with improved services and to enable us to understand the use of our Website better. We also use cookies to help us compile aggregate data about site traffic and site interaction so that we can offer better site experiences and tools in the future. This help us to ensure that our Website is up to date and relevant to your interests and needs.

A cookie in no way gives us access to your computer or any information about you, other than the data you choose to share with us. You can choose 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. This may prevent you from taking full advantage of the Website.

Types of cookies we use;

Traffic Log Cookies

Analytics Cookies

Social Media Cookies

Shopping cart functionality

Advertisement performance assessment and conversion tracking

Remarketing advertising

IP Tracking

All Cookies used by and on our Website are used in accordance with current English and EU Cookie Law.

How to complain

Please contact us if you have any query or concern about our use of your information (see below ‘How to contact us’). We hope we will be able to resolve any issues you may have.

You also have the right to lodge a complaint with the Information Commissioner . The Information Commissioner may be contacted at https://ico.org.uk/make-a-complaint or telephone: 0303 123 1113.

Changes to this privacy policy

This privacy notice was published on 3rd May 2018and last updated on 1st November 2018

We may change this privacy notice from time to time - when we do we will inform you via website and email.

How to contact us

Individuals in the UK

You can contact us and/or our Data Protection Officer by post, email or telephone if you have any questions about this privacy policy or the information we hold about you, to exercise a right under data protection law or to make a complaint.

Our contact details are shown below:

Our contact details

Richard Auger

Pro2col Limited, Devonshire Suite, Saxon Centre, Christchurch, Bournemouth, BH23 1PZ

info@pro2colgroup.com

0207 118 9640

Devonshire Suite Saxon Centre, Christchurch, Bournemouth, BH23 1PZ

support@pro2colgroup.com

0333 123 1240