You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK supervisory authority 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 by emailing us at firstname.lastname@example.org.
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.
Who are we?
Here are the details that the Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regards to the processing of personal data and on the free movement of such data, known as General Data Protection Regulation (GDPR) says we have to give you as a ‘data controller’:
- Our Website address is www.pro2col.com
- Our company name is Pro2Col Ltd
- Our registered address 8 Spur Road, Cosham, Portsmouth, PO6 3EB
- Our nominated representative is Richard Auger and they can be contacted at email@example.com
We take a proactive approach to user privacy and ensure the necessary steps are taken to protect the privacy of its users throughout their visiting experience.
When you use or contact our Website, you do so at your own discretion and provide any such personal details requested at your own risk. Your personal information is kept private and stored securely until a time it is no longer required or has no use, as detailed below. Every effort has been made to ensure a safe and secure form to email submission process but we advise users using such form to email processes that you do so at your own risk.
As the party responsible for data processing we ensure that the processed data:
- is processed in accordance with the applicable Data Protection Legislation; and
is sufficiently protected to not be exposed to persons who should have no access to it, this both internally and externally by taking technical, contractual and organisational safety measures.
What information Pro2col collects and stores?
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 the following data:
- Name, Job Title
- Contact information, including email address and telephone number
- Company name, location
- Demographic information, such as postcode, preferences and interests
- Other information relevant to customer surveys, training programs and/or promotional offers
- Software licence details
- Payment information via third party payment providers who are PCI compliant.
- How the software is set up and used (diagrammatic, not including passwords)
- Cookies data
- Technical Data includes internet protocol (IP) address, your login 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 this Website.
- Transactional data includes details about payments excluding credit card information and other details of products and services you have purchased from us.
We do not 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.
Why do we keep this information?
Under GDPR we will ensure that your personal data is processed lawfully, fairly, and transparently, without adversely affecting your rights. We will only process Your personal data if at least one of the following basis applies:
a) You have given consent to the processing of your personal data for one or more specific purposes;
b) processing is necessary for the performance of a contract to which you are a party or in order to take steps at the request of you prior to entering into a contract;
c) processing is necessary for compliance with a legal obligation to which we are subject;
d) processing is necessary to protect the vital interests of you or of another natural person
e) processing is necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in the controller; and/or
f) processing is necessary for the purposes of the legitimate interests pursued by us or by a third party such as our financial partners, or to our suppliers etc, except where such interests are overridden by the fundamental rights and freedoms of the data subject, in particular where the data subject is a child.
In some instances, it may be appropriate for us to combine your information with other information that we may be holding about you, such as combining your name with your geographic location or your browsing or purchasing history.
We (or third party data processors, agents and sub-contractors acting on our behalf) may collect, store and use your personal information by way of different methods to collect data from and about you including through:
Direct interactions. You may give us your information by filling in forms via our Website or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:
- present site content;
- express an interest in our Services;
- subscribe to our Services or publications;
- attend training sessions;
- make any purchases of our products or services;
- request marketing to be sent to you;
- give us some feedback.
In addition to the above, we may use the information in the following ways:
- to understand your needs and provide a better service;
- to improve our products and services;
- to notify you of support expiry dates and product security and feature updates;
- Internal sales record keeping;
- to send to you periodic e-mails, containing industry knowledge and news, technology updates and promotional information regarding our services, new products, training courses, events or market research. If you would no longer like to receive promotional e-mail from us, please refer to the “How can you opt-out, remove or modify information you have provided to us?” section below.
Automated technologies or interactions. As you interact with our Website, we may 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.
Third parties or publicly available sources. We shall contract with third parties to supply our Services to you on our behalf. These include our partners, search engine facilities, advertising and marketing. In some cases, the third parties may require access to some or all of your data. Where any of your data is required for such a purpose, we will take all reasonable steps to ensure that your data will be handled safely, securely, and in accordance with your rights, our obligations, and the obligations of the third party under 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.
Where vendor software evaluations have been requested, we will share your personal information with said vendor in order to set up your trial licence with the vendor.
We may keep a record of those links which are used the most to enable us to provide the most helpful information but we agree to keep such information confidential and you will not be identified from this information.
Ecommerce / Online payments
We use a third party provider to collect financial data and all credit card information goes through our Website, currently encrypted in the e-commerce industry using a secure PCI compliant payment gateway. On completion of a successful payment your purchase will be processed immediately. Should you have any problems with your delivery please contact firstname.lastname@example.org with URGENT in the subject line and one of our support team will be notified immediately. We do not store your credit card details.
How do we use your 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 or regulatory obligation
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 communications to you via email or text message. You have the right to withdraw consent to marketing at any time by contacting us at email@example.com and we will delete your data from our systems. However, you acknowledge this will limit our ability to provide the best possible services to you.
As already indicated above, with your permission and/or where permitted by law, we may also use your data for marketing purposes which may include contacting you by email AND/OR telephone with information, news and offers on our Services. We will not, however, send you any unsolicited marketing or spam and will take all reasonable steps to ensure that we fully protect your rights and comply with our obligations under the Data Protection Legislation and the Privacy and Electronic Communications (EC Directive) Regulations 2003, as amended in 2004, 2011 and 2015.
How do we store your data and security
We only keep your data for as long as we need to in order to use it, and/or for as long as we have your permission to keep it. In any event, we will conduct an annual review to ascertain whether we need to keep your data. Your data will be deleted if we no longer need it.
Where we use providers based in the US, we may transfer data to them if they are part of the Privacy Shield which requires them to provide similar protection to personal data shared between the Europe and the US. For further details, see the European Commission: EU-US Privacy Shield.
Data security is of great importance to us, and to protect your data we have put in place suitable physical, electronic and managerial procedures to safeguard and secure data collected through the normal course of our business with you, via our Website and through any other form of correspondence with us, such as in person at events, business meetings etc or by email or phone. 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.
By giving us your personal data, you agree to this arrangement. We will do what we reasonably can to keep your data secure.
Data security is of great importance to us, and to protect your data we have put in place suitable physical, electronic and managerial procedures to safeguard and secure any data collected through our Website.
Notwithstanding the security measures that we take, it is important to remember that the transmission of data via the internet may not be completely secure and that you are advised to take suitable precautions when transmitting to us data via the internet and you take the risk that any sending of that data turns out to be not secure despite our efforts.
If we give you a password upon registration on our Website, you must keep it confidential. Please don’t share it.
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.
Children under the age of 18
Our Website, content and services are not intended for persons under 18 years of age. We do not knowingly collect personal information from persons under 18. If we learn we have received personal information from a person under 18, we will delete that information immediately.
Do we disclose the information we collect to outside parties?
We do not sell, trade, or otherwise transfer to outside parties your personally identifiable information unless we provide you with advance notice. The term “outside parties” does not include Pro2col Ltd. It also does not include our website hosting partners, subcontractors and other third parties who assist us in operating our website, conducting our business, or servicing you, so long as those parties agree to keep this information confidential. We may also release your information when we believe release is appropriate to comply with the law, enforce our site policies, or protect ours or others’ rights, property, or safety.
We contract with third parties to supply services to you on our behalf. These may include our partners, search engine facilities, advertising and marketing. In some cases, the third parties may require access to some or all of your data. Where any of your data is required for such a purpose, we will take all reasonable steps to ensure that your data will be handled safely, securely, and in accordance with your rights, our obligations, and the obligations of the third party under the law.
However, non-personally identifiable visitor information may be provided to other parties for marketing, advertising, or other uses.
We are also allowed to disclose your information in the following cases:
- If we want to sell our business, or our company, we can disclose it to the potential buyer
- We can disclose it to other businesses in our group
- We can disclose it if we have a legal obligation to do so, or in order to protect other people’s property, safety or rights
We can exchange information with others to protect against fraud or credit risks.
Our company is registered in England and Wales, but we also provide our Services to other countries within the European Union, you also agree that we may disclose your personal data to other persons if this is required by law or where a legitimate interest is served.
Where any of your data is required for such a purpose, we will take all reasonable steps to ensure that your data will be handled safely, securely, and in accordance with your rights, our obligations, and the obligations of the third party under the Data Protection Legislation and the law.
Change of Purpose
We will only use your 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 get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.
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.
We aim to give you strong controls on our use of your data (including the ability to opt-out of receiving emails from us which you may do by unsubscribing at any point.
Under the GDPR, You have the right to:
- request access to, deletion of or correction of, your personal data held by us at no cost to you;
- request that your personal data be transferred to another person (data portability);
- be informed of what data processing is taking place;
- restrict processing;
- to object to processing of your personal data; and
- complain to a supervisory authority.
Request for Data Held
We are happy to provide an electronic copy of the data held in our systems and how it is used for a specific person. This can be requested by emailing firstname.lastname@example.org or by writing to Pro2col Ltd, 144 Tuckton Road, Bournemouth, BH8 0DS. We will process and respond to your request within 30 days and this service is free of charge.
Request to Object
Users can unsubscribe via the footer provided in individual electronic communications or they can contact us directly. If you receive a telephone call from us, you have the right to request not to receive any further calls. Your details will be added to a suppression file to ensure that your details are removed from all marketing lists in the future. Please note that this will only apply to your personally identifiable data, not that of the business data.
Request to Rectify
Users can change their preferences – contact details or the products you would like to receive information on by contacting us directly.
If you believe that any information we are holding on you is incorrect or incomplete, please email email@example.com or write to Pro2col Ltd, 144 Tuckton Road, Bournemouth, BH6 3JX as soon as possible and we will promptly correct any information found to be incorrect.
Request for Deletion
If you make a request for deletion, we will remove any data we hold about you from the Pro2col CRM system. This will also mean that we will remove you from our suppression files. If you are removed from our suppression files, there is a risk that your data may be processed again in the future if your details are re-added to our CRM system by a member of our sales team who genuinely believes that your business would benefit from our services. If you do not wish for us to contact you again, we would recommend you request to object rather than a request for deletion, as this will ensure that your details are always suppressed from processing. This can be requested by emailing firstname.lastname@example.org or by writing to Pro2col Ltd, 144 Tuckton Road, Bournemouth, BH6 3JX. We will process and respond to your request within 30 days and this service is free of charge.
Where there is information held on software sold by us, the personal details of the contact involved can be erased, but the company owned licence details will remain in our system. Where software licences are associated to a specific contact, you have the right to change the contact details and delete the original ones. We reserve the right to charge for changes to licence details and do recommend a company email address is used for licences such as email@example.com
Automated Decision Making and Profiling
In the event that we use personal data for the purposes of automated decision-making and those decisions have a legal (or similarly significant effect) on you, you have the right to challenge to such decisions under GDPR, requesting human intervention, expressing their own point of view, and obtaining an explanation of the decision from us.
We will not sell, distribute or lease your personal information to third parties unless we have your permission or are required by law to do so.
Changes to Policy