Privacy Policy
At PIMS Associates Limited we provide Management consultancy services such as strategic benchmarking and customer value as well as operational excellence benchmarking for specific industries and transformation and change managment (“Services”). We are committed to protecting the privacy of our clients and users of our websites and apps. We want to provide a safe and secure service where we deal with your personal data.
This Privacy Notice sets out how we process your personal data in connection with the provision of our Services, including any Services offered through our websites (“Sites”). This Privacy Notice also sets out your rights in respect of our processing of your personal data.
This Privacy Notice is intended to assist you in making informed decisions when using our Services and our Sites. Please take a moment to read and understand it. It should be read in conjunction with our Cookie Notice.
Please note that your access to and use of our Services and our Sites (including any secure area) is subject at all times to separate terms and conditions. If you are one of our clients, we will have a separate written agreement with you governing our provision of the Services. If you are simply browsing our Sites, there may be separate terms and conditions of use applicable to the relevant Site.
We will update this Privacy Notice from time to time to reflect any changes or proposed changes to our use of your personal data, or to comply with changes in applicable law or regulatory requirements. We may notify you by email of any significant changes to this Privacy Notice, but we encourage you to review this Privacy Notice periodically to keep up to date on how we use your personal data.
Our Services and our Sites are made available by PIMS Associates Limited (“PIMS”, “we”, “us, “our”). PIMS is the data controller responsible for your personal data. PIMS is an English company (No: 02429278) with its registered office at First Floor, Winston House, 349 Regents Park Road, London, United Kingdom, N3 1DH. We are registered with the Information Commissioner’s Office under registration number [02429278].
If you have any questions about this Privacy Notice or want to exercise Your_Rights_as_a_Data_Subject set out in this Privacy Notice, you can contact us using the following methods:
On Site
Contact us using our Enquiry Form.
Send us an email at: info@pims.ai.
Post
Write to us at:
Michelin House, 81 Fulham Road, London SW3 6RD UK
Telephone
Call us on: +44 203 161 4000.
In providing our Services and our Sites, we may collect and process different types of personal data about you for different processing purposes. When we talk about “personal data”, we mean any information which relates to an identified or identifiable living individual. Individuals might be identified by reference to a name, an identification number, location data, an online identifier (such as an IP address) or to other factors that are specific to them, such as their physical appearance. The types of personal data we collect depends on who you are and how you use our Services and our Sites and includes the following:
Identity Data
First name; last name.
Contact Data
Home address; billing and/or delivery address; email address; telephone number.
Account Data
Account username; password; job title; first name; last name; date of birth; gender; country; nationality; whether you have participated in any survey or questionnaire responses and feedback; survey responses, participation in any promotions or competitions.
Transaction Data
Bank account details; partial payment card details and details about payments made between you and us.
Observed Data
Data that is observed about your use of our Site and App or interaction with our emails and/or data that we infer through your use of our Site, our App and our Products and Services. This data may include: details of when your current or previous sessions started; the referrer URL (web page that you were on when you clicked a link that sent you to our Site); information about the pages of our Site and App that you have visited and any Products and Services that you have purchased or shown an interest in.
Technical Data
IP address; browser type and operating system; general geolocation derived from your IP address, to ensure we’re showing you the correct notices and information; any other unique numbers assigned to a device.
Job Applicant Data
Date of birth; gender; country; nationality; CVS; work experience; dietary requirements; any other personal data you may provide in advance of/during your supply of services to us.
Communications Data
Marketing communication preferences; service communication preferences.
We collect and receive personal data using different methods:
Personal data you provide to us
You may give us your personal data directly, for example, when you provide your Contact Data as part of a survey, purchase services via our Site, contact us with enquiries, complete forms on our Site, subscribe to receive our marketing communications or provide feedback to us.
Personal data we collect using cookies and similar technologies
When you access and use our Site, we will collect certain Observed Data and Technical Data. We collect this personal data by using cookies and other similar technologies (see the Insight and Analysis section for more information).
Personal data received from third parties
We may receive personal data about you from third parties. Such third parties may include our clients, analytics providers, data brokers and third party directories.
Publicly available personal data
From time to time, we may collect personal data about you (Identity Data and Contact Data) that is contained in publicly available sources (including open source data sets or media reports) or that you or a third party may otherwise make publicly available (for example through speeches at events or publishing articles or other news stories or posts on social media platforms).
We use your personal data for the purposes set out in this section. If we wish to make any changes to these purposes, or if we wish to use your personal data for any purpose that is not listed in this section, we will notify you using the contact details we hold for you.
It is in our legitimate interest to use personal data in such a way to ensure that we provide access to our Sites in a secure and effective way and so that we can make improvements to our Sites or it is necessary for us to use your personal data to perform our obligations in accordance with any contract that we may have with you for the Services.
We collect and process personal data from the following people:
Site visitors
If you browse our Site or register an account on our Site, we will collect and process your personal data in connection with your interaction with us and our Site.
People who contact us with enquiries
If you contact us with an enquiry through our Site, submit a complaint through our Site or provide any feedback, we will collect and process your personal data in connection with your interaction with us and our Site.
Clients
If you purchase our Services, we may collect and process your personal data in connection with the supply of our Services to you.
People who work for our clients and suppliers
If you work for one of our clients or suppliers and have responsibility for placing orders with us, administering your organisation’s account with us or handling our orders or our account with your organisation, we will process your personal data in connection with your organisation’s relationship with us.
Visitors to our physical locations
If you attend one of our offices or other locations, we may process personal data that you volunteer in connection with your visit and any enquiries you make. For example, you may volunteer personal data when asking us to assist you in finding accommodation or transportation suitable for your needs, or when signing in as a guest. CCTV footage may also be collected for security purposes.
Event attendees
If you attend one of our events, we will process personal data about you in connection with your attendance at the event. For example, we may ask you to complete a registration or feedback form, a dietary requirements form or other document relating to the event.
Job applicants
If you apply for a job with us, whether through the Site or otherwise, we will collect and process your personal data in connection with your application.
If you browse our Sites
When you browse our Sites, we collect and process Observed Data and Technical Data to help us understand how you are using and navigating our Sites. We do this so that we can better understand which parts of our Sites are more or less popular and improve the structure and navigation of our Sites.
Our legal basis for processing
If you use the interactive features on our Sites
We will collect and use personal data about you when you use certain interactive features on our Sites. For example, depending on the nature of your enquiry, we may process your Identity Data, Contact Data and certain Observed Data and Technical Data when you use the Enquiry Form to get in touch with us.
Our legal basis for processing
It is in our legitimate interest to use personal data in such a way to ensure that we can respond to your enquiries, provide access to our Sites in a secure and effective way and make improvements to our Sites.
If you link to social media sites and/or interact with our social media pages
If you click on one of the social media links on our Sites or otherwise interact with our social media pages such as on Twitter or Instagram or YouTube (including interacting with any “like” or similar embedded features on our Sites or social media accounts), we and the relevant social media platform may receive information relating to such interaction and may share your personal data in connection with this purpose, such as certain Observed Data and Technical Data. For more information about how we use this personal data, please see the Insight and Analysis section.
The relevant social media platform may also be a controller in respect of the personal data that is collected via your use of our social media pages and may use that personal data for additional purposes. For details of how the relevant social media platform uses your personal data, please see the privacy policy of the relevant social media platform.
Our legal basis for processing
It is in our legitimate interest to use personal data in the ways described above to ensure that we provide the Sites in an effective way and to promote our Sites via social media.
If you purchase our Services, whether through our Sites or otherwise
We collect and maintain personal data that you submit to us for the purpose of supplying our Services that you have requested from us, including where requested via our Sites. We may collect and process your personal data whether you are interacting with us on your own behalf or on behalf of any organisation you represent.
The personal data we process may include your Identity Data, Contact Data, Account Data and Transaction Data (where applicable). We process this information so that we can fulfil the supply of Services, to maintain our client databases and to keep a record of how our Services are being used.
Our legal basis for processing
It is necessary for us to use your personal data to perform our obligations in accordance with any contract that we may have with you for the Services, or it is in our legitimate interest to use personal data in such a way to ensure that we provide our Services in an effective, safe and efficient way.
If you access Services on our Sites
You may be required to register an account with us in order to gain access to certain Services and secure areas of our Sites. Account applicants will need to complete the registration form, providing all required Identity Data, Contact Data and Account Data. We will use this data in order to process your registration.
Once the account is registered, we will process your Account Data to identify you when you log in to your account and access secure areas of the Sites. We will also process certain Technical Data and Communications Data so that we can administer your account and contact you about your account or any aspect of the Services we are providing to you.
We will also collect and process Observed Data and Technical Data when you use certain features and functionality on our Sites. This data helps us understand how you use our Services and our Sites so that we can improve them.
Our legal basis for processing
It is necessary for us to use your personal data to perform our obligations in accordance with any contract that we may have with you, or it is in our legitimate interest to use personal data in such a way to ensure that we provide access to the Services and our Sites in a secure and effective way and so that we can make improvements to our Services and our Sites.
If you complete our surveys or provide feedback on your experience of our Services and/or our Sites
From time to time, we will invite you to provide feedback about us, our Sites and our Services in the form of online surveys. We will collect and process your Identity Data and Contact Data as well as any other personal data you choose to volunteer in your survey response or other feedback.
We use this information to help us to monitor and improve our Sites and our Services, to assist with the selection and development of future Services and to train our personnel.
You can also voluntarily provide feedback by email or via our Enquiry Form.
Our legal basis for processing
It is in our legitimate interest to use the personal data provided by you so that we can improve our Sites and our Services and provide them in an effective way.
If you participate in one of our promotions
From time to time, we may run prize draws, prize competitions and other promotions on our Sites and/or on our social media accounts. For the purposes of administering such promotions, we may process your Identity Data, Contact Data, Account Data and any other personal data volunteered by you in relation to your promotion entry.
Our promotions are subject to separate terms and conditions, which you may be required to accept as a condition of entry.
Our legal basis for processing
It is necessary for us to use your personal data to perform our obligations in accordance with any contract that we may have with you (e.g. the promotion terms and conditions) or it is in our legitimate interest to use your personal data to enable us to administer our promotion fairly and effectively and to ensure that we comply with self-regulatory codes governing the operation of promotions.
If you have a general question or need help with any issue concerning our Sites or our Services
There are various ways in which you are able to contact us (see the How_to_Contact_Us section). In particular, our Sites features an Enquiry Form, which invites you to submit general enquiries about our Sites and our Services by email. From time to time, you may also be able to submit specific enquiries on other pages of our Sites, including in secure account areas.
When you make an enquiry, we will collect and process your Identity Data, Contact Data, Account Data as well as any other personal data you volunteer that is relevant to your enquiry. If you have a technical issue concerning our Sites, we may also collect and process Observed Data and Technical Data to help us diagnose the technical issues you are experiencing and to help us resolve them in an efficient way. We use this information to manage and respond to your enquiry.
Our legal basis for processing
It is in our legitimate interest to use your personal data in the ways described above to ensure that we are able to help you with your enquiry, provide a good standard of service and improve our customer services.
If we use cookies to help us personalise our Sites and our Services and to understand more about users of our Sites and our Services
We and our third-party partners use cookies, web beacons, pixel tags and other similar technologies (which we generically refer to as “Cookies”) or may otherwise collect Observed Data through your use of our Sites and our Services. Please see our Cookie Notice for further information, including details of our third-party partners.
We and our third-party partners use Observed Data and Transaction Data to personalise your experience on the Sites and to personalise the content that we deliver to you through our advertising and marketing activities referred to in the Advertising and Marketing section.
In addition, we and our third-party partners may use Observed Data and Transaction Data on an aggregated basis, or in a way that does not directly identify you, for the following purposes:
to count users who have visited our Sites and collect other types of information, including insights about visitor browsing habits, which helps us to improve our Sites and our Services and the effectiveness of our emails;
Our legal basis for processing
Where your data is collected through the use of non-essential Cookies, we rely on consent to collect your personal data and for the onward processing purpose. Please see our Cookie Notice for further details.
In certain circumstances, we may rely on another lawful basis when we use your personal data collected via the use of cookies. For example, where we use personal data collected through the use of analytics cookies to analyse how you use our Sites and our Services, it is in our legitimate interest to use your personal data in such a way to improve our Sites and Services.
If we send you marketing communications by post and/or email/SMS
We use your Identity Data, Contact Data and Communications Data to send you (or the organisation you represent) marketing communications by post and/or email/SMS. Our marketing will include press releases and information about us, our Sites, our Services, any events we may hold and the offers and promotions we offer from time to time.
Our marketing communications will include personalised and non-personalised marketing. Personalised marketing has been specifically tailored to you and will include content that we think is most relevant to you, based on what we know about you. Non-personalised marketing is marketing that is not tailored to you.
Where we are sending you personalised marketing, we may also use Identity Data, Contact Data, Account Data, Observed Data and Transaction Data to help us decide what sort of personalised marketing to send you. Please see the Insight_and_Analysis section for more details about how we may collect Observed Data.
Our legal basis for processing
It is in our legitimate interest to use your personal data for marketing purposes, for example to decide what marketing content we think may appeal to you.
It is in our legitimate interest to use your personal data to send our marketing to you by post.
We will only send marketing communications to you by email and/or SMS where you have consented to receive such content by email and/or SMS, or where we have another lawful right to send marketing to you using email and/or SMS. For example, in certain circumstances we may rely on our legitimate interest to send marketing by email and/or SMS to consumers who have purchased our Services. We may also rely on our legitimate interest to send marketing by email and/or SMS to certain business users of our Sites and our Services.
In addition, please see the Insight_and_Analysis section to learn about the legal basis that we rely on to collect Observed Data via the use of Cookies.
If we make telephone marketing calls to you
We use your Identity Data, Contact Data and Communications Data to make marketing telephone calls to you. Our marketing calls will include information about us, our Sites and our Services.
Our marketing calls may include personalised and/or non-personalised marketing (please see the above section on post and email/SMS marketing for more information on the difference).
Where we are contacting you with personalised marketing, we may also use Identity Data, Contact Data, Account Data, Observed Data and Transaction Data to help us decide what sort of personalised marketing to contact you about. Please see the Insight_and_Analysis section for more details about how we may collect Observed Data.
We may record our telephone conversations with you and use the recordings for evaluation and training purposes.
You are free to opt out of our marketing communications at any time.
Our legal basis for processing
It is in our legitimate interest to use your personal data for marketing purposes, for example to decide what marketing content we think may appeal to you.
It is in our legitimate interest to use your personal data to make telephone marketing calls to you. However, if you have expressly opted in to receive telephone marketing calls from us, then our legal basis for making those calls to you will be based on your consent.
It is in our legitimate interest to use your personal data included in recordings of our telephone conversations to help improve our customer services and our Services.
We will not make telephone marketing calls to you if you have opted out of receiving such calls from us or you have otherwise registered with the Telephone Preference Service and you have not separately opted in to receive telephone marketing calls from us.
In addition, please see the Insight_and_Analysis section to learn about the legal basis that we rely on to collect Observed Data via the use of Cookies.
If we use your personal data in connection with our recruitment activities
We use your personal data for recruitment purposes, in particular, to assess your suitability for any of our positions that you apply for, whether such application has been received by us online, by email or by hard copy and whether submitted directly by you or by a third-party recruitment agency on your behalf. We also use your Identity Data and Contact Data to communicate with you about the recruitment process, to keep records about our recruitment process and to comply with our legal and regulatory obligations in relation to recruitment.
We will process your Identity Data, Contact Data, Job Applicant Data and any other personal data about you that you volunteer, including during any interview, when you apply for a position with us. We may also process your personal data obtained from any third parties we work with in relation to our recruitment activities, including without limitation, recruitment agencies, background check providers, credit reference agencies and your referees.
The personal data we process may include your Identity Data, Contact Data and any other personal data that you volunteer during an interview or your interactions with us, or any personal data which is contained in any reference about you that we receive. Such information may also include special categories of personal data (such as information about your health, any medical conditions and your health and sickness records) and information relating to criminal convictions and offences if that information is relevant to the role you are applying for.
We also use your personal data for the purposes of reviewing our equal opportunity profile in accordance with applicable legislation. We do not discriminate on the grounds of gender, race, ethnic origin, age, religion, sexual orientation, disability or any other basis covered by local legislation. All employment-related decisions are made entirely on merit.
Our legal basis for processing
Where we use your personal data in connection with our recruitment activities, it will be in connection with us taking steps at your request to enter into a contract with you, or it is in our legitimate interest to use personal data in such a way to ensure that we can make the best recruitment decisions.
We will not process any special (or sensitive) categories of personal data or personal data relating to criminal convictions or offences except where we are able to do so under applicable legislation or with your explicit consent.
If we have engaged you or the organisation you represent to provide us with products or services
If we have engaged you or the organisation you represent to provide us with products or services (for example, if you or the organisation you represent provide us with services such as IT support or financial advice), we will collect and process your personal data in order to manage our relationship with you or the organisation you represent, to receive products and services from you or the organisation you represent and, where relevant, to provide our Services to others. The personal data we collect from you may include your Identity Data and Contact Data and any other personal data you volunteer that is relevant to our relationship with you or the organisation you represent.
Our legal basis for processing
It is necessary for us to use your personal data to perform our obligations in accordance with any contract that we may have with you or the organisation you represent, or it is in our legitimate interest to use personal data in such a way to ensure that we have an effective working relationship with you or the organisation you represent and are able to receive the products and services that you or your organisation provides, and provide our Services to others, in an effective way.
If we need to use your personal data in connection with the administration of our security measures
We have security measures in place at our premises, including CCTV and building access controls. There are signs in place showing that CCTV is in operation. The images captured are securely stored and only accessed on a need to know basis (e.g. to look into an incident). CCTV recordings are typically automatically overwritten after a short period of time unless an issue is identified that requires investigation (such as a theft).
We may require visitors to our premises to sign in on arrival and where that is the case, we will keep a record of visitors for a short period of time. Our visitor records are securely stored and only accessible on a need-to-know basis (e.g. to look into an incident).
Our legal basis for processing
It is in our legitimate interests to process your personal data so that we can keep our premises secure and provide a safe environment for our personnel and visitors to our premises.
If we need to use your personal data to comply with our legal obligations or in connection with the administration of our business
We may use your personal data: (i) to comply with our legal obligations; (ii) to enforce or protect our legal rights; (iii) to protect the rights of third parties; and (iv) in connection with a business transition such as a merger, reorganisation, acquisition by another company, or sale of any of our assets.
Our legal basis for processing
Where we use your personal data in connection with a business transition, to enforce or protect our legal rights or to protect the rights of third parties, it is in our legitimate interest to do so. For all other purposes described in this section, we have a legal obligation to use your personal data to comply with any legal obligations imposed upon us, such as a court order.
We will not process any special (or sensitive) categories of personal data or personal data relating to criminal convictions or offences except where we are able to do so under applicable legislation or with your explicit consent.
Where we are required by law to collect your personal data, or we need to collect your personal data under the terms of a contract we have with you, and you fail to provide that personal data when we request it, we may not be able to perform the contract we have or are trying to enter into with you. This may apply where you do not provide the personal data we need in order to provide the Services you have requested from us or to process an application for employment with us. In these circumstances, we may have to cancel your application or the provision of the relevant Services to you, in which case we will notify you.
Where our use of your personal data requires consent, you can provide such consent at the time we collect your personal data following the instructions provided, or by informing us using the contact details set out in the How_to_Contact_Ussection.
This Privacy Notice only applies to personal data processed by us through your use of our Sites and/or in connection with our Services and our business operations more generally. However, from time to time, our Sites may contain links to third-party websites and services. We have no control over these websites and services and this Privacy Notice does not apply to your interaction with the relevant third parties.
When you use a link to go from our Site to another website (even if you don’t leave our Site) or you request a service from a third party, your browsing and interactions on any other websites, or your dealings with any other third-party service provider, is subject to that website’s or third-party service provider’s own rules and policies. For example, where our Site invites you to connect with us on social media platforms such as Twitter and LinkedIn, when you click on the links we provide to such third-party platforms, you will be transferred from our Site to the relevant third-party platform and the privacy notice (and other terms and conditions) of that platform will apply to you.
We do not monitor, control or endorse the privacy practices of any third parties. We encourage you to become familiar with the privacy practices of every website you visit or third-party service provider that you use in connection with your interaction with us and to contact them if you have any questions about their respective privacy notices and practices.
We only share personal data with others when we are legally permitted to do so. When we share personal data with others, we put contractual arrangements and security mechanisms in place to protect the personal data shared and to comply with our data protection, confidentiality and security standards and obligations.
When processing your personal data, we may need to share it with third parties (including other entities within our group of companies), as set out in the table below. This list is non-exhaustive and there may be circumstances where we need to share personal data with other third parties.
Our clients
We may share personal data with our clients for the purposes of providing them with our Services.
Third-party suppliers who provide applications/ functionality, data processing or IT services
We share personal data with third parties who support us in providing our Sites and help provide, run and manage our internal IT systems. Such third parties may also include, for example, providers of information technology, cloud-based software-as-a-service providers, identity management, website design, hosting and management, data analysis, data back-up, security and storage services. The servers powering and facilitating that cloud infrastructure are located in secure data centres around the world, and personal data may be stored in any one of them. We also share your personal data with third-party service providers to assist us with insight analytics. These providers are described in our Cookie Notice.
Payment providers and banks
We share personal data with third parties who assist us with the processing of payments and refunds.
Third-party post/email marketing and CRM specialists
We share personal data with specialist suppliers who assist us in managing our marketing database and sending out our post and email marketing communications and account-related communications.
Third-party suppliers who assist us in administering our promotions
We share personal data with specialist suppliers who assist us in administering our prize draws, prize competitions and other promotions.
Event partners and suppliers
When we run events, we will share your personal data with third-party service providers that are assisting us with the operation and administration of that event. If we are running an event in partnership with other organisations, we will share your personal data with such organisations for use in relation to the event.
Recruitment agencies and related organisations
We share personal data with external recruiters, third-party providers that undertake background checks on our behalf.
Auditors, lawyers, accountants and other professional advisers
We share personal data with professional services firms who advise and assist us in relation to the lawful and effective management of our organisation and in relation to any disputes we may become involved in.
Law enforcement or other government and regulatory agencies and bodies
We share personal data with law enforcement or other government and regulatory agencies or other third parties as required by, and in accordance with, applicable law or regulation.
Other third parties
Occasionally, we may receive requests from third parties with authority to obtain disclosure of personal data, such as to check that we are complying with applicable law and regulation, to investigate an alleged crime, or to establish, exercise or defend legal rights. We will only fulfil requests for personal data where we are permitted to do so in accordance with applicable law or regulation.
Where necessary in order to provide our Sites and our Services, we may transfer personal data to countries outside the United Kingdom (“UK”) and the European Economic Area (“EEA”).
Countries outside the UK and EEA have different data protection laws to the UK and the EEA. In particular, such countries may not provide the same degree of protection for your personal data, may not give you the same rights in relation to your personal data and may not have a data protection supervisory authority to help you if you have any concerns about the processing of your personal data.
However, when transferring your personal data outside the UK or the EEA, we will comply with our legal and regulatory obligations in relation to your personal data, including having a lawful basis for transferring personal data and putting appropriate safeguards in place to ensure an adequate level of protection for the personal data. We will take reasonable steps to ensure the security of your personal data in accordance with applicable data protection laws.
In particular, where your personal data is transferred outside the UK or the EEA to a territory not subject to an “adequacy decision” by the European Commission (meaning that the relevant country has been deemed by the UK and the European Commission to offer an adequate level of protection), we have agreements in place with the relevant parties which include standard data protection clauses adopted by the relevant data protection regulator and approved by the relevant UK and/or EEA authorities that give personal data the same protection it has in the UK and the EEA. Alternatively, we may put in place other appropriate safeguards. Please contact us if you require more information about these safeguards.
In respect of personal data that we process in connection with the supply of our Services, we may retain your personal data for up to six years from the date of supply of the relevant Services and in compliance with our data protection obligations. We may then destroy such files without further notice or liability.
Where we process personal data in connection with the registration and use of an account on our Sites, we may retain your personal data for up to six years from the date that the relevant account is terminated (and in compliance with our data protection obligations). We may then destroy such files without further notice or liability.
Where we process any other personal data, we will retain relevant personal data for up to three years from the date of our last interaction with you (and in compliance with our data protection obligations). We may then destroy such files without further notice or liability.
If any personal data is only useful for a short period (e.g. for a specific promotion or marketing campaign), we will not retain it for longer than the period for which it is used by us.
If you have made a complaint or have brought a claim against us, or if we have brought a claim against you, we will keep the relevant records for at least six years after the complaint or claim is resolved.
If you have opted out of receiving marketing communications from us, we will need to retain certain personal data on a suppression list indefinitely so that we know not to send you further marketing communications in the future. However, we will not use this personal data to send you further marketing unless you subsequently opt back in to receive such marketing.
We are committed to keeping the personal data you provide to us secure and we have implemented information security policies, rules and technical measures to protect the personal data under our control from unauthorised access, improper use or disclosure, unauthorised modification and unlawful destruction or accidental loss. In addition, all our employees and data processors (i.e. those who process your personal data on our behalf) are obliged to respect the confidentiality of the personal data of all users of our Sites and our Services.
Our Sites and our Services are not intended for use by, or targeted at, minors (those aged under 18). However, this does not prevent minors from providing personal data to us. If we do collect and process personal data of minors, we will comply with all applicable laws and regulations relating to the processing of personal data of minors.
You have certain rights in relation to the personal data we hold about you. These rights include the right: (i) to obtain copies of your personal data; (ii) to have your personal data corrected or deleted; (iii) to limit the way in which your personal data is used; (iv) to object to our use of your personal data; (v) to transfer your personal data; (vi) not to be subject to decisions based on automated processing (including profiling); and (vii) to complain to a supervisory authority. If you would like to exercise any of these rights, please contact us using the details set out in the How_to_Contact_Us section.
Your right of access
If you ask us, we will confirm whether we are processing your personal data and, if so, provide you with a copy of that personal data (along with certain other details). If you require additional copies, we may charge a reasonable fee for producing those additional copies.
Your right to rectification
If the personal data we hold about you is inaccurate or incomplete, you are entitled to have it rectified. If we have shared your personal data with others, we’ll let them know about the rectification where possible. If you ask us, where possible and lawful to do so, we will also tell you who we’ve shared your personal data with so that you can contact them.
Your right to erasure
You can ask us to delete or remove your personal data in some circumstances, such as where we no longer need it or where you withdraw your consent (where applicable). If we have shared your personal data with others, we will let them know about the erasure where possible. If you ask us, where it is possible and lawful for us to do so, we will also tell you who we have shared your personal data with so that you can contact them directly.
Your right to restrict processing
You can ask us to “block” or suppress the processing of your personal data in certain circumstances such as where you contest the accuracy of that personal data or you object to us processing it for a particular purpose. This may not mean that we will stop storing your personal data but, where we do keep it, we will tell you if we remove any restriction that we have placed on your personal data to stop us processing it further. If we’ve shared your personal data with others, we’ll let them know about the restriction where it is possible for us to do so. If you ask us, where it is possible and lawful for us to do so, we’ll also tell you who we’ve shared your personal data with so that you can contact them directly.
Your right to data portability
You have the right, in certain circumstances, to obtain personal data you have provided to us (in a structured, commonly used and machine-readable format) and to reuse it elsewhere or to ask us to transfer it to your chosen third party.
Your right to object
You can ask us to stop processing your personal data, and we will do so, if we are: (i) relying on our own or someone else’s legitimate interest to process your personal data, except if we can demonstrate compelling legal grounds for the processing; or (ii) processing your personal data for direct marketing purposes.
Your rights in relation to automated decision-making and profiling
You have the right not to be subject to a decision when it is based on automatic processing, including profiling, if it produces a legal effect or similarly significantly affects you, unless such profiling is necessary for the entering into, or the performance of, a contract between you and us.
Your right to withdraw consent
If we rely on your consent (or explicit consent) as our legal basis for processing your personal data, you have the right to withdraw that consent at any time. You can exercise your right of withdrawal by contacting us using our contact details in the How_to_Contact_Us section or by using any other opt-out mechanism we may provide, such as an unsubscribe link in an email.
Your right to lodge a complaint with the supervisory authority
If you have a concern about any aspect of our privacy practices, including the way we have handled your personal data, please contact us using the contact details provided in the How_to_Contact_Us section. You can also report any issues or concerns to a national supervisory authority in the country of your residence or the place of the alleged infringement. As we are incorporated in [the United Kingdom], our regulatory authority is the [Information Commissioner’s Office (“ICO”)]. Contact details for [the ICO] can be found on its website at [https://ico.org.uk]. You can find a list of contact details for EU supervisory authorities at https://edpb.europa.eu/about-edpb/about-edpb/members_en.