Privacy Policy
1.0 About this Policy
1.1 We appreciate your interest in our products and services. Your
privacy is important to us and we want you to feel comfortable with how
we use and share your personal information.
1.2 This policy sets out how Pall Mall Investments International
Ltd handles your personal information, including when and why it is
collected, used and disclosed and how it is kept secure.
1.3 You will find our contact details at the end of this policy
which you can use if you have any questions, including how to update or
access your personal information or to make a complaint.
1.4 This policy may change, so please check this page from time to
time to ensure that you’re happy with any changes. Please see further
Changes to this policy in Section 11.
1.5 This policy was last updated on 31/01/2020.
2. WHO WE ARE
2.1 Where this policy refers to “we”, “our” or “us” or “the company”
in this policy unless it mentions otherwise, it is referring to Pall
Mall Investments International Ltd the controller of your personal
information.
3. HOW AND WHAT PERSONAL INFORMATION WE COLLECT
3.1 We may collect and process the following personal
information about you:
The personal information you give to us: This is information about you
that you give to us by entering information via our websites or our
social media pages or by corresponding with us by phone, email or
otherwise and is provided entirely voluntarily. The information you give
to us includes your name, contact details (such as phone number, email
address and address), enquiry details and your opinion of our products.
Personal information we collect about you: We may automatically collect
the following personal information: our web servers store as standard
details of your browser and operating system, the website from which you
visit our website, the pages that you visit on our website, the date of
your visit, and, for security reasons, e.g. to identify attacks on our
website, the Internet protocol (IP) address assigned to you by your
internet service. We collect some of this information using cookies –
please see Cookies in Section 9.2 for further information. We may also
collect any personal information which you allow to be shared that is
part of your public profile on a third party social network.
Personal information we may receive from other sources: We obtain
certain personal information about you from sources outside our
business; the personal information received is as described in the two
paragraphs above.
3.2 Please see further “How we use your personal information” in
Section 4 for details of the purposes for which we use the personal
information we obtain from these sources and the legal basis on which we
rely to process that information. The remaining provisions of this
policy also apply to any personal information we obtain from these
sources.
4. HOW WE USE YOUR PERSONAL INFORMATION
4.1 Where you have provided CONSENT
We may use and process your personal information where you have
consented for us to do so for the following purposes: to supply
brochures and other material you have specifically requested from us; to
contact you via email, text message, post or telephone with marketing
information about Pall Mall Investments International Ltd and other
products and services (see Marketing section below for further details);
4.2 You may withdraw your consent for us to use your information
in any of these ways at any time. Please see Withdrawing your consent
in Section 8.4 for further details.
4.3 Where required to perform a CONTRACT with you
We may use and process your personal information where it is necessary
for the performance of a contract with you or in order to take steps at
your request before entering into a contract with you.
4.4 Where it is in your VITAL INTEREST
We may use your personal information to contact you if there are any
urgent safety or product recall notices to communicate to you or where
we otherwise reasonably believe that the processing of your personal
information will prevent or reduce any potential harm to you. It is in
your vital interests for us to use your personal information in this
way.
4.5 Where required to comply with our LEGAL OBLIGATIONS
We will use your personal information to comply with our legal obligations including:
to assist any legitimate public authority;
(ii) to identify you when you contact us; and
(iii) to verify the accuracy of data that we hold about you.
4.6 Where there is a LEGITIMATE INTEREST
We may use and process your personal information where it is necessary
for us to pursue our legitimate interests as a business for the
following purposes:
● for analysis and profiling to inform our marketing strategy,
and to enhance and personalise your customer or visitor experience;
● for market research in order to continually improve the
products and services that we and our authorised dealers deliver to you;
● to administer our websites and for internal operations, including troubleshooting, testing, statistical purposes;
● for marketing activities (other than where we rely on your
consent) e.g. to tailor marketing communications or send targeted
marketing messages via social media and other third-party platforms;
● for the prevention of fraud and other criminal activities;
● to undertake credit checks for finance;
● to correspond and communicate with you;
● to create a better understanding of you as a customer or supplier;
● for network and information security in order for us to take
steps to protect your information against loss or damage, theft or
unauthorised access;
● to comply with a request from you in connection with the
exercise of your rights (for example where you have asked us not to
contact you for marketing purposes, we will keep a record of this on our
suppression lists in order to be able to comply with your request);
● for the purposes of corporate restructure or reorganisation or sale of our business or assets;
● for efficiency, accuracy or other improvements of our
databases and systems e.g. by combining systems or consolidating records
we or our group companies hold about you;
● to enforce or protect our contractual or other legal rights or to bring or defend legal proceedings; and
● for general administration including managing your queries, complaints, or claims, and to send service messages to you.
5. OTHERS WHO MAY RECEIVE OR HAVE ACCESS TO YOUR PERSONAL INFORMATION
5.1 Our suppliers and service providers
We may disclose your information to our third-party service
providers, agents, subcontractors and other organisations for the
purposes of providing services to us or directly to you on our behalf.
Such third parties may include cloud services providers (such as hosting
and email management) or advertising agencies, administrative services
or other third parties who provide services to us.
When we use third-party service providers, we only disclose to them any
personal information that is necessary for them to provide their service
and we have a contract in place that requires them to keep your
information secure and not to use it other than in accordance with our
specific instructions.
We may disclose your personal data to our insurers and/or professional
advisers insofar as reasonably necessary for the purposes of obtaining
or maintaining insurance coverage, managing risks, obtaining
professional advice, or the establishment, exercise or defence of legal
claims, whether in court proceedings or in an administrative or
out-of-court procedure.
5.2 Other ways we may share your personal information
We may transfer your personal information to a third party as
part of a sale of some or all of our business and assets to any third
party or as part of any business restructuring or reorganisation. We may
also transfer your personal information if we’re under a duty to
disclose or share it in order to comply with any legal obligation to
detect or report a crime, to enforce or apply the terms of our contracts
or to protect the rights, property or safety of our visitors and
customers.
However, we will always take steps with the aim of ensuring that your
privacy rights continue to be protected.
6. WHERE WE STORE YOUR PERSONAL INFORMATION OUTSIDE THE EEA
6.1 The hosting facilities for our website are situated in The
UK and our own servers are located in the UK. Consequently, we do not
routinely transfer your data to countries outside the EEA.
6.2 If you use our services whilst you are outside the EEA, your
information may be transferred outside the EEA in order to provide you
with those services.
7. HOW LONG WE KEEP YOUR PERSONAL INFORMATION FOR
7.1 Section 7 sets out our data retention policies and
procedure, which are designed to help ensure that we comply with our
legal obligations in relation to the retention and deletion of personal
data.
7.2 Personal data that we process for any purpose or purposes
shall not be kept for longer than is necessary for that purpose or those
purposes.
7.3 We will retain your personal data for a minimum period of
twelve years following the end of the financial year in which we have
our last communication or transaction with you.
7.4 Notwithstanding the other provisions of this Section 7, we
may retain your personal data where such retention is necessary for
compliance with a legal obligation to which we are subject, or in order
to protect your vital interests or the vital interests of another
natural person.
8. YOUR RIGHTS
8.1 Your ‘data subject’ rights
You have a number of rights in relation to your personal information
under data protection law. In relation to certain rights, we may ask you
for information to confirm your identity and, where applicable, to help
us to search for your personal information. Except in rare cases, we
will respond to you within 30 days after we have received this
information or, where no such information is required after we have
received your request.
8.2 Accessing your personal information
You have the right to ask for a copy of the information that we hold
about you by emailing or writing to us at the address at the end of this
policy. We may not provide you with a copy of your personal information
if this concerns other individuals or we have another lawful reason to
withhold that information.
8.3 Correcting and updating your personal information
The accuracy of your information is important to us and we are working
on ways to make it easier for you to review and correct the information
that we hold about you.
In the meantime, if you change your name or address/email
address, or you discover that any of the other information we hold is
inaccurate or out of date, please let us know by contacting us in any of
the details described at the end of this policy.
8.4 Withdrawing your consent
Where we rely on your consent as the legal basis for processing your
personal information, as set out under “How we use your personal
information” in Section 4, you may withdraw your consent at any time by
contacting us using the details at the end of this policy. If you would
like to withdraw your consent to receiving any direct marketing to which
you previously opted-in, you can also do so using our unsubscribe tool.
If you withdraw your consent, our use of your personal information
before you withdraw is still lawful.
8.5 Objecting to our use of your personal information and
automated decisions made about you.
Where we rely on our legitimate business interests as the legal basis
for processing your personal information for any purpose(s), as out
under “How we use your personal information” in Section 4, you may
object to us using your personal information for these purposes by
emailing or writing to us at the address at the end of this policy.
Except for the purposes for which we are sure we can continue to process
your personal information, we will temporarily stop processing your
personal information in line with your objection until we have
investigated the matter. If we agree that your objection is justified in
accordance with your rights under data protection laws, we will
permanently stop using your data for those purposes. Otherwise, we will
provide you with our justification as to why we need to continue using
your data.
You may object to us using your personal information for direct
marketing purposes and we will automatically comply with your request.
If you would like to do so, please contact us using the details at the
end of this policy.
You may also contest a decision made about you based on automated processing by contacting the data protection department.
8.6 Erasing your personal information or restricting its processing
In certain circumstances, you may ask for your personal
information to be removed from our systems by emailing or writing to us
at the address at the end of this policy. Unless there is a reason that
the law allows us to use your personal information for longer, we will
make reasonable efforts to comply with your request.
You may also ask us to restrict processing your personal
information in the following situations:
where you believe it is unlawful for us to do so,you have objected to
its use and our investigation is pending or you require us to keep it in
connection with legal proceedings.
In these situations, we may only process your personal information
whilst its processing is restricted if we have your consent or are
legally permitted to do so, for example for storage purposes, to protect
the rights of another individual or company or in connection with legal
proceedings.
8.7 Transferring your personal information in a structured data
file
Where we rely on your consent as the legal basis for processing your
personal information or need to process it in connection with your
contract, as set out under Section 4 “How we use your personal
information”, you may ask us to provide you with a copy of that
information in a structured data file. We will provide this to you
electronically in a structured, commonly used and machine-readable form,
such as a CSV file.
You can ask us to send your personal information directly to another
service provider, and we will do so if this is technically possible. We
may not provide you with a copy of your personal information if this
concerns other individuals or we have another lawful reason to withhold
that information.
8.8 Complaining to the UK data protection regulator
You have the right to complain to the Information Commissioners Office
(ICO) if you are concerned about the way we have processed your personal
information. Please visit the ICO’s website for further details.
9. SECURITY / COOKIES / LINKS / SOCIAL PLUGINS
9.1 Security measures we put in place to protect your personal
information
We use technical and organisational security measures to protect the
personal information supplied by you and managed by us against
manipulation, loss, destruction, and access by third parties. Our
security measures are continually improved in line with technological
developments.
Unfortunately, the transmission of information via the internet is not
completely secure. Although we will do our best to protect your personal
information, we cannot guarantee the security of your information
whilst in transit to our website and any transmission is at your own
risk.
Where we have given (or where you have chosen) a password which enables
you to access an account, you are responsible for keeping this password
confidential. We ask you not to share your password with anyone.
9.2 Use of ‘cookies’
‘Cookies’ are small pieces of information sent to your device
and stored on its hard drive to allow our websites to recognise you when
you visit.
We use Google Analytics to analyse the use of our website. Google
Analytics gathers information about website use by means of cookies. The
information gathered relating to our website is used to create reports
about the use of our website. Google’s privacy policy is available at:
https://www.google.com/policies/privacy/.[ The relevant cookies are:
[identify cookies].]
Most browsers allow you to refuse to accept cookies and to
delete cookies. The methods for doing so vary from browser to browser,
and from version to version. You can, however, obtain up-to-date
information about blocking and deleting cookies via these links:
(a) https://support.google.com/chrome/answer/95647?hl=en (Chrome);
(b) https://support.mozilla.org/en-US/kb/enable-and-disable-cookies-website-preferences (Firefox);
(c) http://www.opera.com/help/tutorials/security/cookies/ (Opera);
(d) https://support.microsoft.com/en-gb/help/17442/windows-internet-explorer-delete-manage-cookies (Internet Explorer);
(e) https://support.apple.com/kb/PH21411 (Safari); and
(f) https://privacy.microsoft.com/en-us/windows-10-microsoft-edge-and-privacy (Edge).
Blocking all cookies will have a negative impact upon the usability of many websites.
If you block cookies, you may not be able to use all the features on our website.
9.3 Links to other websites
Our website may contain links to other websites run by other
organisations which we do not control. This policy does not apply to
those other websites and Apps‚ so we encourage you to read their privacy
statements. We are not responsible for the privacy policies and
practices of other websites and Apps (even if you access them using
links that we provide) and we provide links to those websites solely for
your information and convenience. We specifically disclaim
responsibility for their content, privacy practices and terms of use,
and we make no endorsements, representations or promises about their
accuracy, content or thoroughness. Your disclosure of personal
information to third party websites is at your own risk.
In addition, if you linked to our website from a third-party website, we
cannot be responsible for the privacy policies and practices of the
owners and operators of that third party website and recommend that you
check the policy of that third party website.
9.4 Social plugins
We use so-called social plugins (buttons) of social networks such as
Facebook, Google+ and Twitter.
When you visit our websites, these buttons are deactivated by default,
i.e. without your intervention, they will not send any data to the
respective social networks. Before you are able to use these buttons,
you must activate them by clicking on them. They then remain active
until you deactivate them again or delete your cookies. Please see
Cookies in Section 9.2 for further details regarding our use of cookies.
After their activation, a direct link to the server of the respective
social network is established. The contents of the button are then
transmitted from the social network directly to your browser and
incorporated in the website.
After activation of a button, the social network can retrieve data,
independently of whether you interact with the button or not. If you are
logged on to a social network, the network can assign your visit to the
website to your user account. A social network cannot assign a visit to
websites operated by our other group companies unless and until you
activate the respective button there as well.
If you are a member of a social network and do not wish it to combine
data retrieved from your visit to our websites with your membership
data, you must log out from the social network concerned before
activating the buttons.
We have no influence on the scope of data that is collected by the
social networks through their buttons. The data use policies of the
social networks provide information on the purpose and extent of the
data that they collect, how this data is processed and used, the rights
available to you and the settings that you can use to protect your
privacy.
10. MARKETING
10.1 We may contact you with targeted advertising delivered
online through email or social media and platforms (operated by other
companies) by using your personal information, or use your personal
information to tailor marketing to improve its relevance to you, unless
you object.
10.2 From time to time, we may ask you to refresh your marketing
preferences by asking you to confirm that you consent to continue
receiving marketing information from us.
10.3 You have the right to opt-out of our use of your personal
information to provide marketing to you in any of the ways mentioned
above. Please see “Withdrawing your Consent” in Section 8.4 and
“Objecting to our use of your personal information and automated
decisions made about you” in Section 8.5 above for further details on
how you can do this.
11. CHANGES TO THIS POLICYWe may review this policy from time to time and any changes will be
notified to you by posting an updated version on our website and/or by
contacting you by email. Any changes will take effect 7 days after the
date of our email or the date on which we post the modified terms on our
website, whichever is the earlier. We recommend you regularly check for
changes and review this policy when you visit our website. If you do
not agree with any aspect of the updated policy, you must promptly
notify us and cease using our services.
12. CONTACT US
If you have any questions, suggestions or complaints about the
processing of your personal information or wish to contact us to
amend/update your marketing preferences, please contact us
12 Fratton Road , Portsmouth , PO1 5BX
Email: admin@pallmall-investments.co.uk
Telephone: 0203 633 8974
