"Privacy Policy: Protecting Your Personal Information with Care"
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 privacy 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 privacy 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:
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 there is a LEGITIMATE INTERESTWe 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;
● 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.
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.
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.
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 privacy 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.
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.
8.5Complaining 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.
LINKS / SOCIAL PLUGINS
9. SECURITY / COOKIES /
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.
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.
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.
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 POLICY
We 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/page?system_tag=Privacy_Policy
Telephone: 0203 633 8974
