Last updated on 24th May 2018
- a. Our details
- In this policy, “we”, “us” and “our” refer to PJH Group Limited;
or, where applicable, to LUXSON ltd as data processor in the provision of this online service.
You can contact us using the contact details published on this service.
- b. Changes to this policy
- c. Purpose
- Section 4 below explains how we use your information and the legal basis.
We will use your personal data for the purposes for which we collected them, unless we reasonably consider that we need to use them for another purpose and that purpose is compatible with the original purpose.
Please also note that where required or permitted by law (only) we may process your personal data without your knowledge or consent (for example, where we may be obligated to do so by Governmental bodies).
- d. Third-party links
- This service may contain links or references to and from third-party services. Clicking on those links or enabling those connections may allow third-parties to collect or share data about you. Please check the relevant third-party privacy policies before you provide any personal data to them.
- e. Governing Law and Jurisdiction
2. Information We May Collect
The types of information we collect may vary, depending on specific circumstances and services.
Personal data means any information about a person from which they can be identified and doesn’t include anonymised data.
Generally speaking, we may collect information in the following ways:
- information provided by you (for example, in your communications with us, or your online form inputs, or your online transactions);
- automated data collection during your use of this service;
- Information collected via social media and other third parties, lawfully shared with us.
We may collect, use, store and transfer different kinds of data as follows:
- Identity Data includes your name, username or similar identifier, marital status, title, date of birth and gender and could also include audio, photos, videos and other forms of media.
- Contact Data includes physical addresses, email addresses, telephone numbers and other personal communications addresses.
- Marketing Communications Data includes your marketing and communications preferences.
- Correspondence Data includes information contained in or relating to any correspondence between you and us.
- Profile Data includes your login credentials, preferences and content you provide.
- Financial Data includes account and payment details.
- Transaction Data includes details about payments to and from you and other details of products and services transactions you may have made with us.
- Technical Data includes your internet protocol (IP) address, cookies, login data, device type profiles (including operating system and browser information), time-zone settings and location, system logs.
- Usage Data includes information about how you use this service.
- We do not collect any Special Category Data about you. Special Category Data includes details about your race or ethnicity, religious or philosophical beliefs, sexual orientation, political opinions, trade union membership and information about your health, genetic or biometric data.
- We do not collect any information about criminal convictions and offences.
- We also handle anonymised Aggregated Data derived from other data. If Aggregated Data is ever connected with other data so that you can be directly or indirectly identified, we will handle the combined data as personal data in accordance with this policy.
This website, like all modern online services, uses browser ‘cookies’ (text-only strings of information known as ‘session’ and ‘persistent’ cookies) for the proper functioning, activity data and ongoing developments of this service. ‘Cookies’ are set for each domain used by this service, which you may remove at any time with your browser settings; but if you choose to do so this service may not function properly and you should discontinue your use of it.
Information about ‘cookies’ and visitor options can be easily found online (http://en.wikipedia.org/wiki/HTTP_cookie).
4. How We Use Your Information and Legal Basis for Processing
We will only use your personal data in accordance with the lawful basis (there may be more than one) for the corresponding purpose.
Most commonly, we will use your personal data where:
- we are performing a contract with you;
- we may have other legal obligations;
- it is necessary for our legitimate interests (or those of a third-party) and your fundamental rights do not override those interests; and/or
- you have given your consent.
5. Where We Store and Use Your Information
The data that we collect from you will be stored on secure servers within the European Economic Area ("EEA"). The majority (or all) of such data is held within the UK.
If we ever transfer your data out of the EEA, appropriate safeguards will be in place to a reasonable standard recognised by the European Commission for protection of personal data.
6. Securing Your Information
We maintain appropriate organisational and technological safeguards to help protect against loss, misuse or unauthorised access, disclosure, alteration or destruction of the information we hold about you. We also seek to ensure our service providers do the same. Unfortunately, no system can be guaranteed as completely secure and there is an inherent risk in transmitting information over the internet. It may be possible for an unrelated party to intercept or access such transmissions unlawfully.
If you believe that your personal information under our control has been compromised, including access to any accounts you hold with our services, please contact us immediately.
7. How Long We Hold Your Information
We will hold your personal information on our systems for as long as is necessary for the relevant service to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements, in accordance with our retention policies.
To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.
Where you contribute content to our online services, we will generally only keep your contribution for as long as is reasonably required for the purpose(s) for which it was submitted. After this time, your personal information will either be securely deleted or anonymised so that it can be used for research or statistical purposes in which case we may use this information indefinitely without further notice to you.
8. Sharing Your Information
Your personal data will not be shared with third-parties unnecessarily.
We may disclose your personal data to our professional service providers and suppliers insofar as reasonably necessary for them to perform their services for us or for you.
We may disclose your personal data to others 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.
If you contribute inappropriate or objectionable content on our services or where we reasonably believe you may be in breach of the law, we may report your content and behaviour to relevant parties.
In addition to the specific disclosures of personal data set out in this section, we may disclose your personal data where such disclosure 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.
We reserve the right to transfer your personal information in the event we sell or transfer all or a part of our business or assets so that the buyer can continue to provide the services. We will make reasonable efforts to provide you with advance notification of the transfer of your information in such circumstances.
9. Your Rights
You have personal data rights in law and this policy is intended to respect those rights.
Some rights are complex and for a full explanation of these rights you should read the relevant laws and guidance from the regulatory authorities.
Good information about your rights can be easily found online from the UK’s Information Commissioner’s Office (ICO) ( https://ICO.org.uk/your-data-matters/ )
These rights include:
- Your right to be informed if your personal data is being used
- Your right to get copies of your data
- Your right to get your data corrected
- Your right to get your data deleted
- Your right to limit how organisations use your data
- Your right to data portability
- Your right to object to the use of your data
- Your rights relating to decisions being made about you without human involvement
- Your right to access information from a public body
- Your right to raise a concern