Pennington Choices (“We”) are committed to protecting and respecting your privacy.
This policy sets out the basis on which any personal data we collect from you, or that you provide to us, will be processed by us.
Please read the following carefully to understand our views and practices regarding your personal data and how we will treat it. By visiting http://pennington.org.uk/ you are accepting and consenting to the practices described in this policy.
- Definitions and Interpretation
In this Policy, the following terms shall have the following meanings:
“Account” means an account required to access and/or use certain areas and features of Our Site or such as may be created as a reference when you submit an online order or enquiry;
“Cookie Law” means the relevant parts of the Privacy and Electronic Communications (EC Directive) Regulations 2003;
“personal data” means any and all data that relates to an identifiable person who can be directly or indirectly identified from that data. In this case, it means personal data that you give to Us via Our Site. This definition shall, where applicable, incorporate the definitions provided in the EU Regulation 2016/679 – the General Data Protection Regulation (“GDPR”); and
“We/Us/Our” means by Pennington Choices, Brookfield House, Tarporley Road, Norcott Brook, Cheshire, WA4 4EA
- Information About Us
2.1 Our Site is operated by Pennington Choices, Brookfield House, Tarporley Road, Norcott Brook, Cheshire, WA4 4EA.
2.2 Our Data Compliance Manager is Becky Crook , and can be contacted by email at firstname.lastname@example.org, by telephone on 01928 568 842, or by post at Brookfield House, Tarporley Road, Norcott Brook, Cheshire, WA4 4EA.
- What Does This Policy Cover?
- Your Rights
4.1 As a data subject, you have the following rights under the GDPR, which this Policy and Our use of personal data have been designed to uphold:
4.1.1 The right to be informed about Our collection and use of personal data;
4.1.2 The right of access to the personal data We hold about you (see section 12);
4.1.3 The right to rectification if any personal data We hold about you is inaccurate or incomplete (please contact Us using the details in section 14);
4.1.4 The right to be forgotten – i.e. the right to ask Us to delete any personal data We hold about you (We only hold your personal data for a limited time, as explained in section 6 but if you would like Us to delete it sooner, please contact Us using the details in section 14);
4.1.5 The right to restrict (i.e. prevent) the processing of your personal data;
4.1.6 The right to data portability (obtaining a copy of your personal data to re-use with another service or organisation);
4.1.7 The right to object to Us using your personal data for particular purposes; and
4.1.8 Rights with respect to automated decision making and profiling.
4.2 If you have any cause for complaint about Our use of your personal data, please contact Us using the details provided in section 14 and We will do Our best to solve the problem for you. If We are unable to help, you also have the right to lodge a complaint with the UK’s supervisory authority, the Information Commissioner’s Office.
4.3 For further information about your rights, please contact the Information Commissioner’s Office or your local Citizens Advice Bureau.
- What Data Do We Collect?
5.1 The contents of any contact forms of user completed fields on the website, including your name, address and contact details;
5.2 The full details of any orders placed on this website;
5.3 Any user submitted contact information such as email addresses and telephone numbers;
5.4 Demographic information such as postcode, preferences, and interests;
5.5 Any files uploaded to Our Site;
5.6 IP address;
5.7 Web browser type and version;
5.8 Operating system;
5.9 A list of URLs starting with a referring site, your activity on Our Site, and the site you exit to;
- How Do We Use Your Data?
6.1 All personal data is processed and stored securely, for no longer than is necessary in light of the reason(s) for which it was first collected. We will comply with Our obligations and safeguard your rights under the GDPR at all times. For more details on security see section 7, below.
6.2 Our use of your personal data will always have a lawful basis, either because it is necessary for Our performance of a contract with you, because you have consented to Our use of your personal data (e.g. by subscribing to emails), or because it is in Our legitimate interests. Specifically, We may use your data for the following purposes:
6.2.1 Providing and managing your Account;
6.2.2 Providing and managing your access to Our Site;
6.2.3 Personalising and tailoring your experience on Our Site;
6.2.4 To carry out our obligations arising from any contracts entered into between you and us and to provide you with the information, products and services that you request from us (please note that We require your personal data in order to enter into a contract with you);
6.2.5 Personalising and tailoring Our products or services for you;
6.2.6 Replying to emails from you;
6.2.7 Supplying you with emails that you have opted into (you may unsubscribe or opt-out at any time by following the unsubscribe link in any of these emails);
6.2.8 to allow you to participate in interactive features of our service
6.2.9 Market research;
6.2.10 Analysing your use of Our Site and gathering feedback to enable Us to continually improve Our Site and your user experience;
6.2.11 as part of our efforts to keep our site safe and secure
6.3 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, telephone, text message or post with information, news and offers on Our products and 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 GDPR and the Privacy and Electronic Communications (EC Directive) Regulations 2003.
6.5 You have the right to withdraw your consent to Us using your personal data at any time, and to request that We delete it.
6.6 We do not keep your personal data for any longer than is necessary in light of the reason(s) for which it was first collected. Data will therefore be retained for the following periods (or its retention will be determined on the following bases):
6.6.1 Personal data will be stored for no more than 7 years unless you have created an Account, if you create an Account your data will be stored until such a time as you close the Account and then for no more than 7 years afterwards.
- How and Where Do We Store Your Data?
7.1 We only keep your personal data for as long as We need to in order to use it as described above in section 6, and/or for as long as We have your permission to keep it.
7.2 Our server is entirely based within the UK, however some of your data (for example your name and email address) may be stored outside of the European Economic Area (“the EEA”) (The EEA consists of all EU member states, plus Norway, Iceland, and Liechtenstein). You are deemed to accept and agree to this by using Our Site and submitting information to Us. If We do store data outside the EEA, We will take all reasonable steps to ensure that your data is treated as safely and securely as it would be within the UK and under the GDPR including:
7.2.1 Ensuring that any information transferred outside the EEA is handled in accordance with the EU-U.S. Privacy Shield Framework and Swiss-U.S. Privacy Shield Framework
7.3 Data security is very important to Us, and to protect your data We have taken suitable measures to safeguard and secure data collected through Our Site.
7.4 Unfortunately the transmission of information via the internet is not completely secure. Although we will dour best to protect your personal data, we cannot complete guarantee the security of your data transmitted to our site, and any transmission is at your own risk. Once we have received your information, we will restrict procedures and security features to try to prevent unauthorised access, and will notify you without delay if we become aware of a breach likely to adversely affect your personal data or privacy.
Steps We take to secure and protect your data include:
7.4.1 Server side encryption of personal information
7.4.2 Strict access limitation and logging for our physical servers
7.4.3 Limited and heavily monitored access to our front end systems
- Do We Share Your Data?
8.1 We may share your data with other companies in Our group for the reasons listed in 6.2. If applicable this includes our holding company and its subsidiaries.
8.2 We may sometimes contract with third parties to supply products and services to you on Our behalf. These may include payment processing, delivery of goods, 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.
8.3 We may compile statistics about the use of Our Site including data on traffic, usage patterns, user numbers, sales, and other information. All such data will be anonymised and will not include any personally identifying data, or any anonymised data that can be combined with other data and used to identify you. We may from time to time share such data with third parties such as prospective investors, affiliates, partners, and advertisers. Data will only be shared and used within the bounds of the law.
8.4 We may sometimes use third party data processors that are located outside of the European Economic Area (“the EEA”) (The EEA consists of all EU member states, plus Norway, Iceland, and Liechtenstein). Where We transfer any personal data outside the EEA, We will take all reasonable steps to ensure that your data is treated as safely and securely as it would be within the UK and under the GDPR.
8.5 In certain circumstances, We may be legally required to share certain data held by Us, which may include your personal data, for example, where We are involved in legal proceedings, where We are complying with legal requirements, a court order, or a governmental authority.
- What Happens If Our Business Changes Hands?
9.2 In the event that any of your data is to be transferred in such a manner, you may not be contacted in advance and informed of the changes.
- How Can You Control Your Data?
10.1 In addition to your rights under the GDPR, set out in section 4, when you submit personal data via Our Site, you may be given options to restrict Our use of your data. In particular, We aim to give you strong controls on Our use of your data for direct marketing purposes (including the ability to opt-out of receiving emails from Us which you may do by unsubscribing using the links provided in Our emails and at the point of providing your details and by managing your Account).
10.2 You may also wish to sign up to one or more of the preference services operating in the UK: The Telephone Preference Service (“the TPS”), the Corporate Telephone Preference Service (“the CTPS”), and the Mailing Preference Service (“the MPS”). These may help to prevent you receiving unsolicited marketing. Please note, however, that these services will not prevent you from receiving marketing communications that you have consented to receiving.
- Your Right to Withhold Information
11.1 You may access certain areas of Our Site without providing any data at all. However, to use all features and functions available on Our Site you may be required to submit or allow for the collection of certain data.
- How Can You Access Your Data?
You have the right to ask for a copy of any of your personal data held by Us (where such data is held). Under the GDPR, no fee is payable and We will provide any and all information in response to your request free of charge. Please contact Us for more details at email@example.com, or using the contact details below in section 14.
- Contacting Us