We collect, use and are responsible for certain personal information about you. When we do so we are subject to the General Data Protection Regulation, which applies across the European Union (including in the United Kingdom) and we are responsible as ‘controller’ of that personal information for the purposes of those laws.
It would be helpful to start by explaining some key terms used in this policy:
|We, us, our||Precognitive Acumen Limited (company number 10516873) and its subsidiary PAL Stats Limited (company number 10517147)|
|Personal information||Any information relating to an identified or identifiable individual|
Personal information we collect about you
We may collect and use the following personal information about you:
- Your name and contact information, including email address and telephone number and company details
- Information to enable us to check and verify your identity, e.g. your date of birth
- Location data, if you choose to give this to us
- Your billing information, transaction and payment card information
- Your professional interests
- Your professional online presence, e.g. LinkedIn profile
- Information about how you use our website, IT, communication and other systems
- Your responses to surveys and promotions
This personal information is required to provide products and services to you. If you do not provide personal information we ask for, it may delay or prevent us from providing products and services to you.
How your personal information is collected
We collect most of this personal information directly from you—in person, by telephone, or email and/or via our website.
How and why we use your personal information
Under data protection law, we can only use your personal information if we have a proper reason for doing so, which includes:
- To comply with our legal and regulatory obligations
- For the performance of our contract with you or to take steps at your request before entering into a contract
- For our legitimate interests or those of a third party
- Where you have given consent
A legitimate interest is when we have a business or commercial reason to use your information, so long as this is not overridden by your own rights and interests.
The table below explains what we use (process) your personal information for and our reasons for doing so:
|What we use your personal information for||Our reasons|
|To provide products and services to you||For the performance of our contract with you or to take steps at your request before entering into a contract|
Conducting checks to identify our customers and verify their identity
Other processing necessary to comply with professional, legal and regulatory obligations that apply to our business, e.g. under health and safety regulation or rules issued by our professional regulator
|To comply with our legal and regulatory obligations|
|Gathering and providing information required by or relating to audits, enquiries or investigations by regulatory bodies||To comply with our legal and regulatory obligations|
|Ensuring business policies are adhered to, e.g. policies covering security and internet use||For our legitimate interests or those of a third party, i.e. to make sure we are following our own internal procedures so we can deliver the best service to you|
|Operational reasons, such as improving efficiency, training and quality control||For our legitimate interests or those of a third party, i.e. to be as efficient as we can so we can deliver the best service for you at the best price|
|Ensuring the confidentiality of commercially sensitive information||
For our legitimate interests or those of a third party, i.e. to protect trade secrets and other commercially valuable information
To comply with our legal and regulatory obligations
|Statistical analysis to help us manage our business, e.g. in relation to our customer base, product range or other efficiency measures||For our legitimate interests or those of a third party, i.e. to be as efficient as we can so we can deliver the best service for you at the best price|
|Updating customer records||
For the performance of our contract with you or to take steps at your request before entering into a contract
To comply with our legal and regulatory obligations
For our legitimate interests or those of a third party, e.g. making sure that we can keep in touch with our customers about existing orders and new products
|Ensuring safe working practices, staff administration and assessments||
To comply with our legal and regulatory obligations
For our legitimate interests or those of a third party, e.g. to make sure we are following our own internal procedures and working efficiently so we can deliver the best service to you
We may use your personal information to send you updates (by email, telephone or post) about our products and services, including offers, newsletters or new products or services. We will ask for this consent from you separately and clearly.
We will always treat your personal information with the utmost care and never sell or share it with other organisations outside of our group for marketing purposes.
You have the right to opt out of receiving promotional communications at any time by:
- Contacting us at firstname.lastname@example.org
- Using the ‘unsubscribe’ link in emails
We may ask you to confirm or update your marketing preferences if you instruct us to provide further products or services in the future, or if there are changes in the law, regulation, or the structure of our business.
We may record and keep track of conversations you have with us including phone calls, letters, emails or any other kinds of communication. We may use these recordings to check your instructions to us, assist with dispute resolution, assess and improve our services and for training purposes.
Who we share your personal information with
We may share personal information with:
- Companies within our group
- Third parties we use to help deliver our products and services to you, e.g. payment service providers
- Other third parties we use to help us run our business, e.g. marketing agencies or website hosts
- Third parties approved by you, e.g. social media sites you choose to link your account to or third party payment providers.
We only allow our service providers to handle your personal information if we are satisfied they take appropriate measures to protect your personal information. We also impose contractual obligations on service providers relating to ensure they can only use your personal information to provide services to us and to you.
We may disclose and exchange information with law enforcement agencies and regulatory bodies to comply with our legal and regulatory obligations.
We may also need to share some personal information with other parties, such as potential buyers of some or all of our business or during a re-structuring. Usually, information will be anonymised but this may not always be possible. The recipient of the information will be bound by confidentiality obligations.
Where your personal information is held
Information may be held at our offices and those of our third party agencies, service providers, representatives and agents as described above (see above: ‘Who we share your personal information with’).
Some of these third parties may be based outside the European Economic Area. For more information, including on how we safeguard your personal information when this occurs, see below: ‘Transferring your personal information out of the EEA’.
How long your personal information will be kept
We will keep your personal information while you have an account with us or we are providing products or services to you. Thereafter, we will keep your personal information for as long as is necessary:
- To respond to any questions, complaints or claims made by you or on your behalf
- To show that we treated you fairly
- To keep records required by law.
We will not retain your personal information for longer than necessary for the purposes set out in this policy. Different retention periods apply for different types of personal information.
When it is no longer necessary to retain your personal information, we will delete or anonymise it.
Transferring your personal information out of the EEA
To deliver services to you, it is sometimes necessary for us to share your personal information outside the European Economic Area (EEA) including:
- With your and our service providers located outside the EEA
- With our consultants located outside of the EEA
- If you are based outside the EEA
These transfers are subject to special rules under European and UK data protection law.
We will only share your personal information with countries outside of the EEA which have been assessed by the European Commission as providing an adequate level of protection for personal information including, but not limited to, Israel and United States of America as well as organisations which are part of the Privacy Shield Framework.
If you would like further information please contact us (see ‘How to contact us’ below).
You have the following rights, which you can exercise free of charge:
- The right to be provided with a copy of your personal information
- The right to require us to correct any mistakes in your personal information
- The right to require us to delete your personal information in certain situations
- The right to require us to restrict processing of your personal information in certain circumstances
- The right to receive the personal information you provided to us, in a structured, commonly used and machine-readable format and/or transmit that data to a third party in certain situations
- The right to object:
- at any time to your personal information being processed for direct marketing (including profiling);
- in certain other situations to our continued processing of your personal information, e.g. processing carried out for the purpose of our legitimate interests.
- The right not to be subject to a decision based solely on automated processing (including profiling) that produces legal effects concerning you or similarly significantly affects you
If you would like to exercise any of those rights, please:
- Email, call or write to us – see below: ‘How to contact us’;
- Let us have enough information to identify you;
- Let us have proof of your identity and address; and
- Let us know what right you want to exercise and the information to which your request relates.
Keeping your personal information secure
We have appropriate security measures to prevent personal information from being accidentally lost, or used or accessed unlawfully. We limit access to your personal information to those who have a genuine business need to access it. Those processing your information will do so only in an authorised manner and are subject to a duty of confidentiality.
We also have procedures in place to deal with any suspected data security breach. We will notify you and any applicable regulator of a suspected data security breach where we are legally required to do so.
How to complain
We hope that we can resolve any query or concern you may raise about our use of your information.
The General Data Protection Regulation also gives you right to lodge a complaint with a supervisory authority, in particular in the European Union (or European Economic Area) state where you work, normally live or where any alleged infringement of data protection laws occurred. The supervisory authority in the UK is the Information Commissioner who may be contacted at https://ico.org.uk/concerns or telephone: 0303 123 1113.
This privacy notice was published on 24 August 2018 and last updated on 20 September 2018.
We may change this privacy notice from time to time—when we do we will inform you via our website or by contacting you.
How to contact us
If you wish to contact us you may:
- Email us at email@example.com
- Write to us at Holmbury, 57 Church Green Road, Bletchley, Milton Keynes, MK3 6BY
- Call us on +44 (0)1908 921000.