PRIVACY NOTICE FOR CUSTOMERS OF PALAGAN LIMITED
Purpose of Notice
We, Palagan Limited, company number: 2981704 whose registered office is at, Room 1.1 London Heliport. Bridges Court Road. London. SW11 3BE, is the controller and accordingly responsible for the personal information about you which we may hold (personal data).
We are required under data protection legislation (and in particular the General Data Protection Regulation, which came into force on 25th May 2018) to notify you of the information contained in this privacy notice.
This notice explains to you how we collect and process your personal data through your use of our website and prior to, during and after the supply of products or the provision of services by us and your rights in relation to that personal data.
This privacy notice supplements any other notices we may have previously provided to you and should be read in conjunction with them.
Website and Third Party Links
We do not control these third-party websites or applications and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy notice of every third party website you visit.
2. DATA WE COLLECT
"Personal data" means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).
Relevance of Data
The personal data we collect about you will depend on the products we supply and the services we provide. We will however only collect personal data, which is relevant in the context of our business relationship with you.
Categories of Data
We will collect and process the following categories of personal data:Identity Data including personal contact details such as name and title.
Contact Data including addresses, telephone numbers, and personal email addresses.
Financial Data including bank account details, your debit or credit card information, your credit rating information (which we acquire from credit reference agencies) and other banking information.
Transaction Data including your billing history and products and services you use and anything else relating to your account.
Profile Data including information you provide to us in your communications with us, including for example information you provide to us when participating in market or product surveys.
Technical Data including information on how you use our products and services.
Marketing and Communications Data including your preferences in receiving marketing information from us and our third parties and your communication preferences.
Special Categories of Personal Data
We do not collect any of this data about you (which includes in particular details about your race or ethnicity, religious or philosophical beliefs, political opinions, trade union membership), nor do we collect any information about criminal convictions or offences.
Failure to provide Data
Where we need to collect personal data by law or under the terms of our contract (or proposed contract) to provide products or services to you and you fail to provide that data when requested, we may not be able to perform the contract we have, or are trying to enter into, with you. In such event, we may have to terminate the contract (or any negotiations in relation to a proposed contract) but we will notify you if this is the case at the time.
Change of Data
It is important that personal data we hold about you is accurate and up to date and we ask you to keep us informed if your personal data changes during your relationship with us.
3. HOW WE COLLECT YOUR DATA
You may give us your Identity, Contact, Financial and Transaction Data when you use our website, when you purchase our products or use our services, or during the sales process, or in the course of our providing products and services to you throughout the period of your contract with us.
Third Parties or Publicly Available Sources
We may receive personal data and additional information from third parties including credit reference agencies or other background agencies and business directories.
4. HOW WE USE YOUR DATA
We will only use your personal data for a particular reason and where there is a legal basis to do so.
We will use your personal data in the following circumstances in particular:
- Where we need to perform a contract we have entered into with you or are taking steps to enter into with you.
- Where we need to comply with a legal obligation or are required to do so by law.
- Where you have consented to such use.
- Where it is necessary for the purposes of our own legitimate business interests (or those of a relevant third party) except where the law requires such interests to be overridden by your interests, rights or freedoms.
You will only receive marketing messages from us if you have requested information, or purchased products or services, from us and you have not opted out of receiving such messages.
You can ask us to stop sending you marketing messages at any time by following the opt-out links on any marketing message sent to you or by contacting us at any time.
Where you opt out of receiving these marketing messages, this will not apply to personal data already provided to us as a result of a product/service purchase, warranty registration, product/service experience or other commercial transaction.
5. DATA SHARING
Sharing Personal Data with Third Parties
We may share your personal data with third parties where required by law, or where it is necessary to perform our contract with you or where we have a legitimate business interest in doing so.
"Third parties" may include third party service providers, being parties for example which provide software, technical or professional services to us, and may also include other members of the Plastics Capital Group, where it is required for example as part of the sales or project process or fulfilling our contract with you.
Any third-party service provider with whom your personal data has been shared will be required to take appropriate security measures to protect such data in line with our policies and the law and to process your personal data only for specified lawful purposes and not for their own purposes.
Transfer outside the EU
We will not transfer your personal data outside the EU without your consent and then only on terms approved by us.
6. DATA SECURITY
We have put in place appropriate security measures to prevent personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed and to deal with any suspected data security breach.
We will notify you and any applicable regulator of a suspected breach where we are legally required to do so.
We limit access to personal data to only those of our employees or agents on a strictly need to know basis. They will only process your personal data on our instructions and will be subject to a duty of confidentiality.
7. DATA RETENTION
Length of Retention
We will only retain your personal data for as long as is necessary to fulfil the purposes it was collected for, including the purposes of satisfying any legal, accounting, or reporting requirements.
By law, for example, we are required for tax purposes to keep certain information about our customers (including Contact, Identity, Financial and Transaction Data) for a period of time after they cease being customers.
Determination of Retention Period
To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of your personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purpose for which such data is being processed and any applicable legal requirements.
8. YOUR RIGHTS IN CONNECTION WITH DATA
Access, Correction, Erasure and other Rights
By law you have the right in certain circumstances to:
If you want us to verify, correct or request erasure of your personal data, or object to the processing of your personal data, or request that we transfer a copy of your personal data to another party, please contact our Data Protection Compliance Manager in writing.
No Fee Usually Required
You will not have to pay a fee to access your personal data or exercise any of your other rights referred to above. However, we may charge a reasonable fee if your request is unfounded or excessive.
Refusal of Request
We may also refuse your request for access in certain circumstances where your request is unfounded or excessive.
9. WITHDRAWAL OF CONSENT
Right to Withdraw
In those circumstances where you have provided your consent to the collection, processing and transfer of your personal data for a particular purpose, you have the right to withdraw your consent for that specific processing at any time.
To withdraw your consent, please notify our Data Protection Compliance Manager in writing.
Processing following Withdrawal
Once we have received notification that you have withdrawn your consent, we will no longer process your data for the purpose you originally agreed to, unless there remains another lawful basis for doing so.
10 DATA PROTECTION COMPLIANCE MANAGER AND QUESTIONS
Details and Contact Information
If you have any questions about this privacy notice or how we handle your personal information, please contact Adam Priestley, our Data Protection Compliance Manager, at Palagan Limited, Albion Works, Tavistock Street, Dunstable. LU6 1NE. or email firstname.lastname@example.org
Right to Complain
You have the right to make a complaint at any time to the Information Commissioner's Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk). However, as we take our obligations seriously in relation to your personal information, we would ask and encourage you to contact us first if you have any issues or concerns so that we may address and try to resolve these before you approach the ICO.
12 EFFECTIVE DATE AND UPDATE
This version is effective 25th May 2018.
We reserve the right to update this privacy notice at any time, and we will provide you with a new privacy notice when we make any substantial updates.