ProperComms are committed to ensuring that any personal data supplied by you is collected and held securely and processed lawfully.
This Notice explains when and why we collect personal information about people who visit our website, how we use it, the conditions under which we may disclose it to others and how we keep it secure.
This Notice was last updated in Dec 2019.
For the purpose of this Privacy Notice, ‘we’ and ‘us’ refers to ProperComms Limited, whose registered address is:
148 Great Charles Street
Personal Information is any personally identifiable information, such as your email address, name, home or business address, telephone number, bank details or online identifier, which can directly or indirectly identify you. This definition shall, where applicable, incorporate the definitions provided in the EU Regulation 2016/679 – the General Data Protection Regulation, commonly referred to as ‘GDPR’.
What information may we collect about you?
When you interact with us in the different ways described below, we may ask you for the following information:
- Personal and contact details, for example; your name, email address, address, phone number, payment information;
- Personal and contact details you give us when subscribing to receive emails, newsletters, service provision updates or marketing information from us;
- Information we collect via cookies or similar technologies stored on your device
- Technical information, including the IP address used to connect your computer or device to the Internet, your log in information, browser type and version, time zone settings, browser plug-in type and versions, operating systems, platform and geographical location;
- Information about your website visit, including the full URL, clickstream to, through and from our website (including date and time, pages you have viewed, choices you make during your visit, page response times, errors (on page and download), length of page visits, page interaction information (scrolling, clicks and mouse-overs) and methods used to browse away from the page;
- Information from social media activity (such as likes, shares, tweets) when you interact with us on social media;
- Information and records obtained when you contact our team by telephone, email or web form;
- Information you provide if you report a problem with our website and service;
- Additional information which you provide voluntarily and/or which we may ask from you to better understand you and your interests
How, when and why do we collect Personal Information?
How and when do we collect your Personal Information?
We may collect your Personal Information when you request services from us (or otherwise contact us from time to time) by:
- Entering your data onto our website
- By directly contacting our business, via telephone, email, web form or our social media channels;
- When you communicate with one of our team by telephone, email, web form or our social media channels;
- Another business or organisation passing your details to us
Why do we collect your Personal Information?
We collect and use your Personal Information because it is necessary to obtain certain details including Personal Information from you to provide you with the services you have requested, and it is in our legitimate interests while operating our business, including:
- Providing the requested services and/or information to you;
- Responding to your queries;
- Transmitting Personal Information between our offices or functions for internal administrative purposes;
- Hosting and maintaining our websites;
- Ensuring network and information security; and/or
- Carrying out direct marketing activities
However, we will only collect, use and handle your Personal Information when:
- It is necessary for our legitimate interests in connection with carrying out our business, if, in each case, these interests are in line with applicable laws and your legal rights; and/or
- Where you have agreed: and/or
- Where this is necessary for legal obligations which apply to us
How we use Personal Information provided to us
We undertake processing of your Personal Information on the legal basis that it is necessary to perform the contract with you and to provide the services we have agreed to provide you. Where we have not entered into a contract with you, we may also carry out this processing because in that pre-contractual stage where we consider it is necessary in our legitimate business interests to deal with requests, enquiries, or comments you have made to us.
Pre-contract processing – We collect your Personal Information which you provide to us when applying for a service with us to comply with our legal obligations and to carry our fraud checks. We may also process your Personal Information for this purpose where we consider it necessary for the performance of the contract with you, or otherwise with your consent.
Enhancing your experience and our business – We may use your Personal Information to administer our website and for internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes. We may also share limited Personal Information with social media platforms to provide you with tailored services relevant to the services you have requested or received.
Other lawfully permitted processing – We may also use any Personal Information that you provide to us. For example, to other companies within ProperComms or to other organisations required to provide you with the requested service. If you choose not to provide Personal Information requested by us, we may not be able to provide you with the services and/or information you have requested or otherwise fulfil the purpose(s) for which we have asked for the Personal Information.
Marketing – Where legally permitted to do so where you have provided us with your contact details and have agreed to be contacted for marketing purposes, we may contact you by telephone, by email or by post for marketing purposes relating to our services, our website, and/or to research opinion on proposed business developments.
Marketing Opt-Out – You are entitled to opt out from receipt of marketing communications at any time, and free of charge by using the unsubscribe option that we include in any marketing email or other marketing material received from us.
How and when do we share information with third parties?
Some services that we provide require the involvement of carefully selected third parties. We have taken steps to ensure that Personal Information is adequately protected. The third parties involved may include business partners, suppliers, sub-contractors, advertisers and search engine providers.
Where we employ third party companies or individuals to process Personal Information provided by us on our behalf for business functions, including (without limitation) IT, marketing, legal, accounting, consulting and other professional service providers, and providers of other services related to our business.
Portions of our services may be provided by organisations with which we have a contractual relationship, including subcontractors, and, accordingly, your Personal Information may be disclosed to them. We only provide these organisations with the information that they need to be able to perform services and have an agreement in place that restrict how they can process Personal Information.
Sharing within ProperComms and to Service Providers
The Personal Information you provide to us is collected by ProperComms. However, where we are legally permitted to do so in accordance with this Privacy Notice, we may transfer your Personal Information between and to other functions or offices within the same corporate group as defined by Section 1159 of the Companies Act for the aforementioned purpose.
International Transfers of your Personal Information
We may share or store your Personal Information with our third-party service providers based outside the European Economic Area (‘EEA’) who we engage to help us, and amongst other things, fulfil your order, process your details and execute support services. We only transfer your Personal Information outside of the EEA:
- Where the transfer is to a place that is regarded by the European Commission as providing adequate protection for your Personal Information; or
- Where we have put in place appropriate safeguards;
- Where you have consented to it, or there is another legal basis to allow us to make the transfer
Sharing with other third parties
We may also provide your information to other third parties as part of a sale of some or all our business and assets as part of any business restructuring or reorganisation, or regulators and law enforcement agencies, where we are required by law to do so, where necessary for the purposes of preventing and detecting fraud, other criminal offences and/or to ensure network and information security. However, we will take steps with the aim of ensuring that your privacy rights continue to be protected.
How long do we store Personal Information for?
It is our policy to retain your Personal Information for the length of time required for the specific purpose or purposes that it was collected, which are set out in this Privacy Notice. However, on occasion we may be obliged to store some data for a longer period, for example, where a longer period is required by applicable laws. In this case, we will ensure that your Personal Data will continue to be treated in accordance with this Privacy Notice.
Security and Confidentiality
We employ appropriate security measures to protect your Personal Information and guard against access by unauthorised persons.
Storage of any information is on our secure servers, located in all year round and around the clock monitored and guarded data centres in the United Kingdom.
When you give us Personal Information, we take steps to ensure that it’s treated securely. When you are on a secure page, a lock icon will appear in web browsers such as Google Chrome, Mozilla Firefox and Microsoft Edge. Any sensitive information is encrypted and protected with the 256 Bit encryption on SSL and where necessary comply with our PCI compliance obligations.
Our website may contain links to other websites run by other organisations. This Privacy Notice applies only to our website. As such we encourage you to read the privacy notices or policies on the other websites you visit. We cannot be responsible for the privacy policies and practices of other websites even if you access them using links from our website. In addition, if you linked to our website from a third-party website, we cannot be responsible for the privacy policies and practices of the owners and operators of that third-party website and recommend that you check the notice or policy of that third-party website.
Unfortunately, the transmission of information via the Internet is not completely secure. As such we cannot guarantee the security of your information when it is transmitted to our website or from third-party websites. We utilise strict procedures and security features to prevent unauthorised access, however transmission is entirely at your own risk.
We acknowledge that the information you provide may be confidential. We do not sell, rent, distribute or otherwise make Personal Information commercially available to any third party, but we may share information with our service providers for the purposes set out in this Privacy Notice. We will keep your information confidential and protect it in accordance with our Privacy Notice and all applicable laws.
You may withdraw your consent to receiving marketing at any time by emailing email@example.com. It is important to us that you are in control of your own information. As a result, we offer the following controls:
- You may request access to or copies of the Personal Information that we hold about you. If you wish to exercise this right, please contact us via email at firstname.lastname@example.org or in writing to our registered address. No charge will be made for first copies, however additional copies may incur an administrative charge of £10;
- If you believe that any information we have about you is incorrect, or incomplete, please contact us as soon as possible via email at email@example.com. We will take steps to seek to correct or update any information if we are satisfied the information we hold is inaccurate;
- You may request that your Personal Information be deleted, where it is no longer necessary for the purposes for which it is being processed and provided there is no other lawful basis for which we may continue to process such information;
- To the extent we are processing your Personal Information to meet our legitimate interests (as set out above), you may object to the processing of your Personal Information by us. If we are unable to demonstrate our legitimate grounds for that processing, we will no longer process your Personal Information for those purposes;
- You may object to our processing as set out above;
- You may withdraw any consent given to processing; and
- Where we are processing your Personal Information automatically for the purposes of performing our contract with you, you may have the right to request that the Personal Information we hold about you to be transferred to a third-party data controller.
We will be happy to assist you and provide you with all rights to which you are entitled in relation to your Personal Information under applicable data protection law.
If you are unhappy with the way that we have handled your Personal Information, you can make a complaint to the Information Commissioners Office (ICO) which is the UK authority responsible for data protection. Contact details are available here, or alternatively please ask us.
Changes to our Privacy Notice
If you have any questions about this Privacy Notice, or you would like to exercise your rights as stated in this Privacy Notice, you may contact us via email at firstname.lastname@example.org or in writing to our registered address:
148 Great Charles Street
When communicating with us please ensure that your query is clear, particularly if it is a request for Personal Information we hold about you.