We are committed to safeguarding the privacy of our website visitors and service users.
This policy applies where we are acting as a data controller with respect to the personal data of our website visitors and service users; in other words, where we determine the purposes and means of the processing of that personal data.
Our website incorporates privacy controls which affect how we will process your personal data. By using the privacy controls, you can specify whether you would like to receive direct marketing communications and limit the publication of your information. You can access the privacy controls via www.pipmg.org/members/contact-preferences.
In this policy, “we”, “us” and “our” refer to PIPMG Ltd.
How we use your personal data
In this section we have set out:
- The general categories of personal data that we may process
- The purposes for which we may process personal data
- The legal bases of the processing
We may process data about your use of our website and services (“usage data”). The usage data may include your IP address, geographical location, browser type and version, operating system, referral source, length of visit, page views and website navigation paths, as well as information about the timing, frequency and pattern of your service use. The source of the usage data is our web page visitor logging system.This usage data may be processed for the purposes of analysing the use of the website and services. The legal basis for this processing is our legitimate interests, namely monitoring and improving our website and services.
We may process your information included in your personal profile on our website(“profile data”). The profile data may include your name, address, telephone number, email address and employment details. The profile data may be processed for the purposes of enabling and monitoring your use of our website and services. The legal basis for this processing is our legitimate interests, namely the proper administration of our website and business. Note that we do not hold any financial details about you other than a record of payments that you have made for goods and services that we supply. We hold no details of the credit/debit cards or PayPal accounts which may have been used to make payments.
We may process your personal data that are provided in the course of the use of our services (“service data”). The service data may include your name, address, telephone number, email address and employment details. The source of the service data is you. The service data may be processed for the purposes of operating our website, providing our services and communicating with you. The legal basis for this processing is our legitimate interests, namely the performance of a contract between you and us and/or taking steps, at your request, to enter into such a contract.
We may process information contained in or relating to any communication that you send to us (“correspondence data”). The correspondence data may include the communication content and metadata associated with the communication. Our website will generate the metadata associated with communications made using the website contact forms. The correspondence data may be processed for the purposes of communicating with you and record-keeping. The legal basis for this processing is our legitimate interests, namely the proper administration of our website and business and communications with users.
We may process any of your personal data identified in this policy where necessary for the establishment, exercise or defence of legal claims, whether in court proceedings or in an administrative or out-of-court procedure. The legal basis for this processing is our legitimate interests, namely the protection and assertion of our legal rights, your legal rights and the legal rights of others.
We may process any of your personal data identified in this policy where necessary for the purposes of obtaining or maintaining insurance coverage, managing risks, or obtaining professional advice. The legal basis for this processing is our legitimate interests, namely the proper protection of our business against risks.
In addition to the specific purposes for which we may process your personal data set out above, we may also process any of your personal data where such processing 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.
Please do not supply any other person’s personal data to us, unless we prompt you to do so.
We will use your personal data for the purposes of automated decision-making in relation to:
- Checking your username and password when logging in to the members’ area of the website
- Checking your eligibility for discounts that we may offer from time to time for goods and services
- Populating parts of the website which allow you to update and maintain the personal data which we hold about you
Providing your personal data to others
We may disclose your personal data to our insurers and/or professional advisers 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.
Financial transactions relating to our website and services are handled by our payment services provider, PayPal and Stripe. We will share transaction data with our payment services provider only to the extent necessary for the purposes of processing your payments, refunding such payments and dealing with complaints and queries relating to such payments and refunds. You can find information about the payment services provider’s privacy policies and practices here for Paypal and here for Stripe.
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 may also disclose your personal data where such disclosure is necessary for the establishment, exercise or defence of legal claims, whether in court proceedings or in an administrative or out-of-court procedure.
International transfers of your personal data
In this section, we provide information about the circumstances in which your personal data may be transferred to other countries.
The hosting facilities for our website are situated in the UK.
We use PayPal to process financial transactions on our behalf. PayPal is based in Luxembourg. You can find information about the payment services provider’s privacy policies and practices here.
We use Stripe to process financial transactions on our behalf. Stripe is Stripe is an Irish-American financial services and software as a service (SaaS) company dual-headquartered in San Francisco, United States and Dublin, Ireland. You can find information about the payment services provider’s privacy policies and practices here.
We use Mailchimp for sending newsletters and information to our members. Mailchimp is based in the USA. You can find information about Mailchimp’s privacy policies and practices here.
Retaining and deleting personal data
This section sets out our data retention policies and procedure, which are designed to help ensure that we comply with our legal obligations in relation to the retention and deletion of personal data.
Personal data that we process for any purpose or purposes shall not be kept for longer than is necessary for that purpose or those purposes.
For PIPMG members, we will retain your personal (and non-personal) data for as long as you remain a member of PIPMG. We will arrange to have your details removed from our database and mailing lists as soon as is reasonably possible after you have informed us in writing or by email to firstname.lastname@example.org that you no longer wish to be a member of PIPMG.
For attendees at PIPMG events, we will retain your personal data for a period of 3 years from the date of the event. After this, the data will be ‘anonimised’ so that it cannot be associated with an individual.
Notwithstanding the other provisions of this section, we may retain your personal data where such retention 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.
Security of personal data
We will take appropriate technical and organisational precautions to secure your personal data and to prevent the loss, misuse or alteration of your personal data.
We will store your personal data on secure servers, personal computers and mobile devices, and in secure manual record-keeping systems.
Passwords are stored in encrypted form.
Data relating to your enquiries and financial transactions that is sent from your web browser to our web server, or from our web server to your web browser, will be protected using encryption technology.
You acknowledge that the transmission of unencrypted (or inadequately encrypted) data over the internet is inherently insecure, and we cannot guarantee the security of data sent over the internet.
You should ensure that your password is not susceptible to being guessed, whether by a person or a computer program. You are responsible for keeping the password you use for accessing our website confidential and we will not ask you for your password (except when you log in to our website).
We may update this policy from time to time by publishing a new version on our website.
You should check this page occasionally to ensure you are happy with any changes to this policy.
We may notify you of changes to this policy by email or by bringing the changes to your attention on the website.
In this section, we have summarised the rights that you have under data protection law. Some of the rights are complex, and not all of the details have been included in our summaries. Accordingly, you should read the relevant laws and guidance from the regulatory authorities for a full explanation of these rights.
Your principal rights under data protection law are:
- the right to access
- the right to rectification
- the right to erasure
- the right to restrict processing
- the right to object to processing
- the right to data portability
- the right to complain to a supervisory authority
- the right to withdraw consent.
You have the right to confirmation as to whether or not we process your personal data and, where we do, access to the personal data, together with certain additional information. That additional information includes details of the purposes of the processing, the categories of personal data concerned and the recipients of the personal data. Providing the rights and freedoms of others are not affected, we will supply to you a copy of your personal data. The first copy will be provided free of charge, but additional copies may be subject to a reasonable fee. You can access your personal data by visiting www.pipmg.org/members/your-details when logged into our website.
You have the right to have any inaccurate personal data about you rectified and, taking into account the purposes of the processing, to have any incomplete personal data about you completed.
In some circumstances you have the right to the erasure of your personal data without undue delay. Those circumstances include: the personal data are no longer necessary in relation to the purposes for which they were collected or otherwise processed; you withdraw consent to consent-based processing; you object to the processing under certain rules of applicable data protection law; the processing is for direct marketing purposes; and the personal data have been unlawfully processed. However, there are exclusions of the right to erasure. The general exclusions include where processing is necessary: for exercising the right of freedom of expression and information; for compliance with a legal obligation; or for the establishment, exercise or defence of legal claims. Note that erasure of your PIPMG membership data will automatically mean that you are no longer a member of PIPMG.
You have the right to object to our processing of your personal data on grounds relating to your particular situation, but only to the extent that the legal basis for the processing is that the processing is necessary for: the performance of a task carried out in the public interest or in the exercise of any official authority vested in us; or the purposes of the legitimate interests pursued by us or by a third party. If you make such an objection, we will cease to process the personal information unless we can demonstrate compelling legitimate grounds for the processing which override your interests, rights and freedoms, or the processing is for the establishment, exercise or defence of legal claims.
You have the right to object to our processing of your personal data for scientific or historical research purposes or statistical purposes on grounds relating to your particular situation, unless the processing is necessary for the performance of a task carried out for reasons of public interest.
To the extent that the legal basis for our processing of your personal data is:
- that the processing is necessary for the performance of a contract to which you are party or in order to take steps at your request prior to entering into a contract
and such processing is carried out by automated means, you have the right to receive your personal data from us in a structured, commonly used and machine-readable format. However, this right does not apply where it would adversely affect the rights and freedoms of others.
If you consider that our processing of your personal information infringes data protection laws, you have a legal right to lodge a complaint with a supervisory authority responsible for data protection. You may do so in the EU member state of your habitual residence, your place of work or the place of the alleged infringement.
To the extent that the legal basis for our processing of your personal information is consent, you have the right to withdraw that consent at any time. Withdrawal will not affect the lawfulness of processing before the withdrawal.
You may exercise any of your rights in relation to your personal data by written notice to us or by email to email@example.com
Third party websites
Our website includes hyperlinks to, and details of, third party websites.
We have no control over, and are not responsible for, the privacy policies and practices of third parties.
Personal data of children
Our website and services are targeted at persons over the age of 18.
If we have reason to believe that we hold personal data of a person under that age in our databases, we will delete that personal data.
Please let us know if the personal information which we hold about you needs to be corrected or updated. Alternatively, you can update your personal details yourself by visiting www.pipmg.org/members/your-details when logged into our website.
A cookie is a file containing an identifier (a string of letters and numbers) that is sent by a web server to a web browser and is stored by the browser. The identifier is then sent back to the server each time the browser requests a page from the server.
Cookies may be either &ldsquo;persistent&rdsquo; cookies or &ldsquo;session&rdsquo; cookies: a persistent cookie will be stored by a web browser and will remain valid until its set expiry date, unless deleted by the user before the expiry date; a session cookie, on the other hand, will expire at the end of the user session, when the web browser is closed
Cookies do not typically contain any information that personally identifies a user, but personal information that we store about you may be linked to the information stored in and obtained from cookies.
Cookies that we use
Most browsers allow you to refuse to accept cookies and to delete cookies. The methods for doing so vary from browser to browser, and from version to version. You can however obtain up-to-date information about blocking and deleting cookies via these links:
- https://support.google.com/chrome/answer/95647?hl=en (Chrome)
- https://support.mozilla.org/en-US/kb/enable-and-disable-cookies-website-preferences (Firefox)
- http://www.opera.com/help/tutorials/security/cookies/ (Opera)
- https://support.microsoft.com/en-gb/help/17442/windows-internet-explorer-delete-manage-cookies (Internet Explorer)
- https://support.apple.com/kb/PH21411 (Safari)
- https://privacy.microsoft.com/en-us/windows-10-microsoft-edge-and-privacy (Edge)
Blocking all cookies will have a negative impact upon the usability of many websites.
If you block cookies, you will not be able to use all the features on our website.
Data protection registration
We are registered as a data controller with the UK Information Commissioner’s Office.
Our data protection registration number is Z867401X.