3. For the purposes of the General Data Protection Regulation 2016/679 (“GDPR”), we are the data controller and our trading address is 71-75 Shelton Street, Covent Garden, London, England, WC2H 9JQ. Our ICO registration number is ZA345736.
“client” is a reference to a client to which PU provides services;
“customer” is a reference to a customer of a client; and
“prospect” is a reference to a prospective customer of a client.
INFORMATION WE COLLECT
Information given to us:
1. An individual may give us personal data about themselves in a number of ways and these include:
2. Using, visiting or interacting with our website (such as filling out a form on our website);
3. Corresponding with us by phone, e-mail or post; and
4. Sending information directly to us, for example when paying our fees
Types of information collected:
1. We may collect the following personal information in relation to a customer or prospect:
full name of the business contact
business contact details (including business address, e-mail address, mobile number and/or business direct dial); and
the business contact’s online business profile.
2. We may collect the following personal information in relation to our clients, suppliers or other enquirers:
name, address, email address and phone number; and
business details (e.g. place of work and company number).
3. We may collect the following personal information in relation to job applicants:
name, address, email address and phone number;
curriculum vitae; and
Technical information we collect about you when you visit our website
1. With regards to each of your visits to our website we or our supplier may automatically collect the following information:
technical information, including the Internet Protocol (IP) address used to connect your computer to the Internet, browser type and version, time zone setting, browser plug-in types and versions, operating system and platform; and
information about your visit, including the full Uniform Resource Locators (URL) clickstream to, through and from our website (including date and time); pages you viewed or searched for; page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs), and methods used to browse away from the page and any phone number used to call our number.
2. Our website may contain links to and from the websites of our partner networks, advertisers, suppliers and affiliates. If you follow a link to any of these websites, please note that these websites have their own privacy policies and that we do not accept any responsibility or liability for these policies. Please check these policies before you submit any personal data to these websites.
Information we receive from other sources
1. We may receive information about customers and prospects from our clients. For example, our client may give us its customer and/or prospect database which contains the information about the customer which is described in paragraph 2.2. Also, our client may be asked to fill out a feedback form on the PU mobile application.
2. We may be working closely with third parties (including, for example, database providers or data licensors) and may receive information about a customer or prospect from them, particularly phone numbers for business contacts.
3. We also may extract information about a customer or prospect which is publicly available on the Internet (for example, we may extract information about contact details of customers or prospects from networking sites such as LinkedIn and keep this information for our own records).
4. We may also receive personal information about customers and prospects from the customers and prospects themselves, for example, via our website or at an exhibition or networking event.
Uses made of the information
Information you give to us.
1. We will use the information provided to us or collected from other sources to pursue the following legitimate interests:
to deliver services to our clients. In essence, PU provides various telemarketing services for its clients. Therefore, we may use databases which we have built in-house or purchased from a third party to contact customers and/or prospects over the phone. The services include:
1. lead generation, where PU sources prospective customers and arranges appointments for our clients;
2. telephone account management, where PU maintains customer relationships on behalf of our clients;
3. exhibition or networking support (e.g. collecting business cards whilst staffing a client exhibition stand or attending a networking event);
4. concluding transactions for our clients (for example, closing a commercial deal for a client); and
5. database building, where PU updates and refines a customer and/or prospect database for its clients;
2. to manage our relationship with our clients;
3. to manage our relationship with customers and prospects on behalf of our clients;
4. to store the information as part of our own records which we may use to provide services to multiple clients;
5. to carry out market research; and
6. to manage any queries or disputes you may have with us or that we have with you.
2. We will also use any personal information in respect of our clients to do what is necessary to carry out our obligations arising from the contract (or potential contract) between PU and the client and to provide the client with the information and services that it request from us. We will also use personal information to invoice the appropriate contact at the client for our services pursuant to the contract between PU and the client. We may also require a certain amount of personal information about the client contact at the pre-contract enquiry stage.
3. Inevitably, there will be an overlap between what we do that is necessary to (a) perform our contract with you and (b) pursue a legitimate interest although we have tried our best to demarcate these as set out above. If you have any questions about these please contact our Data Protection Officer (see paragraph 4).
Information we collect about you from our website
We will use this information for the following legitimate interests:
1. to contact you if you have made an enquiry to us via our online enquiry form;
2. to administer our website and for internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes;
3. to improve our website to ensure that content is presented in the most effective manner, and your online experience is as effective and appropriate as possible, for you and for your computer; and
4. as part of our efforts to keep our website safe and secure.
When we disclose information
1. In order to pursue one of the legitimate interests set out above, we may share personal information with our clients, business partners, professional advisors, debt collectors, suppliers and sub-contractors for the performance of any contract we enter into with them.
2. We may disclose personal information to third parties if we are under a duty to disclose or share personal data in order to comply with any legal obligation, or in order to enforce or apply the terms of a contract.
TRANSMISSION OF PERSONAL INFORMATION OUTSIDE THE EEA
Under the GDPR, you have the following rights if we are processing personal information about you:
1. Right to correction. You have the right to have inaccurate personal data about you rectified.
2. The right to erasure. You have the right to request that we delete your personal data where: (a) the personal data are no longer necessary in relation to the purposes for which they were collected or processed; (b) you withdraw your consent to processing for which we previously obtained your consent; (c) you object to the processing and, as a result, we agree to cease that processing (please see paragraph 7.1.5 for more details); (d) the personal data has been unlawfully processed; and (e) we are required to erase the personal data in order to comply with the law.
3. Right to restriction. You have the right to obtain from us the restriction of processing where: (a) you contest the accuracy of the personal data we hold about you; (b) the personal data has been unlawfully processed; (c) we no longer need the personal data but they are required in limited circumstances; and (d) you object to the processing and, as a result, we agree to cease that processing (please see paragraph 7.1.5 for more details).
4. Right to request transfer. In certain circumstances, you have the right to receive personal data from us in a structured, commonly used and machine-readable format and the right to transmit it to a third party organisation.
5. Right to object. You have the right to raise an objection to any of our processing in paragraphs 5.1 and 5.2. Please tell us if you object to any type of processing that we do and we will work with you to address any concerns you may have.
6. Right to object to marketing. If you do not want us to process your personal data for direct marketing, please tell us and we will ensure that we no longer do this.
7. Right to complain to the ICO. Whilst we would always prefer it if you approached us first about any complaints or queries you may have, you always have the right to lodge a complaint with the Information Commissioner’s Office.
8. Right to request access. You have the right to access personal data we hold about you.
how long we keep personal information
1. We will not keep any personal data about you for any longer than is necessary for the purposes for which the personal data are processed. We also ensure that the data we hold is adequate, relevant, limited to what is necessary, accurate and kept up to date. In addition, we will only process personal data fairly, lawfully and transparently.
2. The nature of what we do for our clients means that our databases are in regular need of refreshment and refining, not necessarily deleting. If a contact retires, we will delete information about that person. If a contact leaves a particular business or sector, but moves to another business or sector, we will ensure that information is updated. If a contact requests not to be contacted, we will add that contact to a separate list to ensure that he or she is not contacted in future. We are mainly targeting the business, not the individual behind the business.
3. We follow a personal data retention policy which determines how long we keep specific types of personal information for. For further information about the criteria we use to determine what periods we keep specific information, please contact our Data Protection Officer (see paragraph 4).
4. It is our policy to keep information about unsuccessful job applicants for no longer than 6 months after the closing of the job application process.
Changes to our privacy NOTICE