1. Purpose of this Policy
This notice describes how we collect and use personal data about you, in accordance with the General Data Protection Regulation (GDPR), the Data Protection Act 1998 and any other national implementing laws, regulations and secondary legislation, as amended or updated from time to time, in the UK (‘Data Protection Legislation’).
Please read the following carefully to understand our practices regarding your personal data and how we will treat it.
2. Who We Are
P.A. Hilton Limited (‘PAH’ or ‘we’ or ‘us’ or ‘our’) gather and process your personal information in accordance with this privacy notice and in compliance with the relevant data protection Regulation and laws. This notice provides you with the necessary information regarding your rights and our obligations, and explains how, why and when we process your personal data.
PAH’s registered office is at Horsebridge Mill, King’s Somborne, Stockbridge, Hampshire, SO20 6PX and we are a company registered in England and Wales under company number 743785. We are registered on the Information Commissioner’s Office Register registration number ZA393717, and act as the data controller.Our designated Data Protection Representatives for PAH are Paul Ingram and Andrew Ward, who can be contacted at email@example.com
3. Purpose of Processing
Your data will be processed in order to:
• Meet our legal, statutory and contractual obligations
• Provide you with our products and services.
• Market PAH products and services to you.
• Provide services to others (in so far as this does not breach client confidentiality).
• Protect PAH against potential claim.
We will never collect unnecessary personal data from you and do not process your information in any way, other than as specified within this policy.
4. The ways we collect data
PAH obtains most personal data from its customers and those who have indicated that they have an interest in PAH products and services.We may collect your personal data in the below ways:
• Business Cards;
• Site visits;
• Attendance at events;
• Social media;
• Third parties and/or publicly available resources (e.g. Companies House, information published in articles/newspapers);
• Other correspondents;
5. The kind of information we hold about you
PAH holds whatever information is provided to it by its customers and suppliers and others.The information we hold about you may include the following:
• your personal details (such as your name and/or address);
• details of contact we have had with you in relation to the provision, or the proposed provision, of our products and/or services;
• details of any products and/or services you have received from us;
• our correspondence and communications with you;
• information about any complaints and enquiries you make to us;
• information from research, surveys, and marketing activities;
• Information we receive from other sources, such as publicly available information.
6. How we use personal data we hold about you
We use your personal information including name, address, email address and telephone number for customer and supplier administration. For example, to handle your order, deliver your products/services, process payments, communicate with you regarding your order, our products, services and promotional offers, update our records and maintain your account with us.
7. Your rights
You have the right to access any personal information that PAH processes about you and to request information about:
• Request access to your personal data. This enables you to receive details of the personal data we hold about you and to check that we are processing it lawfully.
• Request correction of the personal data that we hold about you.
• Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have exercised your right to object to processing (see below).
• Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this basis. You also have the right to object where we are processing your personal information for direct marketing purposes.
• Request the restriction of processing of your personal data. This enables you to ask us to suspend the processing of personal data about you, for example if you want us to establish its accuracy or the reason for processing it.
• Request the transfer of your personal data to you or another data controller if the processing is based on consent, carried out by automated means and this is technically feasible.
If you want to exercise any of the above rights, please email our data protection representatives at firstname.lastname@example.org.
You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request for access is clearly unfounded or excessive. Alternatively, we may refuse to comply with the request in such circumstances.
We may need to request specific information from you to help us confirm your identity and ensure your right to access the information (or to exercise any of your other rights). This is another appropriate security measure to ensure that personal information is not disclosed to any person who has no right to receive it.
8. Data Sharing
Why might you share my personal data with third parties?
We will share your personal data with third parties where we are required by law, where it is necessary to administer the relationship between us or where we have another legitimate interest in doing so.
Which third-party service providers process my personal data?
“Third parties” includes third-party service providers. The following activities are carried out by third-party service providers: IT and cloud services, professional advisory services such as IFS’s, administration and HR services.
All of our third-party service providers are required to take commercially reasonable and appropriate security measures to protect your personal data. We only permit our third-party service providers to process your personal data for specified purposes and in accordance with our instructions.
What about other third parties?
We may share your personal data with other third parties, for example in the context of the possible sale or restructuring of the business. We may also need to share your personal data with a regulator or to otherwise comply with the law.
9. Data Security
We have put in place commercially reasonable and appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions, and they are subject to a duty of confidentiality.
We have put in place procedures to deal with any suspected data security breach and will notify you and any applicable regulator of a suspected breach where we are legally required to do so.
10. Transferring personal data outside the European Economic Area (EEA)
In order to perform our contract with you we may transfer the personal data we collect about you to the following country outside of the EEA: - India.
As there is not an adequacy decision by the European Commission in relation to India, it is not deemed to provide an adequate level of protection for your personal information for the purpose of the Data Protection Legislation.
We have put in place the following measures to ensure that your personal data is treated by those third parties in a way that is consistent with and which respects the Data Protection Legislation, as follows: Comprehensive engagement letters and contract agreement that covers Data Protection Legislation. Security vetting of Privacy Policies, Terms and Conditions, Security Policies and Data Security Certification.
Should you require further information about these protective measures, please contact us using the contact details outlined below.
11. Failure to provide data
If you refuse to provide us with certain information when requested, we may not be able to perform the contract we have entered into with you. Alternatively, we may be unable to comply with our legal or regulatory obligations.
12. Legitimate Interests
Your data will be processed on the basis that PAH has a legitimate interest in being able to achieve the aims of processing set out in section 3 above.
13. Data retention
We will only retain your personal data for as long as necessary and for the purposes specified in this notice.
Where you have consented to us using your details for direct marketing, we will keep such data until you notify us otherwise and/or withdraw your consent.
14. Special Categories Data
Where special category data is provided, the provider of the data warrants that they consent to PAH processing that data, or that they have obtained written consent from the data subject.
15. Right to withdraw consent
In the limited circumstances where you may have provided your consent to the collection, processing and transfer of your personal data for a specific purpose (for example, in relation to direct marketing that you have indicated you would like to receive from us), you have the right to withdraw your consent for that specific processing at any time. To withdraw your consent, please email our data protection representatives at email@example.com.
Once we have received notification that you have withdrawn your consent, we will no longer process your personal information (personal data) for the purpose or purposes you originally agreed to, unless we have another legitimate basis for doing so in law.
16. Changes to this Policy
17. Contact Us
If you have any questions regarding this notice or if you would like to speak to us about the manner in which we process your personal data, please email our data protection representatives at firstname.lastname@example.org.
18. Lodging a Complaint
You have the right to make a complaint to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues, at any time. The ICO’s contact details are as follows:
Information Commissioner’s Office
Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF
Telephone: 0303 123 1113 (local rate) or 01625 545 745