PinPointUK Ltd understands that your privacy is important to you and that you care about how your personal data is used and shared online. We respect and value the privacy of our clients and suppliers. Clients and suppliers can be individual, corporate or employees of a corporate client or supplier – all references to ‘you’ or ‘your’ relate to either an individual client/supplier, corporate client/supplier or employee of a corporate client/supplier. We will only collect and use personal data in ways that are described here, and in a manner that is consistent with our obligations and your rights under the law.
This website, www.pinpoint-media.global (“Our Site”) is not intended for children and we do not knowingly collect data relating to children.
1. Information About Us
Our Site is owned and operated by PinPointUK Ltd, a limited company registered in England under company number 08448972, whose main trading and registered address is 2nd Floor, 43-45 Promenade, Cheltenham, GL50 1LE.
Our VAT number is 183264892.
“We/Us/Our” means PinPointUK Ltd, a limited company registered in England under company number 08448972, whose main trading and registered address is 2nd Floor, 43-45 Promenade, Cheltenham, GL50 1LE.
We are the controller and are responsible for your personal data.
You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK regulator for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.
2. What Does This Policy Cover?
3. What Data Do We Collect?
3.1 Personal data, or personal information, 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).
3.2 We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:
3.2.1 Identity Data includes first name, maiden name, last name, username or similar identifier, marital status, title, date of birth and gender.
3.2.2 Contact Data includes billing address, delivery address, email address and telephone numbers.
3.2.3 Financial Data includes bank account and payment card details.
3.2.4 Transaction Data includes details about payments to and from you and other details of products and services you have purchased from us.
3.2.5 Technical Data includes internet protocol (IP) address, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, and other technology on the devices you use to access this website including a list of URLs starting with a referring site, your activity on Our Site, and the site you exit to.
3.2.6 Profile Data includes your username and password, purchases or orders made by you, your interests, preferences, feedback and survey responses.
3.2.7 Usage Data includes information about how you use our website, products and services.
3.2.8 Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.
3.4 We do not collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health, and genetic and biometric data). Nor do we collect any information about criminal convictions and offences.
4. If you fail to provide personal data
Where we need to collect personal data by law, or under the terms of a contract we have with 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 (for example, to provide you with goods or services). In this case, we may have to cancel a product or service you have with us but we will notify you if this is the case at the time.
5. How is Your Personal Data Collected?
5.1 We use different methods to collect data from and about you including through:
5.1.1 Direct interactions. You may give us your Identity, Contact and Financial Data by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:
18.104.22.168 apply for our products or services;
22.214.171.124 create an account on our website;
126.96.36.199 subscribe to our service or publications;
188.8.131.52 request marketing to be sent to you;
184.108.40.206 enter a competition, promotion or survey; or
220.127.116.11 give us feedback or contact us.
5.3 Third parties or publicly available sources. We will receive personal data about you from various third parties and public sources as set out below:
5.3.1 Technical Data from the following parties:
18.104.22.168 analytics providers such as Google based outside the UK;
22.214.171.124 Identity and Contact Data from data brokers or aggregators such as Experian PLC based inside the UK.
126.96.36.199 Identity and Contact Data from publicly available sources such as Companies House and the Electoral Register based inside the UK.
6. How Do We Use Your Data?
6.1 All personal data is processed and stored securely, for no longer than is necessary in light of the reason(s) for which it was first collected.
6.2 Our use of your personal data will always have a lawful basis, either because it is necessary for our performance of a contract with you, because you have consented to our use of your personal data (e.g. by subscribing to emails),because it is in our legitimate interests or because we need to comply with a legal obligation.
6.3 Generally, we do not rely on consent as a legal basis for processing your personal data although we will get your consent before sending third party direct marketing communications to you via email or text message. You have the right to withdraw consent to marketing at any time by contacting us.
Purposes for which we will use your personal data
6.4 We have set out below, in a table format, a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.
6.5 Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below.
|Purpose/Activity||Type of data||Lawful basis for processing including basis of legitimate interest|
To register you as a new customer
Performance of a contract with you
To process and deliver your order including:
(a) Manage payments, fees and charges
(b) Collect and recover money owed to us
(e) Marketing and Communications
(a) Performance of a contract with you
(b) Necessary for our legitimate interests (to recover debts due to us)
with you which will include:
(b) Asking you to leave a review or take a survey
(c) Marketing and Communications
(a) Performance of a contract with you
(b) Necessary to comply with a legal obligation
(c) Necessary for our legitimate interests (to keep our records updated and to study how customers use our products/services)
To enable you to partake in a prize draw, competition or complete a survey
(d) Marketing and Communications
(a) Performance of a contract with you
(b) Necessary for our legitimate interests (to study how customers use our products/services, to develop them and grow our business)
To administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)
(a) Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise)
(b) Necessary to comply with a legal obligation
To deliver relevant website content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you
(d) Marketing and Communications
Necessary for our legitimate interests (to study how customers use our products/services, to develop them, to grow our business and to inform our marketing strategy)
To use data analytics to improve our website, products/services, marketing, customer relationships and experiences
Necessary for our legitimate interests (to define types of customers for our products and services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy)
To make suggestions and recommendations to you about goods or services that may be of interest to you
(e) Marketing and Communications
Necessary for our legitimate interests (to develop our products/services and grow our business)
6.6 We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising.
Promotional offers from us
6.7 We may use your Identity, Contact, Technical, Usage and Profile Data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which products, services and offers may be relevant for you (we call this marketing).
6.8 You will receive marketing communications from us if you have requested information from us or purchased goods or services from us and you have not opted out of receiving that marketing.
6.9 We will get your express opt-in consent before we share your personal data with any third party for marketing purposes.
6.10 You can ask us or third parties 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.
6.11 Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of a product/service purchase, warranty registration, product/service experience or other transactions.
Change of purpose
6.13 We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.
6.14 If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.
6.15 Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.
7. How and Where Do We Store Your Data?
7.1 We only keep your personal data for as long as we need to in order to use it as described above in section 5, and/or for as long as we have your permission to keep it.
7.2 Some or all of your data may be stored outside of the UK. If we do store data outside the UK, we will take all reasonable steps to ensure that your data is treated as safely and securely in accordance with section 9.
7.3 Data security is very important to us, and to protect your data we have taken suitable measures to safeguard and secure data collected.
8. Do We Share Your Data?
8.1 We may share your personal data with the parties set out below for the purposes set out in the table above:
8.1.1 Service providers acting as processors based in the UK who provide IT and system administration services.
8.1.2 Professional advisers acting as processors or joint controllers including lawyers, bankers, auditors and insurers based in the UK who provide consultancy, banking, legal, insurance and accounting services.
8.1.3 HM Revenue & Customs, regulators and other authorities acting as processors or joint controllers based in the United Kingdom who require reporting of processing activities in certain circumstances.
8.1.4 Specific third parties such as Hubspot Inc.
8.2 In certain circumstances, we may be legally required to share certain data held by Us, which may include your personal data, for example, where we are involved in legal proceedings, where we are complying with legal obligations, a court order, or a governmental authority.
8.3 We may compile statistics about the use of Our Site including data on traffic, usage patterns, user numbers, sales, and other information. All such data will be anonymised and will not include any personally identifying data, or any anonymised data that can be combined with other data and used to identify you. We may from time to time share such data with third parties such as prospective investors, affiliates, partners, and advertisers. Data will only be shared and used within the bounds of the law.
We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.
9. International Transfers
9.1 Many of our external third parties are based outside the UK so their processing of your personal data will involve a transfer of data outside the UK.
9.2 Whenever we transfer your personal data out of the UK, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:
9.2.1 We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data.
9.2.2 Where we use certain service providers, we may use specific contracts approved for use in the UK which give personal data the same protection it has in the UK.
9.3 Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the UK.
10. Data Security
10.1 We have put in place 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.
10.2 We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.
11. Data Retention - How Long Will You Use My Personal Data For?
11.1 We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.
11.2 To determine the appropriate retention period for personal data, we consider the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements.
11.3 By law we have to keep basic information about our customers (including Contact, Identity, Financial and Transaction Data) for six years after they cease being customers for tax purposes.
11.4 In some circumstances you can ask us to delete your data: see your legal rights below for further information.
11.5 In some circumstances we will anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes, in which case we may use this information indefinitely without further notice to you.
12. How Can You Access Your Data?
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 is clearly unfounded, repetitive or excessive. Alternatively, we could refuse to comply with your request in these circumstances. Please contact us for more information.
13. Contacting Us
15. Your legal rights
15.1 Under certain circumstances, you have rights under data protection laws in relation to your personal data.
15.1.1 Request access to your personal data: (commonly known as a “data subject access request”). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
15.1.2 Request correction of your personal data: This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
15.1.3 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 successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
15.1.4 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 ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
15.1.5 Request restriction of processing your personal data: This enables you to ask us to suspend the processing of your personal data, for example if you want us to establish the data’s accuracy.
15.1.6 Request transfer of your personal data: We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
15.1.7 Right to withdraw consent: Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.
15.2 If you wish to exercise any of the rights set out above, please contact us.
What we may need from you
15.3 We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.
Time limit to respond
15.4 We try to respond to all legitimate requests within one month. Occasionally it could take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.