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PDM Analysis Limited Privacy Policy

Introduction

Welcome to the PDM Analysis Limited (“PDM”) privacy policy.

PDM respects your privacy and is committed to protecting your personal data. This privacy policy will inform you as to how we look after your personal data when you visit our website and/or any of our Virtual Machine Portals (the “Websites”) (regardless of where you visit it from) and tell you about your privacy rights and how the law protects you. For details on how we collect and use cookies please see our Cookie Policy.

 

1. Important information and who we are

Purpose of this privacy policy

This privacy policy aims to give you information on how PDM collects and processes your personal data through your use of the Websites, including any data you may provide through the Websites when you sign up, purchase a product or service and/or if you provide data to us for any other purpose.

The Websites are not intended for children and we do not knowingly collect data relating to children.

It is important that you read this privacy policy together with any other privacy policy or fair processing policy we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data.

 

Contact details

If you have any questions about this privacy policy or our privacy practices, please contact us in the following ways:

Full name of legal entity: PDM Analysis Limited Email address: privacy@pdmanalysis.co.uk

Postal address: Bourne House, 475 Godstone Road, Whyteleafe, Surrey, CR3 0BL, United Kingdom

You have the right to make a complaint at any time to the Information Commissioner's Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk).

 

Changes to the privacy policy

We keep our privacy policy under regular review. This version was last updated on 04th May 2021.

 

Third-party links

The Websites may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy policy of every website you visit.

 

2. The data we collect about you

We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:

    • Identity Data includes first name, last name, username or similar identifier, title, date of birth.
    • Contact Data includes billing address, email address and telephone numbers.
    • Financial Data includes bank account and payment card details.
    • Transaction Data includes details about payments to and from you and other details of products and services you have purchased from us.
    • Technical Data includes internet protocol (IP) address, your login data, 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 the Websites.
    • Profile Data includes your username and password, purchases or orders made by you, your interests, preferences, feedback and survey responses.
    • Usage Data includes information about how you use our website, products and services.
    • Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.

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.

 

3. How is your personal data collected?

We use different methods to collect data from and about you including through:

    • 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:
      • apply for our products or services;
      • create an account on the Website;
      • subscribe to our service or publications;
      • request marketing to be sent to you; or
      • give us feedback or contact us.
    • Automated technologies or interactions. As you interact with the Websites, we will automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies, server logs and other similar technologies. We may also receive Technical Data about you if you visit other websites employing our cookies. Please see our Cookie Policy for further details.
    • Third parties or publicly available sources. We will receive personal data about you from various third parties:

Technical Data from the following parties:

  1. analytics providers such as Microsoft based outside the EU;
  2. advertising networks such as Linkedin based outside the EU, or other similar providers based within the EU; and
  3. search information providers such as Google based outside the EU, or other similar providers based within the EU.
    • Contact, Financial and Transaction Data from providers of technical, payment and delivery services such as Barclays Bank PLC based inside OR outside the EU.
    • Identity and Contact Data from publicly available sources such as Companies House and the Electoral Register based inside the EU.

 

4. How we use your personal data

Purposes for which we will use your personal data

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.

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 grounds that 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.
  • To process and deliver your order including:
    1. Manage payments, fees and charges;
    2. Collect and recover money owed to us.
  • To manage our relationship with you which will include:
    1. Notifying you about changes to our terms or privacy policy;
    2. Asking you to leave a review or take a survey.
  • To administer and protect our business and the Websites (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data).
  1. Identity
  2. Contact
  3. Financial
  4. Transaction
  5. Communications
  6. Profile

Performance of a contract with you
  • To deliver relevant website content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you.
  1. Identity
  2. Contact
  3. Profile
  4. Usage
  5. Marketing and Communications
  6. Technical

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.
  1. Technical
  2. Usage

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.
  1. Identity
  2. Contact
  3. Technical
  4. Usage
  5. Profile
  6. Marketing and Communications

Necessary for our legitimate interests (to develop our products/services and grow our business).

 

Third-party marketing

We do not share your personal data with any third party for marketing purposes.

 

5. Disclosures of your personal data

We may share your personal data with the parties set out below for the purposes set out in the table above.

  • External Third Parties as set out below:
  • IT service providers and system administration services;
  • Professional advisers including but not limited technical advisers, lawyers, bankers, auditors and insurer.
  • HM Revenue & Customs, regulators and other government authorities.

 

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 in accordance with a signed Data Protection Agreement.

 

6. International transfers

We do not transfer your personal data outside the European Economic Area (EEA) or the UK.

 

7. Data security

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.

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.

 

8. Data retention

How long will you use my personal data for?

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.

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.

In some circumstances you can ask us to delete your data: see below for further information.

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.

 

9. Your legal rights

Under certain circumstances, you have rights under data protection laws in relation to your personal data in order to:

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.

Request correction of the personal data that we hold about you. 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.

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.

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.

Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios:

  • If you want us to establish the data's accuracy.

Request the transfer of your personal data to you or to a third party. 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.

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.

If you wish to exercise any of the rights set out above, please contact us.

No fee usually required

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.

What we may need from you

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

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.