Privacy and Cookie Policy

PURPOSE OF THIS PRIVACY NOTICE

CONTROLLER AND CONTACT DETAILS

P2i Limited is the controller and is responsible for your personal data (collectively referred to as “P2i Limited”, “P2i”, “we”, “us” or “our” in this privacy notice). Our full details are:

• Full name of legal entity: P2i Limited
• Postal address: 126b Olympic Avenue, Milton Park, Abingdon, OX14 4SA
• Telephone: +44 1235 833 100
• Email address: marketing@p2i.com

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). We would appreciate the chance to address your concerns before you approach the ICO so please contact us in the first instance.

CHANGES TO THE PRIVACY NOTICE AND YOUR DUTY TO INFORM US OF CHANGES

Please keep us informed if your personal data changes during your relationship with us.

We may change this privacy notice at any time and you should check it regularly. However, if we change it in a material way, we will advise of changes at the beginning of this privacy notice. It is important that the personal data we hold about you is accurate and current.

THIRD-PARTY LINKS

This website 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 notice of every website you visit.

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

• Identity Data including: first name, last name, title, date of birth and gender.
• Contact Data including: addresses, email address and telephone numbers.
• Technical Data including: internet protocol (IP) address, 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 this website.
• Usage Data including: information about how you use our website, products and services.
• Marketing and Communications Data including: your preferences in receiving marketing from us.

We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data may be derived from your personal data but is not considered personal data in law as this data does not directly or indirectly reveal your identity.

We do not collect any Special Categories of Personal Data about you (e.g. 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.

Direct interactions. You may give us your Identity/Contact Data by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:

• subscribe to our service or publications;
• request marketing to be sent to you;
• give us some feedback.

Automated technologies or interactions. As you interact with our website, we may automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies and other similar technologies. Please see our cookie policy for further details.

Third parties. We may receive personal data about you from various third parties including but not limited to Technical Data from the analytics providers such as Google based outside the EU

• Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
• Where we need to comply with a legal or regulatory obligation.

We will only rely on your consent as a legal basis for processing your personal data other than in relation to 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

We have set out below a description of 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 ground we are relying on to process your personal data where more than one ground has been set out in the table below.

MARKETING & OPTING OUT

We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising. We have established the following personal data control mechanisms:

You will receive marketing communications from us if you have requested information from us, or if you provided us with your details when you registered for marketing promotions and, in each case, you have not opted out of receiving that marketing.

You can ask us to stop sending you marketing messages by contacting us at any time at marketing@p2i.com.

THIRD-PARTY MARKETING

We will get your express opt-in consent before we share your personal data with any company outside the P2i group of companies for marketing purposes.

COOKIES

You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of this website may become inaccessible or not function properly. Please see our cookie policy for further details.

CHANGE OF PURPOSE

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.

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.

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.

We may have to share your personal data with the parties set out below for the purposes set out in the table in paragraph 4 above.

• Internal Third Parties – other companies in the P2i Group
• External Third Parties, including but not limited to service providers, professional advisers, HM Revenue & Customs, regulators and other authorities. This includes mailchimp whom we use to, for example, distribute our marketing emails.
• Third parties to whom we may choose to sell, transfer, or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy notice.

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 third-party service providers to use your personal data for their own purposes and only permit them to process personal data for specific purposes in accordance with our instructions.

Some of our external third parties are based outside the European Economic Area (EEA) so their processing of your personal data will involve a transfer of data outside the EEA.

Whenever we transfer your personal data out of the EEA, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:

• • Either we will transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data by the European Commission. For further details, see European Commission: Adequacy of the protection of personal data in non-EU countries.
  • Alternatively, where we use certain service providers, we may use specific contracts approved by the European Commission which give personal data the same protection it has in Europe. For further details, see European Commission: Model contracts for the transfer of personal data to third countries.

Please Contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the EEA.

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 have 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.

HOW LONG WILL YOU USE MY PERSONAL DATA FOR?

We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements. In some circumstances you can ask us to delete your data, see below for further information.

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 requirements.

We may 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.

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

• 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. However, 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: (a) if you want us to establish the data’s accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
• 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.

If you wish to exercise any of the rights set out above, please contact us at: marketing@p2i.com

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 may 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 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 may 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.

This website uses cookies to collect information. Cookies are small data files which are placed on your computer or other mobile or handheld device (such as smartphones or tablets) as you browse this website. They are used to improve your user experience by remembering when your computer or device accesses this website. This makes the interaction between you and our website faster and easier.

The cookies are essential to the effective operation of our website. Cookies are also used to tailor the products and services offered and advertised to our customers, both on this website and elsewhere.

This website also uses Google Analytics, a web analytics service provided by Google Inc. The information generated by the cookie about your use of this website (including your IP address) is transmitted to a Google server in the US and stored there. Google will use this information to evaluate your use of the website, compiling reports on website activity for website operators and to provide other site usage and internet related services. Google may also transfer this information to third parties where required by law or where such third parties process the information on Google’s behalf. Google will not associate your IP address with any other data held by Google in conjunction. You may refuse the use of cookies by selecting the appropriate settings on your browser. We point out, however, that you may not be able to use all features of this website in this case.

By using this site you consent to the processing of data about you by Google in the manner described above and for the purposes set out above. You can opt-out of data collection at any time.

Who sets the cookies?

The cookies stored on your computer or other device when you access this website are set by P2i Ltd. and our suppliers who partner with us to help deliver a high quality website.

How can I control what cookies are set?

By using this website, you consent to having the below-mentioned  cookies stored on your computer or device.

Most web browsers allow some control of most cookies through the browser settings. To find out more about cookies, including how to see what cookies have been set and how to manage and delete them, visit http://www.allaboutcookies.org.

To opt out of being tracked by Google Analytics across all websites visit: http://tools.google.com/dlpage/gaoptout.

Please note that if you choose to disable any or all of the cookies set by this website, some website functionality may no longer be available to you.

If you have any other questions or concerns please contact us at: marketing@p2i.com