EFECTIVE DATE: 28 October 2020
We at Pension Times respect your privacy and are committed to safeguarding your personal data.
This policy describes the information we collect or you shared with us when you visit our website (regardless of where you visit it from), how it is used, stored and safeguarded, and your choices regarding this information.
This policy outlines how we at [Pension Times] collects and processes your personal data through your use of this website, including any data your may provide through this website when you subscribe to our newsletter.
This website is not intended for children and we do not knowingly collect data relating to children.
DATA CONTROLLER AND CONTACT DETAILS
Our details are as follows:
Pension Times Ltd
Lower Ground Floor
One George Yard
HOW TO CONTACT US ABOUT YOUR RIGHTS AND DATA
By email at: Privacy@pensiontimes.co.uk
We are regulated by the Information Commissioner’s Office and you have the right to make a complaint at any time to them. We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.
INFORMATION COLLECTED ABOUT YOU
We have set out below the personal data about you we may collect, use, store and transfer when you interact with us through our website. Personal data means any information from which you can identify you, it does not include information we collected on an anonymous basis.
- Identity Data & Contact Data includes first name, last name and your email address.
- 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 this website.
- Profile Data includes your username and password, information about your newsletter subscription, your interests, preferences, feedback and survey responses.
- Usage Data includes information about how you use our website and services.
- Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences. In particular, as part of you subscribing to our newsletter we will send you marketing from us and our third parties carefully selected from your preferences; you can opt-out of this at any time.
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.
How your data is collected
We use different methods to collect data from and about you including through:
Direct interactions. You may give us your 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 newsletter or other publications;
- request marketing to be sent to you;
- enter a competition, promotion or survey; or
- give us feedback or contact us.
Automated technologies or interactions. As you interact with our website, we automatically collect information about the device you use when you interact with us, browsing actions and patterns. We collect this personal data by using cookies, server logs and other similar technologies.
Third parties or publicly available sources. We will receive personal data about you from various third parties and public sources as set out below:
- Technical Data from the following parties (who may be based both inside and outside the UK):
- analytics providers such as Google and Facebook ;
- advertising networks such as Facebook and Google;
- automated mailing systems, such as Mailchimp; and
- search information providers.
HOW WE USE YOUR INFORMATION
We collect, process, store and disclose personal data for a variety of different reasons, but in all cases when the law allows us to.
The General Data Protection Regulation (“GDPR”) requires that companies processing personal data of EU citizens set out the specific lawful basis on which they process that data. For the personal data identified in this policy we rely on the following lawful basis to processing your data:
- Consent: with the exception of your subscription to our newsletter and to receiving marketing information from us, generally, we do not rely on consent as a legal basis for processing your personal data. You have the right to withdraw consent at any time by contacting us.
- Contractual Obligations: where we need to perform the contract we are about to enter into or have entered into with you.
- Regulatory or Legal Obligations: where we need to comply with a legal obligation.
- Legitimate Interests: 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.
We have summarised below the various ways we use your personal data and our legal basis for doing so.
|Purpose/Activity||Type of data||Lawful basis for processing including basis of legitimate interest|
|To register you as a subscriber to our newsletter||(a) Identity|
|Performance of a contract with you|
|To manage our relationship 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||(a) Identity|
(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) Identity|
|(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||(a) Identity|
(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) and your Consent.|
|To use data analytics to improve our website, products/services, marketing, customer relationships and experiences||(a) Technical|
|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||(a) Identity|
(e) Marketing and Communications
|Necessary for our legitimate interests (to develop our products/services and grow our business) and your Consent.|
We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising. In general we employ the following data control mechanisms when we use your personal data for the purpose of direct marketing:
If you subscribe to our newsletter and mailing list, we will send you marketing from us and our third parties; in order to ensure we deliver the most relevant marketing content to you, we will use your Identity, Contact, Technical and Usage Data to tailor marketing to your preferences.
Promotional offers from us
We may use your Identity, Contact, Technical and Usage 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).
You will receive marketing communications from us if you have requested information from us and you have not opted out of receiving that marketing.
We will get your express opt-in consent before we share your personal data with any third party for marketing purposes.
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. You can withdraw your consent, or opt-out from our mailing list by unsubscribing.
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.
COOKIES AND OTHER TECHNOLOGIES
Cookies come in a variety of forms but are essentially small data files used to collect and store information about you. We use them on our website for a variety of different functions:
- for the smooth and safe operation of our website;
- to manage your preferences and remember you for future visits;
- to analyse how you use our website in order to continually make improvements.
The majority of these cookies are linked to your browser session (session cookies) and disappear once you close your browser. Others remain on your device for a longer period (persistent cookies).
INFORMATION SHARING AND DISCLOSURE
We share the information we collect or that is provided to us as follows:
Sharing with our Partners
We may share your personal data with the parties set out below for the purposes we have identified above.
- The External Third Parties set out below.
Currently, we use the following trusted Partners:
|Company subcontractor||Service||Location(s) of Processing|
|Amazon - AWS||Website Hosting||London|
|Website Analytics, AdSense||Europe|
|Mailchimp||Automated email provider||US|
When we share your personal data within the some of the above External Third Parties, this will involve transferring your data outside the European Economic Area (EEA).
Where we share your personal data with those parties, we ensure there are mechanisms in place to ensure your personal data is protected as if it were in the EEA, such as by ensuring those providers utilise binding corporate rules, using the European Commission’s Model contracts for the transfer of personal data to third countries, or ensuring transfers only take place to countries that have been deemed to provide an adequate level of protection for personal data.
HOW WE SAFEGUARD YOUR DATA
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.
RETENTION AND DELETION
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 by contact us (see the below section 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.
YOUR DATA, YOUR RIGHTS
The title of this section says it all and as a citizen of an EU country you have a wide range of rights with regards to your data, which have, as of the 25 May 2018, been enhanced by the General Data Protection Regulation (“GDPR”).
You can enforce your rights by contacting us, or in most cases, by unsubscribing and/or by ending your use of your website.
- Right to Correction: if you believe any of the information on your profile to be inaccurate you have a right to request that we correct this. This right also extends to various other information we collect about you which you can request a copy of (see Right to Copies below).
- Right to Copies of your data: you have a right to request a copy of the information that we hold about you along with an explanation from us as to why we process that information. We will provide this information to you free of charge for a first request, but will charge for reasonable administrative costs for further requests.
- Right to erasure: you have a right to request the deletion of your data at any time. If you submit such a request to us we will consider carefully and reply with an explanation as to why we are required to retain certain information either by law or for our own legitimate reasons. Where, after review, we identify any data we do not need to retain for these purposes, we will delete that data as per your request.
- Right to object or complain: you have a right to complain about how we are processing your data to our principal Data Protection Authority, the Information Commissioner’s Office here or in writing at the following address:
Information Commissioner's Office
Should you have any concerns about how we are processing your data, we invite that you submit those questions to firstname.lastname@example.org
UPDATES TO OUR POLICY
As we further enhance our website and improve our services, we may make changes to this policy from time to time. If we make any major changes, or any changes which directly affect the services provided to you or the data collected or processed by us, we will notify you of those changes by a prominent banner on our website. However, we encourage you to periodically review this policy for the most up to date version.