1.1 We are committed to respecting and protecting your privacy. This policy sets out our approach and how we collect and process data received from you on our site. “We” in this context are PIVOT COMMERCE LIMITED. We act as the administrators of the policy. In the policy we’re referred to as “The Administrator”.
1.2 We are committed to protecting the privacy of visitors to the website in accordance with the EU General Data Protection Regulation ( EU 2016/679) (GDPR) (the “Regulation”).
1.3 Here are the details that the Regulation says we have to give you as a ’data controller’:
- Our site address is https://pivot.international
- Our company name is Pivot.international
- Our registered address is 201 Borough High Street
· Our nominated representative is James Storie-Pugh and they can be contacted at email@example.com
2. Information collected and retained by the Administrators
2.1 We collect personal information about you from personal details provided by yourself in relation to the Services we offer to Users. We do not collect any sensitive personal information such as information on your racial or ethnic origins, political opinions, religious beliefs, trade union affiliations, sexual life, health or criminal history.
3. Use of information by the Administrators
3.1 We collect information which is necessary to:
3.1.1 provide the Services to you;
3.1.2 notify you of your Service order status; and
3.1.3 carry out internal administration and analysis.
3.2 We can also use that information to enhance your visit to our website by:
3.2.1 (with your consent) telling you about new products, new services and special offers;
3.2.2 tailoring your experience to your preferred choice of activities; and
3.2.3 informing you of changes in our website.
3.3 By providing us with your personal information, you consent to us (and where relevant, our subsidiaries, affiliates and trusted partners) using (including collecting, storing and processing) your personal information.
3.4 Under the Regulation we will ensure that your personal data is processed lawfully, fairly, and transparently, without adversely affecting your rights. We will only process your personal data if at least one of the following basis applies:
3.4.1 you have given consent to the processing of your personal data for one or more specific purposes;
3.4.2 processing is necessary for the performance of a contract to which you are a party or in order to take steps at the request of you prior to entering into a contract;
3.4.3 processing is necessary for compliance with a legal obligation to which we are subject;
3.4.4 processing is necessary to protect the vital interests of you or of another natural person;
3.4.5 processing is necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in the controller; and/or
3.4.6 processing is necessary for the purposes of the legitimate interests pursued by us or by a third party such as our credit card payment processing, except where such interests are overridden by the fundamental rights and freedoms of the data subject which require protection of personal data, in particular where the data subject is a child
3.5 If you do not want us to use your personal data for any of the reasons detailed in 3.1 and 3.2 above, you can let us know at any time by contacting firstname.lastname@example.org and we will delete your data from our systems. However, you acknowledge that this will limit our ability to provide the best possible services to you. In some cases, the collection of personal data may be a statutory requirement and we will be limited in the services we can provide you if you don’t provide your personal data in these cases.
4. Accessing and amending your personal information
We will process your personal data for the purposes set out in clause 3 above. If, however, you have any queries or requests in relation to Data Protection/GDPR please notify our Data Protection Compliance Officer at: Pivot, 201 Borough High Street, SE1 1JA or email@example.com
5. Disclosure to Third Parties
5.1 We are allowed to disclose your information in the following cases:
5.1.1 If we want to sell our business, or our company, we can disclose it to the potential buyer.
5.1.2 We can disclose it to other businesses in our group.
5.1.3 We can disclose it if we have a legal obligation to do so, or in order to protect other people’s property, safety or rights.
5.1.4 We can exchange information with others to protect against fraud or credit risks.
5.2 We may disclose your information to necessary third parties to enable us to provide you with the Services.
5.3 We also reserve the right to access and disclose to third parties your information to comply with applicable laws including but not limited to disclosure in accordance with the GDPR Regulation, the Regulation of Investigatory Powers Act 2000 and lawful authority requests, to safeguard the proper operation of our systems and to protect ourselves and our clients.
5.4 Where any of your data is required for such a purpose, we will take all reasonable steps to ensure that your data will be handled safely, securely, and in accordance with your rights, our obligations, and the obligations of the third party under the Regulation and the law.
6. Protection of personal information
We use our reasonable endeavours, to ensure proper storage and careful disclosure of your personal information in order that nothing improper happens to your private information. These security measures mean that we may occasionally have to ask you for proof of identity before we are able to disclose personal information to you.
7. External Websites
8. Storage of your Data
8.1 We may transfer your collected data to storage outside the European Economic Area (EEA). It may be processed outside the EEA to fulfil your order and deal with payment.
8.2 By giving us your personal data, you agree to this arrangement. We will do what we reasonably can to keep your data secure.
8.3 Payment will be encrypted. If we give you a password, you must keep it confidential. Please don’t share it. Although we try to provide protection, we cannot guarantee complete security for your data, and you take the risk that any sending of that data turns out to be not secure despite our efforts.
8.4 We only keep your personal data for as long as we need to in order to use it as described above in section 3, and/or for as long as we have your permission to keep it. In any event, we will conduct an annual review to ascertain whether we need to keep your personal data. Your personal data will be deleted if we no longer need it.
9.1. Upon registering, there are several communication lists you can opt-out of. These lists are operated on an opt-out basis due to the legitimate interest there is in providing you with the service, information and business intelligence you’re registered for
9.1.1. To update your communication preferences, select to manage your communication preferences at the bottom of any email from PIVOT COMMERCE LIMITED.
10. Your rights
10.1 You can ask us not to use your data for marketing. You can do this by indicating your preferences on our forms, or by contacting us at any time at firstname.lastname@example.org
10.2 Under the Regulation, you have the right to:
10.2.1 request access to, deletion of or correction of, your personal data held by us at no cost to you;
10.2.2 request that your personal data be transferred to another person (data portability);
10.2.3 be informed of what data processing is taking place;
10.2.4 restrict processing;
10.2.5 to object to processing of your personal data; and
10.2.6 complain to a supervisory authority.
10.3 You also have rights with respect to automated decision-making and profiling as set out in section 11 below.
11. Automated Decision Making and Profiling
11.1 In the event that we use personal data for the purposes of automated decision-making and those decisions have a legal (or similarly significant effect) on you, you have the right to challenge to such decisions under the Regulation, requesting human intervention, expressing their own point of view, and obtaining an explanation of the decision from us.
11.2 The right described in section 11.1 does not apply in the following circumstances:
11.2.1 the decision is necessary for the entry into, or performance of, a contract between the you and us;
11.2.2 the decision is authorised by law; or
11.2.3 you have given your explicit consent.
11.3 Where we use your personal data for profiling purposes, the following shall apply:
11.3.1 Clear information explaining the profiling will be provided, including its significance and the likely consequences;
11.3.2 Appropriate mathematical or statistical procedures will be used;
11.3.3 Technical and organisational measures necessary to minimise the risk of errors and to enable such errors to be easily corrected shall be implemented; and
11.3.4 All personal data processed for profiling purposes shall be secured in order to prevent discriminatory effects arising out of profiling.
12. Sponsored Content
12.1. Upon downloading sponsored content, we will provide your contact information (Name, Email, Job Title, Company, Phone Number) to the sponsor of that content. They may contact you via email or telephone thereafter.
12.1.1. This is performed under legitimate interest, for which we have undertaken assessments to confirm the balance therein, specifically, it is the sponsorship of our partners that make the content possible, and we believe our users will find hearing of their products & services – relevant to the subject of the aforementioned content – to be useful and their right to privacy does not override our legitimate interest.
12.1.2. You may unsubscribe from receiving communications from any third party at any time by clicking the unsubscribe link at the bottom of any of their email communications.
12.1.3. PIVOT COMMERCE LIMITED cannot be held liable for any failure of a third party affiliate to reasonably process a request to unsubscribe or for data, once data has been passed over.
12.1.4. We will not pass your personal information on to any third party other than those who are sponsors of the content which you have downloaded
12.1.5. This clause does not extend to the Pivot “Sponsors & Partners” mailing list, which is considered as a part of the Pivot provision. You may unsubscribe from this list at any time on email@example.com