Privacy Policy

This is the privacy policy of Pancroft, Whiteman and Partners Consulting Ltd referred to in this document as "we", "our", or "us".
We are registered in England and Wales under the company number 05469696 .
Our registered office is at 47 Park Crescent, Penygarn, PONTYPOOL, NP4 8BR, Wales. Our e-mail address, which may be used to contact us, is GDPR@pwpcl.com

Introduction

This privacy policy aims to inform you about how we collect and process any information that we collect from you, or that you provide to us. It covers information that could identify you (personal information) and information that could not. In the context of the law and this policy, 'process' means collect, store, transfer, use or otherwise act on information. It tells you about your privacy rights and how the law protects you.
We are committed to protecting your privacy and the confidentiality of your personal information. Our policy is not just an exercise in complying with the law, but a continuation of our respect for you and your personal information.ation.
We undertake to preserve the confidentiality of all information you provide to us, and hope that you reciprocate.
Our policy complies with the Data Protection Act 2018 (Act) accordingly incorporating the EU General Data Protection Regulation (GDPR).
The law requires us to tell you about your rights and our obligations to you in regard to the processing and control of your personal data. We do this now, by requesting that you read the information provided at http://www.knowyourprivacyrights.org
Except as set out below, we will not share, or sell, or disclose to a third party, any information collected.

1.    Data we process

We may collect, use, store and transfer different kinds of personal data about you. We have collated these into groups as follows:
  • Your 'identity' includes information such as first name, last name, title, date of birth, and other identifiers that you may have provided at some time.
  • Your 'contact information' includes information such as any billing address, delivery address, email address, telephone numbers and any other information you have given to us for the purpose of communication or meeting.
  • Your 'financial data' includes information such as your bank account and payment card details.
  • 'Transaction data' includes details about payments or communications to and from you and information about products and services you have purchased from us.
  • 'Marketing data' includes your preferences in receiving marketing from us; communication preferences; responses and actions in relation to your use of our services.
We may aggregate anonymous data such as statistical or demographic data for any purpose. 'Anonymous data' is data that does not identify you as an individual. 'Aggregated data' may be derived from your personal data but is not considered personal information in law because it does not reveal your identity.
For example, we may aggregate profile data to assess interest in a product or service.
However, if we combine or connect aggregated data with your personal information so that it can identify you in any way, we treat the combined data as personal information and it will be used in accordance with this privacy policy.

2.    Special personal information information

Special personal information is data 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. It also includes information about criminal convictions and offences. We will not collect any special personal information about you.

3.    If you do not provide personal information we need

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 that contract. In that case, we may have to stop providing a service or to cancel a delivery to you. If so, we will notify you of this at the time.

The bases on which we process information about you

The law requires us to determine under which of six defined bases we process different categories of your personal information, and to notify you of the basis for each category.
If a basis, on which we process your personal information, is no longer relevant, we will immediately stop processing your data.
If the basis changes, then, if required by law we will notify you of the change and of any new basis under which we have determined that we can continue to process your information.

4.    Information we process because we have a contractual obligation with you

When you buy a product or service from us, or otherwise agree to our terms and conditions, a contract is formed between you and us.
In order to carry out our obligations under that contract, we must process the information you give us. Some of this information may be personal information.
We may use it in order to:
  • Verify your identity for security purposes;
  • Sell products to you;
  • Provide you with our services; and/or
  • Provide you with suggestions and advice on products, services and how to obtain the most from using our website.
We process this information on the basis that there is a contract between you and us or that you have requested that we use the information before we enter into a legal contract.
We will continue to process this information until the contract between us ends or is terminated by either party under the terms of the contract.

5.    Information we process with your consent

Through certain actions when otherwise there is no contractual relationship between us, such as when you browse our website or ask us to provide you more information about our business, including our products and services, you provide your consent to us to process information that may be personal information.
Wherever possible, we aim to obtain your explicit consent to process this information.
If you have given us explicit permission to do so, we may from time to time pass your name and contact information to selected associates, whom we consider may provide services or products you would find useful.
We continue to process your information on this basis until you withdraw your consent or when it can be reasonably assumed that your consent no longer exists.
You may withdraw your consent at any time by instructing us GDPR@pwpcl.com. However, if you do so, you may not be able to use our website or our services further.

6.    Information we process for the purposes of legitimate interests

We may process information on the basis that there is a legitimate interest, either to you or to us, of doing so. Where we process your information on this basis, we do so after having given careful consideration to:
  • Whether the same objective could be achieved through other means;
  • Whether processing (or not processing) might cause you harm; and
  • Whether you would expect us to process your data, and whether you would, in the round, consider it reasonable to do so
For example, we may process your data on this basis for the purposes of:
  • Record-keeping for the proper and necessary administration of our business;
  • Responding to unsolicited communication from you to which we believe you would expect a response;
  • Protecting and asserting the legal rights of any party;
  • Insuring against or obtaining professional advice that is required to manage organisational or business risk; and/or
  • Protecting your interests where we believe we have a duty to do so.

7.    Information we process because we have a legal obligation

Sometimes, we must process your information in order to comply with a statutory obligation.
For example, we may be required to give information to legal authorities if they so request or if they have the proper authorisation such as a search warrant or court order. This may include your personal information.

Specific uses of information you provide to us

8.    Information relating to your method of payment

If you purchase goods or services from us via our website, payment information is never taken by us or transferred to us either through our website or otherwise. Our employees and contractors never have access to it.
At the point of payment, you are transferred to a secure page on the website of a reputable payment service provider. That page may be branded to look like a page on our website, but it is not controlled by us.

9.    Job application and employment

If you send us information in connection with a job application, we may keep it for up to 6 months in case we decide to contact you at a later date.
If we employ you, we collect information about you and your work from time to time throughout the period of your employment. This information will be used only for purposes directly relevant to your employment. After your employment has ended, we will keep your file for six years before destroying or deleting it.

10.    Communicating with us

When you contact us, whether by telephone, through our website, by e-mail or by other means, we collect the data you have given to us in order to reply with the information you need.
We record your request and our reply in order to increase the efficiency of our business.
We keep personally identifiable information associated with your message, such as your name and email address, so as to be able to track our communications with you to provide a high quality service.

11.    Complaining

When we receive a complaint, we record all the information you have given to us.
We use that information to resolve your complaint.
If your complaint reasonably requires us to contact some other person, we may decide to give to that other person some of the information contained in your complaint. We do this as infrequently as possible, but it is a matter for our sole discretion as to whether we do give information, and if we do, what that information is.
We may also compile statistics showing information obtained from this source to assess the level of service we provide, but not in a way that could identify you or any other person.

12.    Affiliate and business partner information

This is information given to us by you in your capacity as an affiliate of us or as a business partner. It allows us to recognise visitors that you have referred to us and to credit to you commission due for such referrals. It also includes information, that allows us to transfer commission to you. The information is not used for any other purpose.
We undertake to preserve the confidentiality of the information and of the terms of our relationship. We expect any affiliate or partner to agree to reciprocate this policy.

Use of information we collect through automated systems when you visit our website

13.    Cookies

Cookies are small text files that are placed on your computer's hard drive by your web browser when you visit any website. They allow information gathered on one web page to be stored until it is needed for use on another, allowing a website to provide you with a personalised experience and the website owner with statistics about how you use the website so that it can be improved. Some cookies may last for a defined period of time, such as one day or until you close your browser. Others last indefinitely.
Our website does not use any cookies.

14.    Personal identifiers from your browsing activity

Requests by your web browser to our servers for web pages and other content on our website are recorded.
We record information such as your geographical location, your Internet service provider and your IP address. We also record information about the software you are using to browse our website, such as the type of computer or device and the screen resolution.
We use this information in aggregate to assess the popularity of the webpages on our website and how we perform in providing content to you. 

15.    Your duty to inform us of changes

It is important that the personal data we hold about you is accurate and current. Please keep us informed if any relevant changes regarding your personal data.

16.    Your rights under the GDPR

The GDPR gives you certain rights in relation to your personal data processed by us. These rights are the following:
  • Right of Access – The right to be informed of and request access to the personal data we process about you;
  • Right to Rectification – The right to request that we amend or update your personal data where it is inaccurate or incomplete;
  • Right to Erasure – The right to request that we delete your personal data;
  • Right to Restrict – The right to request that we temporarily or permanently stop processing all or some of your personal data;
  • Right to Object –
    • The right, at any time, to object to us processing your personal data on grounds relating to your particular situation;
    • The right to object to your personal data being processed for direct marketing purposes;
  • Right to Data Portability – The right to request a copy of your personal data in electronic format and the right to transmit that personal data for use in another party's service; and
  • Right not to be subject to Automated Decision-making – The right to not be subject to a decision based solely on automated decision making, including profiling, where the decision would have a legal effect on you or produce a similarly significant effect.
If you wish to exercise your rights, you should contact us by email or in writing to make that request.
Please note that we will not delete or change any information, if
  • We have a legal obligation to retain that information;
  • We are required by our tax authorities to store that data; and/or
  • This information is needed to support a claim or defence in court.

17.    Verification of your information

When we receive any request to access, edit or delete personal identifiable information, we shall first take reasonable steps to verify your identity before granting you access or otherwise taking any action. This is important to safeguard your information.
Other matters

18.    Use of site by children

We do not sell products or provide services for purchase by children, nor do we market to children.
If you are under 18, you may use our website only with express consent from a parent or guardian

19.    How you can complain

If you are not happy with our privacy policy or if you have any complaint then you should tell us. If a dispute is not settled, we hope you will agree to attempt to resolve it by engaging in good faith with us in a process of mediation or arbitration.
If you are in any way dissatisfied about how we process your personal information, you have a right to lodge a complaint with the Information Commissioner's Office (ICO). This can be done at https://ico.org.uk/make-a-complaint/. We would, however, appreciate the opportunity to talk to you about your concern before you approach the ICO.

20.    Retention period for personal data

Except as otherwise mentioned in this privacy policy, we will keep your personal information only for as long as required by us:
  • To provide you with the services you have requested;
  • To comply with other law, including for the period demanded by our tax authorities; and/or
  • To support a claim or defence in court.   

21.    Compliance with the law

Our privacy policy has been compiled so as to comply with the law of every country or legal jurisdiction in which we aim to do business. If you think it fails to satisfy the law of your jurisdiction, we would like to hear from you.
However, ultimately it is your choice as to whether you wish to use our website and/or to purchase any goods or services from us.

22.    Review of this privacy policy

We may update this privacy policy from time to time as necessary. The terms that apply to you are those posted here on our website on the day you use our website. We advise you to print a copy for your records.
If you have any question regarding our privacy policy, please contact us.