Dated: 6th of July 2020

Introduction to General Data Protection Regulation (GDPR) 2018

As part of our arrangements with you, Pirkx Limited [“pirkx”] has certain obligations under privacy laws and General Data Protection Regulation (GDPR) to notify individuals how we will process their personal information we collect. We may maintain personal records for a minimum of at least six years.

We will inform individuals how information collected is used, where it is transferred, and how they may view or amend it. We will treat all personal information as confidential and will not process it other than for a legitimate purpose. Steps will be taken to ensure that the information is accurate, kept up to date and not kept for longer than is necessary. Measures will also be taken to safeguard against unauthorised or unlawful processing and accidental loss, destruction or damage to the information.

The information provided to us may include personal and sensitive data. By using our services, you consent to us and any company associated with us (including, but not necessarily restricted to business partners and strategic alliances, as well as product and insurance providers) processing your data for the purposes of providing agreed services, administration and management. This processing includes obtaining, recording or holding information or data, transferring it to other companies associated with us such as service and product providers, insurers or statutory, governmental or regulatory bodies for legitimate purposes. The examples of third parties provided is not exhaustive and may be updated from time to time as business needs and legal requirements dictate. We will not sell personal data to any third party.

Some services are provided to our organisation by third parties such as processing business or obtaining consultancy, legal or regulatory advice, which may warrant the disclosure of more than just your basic contact details. Personal information held by us may be disclosed on a confidential basis, and in accordance with the GDPR, to any such third parties. This information may be transferred electronically (e.g. e-mail) and we, or any such third party, may contact you in future by any means of communication which we consider appropriate at the time. We will not pass any of your data – including payment details – to any third parties, without your consent or for any purpose other than that which consent was given.

Some of the companies we work with will hold data on you in countries outside of Europe that do not always have the same standard of Data Protection laws as the UK. If this is the case appropriate due diligence will be completed to ensure that your information is adequately protected, and the organisations concerned will be bound by their obligations under the GDPR when your personal information is processed outside Europe.

Where we introduce you to other business partners in order to support service delivery to you, they will also have obligations under GDPR to process your personal information securely. The parties will share information about you, i.e. we may provide updates about the progression and development of your matter for legitimate business purposes. We consider this will be of benefit to you in respect of the services that we are providing.

We may use your data to contact you in the future to provide you with details of products, services or information that we feel may be of interest or benefit to you. Please be aware that pirkx may record calls for training and quality purposes. If you wish us or any company associated with us to cease processing your data or you would like to obtain copies of the information we hold about you, please write to: The Data Protection Officer, Pirkx Limited, 60 St. Martins Lane, Covent Garden, London WC2N 4JS. Under the terms of the GDPR, Pirkx have a period of a month to provide the copies. Pirkx Limited is registered with the Information Commissioner’s Office (ICO) as a Data Controller. Registration number: ZA425782

Privacy Policy

When you use our services, you trust us with your information. This Privacy Policy is meant to help you understand what data we collect, why we collect it and what we do with it.

There are many different ways that you can use our services. When you share information with us we can make our services better – to show you more relevant search results and to help you connect with people. As you use our services, we want you to be clear how we’re using information and the ways in which you can protect your privacy.

Our Privacy Policy explains:

  • Principles for processing personal data.
  • What information we collect and why we collect it.
  • How we use that information.
  • Information we share, and who we share it with.
  • Transfer to other countries.
  • Legal basis for collecting and processing personal data.
  • Retention of personal data.
  • Updating information.
  • Privacy Policy of other sites.
  • Cookie Policy.

Our principles for processing personal data are:

  • Fairness and lawfulness. When we process personal data, the individual rights of the Data Subjects must be protected. All personal data must be collected and processed in a legal and fair manner.
  • Restricted to a specific purpose. The personal data of Data Subject must be processed only for specific purposes.
  • Transparency. The Data Subject must be informed of how his/her data is being collected, processed and used.

Information we collect

We collect information to provide better services to all of our users.

We collect information in the following ways:

  • Information you give us.
  • Information we get from your use of our services.
  • When you use or view or website via browser cookies.
  • When you register online for our services and products.
  • We may also receive data from your employers.

Pirkx collects several different types of personal data for various purposes.

Personal Data may include, but is not limited to:

  • Email address
  • First name and last name
  • Phone number

How we use information that we collect

To process your order and manage your account.

We use the information we collect from our services to provide, maintain, protect and improve your user experience and to develop new ones.  We also use this information to offer you tailored content.

With consent, we use data to:

  • analyse user cohorts and behaviours across our website; we build aggregated audiences around key attributes and behaviours. This allows us to make product improvements
  • facilitate targeted advertising when we run advertising campaigns to grow our customer base, eg. we can use lookalike modelling to find more potential customers across the web
  • fulfil other commercial interests that allow pirkx to run successfully, such as demonstrating to partners that our audiences are well aligned

We facilitate the above functions by using technology providers:

  • Lotame – data management platform, for the purpose of gaining audience insights and enabling consented audience data to be activated on the below platforms. Lotame uses cookies and other identifiers to track online behavioural, demographic and technographic data. Lotame can receive anonymous data segments that pirkx sends, such as user IDs associated with different interests or behaviours. Lotame stores data on average for 9 months, and in special cases for up to 18 months
  • Lotame does not receive information such as your name and email.Lotame’s privacy policy: https://www.lotame.com/about-lotame/privacy/lotames-products-services-privacy-policy/

When you contact us, we keep a record of your communication to help solve any issues you might be facing.  We may use your e-mail address to inform you about our services, such as letting you know about upcoming changes or improvements.

We will ask for your consent before using information for a purpose other than those set out in this Privacy Policy.

Legal basis for collecting and processing personal data

Pirkx limited, legal basis for collecting and using the personal data described in this Data Protection Policy depends on the personal data we collect and the specific context in which we collect the information:

  • My Company needs to perform a contract with you
  • You have given My Company permission to do so
  • Processing your personal data is in My Company legitimate interests
  • My Company needs to comply with the law

Retention of personal data

“pirkx” will retain your personal information only for as long as is necessary for the purposes set out in this Data Protection Policy.

“pirkx” will retain and use your information to the extent necessary to comply with our legal obligations, resolve disputes, and enforce our policies.

Information that you share

Remember that when you share information publicly, it may be indexable by search engines.

Accessing and updating your personal information

Whenever you use our services, we aim to provide you with access to your personal information.  If that information is wrong, we will strive to update it quickly or to delete it – unless we have to keep that information for legitimate business or legal purposes. When updating your personal information, we may ask you to verify your identity before we can act on your request.

We may reject requests that are unreasonably repetitive, require disproportionate technical effort, risk the privacy of others, or would be extremely impractical.

Where we can provide information access and correction, we will do so free of charge, except where it would require a disproportionate effort. We aim to maintain our services in a manner that protects information from accidental or malicious destruction. Because of this, after you delete information from our services, we may not immediately delete residual copies from our active servers and may not remove information from our backup systems.

Information that we share

We do not share personal information with companies, organisations and individuals outside of pirkx unless one of the following circumstances applies:

  • With your consent

    We will share personal information with companies, organisations or individuals outside of pirkx when we have your consent to do so. We require opt-in consent for the sharing of any data and sensitive personal information.

  • For external processing

    We provide personal information to our affiliates or other trusted businesses or persons, which may be based outside the EU to process it for us, based on our instructions and in compliance with our Privacy Policy and any other appropriate confidentiality and security measures.

  • For legal reasons

    We will share personal information with companies, organisations or individuals outside of pirkx if we have a belief in good faith that access, use, preservation or disclosure of the information is reasonably necessary to:

    • meet any applicable law, regulation, legal process or enforceable governmental request.
    • enforce applicable Terms of Service, including investigation of potential violations.
    • detect, prevent or otherwise address fraud, security or technical issues.
    • protect against harm to the rights, property or safety of pirkx, our users or the public, as required or permitted by law.

    We may share non-personally identifiable information publicly and with our partners. For example, we may share information publicly to show trends about the general use of our services.

Transfer to other countries

pirkx shares your personal data globally with the pirkx group of companies in order to carry out the activities specified in this policy. pirkx may also subcontract processing to, or share your personal data with, third parties located in countries other than your country and this can be outside the European Union. Your personal data, therefore, may be subject to privacy laws that are different from those in your country.

Personal data collected within the European Union and Switzerland may, for example, be transferred to and processed by third parties located in a country outside of the European Union and Switzerland. In such instances pirkx shall ensure that the transfer of your personal data is carried out in accordance with applicable privacy laws and, in particular, that appropriate contractual, technical, and organisational measures are in place such as the Standard Contractual Clauses approved by the EU Commission.

Categories of Recipients Reason for sharing

Service providers We work with service providers that work on our behalf which may need access to certain personal data in order to provide their services to us. These companies include those we've hired to provide, services, customer service support, operate the technical infrastructure that we need to provide the pirkx platform, assist in protecting and securing our systems and services.

Payment processors We will share your personal data with our payment processors as necessary to enable them to process your payments, and for anti-fraud purposes.

pirkx partners Depending on how you sign up for the pirkx platform (e.g. through a third party service or an Introducer), we share your pirkx username or other User Data as necessary to enable your account. We may also share personal data with that third party about your use of the pirkx platform, such as whether and to what extent you have used the offer, activated a pirkx account, or actively used the pirkx platform. We also may share your personal data with an Introducer for the purpose of allowing them to understand if you joined pirkx or not.

Other pirkx group companies We will share your personal data with other pirkx group companies to carry out our daily business operations and to enable us to maintain and provide the pirkx platform to you.

Law enforcement agencies and data protection authorities We share your personal data when we in good faith believe it is necessary for us to do so in order to comply with a legal obligation under applicable law, or respond to valid legal process. We also share your personal data where we in good faith believe that it is necessary for the purpose of our own, or a third party’s legitimate interest relating to national security, law enforcement, litigation, criminal investigation, protecting the safety of any person, or to prevent death or imminent bodily harm, provided that we deem that such interest is not overridden by your interests or fundamental rights and freedoms requiring the protection of your personal data.

Purchasers of our business We will share your personal data in those cases where we sell or negotiate to sell our business to a buyer or prospective buyer. In this situation, pirkx will continue to ensure the confidentiality of your personal data and give you notice before your personal data is transferred to the buyer or becomes subject to a different privacy policy.

Information security

We work hard to protect pirkx and our users from unauthorised access to or unauthorised alteration, disclosure or destruction of information that we hold. In particular:

  • We encrypt many of our services.
  • We review our information collection, storage and processing practices, including physical security measures, to guard against unauthorised access to systems.
  • We restrict access to personal information to pirkx employees, contractors and agents who need to know that information in order to process it for us and who are subject to strict contractual confidentiality obligations. They may be disciplined, or their contract terminated if they fail to meet these obligations.

Privacy Policy of other sites

The pirkx.com website contains links to other sites, our privacy policy only applies to our websites, so if you click on a link to another website you should read their Privacy Policy.

Cookie Policy

We use a variety of technologies to help us better understand how you use pirkx.com

What are Cookies?

Cookies are small data files placed on your computer by websites you visit in order to help them remember certain information about you. At pirkx, we set only a few cookies for tracking user preferences, authentication, and collecting anonymous analytics data. Additionally, we also use other cookies; each of these uses is described in greater detail below:

Strictly necessary cookies

These are cookies that are required for the operation of our Website. They include, for example, cookies that enable you to log into secure areas of our Website.

Browser cookies

This is a small data file sent from a website to your browser that is stored on your computer's hard drive. You can configure your browser's settings to reflect your preference to accept or reject cookies.

Preference Cookies

If you logged out, pirkx will place a simple cookie to remember your preferences’ for the site.

Authentication Cookies

When you log into your account, pirkx will place a cookie for the sole purpose of creating this session. It contains your user id and hashed authentication information.

Analytics Cookies

We use a tool called Google Analytics to help us understand how users interact with our website. It tells us aggregate usage and traffic information, such as how the site was accessed, how long visitors stayed, and the number of first-time visitors to the site. By knowing how people use the site, we can make it better.To learn more about Google Analytics and how it uses your data, please visit http://www.google.com/analytics/learn/privacy.html

Managing Cookies

Most browsers include an option to clear existing cookies or reject new ones. However, if you do this, portions of the pirkx.com website may not function as intended. The links below provide information about cookie settings in major browsers:

You may also choose to opt out of Google Analytics, details can be found below:

https://tools.google.com/dlpage/gaoptout

Manage your Cookie Settings Here:

When this Privacy Policy applies

Our Privacy Policy applies to all of the services offered by all parts of the pirkx and its affiliates.

Our Privacy Policy does not apply to services offered by other companies or individuals, or the information practices of other companies and organisations that we work with.

Data protection rights

If you are a resident of the European Economic Area (EEA), you have certain data protection rights. If you wish to be informed what personal data we hold about you and if you want it to be removed from our systems, please contact us.

In certain circumstances, you have the following data protection rights:

  • The right to access, update or to delete the information we have on you
  • The right of rectification
  • The right to object
  • The right of restriction
  • The right to data portability
  • The right to withdraw consent

Compliance and cooperation with regulatory authorities

We regularly review our compliance with our Privacy Policy.  We may receive requests for information from governments, courts and law enforcement authorities which we are obliged to comply with.  When we receive formal written complaints, we will contact the person who made the complaint to follow up. We may work with the appropriate regulatory authorities, including the Information Commissioner’s Office (ICO) and local data protection authorities, to resolve any complaints regarding the transfer of personal data that we cannot resolve with our users directly.

Changes

Our Privacy Policy may change from time to time and we will post any changes on this page.

Please be assured of our utmost commitment to keep your personal information private and safe.