Our commitment to privacy
Who are we?
Partager Limited is a company registered in England and Wales with a company number of 02998807. Our registered office address is 14 Charterhouse Square, London, EC1M 6AX.
Information we collect about you
When you access the site, or when you engage our services, or when you interact with us, we may collect and process personal data about you:
- Basic Personal identity details – such as name and title.
- Contact details – such as billing address, email address and telephone number.
- Work details – such as job title, company name, company address, email address and telephone number.
- Financial and Payment details – such as bank account and payment card details.
- Profile details – such as your username and password, your interests and preferences, communication and marketing preferences, feedback and survey responses.
We work closely with partners (including, for example, those providing technical, payment or delivery services and analytics providers) and we may receive information about you from them, examples include:
- Technical Data – such as 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.
Usage Data – such as information about how you use our website, products and services.
We do not collect any special categories of personal data about you.
Please be aware that if you do not provide data when requested by us, we may not be able to provide our services or perform our contract with you.
Non-Personal information and use
In common with many commercial organisations we monitor the use of this website by collecting aggregate information. We may automatically collect non-personal information; you cannot be identified from this information and it is used only to assist us in providing an effective service on this website.
A cookie is a small file of letters and numbers that we put on your computer if you agree. These cookies allow us to distinguish you from other users of our website, which helps us to provide you with a positive experience when you view or use our website and also allows us to improve our site.
Lawful basis for processing data
We will only use your personal data when the law allows us to, in the following circumstances:
- User consent – where you have given us consent by express permission to process personal data for a specified purpose.
- Contractual necessity – where we need to use it to perform the contract we are about to enter into or have entered into with you.
- Legitimate business purpose – 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.
- Legal obligation – where we need to comply with a legal obligation.
Purposes for which we will use your personal data
The reasons for which we collect, and process personal data are set out below. We may process your personal data under more than one lawful basis depending on the specific 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. Please note that we may process your personal data without your knowledge or consent, where this is required or permitted by law.
|Purpose/Activity||Type of data||Lawful basis for processing|
|To register you as a new subscriber customer||(a) Identity (b) Contact||Performance of a contract with you|
|To:(a) Manage payments, fees and charges(b) Collect and recover money owed to us||(a) Identity (b) Contact (c) Financial (d) Transaction (e)Marketing and communications||(a) Performance of a contract with you (b) Necessary for our legitimate interests (to recover debts due to us)|
|To enable you to complete a survey||(a) Identity (b) Contact (c) Profile (d) Usage (e) 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(b) Contact(c) Technical||(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 for a legal obligation|
|Purpose/Activity||Type of data||Lawful basis for processing|
|To deliver relevant website content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you||(a) Identity (b) Contact (c) Profile (d) Usage (e) Marketing and Communications (f) Technical||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)|
|To use data analytics to improve our website, products/services, marketing, customer relationships and experiences||(a) Technical (b) Usage||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 (b) Contact (c) Technical (d) Usage (e) Profile (f) Marketing and Communications||Necessary for our legitimate interests (to develop our products/services and grow our business)|
We may use your personal data (for example your identity, contact, technical, usage and profile data) to form a view on what we think may be of interest to you and to decide on products, services and offers that may be relevant for you.
You will receive marketing communications from us if you have requested information from us.
We will get your express 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 relevant links on any marketing message sent to you. This will not apply to personal data provided to us as a result of a product/service purchase, or other transaction with us.
Disclosures of your personal data
We may share your personal data with the parties set out below.
- Internal third parties who are associated companies within our group who help support our business and improve our services.
- External third parties as follows:
- Service providers who provide IT and system administration services.
- Professional advisers including lawyers, bankers, auditors and insurers who provide consultancy, banking, legal, insurance and accounting services.
- Third parties (other businesses) to whom we may choose to sell, transfer or merge parts of our business or our assets, or where we acquire or merge with them.
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 our third-party service providers to use your personal data for their own purposes and we only permit them to process your personal data for specified purposes and in accordance with our instructions.
How long will we retain your personal data?
We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for any legal, regulatory, tax, accounting or reporting requirements, and for our customers this may be for up to six years for financial and tax purposes or in the event of a complaint or dispute.
Details of retention periods for different aspects of your personal data are available in our retention policy which you can request by contacting us.
We may transfer data outside the European Economic Area (EEA). Where this is the case, we take steps to ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:
We will only 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.
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 implemented commercially reasonable measures, technologies and policies with the objective of protecting your personal information from unauthorised access and improper use and will update these measures as appropriate as new technologies become available. In addition, we limit access to your personal data to those of our 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.
Under data protection laws, you have rights as an individual in relation to the personal data we hold about you. These rights include the right to:
- Request access to, correction of, or deletion of, your personal data.
- Object to, or request restriction of, processing of your personal data.
- Request transfer of your personal data.
- Withdraw consent, including where consent has been sought from you for purposes such as direct marketing.
You can exercise these rights by contacting us. You also have the right to lodge a complaint with a supervisory authority. In the UK, this is the Information Commissioner’s Office (ICO) They can be contacted via their website https://ico.org.uk/concerns or by phone: +44 303 123 1113.
You will not have to pay a fee to access your personal data or to exercise any of your other rights. However, we may charge a reasonable fee or refuse to comply if your request is clearly unfounded, repetitive or excessive.
If we receive a request from you to exercise any of the above rights, 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 you for further information in relation to your request to speed up our response.
We try to respond to all legitimate requests within one month. Occasionally it could 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 policy is effective from May 2018.