BUSINESS INFORMATION
If you have any concerns or would like further information about this policy in general, you can contact us;
Contact Name: Sarah Chard
Registered Address: 2 Hamilton Terrace, Leamington Spa, CV22 4LY
Website: theprroom.co.uk
Email Address: sarah.chard@theprroom.co.uk
Company number: 04963435
ICO Registration: ZB504911
VAT Registration: 825 0600 62
Telephone number: +44 (0)333 939 8296
ABOUT THIS PRIVACY NOTICE
This policy sets out, as a business how we process data both inside the business, and on the website.
We are committed to protecting your privacy and complying with our data protection obligations under the Data Protection Act 2018 (the DPA 2018), the UK General Data Protection Regulation 2016/679 (the UK GDPR) and any other applicable UK legislation (together, Data Protection Law).
When you interact with us or use the website, we act as the data controller of your personal data. This means we are responsible for processing your personal data and deciding how to use it. This privacy policy explains the types of personal data we may collect about you when you interact with us, why we collect it, what we use it for and what rights you have over it. Personal data is any information about an identifiable person. Processing is anything we do with your personal data, including using, storing, sharing and deleting it.
This policy was last updated on the date shown in the footer. We may change this policy at any time by posting an updated version on the website and will make reasonable efforts to bring any material changes to your attention. You may wish to check it before using the website, as any changes will be effective from the date they are made.
WHAT INFORMATION DO WE COLLECT AND HOW WILL WE USE IT?
We collect, store and use the types of personal data set out in the tables at the end of this policy.
HOW DO WE SHARE YOUR PERSONAL DATA?
When we share personal data, we do so under Data Protection Law. We may share certain personal data, where necessary, with employees, contractors, consultants or advisers to facilitate the service provision or complete our legal obligations, e.g. HMRC.
We may also provide third parties with aggregated but anonymised information and analytics about our customers. Before doing so, we will ensure that it does not identify you.
SHARING INFORMATION
We endeavour to keep as much data within the UK/EU. However, there may be times when this is not possible. Where the platforms we use are outside of the UK, or not a country where we have adequacy regulations, we will assess if the transfer is necessary to perform our service under the contract and that the data transfer comes under a restricted transfer.
Where we are legally required to do so, information is shared. On occasion, we may not be allowed to tell you of information being shared.
A full list of the information we collect can be found here.
Website
On our website, we do not have any links to external sites. If our site, at any time, contains links to other websites, we are not responsible for and do not review or endorse the privacy policies or practices of other websites you choose to access from this website. We encourage you to review the privacy policies of those other websites to understand how they collect, use and share your personal information.
YOUR RIGHTS
We respect your privacy rights and will respond to requests for access or control over information about you under Data Protection Law. We may require you to verify your identity before we take any action.
Depending on the reason we have your personal data, you have a right to:
• access the personal information we hold about you (commonly known as subject access);
• request that we correct or complete personal information we hold about you that is inaccurate or incomplete;
• request that we erase your personal information in some circumstances or object to our processing it;
• restrict how we use your personal data, in certain circumstances;
• request that we provide you with copies of your personal information in a machine-readable format or transfer it across different services; and
• where we have asked for your consent to process your data to withdraw this consent.
These rights are limited in some situations under Data Protection Law – for example, where we can demonstrate that we are under a legal obligation to process your data.
If you wish to exercise any of these rights, please get in touch with us.
Your right to object
You have a right to object to our processing of your personal data and ask us to stop doing so. If we are processing your personal data for direct marketing purposes (which includes profiling to the extent that it is related to such direct marketing) and you object to this, we will stop processing your personal data immediately.
If our processing of your personal data is in the public interest or under our legitimate interests and you object to this, we will stop processing your personal data unless we have compelling reasons which override your interests or our use of your personal data is for the establishment, exercise or defence of legal claims.
We hope we can satisfy any queries you may have about how we process your data. However, if you have unresolved concerns, you also have the right to complain to data protection authorities (in the UK, the Information Commissioner’s Office). You can call the ICO on 0303 123 1113 or visit their website: https://ico.org.uk/make-a-complaint).
Data Retention
Your personal data will only be kept for as long as necessary for our purposes. Specific retention periods are set out in the table at the end of this policy.
At the end of the specified retention periods, your personal data will either be securely destroyed or anonymised unless we must keep it to comply with our legal obligations.
DATA PROTECTION PRINCIPLES
We process your personal data under the following principles:
• we process your personal data lawfully, fairly and in a transparent way;
• we collect your personal data for specified, explicit and legitimate purposes; any further processing we do is compatible with the original purposes for which we collected it;
• we only process personal data that is adequate, relevant and limited to what is necessary to achieve the purpose for which it is processed;
• we take reasonable steps to ensure that all personal data is accurate and kept up to date where necessary;
• we do not store personal data in a form that identifies you for any longer than is required for the purposes of our processing; and
• we process personal data securely and in a way that protects against unauthorised or unlawful processing, accidental loss, destruction or damage.
When we ask for your personal data, we will tell you whether you are required by law or contract to provide it and what will happen if you do not provide the data.
Any request for consent to processing your personal data will be made directly to you and will include information about why we require the personal data and what will be done with it.
WHAT IS OUR LAWFUL BASIS FOR PROCESSING?
We will only process personal data when we have a lawful basis for processing. The table at the end of this policy sets out the legal basis we rely on for each type of data we process.
We will choose one of the lawful bases in the UK GDPR to justify how we use your personal data. These are:
• Consent: You have given consent to the processing of your personal data for one or more specific purposes. You have the right to withdraw your consent at any time, as detailed above.
• Contract: The processing is necessary to perform a contract with you or to take steps at your request before entering into a contract.
• Legal obligation: We must process your personal data to comply with a legal obligation.
• Vital interests: The processing is necessary to protect the vital interests of you or another person.
• Public interest: Processing is necessary for performing a task in the public interest or in the exercise of some official authority.
• Legitimate interests: Processing is necessary for legitimate interests pursued by us or someone else, except where such interests are overridden by your interests or fundamental rights and freedoms requiring the protection of your personal data.
PERSONAL INFORMATION WE USE
a. Contract
| Category | Name and contact details |
| Purpose of processing | • To deliver your services on your behalf • To send you service updates |
| Lawful basis for processing | • Performance of contract • Compliance with legal obligation • Consent |
| Retention period | For three years since you gave consent, or until you withdraw consent if earlier |
b. Payment information, bank transfer, cheque
| Category | Payment information |
| Purpose of processing | • To take payment and give refunds • For fraud prevention and detection |
| Lawful basis for processing | • Performance of contract • Compliance with legal obligation |
| Retention period | For seven years since you last logged on to the website |
c. Emails
| Category | Contact history |
| Purpose of processing | • To provide customer service and support • To train our team |
| Lawful basis for processing | • Performance of contract • Legitimate interests in dealing with complaints or claims |
| Retention period | For six years since you last logged on to the website |
d. Website, testimonials, emails
| Category | Customer comments and product reviews |
| Purpose of processing | • To improve our products and services • Where relevant, to establish, exercise or defend legal claims |
| Lawful basis for processing | • Performance of contract • Legitimate interest in dealing with complaints or claims and improving our products and/or services generally |
| Retention period | For six years |