Pure360 Privacy Policy

1. Introduction

This privacy notice aims to give you information on how Pure360 (also referred to below as “we”, “us” or “our”) collects, stores, uses and processes your personal data in the course of our business. This includes information that we collect and process in order to provide services to our clients, to operate our business (including our marketing functions) and information that we collect through your use of our website, our social media pages on Twitter, Facebook, LinkedIn and other social media platforms and through other interactions with our members of staff. 

For further details about us and how to contact us, see the section Company details at the end of this Privacy Policy.

We endeavour to take all due care to protect your personal information, in accordance with the applicable Data Protection legislation from time to time.

For the purposes of Data Protection legislation, Pure360 is the data controller in respect of the personal information that we collect.

This version of the Privacy Policy was last updated on 11th November 2021.

2. The type of personal information we collect 

We currently collect and process the following information:

• your name, address, email address and telephone number(s), and the company or other entity on whose behalf you are acting;
• your financial details so far as relevant to providing services to you, including your bank and/or building society details.
• records of emails and other correspondence (including any further information we may request from you) when you contact us to request information, report a problem, or provide feedback on our products and services;
• standard information automatically collected by our web server including your IP address, browser type, and operating system;
• details of your visits to our site, including access time.
• profile data includes preferences, feedback, survey responses, and correspondence.
• marketing and communications data including your preferences in receiving marketing from us and our third parties and your communication preferences.

If you contact us to enquire about a job vacancy, we will collect details relevant to your enquiry and any subsequent application you may make, which will include your name, address, e-mail address and telephone number(s), CV and work experience, and (in certain cases) your personal circumstances. We will provide you with further details at the time.

3. How we get your personal information and how we use it

We will collect personal information in the course of providing our services to our clients. This information will typically be provided by you.

We use different methods to collect data from and about you including through:

Direct interactions from publicly accessible sources, e.g. social media and other online sources; 

You may give us your Identity, Contact, Financial and Profile Data by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:

•  enquire or purchase our services;
•  in the process of supplying our services;
•  completing an online form on our website;
•  request marketing to be sent to you;
•  give us some feedback.

Automated technologies or interactions as you interact with our website

We may automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies, and other similar technologies. Please see our cookie policy available on our website https://www.Pure 360.com/cookies/ for further details.

Technical Data from the following parties:

• analytics providers such as Google 
• search information providers based inside or outside the EU.

Contact, Financial and Transaction Data from providers of technical, payment and delivery services based in the EU.

Identity and Contact Data from publicly available sources such as Companies House and the Electoral Register based in the EU.

Identity and Contact Data from third party sources such as intent data from B2B data suppliers and event management companies based in the EU.

Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.

We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data may be derived from your personal data but is not considered personal data in law as this data does not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature.

We plan to use the personal data we collect as follows:

• to register you as a new client
• to process and deliver your order for services including;
  • Managing payments
  • Collecting and recovering money owed to us
  • to provide you with the information about our products and services that you request
  • to respond to any queries, complaints or requests for further information
• to manage our relationship with you including notifying you about changes to our terms or policies
• to enable you to complete a survey
• to administer and protect our business and our website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data) 
• to deliver relevant content including website content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you
• to use data analytics to improve the content of, or customise our website, services, market ing, client relationships and experiences
• to make suggestions and recommendations to you about services that may be of interest to you
• if you contact us to enquire about a job vacancy, we will only use your Information for that purpose

We use a variety of service providers acting as processors who provide IT and system administration services. These include the following categories:

• Analytics – such as Google Analytics, RStudio
• Phone call management – such as Jiminny, RingCentral
• CRM and customer support – such as Sugar
• Project management – such as Teamwork
• Payments – such as WorldPay, Streamline
• Cloud Storage and services – such as Google, Amazon
• Document management – such as Adobe Sign
• In app messaging – such as Intercom
• Surveys – such as Smartsurvey

4. On what lawful basis do we use your information?

We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:

• Where we need to perform the contract we are about to enter into or have entered into with you.
• 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.
• Where we need to comply with a legal or regulatory obligation.
• Where we have consent to do so.

Our lawful basis or bases for processing your data is as follows:

• Where you are an existing client or likely client: Contract and Legitimate Interests;
• Where your personal data is held by us on a prospect marketing database: Legitimate Interests;

You have the right to withdraw consent to marketing at any time by contacting us or clicking the Unsubscribe link within any marketing email we send.

Our legitimate business interests include our interests in providing our services, complying with legal obligations, recruiting, training and developing our staff, promoting our business through marketing communications, and carrying out our administrative and operational functions. We may process personal information you provide to us where such processing is necessary in order to pursue our legitimate interests, provided that our right to do so is not overridden by your own rights and interests. 

5. Who do we share your Information with?

We may have to share your personal data with the parties set out below for the purposes set out in section 3 above.

• Internal Third Parties.
• External Third Parties as set out in the Glossary below.

We may also need to share some personal data with other parties, such as if we seek to acquire other businesses or merge with them, potential buyers of some or all of our business or assets or during a restructuring. Usually, information will be anonymised but this may not always be possible. The recipient of the information will be bound by confidentiality obligations. 

We may disclose and exchange information with law enforcement agencies and regulatory bodies to comply with our legal and regulatory obligations. 

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 only permit them to process your personal data for specified purposes and in accordance with our instructions.

We will get your express opt-in consent before we share your personal data with any company outside Pure360 for marketing purposes.

When using our website it may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy notice of every website you visit.

Whenever we transfer your personal data out of the UK, we 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.
• 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.  

6. How long do we keep personal information for?

We normally delete your personal data after five years, however for clarity, we will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements, and to show that we treated you fairly.

To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.

In some circumstances you can ask us to delete your data: see Request erasure below for further information.

In some circumstances we may anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes in which case we may use this information indefinitely without further notice to you.

7. Your data protection rights

Under data protection law, you have rights including:

• Your right of access – You have the right to ask us for copies of your personal information. 
• Your right to rectification – You have the right to ask us to rectify personal information you think is inaccurate. You also have the right to ask us to complete information you think is incomplete. 
• Your right to erasure – You have the right to ask us to erase your personal information in certain circumstances. 
• Your right to restriction of processing – You have the right to ask us to restrict the processing of your personal information in certain circumstances. 
• Your right to object to processing – You have the right to object to the processing of your personal information in certain circumstances.
• Your right to data portability – You have the right to ask that we transfer the personal information you gave us to another organisation, or to you, in certain circumstances.

You are not required to pay any charge for exercising your rights. If you make a request, we have one month to respond to you.

Please contact us using the contact details in section 10 if you wish to make a request.

How to complain

If you have any concerns about our use of your personal information, you can make a complaint to us at dpo@pure360.com or using our contact details in section 10

You can also complain to the ICO if you are unhappy with how we have used your data.

The ICO’s address:            

Information Commissioner’s Office

Wycliffe House

Water Lane

Wilmslow

Cheshire

SK9 5AF

Helpline number: 0303 123 1113

ICO website: https://www.ico.org.uk 

8. How we store your personal information 

We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those 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.

We follow generally accepted industry standards to protect your Information from unauthorised use. However, as no data transmissions over the Internet can be guaranteed to be 100% secure, we cannot take responsibility for any unauthorised access or loss of personal information that is beyond our control.

Please remember that other methods of Internet communication, such as emails and messages sent via a website, are not secure unless they are encrypted. We take no responsibility for any unauthorised access or loss of personal information that is beyond our control.

9. Changes to this Privacy Policy and future developments

We may revise this Privacy Policy from time to time. The most current version of this Privacy Policy will govern our use of information about you and will be located on this page.  If we make material changes to this Privacy Policy then where appropriate we will notify you by email or by posting a notice on the Site prior to the effective date of the changes.

10. How to Contact Us

If you have any questions, comments or requests about the Site generally, please contact us by email to support@pure360.com.

If you any questions, comments or requests regarding our use of your personal information, or wish to delete your personal information, please contact us by email to support@pure360.com or write to us at the following address: The Data Protection Manager, Pure360, Spaces, Mocatta House, Trafalgar Place, Brighton, East Sussex, BN1 4DU.

11. Company details

We are Purepromoter Limited, trading as Pure360, registered in England and Wales with company number 4266410. Our registered office is at Spaces, Mocatta House, Trafalgar Place, Brighton, East Sussex, BN1 4DU. England.

12. Glossary

LAWFUL BASIS

Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give you the best service and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). 

Performance of Contract means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps before entering into such a contract.

Comply with a legal or regulatory obligation means processing your personal data where it is necessary for compliance with a legal or regulatory obligation that we are subject to.

THIRD PARTIES

External Third Parties

Service providers acting as processors based in and outside of the EU who provide IT and system administration services.

Professional advisers including lawyers, bankers, auditors and insurers based in the United Kingdom who provide consultancy, banking, legal, insurance and accounting services, Credit reference agencies, and external service suppliers, representatives and agents that we use to make our business more efficient

HM Revenue & Customs, regulators and other authorities based in the United Kingdom who require reporting of processing activities in certain circumstances.