Privacy Policy

Privacy Policy Promentum Ltd

Last updated on [22/05/2018]

In accordance with the Data Protection Act 1998 (as amended, repealed or replaced from time to time) (DPA) and the EU’s General Data Protection Regulation (EU 2016/679) (GDPR) which is directly applicable in all EU member states with effect from 25th May 2018 and to any other applicable privacy regulations operating in England and Wales, Promentum Limited (Company number 03207933) operate with the following Privacy Policy.

Promentum are committed to protecting and respecting your privacy. This policy (together with the relevant terms of use and commercial terms and any other documents referred to in each) sets out the basis on which any personal data we collect from you, or that you provide to us, will be processed by us.

Please read the following carefully to understand our views and practices regarding your personal data and how we will treat it.

For the purpose of applicable data protection legislation, we, Promentum Limited (Company number 03207933), registered in England at 3 The Mews, Holly Bush Lane, Sevenoaks, Kent, United Kingdom, TN13 3TH, are the data controller.

PERSONAL DATA WE MAY COLLECT FROM YOU

We may collect and process the following personal data about you:

Personal data you give us.
You may be required to provide us with personal data about you when enquiring about a Product or Service, requesting a quotation, using our Products or Services or by corresponding with us by phone, e-mail or otherwise. This includes personal data you provide when you register to use any of our Services, and when you report a problem with a Product(s) or Service. The personal data you give us may include items such as your name, address, e-mail address, phone number, date of birth, financial information, company and job role. We rely on ‘contractual necessity’ as the lawful ground for the processing of your personal information in such cases.

Personal data we collect about you.
Regarding the processing of some specific items of personal data that assist us to improve our Products and to provide our Services, we rely on ‘legitimate interests’ as the lawful ground for such processing. This includes automatically collecting and using the following personal data: any phone number used to call our offices, any email address used to contact us, and details provided when you register with www.promentum.co.uk. We may also record which pages of the Promentum website you visit and products and services that interest you.

By registering with www.promentum.co.uk and by expressly consenting to receiving information from us, be assured that we will only use your data in accordance with the DPA, the GDPR and any other applicable privacy regulations operating in England & Wales.

USES MADE OF THE PERSONAL DATA

We use personal data held about you in the following ways:

Personal data you give to us. We will use this personal data:

• to carry out our obligations arising from any contracts entered into between you and us and to provide you with the information, products and services that you request from us;
• to provide you with information about other goods and services we offer that are similar to those that you have already purchased or enquired about, provided that you have expressly opted-in to receive this information;
• to notify you about changes to our Products or Services which are applicable to those Products or Services you have purchased from us and/or made enquiries about;
• to comply with any applicable legal obligation placed upon us

Personal data we collect about you. We will use this personal data:

• to improve our Products and Services;
• to allow you to participate in interactive features of our Products and Services, when you choose to do so;
• as part of our efforts to keep our Products safe and secure;
• to make suggestions and recommendations to you and other users of our Products and Services that may interest you or them, provided that you have expressly opted-in to receive this information.

DISCLOSURE OF YOUR PERSONAL DATA

We may share your personal data with any department within Promentum Ltd. We may disclose your personal data to third parties:

• in the event that we sell or buy any business or assets, in which case we may disclose your personal data to the prospective seller or buyer of such business or assets;
• if Promentum Limited or substantially all of its assets are acquired by a third party, in which case personal data held by it about its users will be one of the transferred assets; or
• if we are under a duty to disclose or share your personal data in order to comply with any legal obligation; in order to enforce or apply our relevant terms of use relating to each Product and other agreements; or to protect the rights, property, or safety of Promentum Limited, our users, or others. This includes exchanging personal data with other companies and organisations for the purposes of fraud protection and credit risk reduction;
• if we use a third-party provider of services or products to assist with the delivery of our Products or Services to you and such use requires access to your personal data, provided that we will ensure a contract is in place with the third-party product or service provider, prior to sharing your personal data with them, which confirms they are under a legal obligation to protect and process your personal data in accordance with the obligations imposed by the DPA and GDPR;
• if your data is required by our sister company Promentum Technologies Ltd, in order for them to provide an additional service(s) associated with our Products or Services provided that, again, we will ensure a contract is in place with Promentum Technologies Limited, prior to sharing your personal data with them, which confirms they are under a legal obligation to protect and process your personal data in accordance with the obligations imposed by the DPA and GDPR.

WHERE WE STORE YOUR PERSONAL DATA

The data that we collect from you, or that you provide to us, will usually be stored by us at a destination anywhere within the European Economic Area (EEA). If it becomes necessary for us to transfer your personal data to a country outside of the EEA we will ensure that appropriate safeguards are in place to safeguard your personal data to the same level of security and protection as exist within the EEA.

RETENTION OF YOUR PERSONAL DATA

We will retain your personal data for as long as your account is active or as long as is necessary to provide you with access and support to our Products and Services and thereafter for a run-off period of [##] years. In some cases, we may retain your information for a longer period and we will advise you of this at the time.

If you wish to cancel your account or request that we no longer use your personal data to provide you with access to our Products or Services, contact us at compliance@promentum.co.uk. We will only retain and use your personal data thereafter as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements.

SECURITY OF YOUR PERSONAL DATA

The security of your personal data is important to us. We comply with accepted industry standards to protect the personal data submitted to us. We use strict procedures and advanced security features to try to prevent unauthorised access. No method of transmission over the Internet, or method of electronic storage, is however 100% secure. Therefore, we cannot guarantee its absolute security.

Where we have given you (or where you have chosen) a password which enables you to access certain parts of an online Service, you are responsible for keeping this password confidential. You are not permitted to share a password with anyone.

In the event of a personal data breach, we have in place procedures to ensure that the effects of such a breach are minimised and shall liaise with the Information Commissioner’s Office (ICO) and with you as appropriate.

YOUR RIGHTS

You have the following rights in relation to the handling of your personal data:

• You have the right to access personal data held about you
• You have the right to have inaccuracies corrected for personal data held about you
• You have the right to have personal data held about you erased
• You have the right to object to direct marketing being conducted based upon personal data held about you
• You have the right to restrict the processing for personal data held about you, including automated decision-making
• You have the right to data portability for personal data held about you

You can exercise any of your rights outlined above by contacting us at compliance@promentum.co.uk and by ensuring that your request is accompanied by suitable proof of your identity we will action the request within one month of receiving a request made under these rights. Where we receive a large number of requests, or receive especially complex requests, this may be extended by a maximum of two further months.

WHO CAN YOU COMPLAIN TO

If you are unhappy about how we are using your information or how we have responded to your request, then initially you should contact our data protection officer using the following e-mail address: compliance@promentum.co.uk.

If your complaint remains unresolved then you can contact the Information Commissioner’s Office whose details are available at www.ico.org.uk.

CHANGES TO OUR PRIVACY POLICY

Any changes we may make to our privacy policy in the future will be posted on our web site and, where appropriate, notified to you by e-mail.

CONTACT

If you have any questions about this privacy policy or about the information we hold about you, please contact us in the first instance.

You have the right to request a copy of the data we hold about you under the DPA and the GDPR, please note that we do NOT charge an administration fee for any request. Please contact us by emailing compliance@promentum.co.uk

Additional Content for Our Websites

MARKETING COMMUNICATIONS

If you register with www.promentum.co.uk we will ask you if you would like to receive email Marketing Communications to keep you up to date with the latest news we think you may be interested in.

You can withdraw your permission to receive emails from Promentum Limited at any time by using the unsubscribe link found at the bottom of every email you receive from us.

DISCLAIMER
The nature of Internet communications means that your communications may be susceptible to data corruption, interception and delays. Promentum Ltd shall not be responsible for any detrimental reliance you place on this web site or its contents.

Promentum Limited is providing this site and its contents (including any downloadable data or software) on an 'as is' basis and makes no representations or warranties of any kind with respect to this site or its contents and disclaims all such representations and warranties, whether express or implied, to the fullest extent permitted by applicable law. In addition, Promentum Limited makes no representations or warranties about the accuracy, completeness or suitability for any particular purpose of the information and related graphics published in this site or that any software or the server that makes it available are free of viruses or other harmful components.

The information contained in this site may contain technical inaccuracies or typographical errors. All liability of Promentum Limited howsoever arising for any such inaccuracies or errors is expressly excluded to the fullest extent permitted by applicable law.

Neither Promentum nor any of its directors, employees or other representatives will be liable for damages arising out of or in connection with the use of this site in any way. This is a comprehensive limitation of liability that applies to all damages of any kind, including (without limitation) compensatory, direct, indirect or consequential damages, loss of data, income or profit, loss of or damage to property and claims of third parties.

COOKIES

When someone visits our website, we collect standard internet log information and details of visitor behaviour patterns. We do this to find out things such as the number of visitors to the various parts of the site. We collect this information in a way which does not identify anyone. We do not make any attempt to find out the identities of those visiting our website. We will not associate any data gathered from this site with any personally identifying information from any source. If we do want to collect personally identifiable information through our website, we will be up front about this. We will make it clear when we collect personal information and will explain what we intend to do with it.

Use of cookies by this web site

Cookies are small amounts of data that are placed on your computer by websites that you visit. They are widely used in order to make websites work, or work more efficiently, as well as to provide information to the owners of the site. The table below explains the cookies we use and why.

Cookie	Name	Purpose	More information
Google Analytics	_utma _utmb _utmc _utmz	These cookies are used to collect information about how visitors use our site. We use the information to compile reports and to help us improve the site. The cookies collect information in an anonymous form, including the number of visitors to the site, where visitors have come to the site from and the pages they visited. We will still be using Google Analytics on this site even when you have not accepted their use as we consider they are essential to the performance of our company.	Click here for an overview of privacy at Google
Online notification form cookie	ASP.NET_SessionId	This cookie is essential to the underlying technology used by the website and has to be set when you first visit	Visit the Microsoft website
Cookie Control	CookiesAccepted cookie_privacy_hide	Used to store your acceptance to storing cookies on your browser, and to remember to hide the Cookie Widget after the first viewing.

Most web browsers allow some control of cookies through the browser settings. To find out more about cookies, including how to see what cookies have been set and how to manage and delete them, visit www.allaboutcookies.org.

To opt out of being tracked by Google Analytics across all websites visit http://tools.google.com/dlpage/gaoptout.

Embedded cookies

We may embed content such as YouTube videos. Embedded content may set cookies which are completely outside of our control.

If you do not want us to use cookies in this way you may disable their use (for more information on how to do this visit www.dma.org.uk). If you do not disable cookies, you are consenting to their use on this Website. Please note if you do disable cookies the performance of the website may be affected, and you may not be able to take advantage of the full range of services we offer.