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PingLocker Privacy Policy

PingLocker Privacy Policy

Welcome to PingLocker Ltd´s privacy notice

Effective as of May 24th, 2018
This platform is operated by PingLocker Ltd. PingLocker Ltd respect your privacy and is committed to protecting your personal data.This privacy notice will inform you as to how we look after your personal data when you visit our Website, the App, or the Services (collectively, the “PingLocker Offerings”), regardless of where you visit them from, and tell you about your privacy rights and how the law protects you.

By visiting and/or accessing or using the PingLocker Offerings, you are agreeing to be bound by the terms of this Privacy Policy and the accompanying Terms of Use, which are incorporated herein by reference. Click here to view the Terms of Use.

You also agree and acknowledge that you will be bound by any additional terms and conditions and/or privacy policy that participating Establishments and/or Vendors may impose, for which PingLocker is not responsible.  In such case, you will be provided with such additional terms and conditions and/or privacy policy and will be required to accept them in order to access and use the PingLocker Offerings.  

By visiting the PingLocker Offerings, Visitors are agreeing to the terms of this Privacy Policy and the accompanying Terms of Use. By signing up, accessing, and/or using the Services, each Customer is agreeing to the terms of this Privacy Policy. If you do not agree with or you are not comfortable with any aspect of this Policy, you should immediately discontinue access or use of our Services. This privacy notice is provided in a layered format so you can click through to the specific areas set out below. Capitalized terms not defined in this Privacy Policy shall have the meaning set forth in our Terms of Use. Please also use the Glossary to understand the meaning of some of the terms used in this privacy notice.

1. IMPORTANT INFORMATION AND WHO WE ARE
2. THE DATA WE COLLECT ABOUT YOU 
3. HOW IS YOUR PERSONAL DATA COLLECTED 
4. HOW WE USE YOUR PERSONAL DATA 
5. DISCLOSURES OF YOUR PERSONAL DATA 
6. INTERNATIONAL TRANSFERS 
7. DATA SECURITY
8. DATA RETENTION 
9. YOUR LEGAL RIGHTS 
10. GLOSSARY 
1. Important information and who we are

Purpose of this privacy notice

This privacy notice aims to give you information on how PingLocker collects and processes your personal data through your use of this website, including any data you may provide through this website when you sign up to our newsletter, purchase a product or service or take part in a competition or survey.

This website is not intended for children and we do not knowingly collect data relating to children.

It is important that you read this privacy notice together with any other privacy notice or fair processing notice we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. This privacy notice supplements the other notices and is not intended to override them.

Controller

We at PingLocker Ltd. (“PingLocker,” “we,” “us,” or “our”) are the controller and responsible for the PingLocker Offerings.

We have appointed a data protection officer (DPO) who is responsible for overseeing questions in relation to this privacy notice. If you have any questions about this privacy notice, including any requests to exercise your legal rights, please contact the DPO using the details set out below.

Contact details

Our full details are:
 
Full name of legal entity: PingLocker Limited
 
Title: The Data Protection Officer

Email address: compliance@pinglocker.com
 
Postal address: 28 Orchard Road, Lytham St. Annes, Lancashire, FY8 1PF

You have the right to make a complaint at any time to the Information Commissioner's Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.

Changes to the privacy notice and your duty to inform us of changes

We may make changes or updates to this document from time to time. Historic versions of this notice can be obtained by contacting us.

It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.

Third-party links

The PingLocker Offerings 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.

2. The data we collect about you

Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).

We may collect, use, store and transfer different kinds of personal data about you which we have grouped together follows:
 
  • Identity Data includes first name, maiden name, last name, username or similar identifier, title, date of birth and gender. 
  • Contact Data includes billing address, delivery address, email address and telephone numbers. 
  • Financial Data includes bank account and payment card details. 
  • Transaction Data includes details about payments to and from you and other details of products and services you have purchased from us. 
  • Technical Data includes 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. 
  • Profile Data includes your username and password, purchases or orders made by you, your interests, preferences, feedback and survey responses. 
  • Usage Data includes information about how you use our website, products and services. 
  • 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. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy notice.

We do not collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data). Nor do we collect any information about criminal convictions and offences.

If you fail to provide personal data

Where we need to collect personal data by law, or under the terms of a contract we have with you and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with goods or services). In this case, we may have to cancel a product or service you have with us but we will notify you if this is the case at the time.

3. How is your personal data collected?

We use different methods to collect data from and about you including through:
 
  • Direct interactions. You may give us your Identity, Contact and Financial Data by filling in forms or by corresponding with us by post, phone, email, chats or otherwise. This includes personal data you provide when you: 
  • apply for or purchase our products or services;  
  • create an account on our website;  
  • subscribe to our service or publications;
  • request marketing to be sent to you;  
  • enter a competition, promotion or survey; or  
  • 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, server logs and other similar technologies. We may also receive Technical Data about you if you visit other websites employing our cookies.  
Information that we collect using “cookie” technology. Cookies are small packets of data that a website stores on your computer’s hard drive so that your computer will “remember” information about your visit. We use cookies to help us collect Other Information and to enhance your experience using the Website. 

We may use the following types of cookies and tracking technologies:
Strictly Necessary Cookies. These cookies are essential because they enable you to move around our Services and use certain features on our Services. For example, strictly necessary cookies allow you to access secure areas. Without these cookies, some Services cannot be provided.

Performance/Analytics Cookies. These cookies collect information about your use and interaction with our Services. The types of information collected by such cookies include which pages you go to most often, how much time you spend on that page, or if you get error messages from certain pages.

Functionality Cookies. These cookies allow us to remember your preferences and choices so that we can tailor our Services to you and your interests. For example, these cookies will remember which country or language you selected, or will use your display name on parts of the Services. If you are logged in to your account, we may associate the cookie information with the Personal Information tied to your account.

Advertising/Marketing Cookies. These cookies allow us to deliver relevant marketing and advertisements to you. They collect information about your interactions with our marketing activities (e.g., on the website or via emails) to determine what your interests and preferences are, and how effective such advertising or marketing campaigns are.
 
  • Third parties or publicly available sources. We may receive personal data about you from various third parties and public sources as set out below: 
  Technical Data from the following parties:  a.     Third-Party Analytics. We use third-party analytics services (such as Google Analytics which may be based outside the EU) to evaluate your use of the PingLocker Offerings, compile reports on activity, collect demographic data, analyse performance metrics, and collect and evaluate other information relating to the Website and Internet usage. These third parties use cookies and other technologies to help analyse and provide us the data. By accessing and using the Website, you consent to the processing of data about you by these analytics providers in the manner and for the purposes set out in this Privacy Policy. 

For more information on these third parties, including how to opt out from certain data collection, please visit the sites below. Please be advised that if you opt out of any service, you may not be able to use the full functionality of the Website.

For Google Analytics, please visit https://www.google.com/analytics 
For Clicky, please visit https://clicky.com 
For Inspectlet, please visit https://www.inspectlet.com/
b. advertising networks such as Google which may be based outside the EU; and   
c. search information providers such as Google which may be based outside the EU.    
  • Contact, Financial and Transaction Data from providers of technical, payment and delivery services such as Stripe, which are based in the EU. 

The Information Collected by or Through Third-Party Advertising Companies

You authorise us to share Other Information about your activity on the Website with third parties for the purpose of tailoring, analysing, managing, reporting, and optimising advertising you see on the Website, and elsewhere. These third parties may use cookies, pixel tags (also called web beacons or clear gifs), and/or other technologies to collect such Other Information for such purposes. Pixel tags enable us, and these third-party advertisers, to recognise a browser’s cookie when a browser visits the site on which the pixel tag is located in order to learn which advertisement brings a user to a given site. You may opt-out of the tailoring of advertising based on information we collect. To learn more about the use of this information, or to choose not to have this information used by our providers or third party advertising partners by opting out, please visit the Network Advertising Initiative by clicking http://www.networkadvertising.org/managing/opt_out.asp

4. How we use your personal data

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. 
Generally, we do not rely on consent as a legal basis for processing your personal data other than in relation to sending third party direct marketing communications to you via email or text message. You have the right to withdraw consent to marketing at any time by contacting us.

Purposes for which we will use your personal data

We have set out below, in a table format, a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.

Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below.
Promotional offers from us

We may use your Identity, Contact, Technical, Usage and Profile Data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which products, services and offers may be relevant for you (we call this marketing).

You will receive marketing communications from us if you have requested information from us or purchased goods or services from us or if you provided us with your details when you entered a competition or registered for a promotion and, in each case, you have not opted out of receiving that marketing.

Third-party marketing

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

Opting out

You can ask us or third parties to stop sending you marketing messages at any time by logging into the website and checking or unchecking relevant boxes to adjust your marketing preferences or by following the opt-out links on any marketing message sent to you.

Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of a product/service purchase, warranty registration, product/service experience, updates or other transactions.

Cookies

You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of this website may become inaccessible or not function properly.

Change of 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. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.

If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.

Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

5. Disclosures of your personal data

We may have to share your personal data with the parties set out below for the purposes set out in the table in paragraph 4 above.

  • External Third Parties as set out in the Glossary. 
  • Retargeting software vendors, email service providers and social media platforms such as Facebook to deliver relevant website content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you 
  • Web analytics and user experience software providers such as Google to improve our website, products/services, marketing, customer experiences 
  • Personalisation tool vendors that allow us to make suggestions and recommendations to you about goods or services that may be of interest to you 
  • Third parties to whom we may choose to provide our Services and process Orders, sell, transfer, or merge parts of our business or our assets. As we develop our businesses, we might sell, buy or merge businesses or assets. In the event of a corporate sale, merger, reorganisation, sale of assets, dissolution, or similar event, the Information may be part of the transferred assets and/or the new owners may use your personal data in the same way as set out in this privacy notice. 
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.

6. International transfers

We do not transfer your personal data outside the European Economic Area (EEA). If we decide to transfer your personal data out of the EEA in future for whatever reason, we will 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. 
  • Where we use providers based in the US, we may transfer data to them if they are part of the Privacy Shield which requires them to provide similar protection to personal data shared between the Europe and the US. For further details, see European Commission: EU-US Privacy Shield. 

7. Data security

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.

You are also responsible for the security of your Personal Information. You should choose a password of sufficient length and complexity when you use our Services and keep your password confidential. If you think there has been unauthorised access to or use of your account, please contact us immediately at compliance@pinglocker.com.

8. Data retention

How long will you use my personal data for?

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.

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 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.

9. Your legal rights

Under certain circumstances, you have rights under data protection laws in relation to your personal data.
 
  • Request access to your personal data. 
  • Request correction of your personal data. 
  • Request erasure of your personal data. 
  • Object to processing of your personal data. 
  • Request restriction of processing your personal data. 
  • Request transfer of your personal data. 
  • Right to withdraw consent. 
If you wish to exercise any of the rights set out above, please contact us at compliance@pinglocker.com

No fee usually required

You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.

What we may need from you

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.

Time limit to respond

We try to respond to all legitimate requests within one month. Occasionally it may 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.

10. 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/product 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). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us.

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 at your request 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

Internal Third Parties

Other companies, such as our software partner, Blackbell Inc, acting as joint controllers or processors and who are based within the EU and provide IT and system administration services and undertake leadership reporting.

External Third Parties
 
  • Service providers acting as processors based within the EU who provide products, services, IT and system administration services. 
  • Professional advisers acting as processors or joint controllers including lawyers, bankers, auditors and insurers based within the EU who provide consultancy, banking, legal, insurance and accounting services. 
  • HM Revenue & Customs, regulators and other authorities based in the European Economic Area who require reporting of processing activities in certain circumstances. 
  • Market research agencies, list brokers, fraud prevention agencies. 

YOUR LEGAL RIGHTS

You have the right to:

Request access to your personal data (commonly known as a “data subject access request”). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.

Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.

Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.

Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.

Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios: (a) if you want us to establish the data's accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.

Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.

Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.