Pimloc Privacy Policy

INTRODUCTION

This Privacy Policy aims to provide you with information about how Pimloc Limited collects and processes your personal data through (i) your use of this website (the Site) and (ii) (where you have created an End User Account) your use of the SecureRedact software application hosted at https://app.secureredact.co.uk (App) and any of the services accessible via the Site or the App (Services).

The Site, the App and the Services are operated by Pimloc Limited, a private company incorporated and registered in England and Wales under company number 10067264 (referred to as Pimloc, we, us or our in this policy). Our registered office is located at 6 Oxford Industrial Park, Yarnton, Oxfordshire, England, OX5 1QU and our main trading address is at New Wing, Somerset House, The Strand, London, WC2R 1LA.

This Privacy Policy sets out the basis on which any personal data we collect from you, or that you provide to us, will be processed by us. The App is not intended for children and we do not knowingly collect data relating to children. Please read the following carefully to understand our practices regarding your personal data and how we will treat it.

Pimloc is committed to protecting your privacy. At Pimloc, we appreciate that you do not want the personal information we may hold about you distributed indiscriminately and here we explain how we collect information, what we do with it and what controls you have.

We have appointed a data privacy manager who is responsible for overseeing questions in relation to this privacy Policy. If you have any questions about this privacy notice, including any requests to exercise your legal rights, please contact the data privacy manager using the details set out at the end of this policy.

CHANGES TO THIS PRIVACY POLICY AND YOUR DUTY TO INFORM US OF CHANGES

We keep our privacy policy under regular review.

This version was last updated in February 2020. It may change and if it does, these changes will be posted on this page and, where appropriate, notified to you when you next log in to your End User Account. The updated policy may be displayed on-screen and you may be required to read and accept the changes to continue your use of the App or the Services.

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 our relationship with you.

THE DATA WE COLLECT ABOUT YOU

We may collect, use, store and transfer different kinds of personal data about you. We explain the categories of personal data that we may collect from you below.

AGGREGATED DATA

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

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.

HOW IS YOUR PERSONAL DATA COLLECTED?

We will collect and process the following data about you:

COOKIES

We use cookies and/or other tracking technologies to distinguish you from other users of the App, the App Site or the Services sites and to remember your preferences. This helps us to provide you with a good experience when you use the App or browse any of our sites and also allows us to improve the App and our sites. For detailed information on the cookies we use, the purposes for which we use them and how you can exercise your choices regarding our use of your cookies, see our cookie policy (https://www.pimloc.com/cookie_policy).

HOW WE USE YOUR PERSONAL DATA

We will only use your personal data when the law allows us to do so (i.e. where we have a Lawful Basis for doing so). Most commonly we will use your personal data in the following circumstances:

DIRECT MARKETING

We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising.

Individuals will receive marketing communications from us if you have requested information from us or purchased goods or services from us, agreed to receive marketing material through the App, 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.

Opting Out. You can ask us to stop sending you marketing messages at any time by following the opt-out links on any marketing message sent to you or by contacting us at any time.

PURPOSES FOR WHICH WE WILL USE YOUR PERSONAL DATA

Purpose/Activity

Type of data

Lawful basis for processing

To register you as a new End User and create your End User Account

Identity, Contact, Financial, Device

Your consent

To process in-App purchases and deliver Services including managing payments and collecting money owed to us

Identity, Contact, Financial, Transaction, Device, Marketing and Communications, Location

Your consent. Performance of a contract with you. Necessary for our legitimate interests (to recover debts due to us).

To manage our relationship with you including notifying you of changes to the App or any Services

Identity, Contact, Financial, Profile, Marketing and Communications

Your consent. Performance of a contract with you. Necessary for our legitimate interests (to keep records updated and to analyse how customers use our products/ Services). Necessary to comply with legal obligations (to inform you of any changes to our terms and conditions)

To enable you to communicate with us, participate in a prize draw, competition or complete a survey

Identity, Contact, Device, Profile, Marketing and Communications

Your consent. Performance of a contract with you. Necessary for our legitimate interests (to analyse how customers use our products/Services and to develop them and grow our business)

To administer and protect our business and this App including troubleshooting, data analysis and system testing

Identity, Contact, Device

Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security)

To deliver content and advertisements to you. To make recommendations to you about goods or services which may interest you. To measure and analyse the effectiveness of the advertising we serve you. To monitor trends so we can improve the App

Identity, Contact, Device, Content, Profile, Usage, Marketing and Communications, Location

Consent. Necessary for our legitimate interests (to develop our products/Services and grow our business)

DISCLOSURES OF YOUR PERSONAL DATA

When you consent to providing us with your personal data, we may also ask you for your consent to share your personal data with our internal third parties (being other companies in the Pimloc Group acting as joint controllers or processors) who provide IT and system administration services and undertake leadership reporting for any of the purposes set out in the table above.

In the event that Pimloc undergoes a reorganisation or is sold to a third party, any personal information Pimloc holds about you may be transferred to that reorganised entity or third party. However none of your personal information will be transferred to a third party prior to a sale or reorganisation completing.

Pimloc may disclose personal information to the appropriate authorities, if required to do so by law or if it believes that such action is necessary to prevent fraud or cyber-crime or to protect and defend the rights, property or personal safety of Pimloc, any of its affiliates, the Site or its visitors.

WHERE IS YOUR INFORMATION STORED?

Generally, information which you submit via the Site or the App is sent to and stored on secure server located in the European Economic Area. This is necessary in order to process your information.

Information submitted by you may be transferred by us to third parties in the circumstances mentioned in this privacy policy, which may be situated outside the European Economic Area. In those circumstances we will not transfer your personal data unless we are satisfied that adequate mechanisms are in place to comply with data protection and privacy laws.

DATA SECURITY

Pimloc places great importance on the security of all personally identifiable information associated with our users. We have security measures in place to attempt to protect against the loss, misuse and alteration of personal information under our control.

All information you provide to us is stored on our secure servers. Any payment transactions carried out by us or our chosen third-party provider of payment processing services will be encrypted using Secured Sockets Layer technology (or equivalent technology). Where we have given you (or where you have chosen) a password that enables you to access certain parts of our sites, you are responsible for keeping this password confidential. We ask you not to share a password with anyone.

Our security and privacy policies are periodically reviewed and enhanced as necessary and only authorised personnel have access to user information. While we cannot ensure or guarantee that loss, misuse or alteration of information will not occur, we use all reasonable efforts to prevent this.

You should bear in mind that transmission of information over the internet is never entirely secure. We cannot guarantee the security of information you transmit to the Site or our Apps and any such transmission is at your own risk.

It is advisable to close your browser when you have finished your user session, and lock your mobile device when not used, to help ensure others do not access your personal information.

DATA RETENTION

By law we have to keep basic information about our customers (including Contact, Identity, Financial and Transaction Data) for six years after they cease being customers for tax purposes.

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

In some circumstances we will 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.

In the event that you do not use the App for a period of 3 months then we will treat the account as expired and your personal data may be deleted.

Processed Videos will be retained in your End User Account for a period of 60 days. We reserve the right to delete such Processed Videos without further notice to you following the expiry of this period.

EXTERNAL LINKS

The Site and/or the App may, from time to time, contain links to external sites. Pimloc is not responsible for the privacy policies or the content of such sites. Please check these policies before you submit any personal data to these websites or use these services.

YOUR LEGAL RIGHTS

Under certain circumstances you have the following rights under data protection laws in relation to your personal data.

INFORMATION COMMISSIONERS OFFICE

You also have a right to report any breaches of your data protection rights to the Information Commissioners Office (website here: https://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 using the details below.

CONTACT DETAILS

Please email any questions, concerns or comments you have about this privacy policy or any requests concerning your personal data to our data privacy manager at info@secureredact.co.uk.