1st January 2010
This Policy applies as between you, the User of this Web Site and PWSMM the owner and provider of this Web Site. This Policy applies to our use of any Data collected by us with your use of the Web Site and any Services or Systems therein.
1. Important information
1.1. Our website is not intended for children, and we do not knowingly collect data relating to children.
1.3. PWSMM is the controller and responsible for your data (we, us, or our).
1.6. By email to info[at]pwsmm.com
1.7. By post to 71-75 Shelton Street, London, United Kingdom, WC2H 9JQ
1.8. You have the right to make a complaint at any time to the ICO (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.
1.9. The data we hold about you must be accurate and current, therefore please keep us informed of any changes to your data.
2. The data we collect about you
2.1. We may collect, use, store, and transfer the types of personal data about you listed in Part 1 of Schedule 1.
2.2. We also collect, use, and share aggregated data. However, if we combine aggregated data with your data so that it can directly or indirectly identify you, we treat this as your data.
2.3. We do not collect any special categories of personal data or any information about criminal convictions and offenses.
2.4. If we are required by law, or under the terms of a contract we have with you, to collect your data and you fail to provide it, we may not be able to enter into performing the contract with you and, we may have to cancel a product or service. We will notify you of this at the appropriate time.
3. How personal data is collected
We collect personal data in the following ways:
you may provide personal data when you complete online forms, request products/services, subscribe to our services, create a user account, join our mailing list, or otherwise or correspond with us (by post, phone or email)
we automatically collect personal data (technical and usage) when you browse or interact with our website by using cookies, server logs, and other similar technologies. We may also receive technical data about you if you visit other websites that use our cookies.
publicly available sources
we may collect personal data from publicly available sources such as Companies House, the Electoral Register, and credit reference agencies based inside the E.U., public government databases inside and outside the E.U.
we may receive personal data from: (a) analytics providers based outside the E.U. (such as Google); (b) advertising networks and (c) search information providers the E.U.; (d) our suppliers such as payment providers, delivery services, website support, and maintenance providers.
4. How we use your data
4.1. We will only use your data when the law allows us to. Most commonly, we will use your data:
4.2. To perform the contract, we are to enter into or have entered into with you;
4.3. To comply with a legal obligation; and
4.4. Where it is necessary to carry out our legitimate interests (or those of a third party) and your interests and fundamental rights, do not override those interests.
4.5. Part 2 of Schedule 1 sets out the lawful basis we will rely on to process your data.
4.6. We do generally only rely on consent as a legal basis for processing your data to send email and SMS marketing communications, and you have the right to withdraw your consent at any time by contacting us. Please note that we may process your data for more than one lawful ground depending on the specific purpose for which we are using your information.
4.7. We may analyze your data to form a view on what products and or services we think may be of interest to you. You will only receive marketing communications from us, if you have requested information from us or purchased services from us, if you consent to market at the time we collect your data and you have not subsequently opted out or withdrawn your consent or if we have another basis to send you the marketing communications.
4.8. We will get your express opt-in consent before we share your data with any third party for marketing purposes.
4.9. You can opt-out of email marketing by clicking the unsubscribe button within the marketing email. You can also withdraw your consent to marketing at any time by contacting our DPM.
4.10. Even if you opt-out of receiving marketing, we may still use your data for other purposes, provided we have a lawful basis for doing so.
4.11. We will only use your data for the purpose that we originally collected it for unless we reasonably consider that we need to use it for another reason. That reason is compatible with the original purpose.
4.12. If we need to use your data for an unrelated purpose, we will notify you, and we will explain the legal basis, which allows us to use your data in this manner.
4.13: We may process your data (without your knowledge or consent) where this is required or permitted by law.
5. Disclosure of your data
5.1. We may have to share your data with third parties, further details of which are set out in Part 4 of Schedule 1. We require all third parties to respect the security of your data and to treat it by the law. We do not allow our third-party service providers to use your data for their purposes. They can only process your data for specified purposes and following our instructions.
6. International transfers
6.1. We do transfer your data outside the European Economic Area (EEA) to countries in which we work.
6.2. We share your data within the PWSMM Group. This will involve transferring your data outside the European Economic Area (EEA).
6.3. Whenever we transfer your data outside of the EEA, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented.
6.4. We will only transfer your data to countries that have been deemed to provide an adequate level of protection for personal data by the European Commission.
6.5. We use specific contracts approved by the European Commission, which give personal data the same protection it has in Europe with our service providers.
6.6. We may transfer data to U.S. based service providers under the Privacy Shield, which requires them to provide similar protection to personal data shared between Europe and the U.S.
6.7. Please contact us if you want further information on the specific mechanism used by us when transferring your data.
7. Data security
7.1. We have put in place appropriate security measures to prevent your data from being accidentally lost, used, or accessed in an unauthorized way, altered or disclosed. We also limit access to your data to those employees, agents, contractors, and other third parties who have a business need to know, and they can only process your data on our instructions. They will be subject to a duty of confidentiality.
7.2. We have procedures in place to deal with any suspected personal data breach. We will notify you and any applicable regulator of a breach where we are legally required to do so.
8. Data retention
8.1. We will only retain your data for as long as necessary to fulfill the purposes we collected it for, including to satisfy any legal, accounting, or reporting requirements.
8.2. Details of retention periods for different aspects of your data are available in our retention policy, which you can request from us. However, we are legally required to keep necessary information about our customers (including contact, identity, financial and transaction data) for six years after they cease being customers, for tax purposes.
8.3: We may also anonymize your data (so that it can no longer be associated with you) for research or statistical purposes. We can use anonymized information indefinitely without further notice to you.
9. Your legal rights
9.1. You have certain rights in certain circumstances under data protection law. These are set out in full in Part 3 of Schedule 1. If you wish to exercise any of your rights, please contact our DPM.
9.2. You will not have to pay a fee to exercise any of your rights. However, if your request is unfounded, repetitive, or excessive, we may charge a reasonable price for this information or refuse to comply with your request.
9.3. We may request specific information from you to help us confirm your identity when you contact us and ensure. It is a security measure to ensure that personal data is not disclosed to any person who does not have the right to receive it.
9.4. 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 many requests. In this case, we will notify you and keep you updated.
Schedule 1: Personal Data
Part 1: Types of personal data
billing address, delivery address, email address, and telephone number
bank account and payment card details
passport number, passport details, national id number, national id card details, first name, maiden name, last name, username or similar identifier, date of birth, gender, marital status
marketing and communication data
your preferences in receiving marketing from our third parties and us, and your communication preferences
your username and password, purchases and orders made by you, preferences, feedback and survey responses
internet protocol (I.P.) 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 our website
details about payments to and from you and other details of products and services you have purchased from us
Part 2: Lawful basis for processing and processing activities
The lawful basis upon which we may rely on to process your data are:
you have given your express consent for us to process your data for a specific purpose
the processing is necessary for us to perform our contractual obligations with you under our contract, or because you have asked us to take specific steps before entering into a contract with you
the processing is necessary for us to comply with the legal or regulatory obligation.
the processing is necessary for our or a third party’s legitimate interest, e.g., for us to provide the best service to you via our website. Before we process your data on this basis, we make sure we consider and balance any potential impact on you, and we will not use your data on this basis where such an impact outweighs our interest.
Set out below are specific details of the processing activities we undertake with your data and the lawful basis for doing this.
Type of data
Lawful basis for processing
to register you as a new customer
identity & contact
to perform our contract with you
to process and deliver your order, manage payments, charges and debt recovery
identity, contact, financial, transaction, and marketing & communications
(i) to perform our contract with you;
(ii) as necessary for our legitimate interest in recovering debts due to us.
identity, contact, profile & marketing & communications
(i) to perform our contract with you
(ii) as necessary to comply with a legal obligation
(iii) as necessary for our legitimate interests in keeping our records updated and analyzing how customers use our products/services.
to administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)
identity, contact & technical
(i) as necessary for our legitimate interests in running our business, provision of administration and I.T. services, network security, to prevent fraud and in the context of a business reorganization or group restructuring exercise
(ii) as necessary to comply with any legal obligations
to deliver relevant website content/advertisements to you and measure or understand the effectiveness of our advertising
identity, contact, profile, usage, marketing & communications & technical
as necessary for our legitimate interests in studying how customers use our products/services, to develop them, to grow our business and to inform our marketing strategy
to use data analytics to improve our website, products/services, marketing, customer relationships and experiences
technical & usage
as necessary for our legitimate interests to define types of customers for our products and services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy
to make suggestions and recommendations to you about goods or services that may be of interest to you, including promotional offers
identity, contact, technical, usage & profile
as necessary for our legitimate interests to develop our products/services and grow our business
Part 3: Your legal rights
You have the following legal rights about your data:
access your data
you can ask for access to and a copy of your data and can check we are lawfully processing it
you can ask us to correct any incomplete or inaccurate personal data we hold about you
you can ask us to delete or remove your data where:
(a) there is no good reason for us continuing to process it;
(b) you have successfully exercised your right to object (see below);
(c) we may have processed your information unlawfully; or
(d) we are required to erase your data to comply with local law.
(e) We may not always be able to comply with your request for specific legal reasons, which will be notified to you at the time of your request
you can object to the processing of your data where:
(a) where we are relying on our legitimate interest (or those of a third party) as the basis for processing your data, if you feel it impacts on your fundamental rights and freedoms;
(b) where we are processing your data for direct marketing purposes.
(c) in some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms, and, in such circumstances, we can continue to process your persona data for such purposes
you can ask us to us to suspend or restrict the processing of your data, if:
(a) you want us to establish the accuracy of your data;
(b) our use of your data is unlawful, but you do not want us to erase it;
(c) you need us to hold your data (where 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 a transfer
you can request a transfer of your data which is held in an automated manner and which you provided your consent for us to process such personal data or which we need to process to perform our contract with you, to you or a third party. We will provide your data in a structured, commonly used, machine-readable format
withdraw your consent
you can withdraw your consent at any time (where we are relying on consent to process your data). This does not affect the lawfulness of any processing carried out before you withdraw your consent
Part 4: Third Parties
acting as processors or controllers based in the EEA but also around the world who provide data center services and I.T. and system administration services.
acting as processors or joint controllers including lawyers, bankers, auditors and insurers based in the United Kingdom or outside of the United Kingdom who provide consultancy, banking, legal, insurance, and accounting services
H.M. Revenue & Customs, regulators and other authorities
acting as processors or joint controllers based in the EEA who require reporting of processing activities in certain circumstances
market researchers, fraud prevention agencies
Part 5: Glossary
information such as statistical or demographic data which may be derived from personal data, but which cannot by itself identify a data subject
a body that determines the purposes and means of processing data
an individual living person identified by personal data (which will generally be you)
information identifying a data subject from that data alone or with other data we may hold but it does not include anonymized or aggregated data
a body that is responsible for processing personal data on behalf of a controller
special categories of personal data
information about the race, ethnicity, political opinions, religious or philosophical beliefs, trade union membership, health, genetic, biometric data, sex life, sexual orientation.
Information Commissioner’s Office, the U.K.’s supervisory authority for data protection issues
10. Changes to this Policy
11.2. [Before the Web Site sets Cookies on your computer, you will be presented with a pop-up or message bar requesting your consent to set those Cookies. [None of the Cookies set by the Web Site jeopardize your privacy in any way, and no personal data is collected.] By giving your consent to the setting of our Cookies you are enabling us to provide the best possible experience and service to you through our Web Site. If you wish to deny your consent to the placing of Cookies, certain features of the Web Site may not function fully or as intended.]
11.3. [Certain features of the Web Site depend upon Cookies to function and are deemed, within the law, to be strictly necessary. These Cookies are detailed in Schedule 2A. You will not be asked for your consent to place these Cookies however you may still disable cookies via your web browser’s settings, as set out in sub-Clause 11.4.]
11.4. You can choose to enable or disable Cookies in your web browser. By default, your browser will accept Cookies; however, this can be altered. For further details, please consult the help menu in your browser. Disabling Cookies may prevent you from using the full range of Services available on the Web Site.
11.5. You may delete Cookies at any time; however, you may lose any information that enables you to access the Web Site more quickly.
11.6. [The Web Site uses the third-party Cookies detailed in Schedule 3 for the purposes described therein. These Cookies are not integral to the services provided by the Web Site to you and maybe blocked at your choosing via your internet browser’s privacy settings or via your response to the request for consent detailed in sub-Clause 11.2.]
11.7. It is recommended that you ensure that your internet browser is up-to-date and that you consult the help and guidance provided by the developer of your browser if you are unsure as to how to adjust your privacy settings.
Schedule 2: First-Party Cookies
Name of Cookie
Schedule 2A: Strictly Necessary Cookies
Name of Cookie
Schedule 3: Third-Party Cookies
Name of Cookie
Name of Provider
PayPal Holdings, Inc.