Privacy Policy

Introduction

This privacy statement describes why and how Pinion Services Limited (“Pinion”, “we”, “us”, or “our”) collects and uses personal data in connection with the Business Solutions for start-up and small to medium sized enterprise market (“applications”) and provides information about your rights as a user of the applications (“you”, “user” or “individual”).   

Personal data is any information relating to an identified or identifiable living person. This privacy statement applies to personal data provided to us, both by you or by others and any personal data created in connection with your use of the applications. We may use personal data provided to us for any of the purposes described in this privacy statement or as otherwise stated at the point of collection.

When collecting and using personal data, our policy is to be transparent about why and how we process personal data. To find out more about our specific processing activities in connection with the applications, please go to the relevant sections of this statement.

Pinion is committed to protecting your privacy and complying with the General Data Protection Regulation (“GDPR”) and the Data Protection Act 2018 (“DPA 2018”). This Privacy policy sets out your rights, and the basis by which we collect, use and disclose the personal data on you. Pinion will always aim to be transparent about how we process personal data.

Security

We adhere to internationally recognised security standards.  Our information security management system relating to client confidential data is independently certified as complying with the requirements of ISO 27001.  We have a framework of policies, procedures and training in place covering data protection, confidentiality and security and regularly review the appropriateness of the measures we have in place to keep the data we hold secure.

Changes to this privacy statement

We recognise that transparency is an ongoing responsibility so we will keep this privacy statement under regular review.

This privacy statement was last updated on 01 July 2019.

Data controller and contact information

The data controller is Pinion Services Limited (the limited partnership registered in England under registration no. 04340989 and with its registration address at 1 Victoria Court Bank Square, Morley Leeds, West Yorkshire, LS27 9SE).

If you have any questions about this privacy statement or how and why we process personal data, please contact us at:

Data Protection Officer
Pinion Services Limited
1 Victoria Court, Bank Square,
Morley, Leeds, West Yorkshire
LS27 9SE

Email: vatify@pinion.services

Collection of personal data

We will collect personal data in connection with the applications as described below.

Personal data provided directly by you:

  • Name
  • Email address
  • Business address

Personal data inferred or derived from your use of the applications:

Personal data may be obtained from third party sources include:

  • Name
  • Email address
  • Business address
  • Job title/role
  • Gender
  • Experience
  • Business ownership data
  • Information about the organisation
  • LinkedIn
  • Companies House
  • We may also obtain your personal details from 1) conference attendee lists where we are partnering with the conference host and 2) exhibitor books from conferences where they are publicly available
  • Internet searches and other social media profiles

Use of personal data

We use personal data for the following purposes:

  • authenticate your identity, to authorise access to the applications and information on it (including preventing unauthorised access) and for other security-related purposes, including system monitoring;
  • provide services to you or to a client you represent;
  • provide, operate, administer, manage and improve the applications;
  • comply with our legal and professional obligations;
  • develop and manage our business, services, applications and relationship with you or a client you represent;
  • providing you with information about us and our range of services;
  • provide you with information about third parties we have a joint business relationship with including offers or discounts they may make available to you or a client you represent; and
  • conduct quality and risk management reviews or data analytics for market research and our business purposes.

Our lawful basis for this processing is  necessity for the provision of the applications, our legitimate interests in providing the applications and our services and promoting our business and services and consent (where applicable).

When and how we share personal data and locations of processing

We will only share personal data with others when we are legally permitted to do so.  When we share data with others, we put contractual arrangements and security mechanisms in place to protect the data and to comply with our data protection, confidentiality and security standards.

Where the locations of processing are outside of the EU, we have the European Commission approved standard contractual clauses in place to provide appropriate safeguards for personal data transferred outside of the EU.  The standard contractual clauses are available here (link) .

We share personal data processed in connection with the applications as follows:

  • Third party organisations that provide applications/functionality, data processing or IT services to us
    We are part of a global network of firms and in common with other professional service providers, we use third parties to help us run our business and these third parties may be located in other countries.  We share personal data processed in connection with the applications as follows:

Name

Role

Address

Microsoft Ireland

Business applications (such as email, documents and calendar)

One Microsoft Place, South County Business Park, Leopardstown, Dublin 18 D18 P521

Data centres located in a number of locations around the world (EU, Asia, USA)

  • Law enforcement or other government and regulatory agencies or to other third parties as required by, and in accordance with, applicable law or regulation
    Occasionally, we may receive requests from third parties with authority to obtain disclosure of personal data, such as to check that we are complying with applicable law and regulation, to investigate an alleged crime, to establish, exercise or defend legal rights.  We will only fulfil requests for personal data where we are permitted to do so in accordance with applicable law or regulation.

Data retention

We retain personal data processed in connection with the applications as follows:

  • We will retain your personal information for as long as it’s required for any of the purposes described above (e.g. for as long as you are a user of the applications and for the duration of our relationship with you).
  • We may also retain your personal information to the extent Pinion is required or permitted to do so by applicable law or regulation.

Individuals’ rights and how to exercise them

You have certain rights over your personal data.  Data controllers are responsible for fulfilling these rights.  Where we decide how and why personal data is processed, we are a data controller.

Individuals’ rights are the right of access to personal data, to rectification of personal data, to erasure of personal data / right to be forgotten, to restrict processing of personal data, to object to processing of personal data, to data portability, the right to withdraw consent at any time (where processing is based on consent) and the right to lodge a complaint with a supervisory authority.

Please see further information about these rights and how to exercise them below.

Your right of access to personal data

You have the right to obtain confirmation as to whether we process personal data about you, receive a copy of your personal data held by us as a data controller and obtain certain other information about how and why we process your personal data (similar to the information provided in this privacy statement).  

You may exercise this right by emailing us at vatify@pinion.services . We will aim to respond to any requests for information promptly, and in any event within the legally required time limits.

Your right to rectification / amendment of personal data

You have the right to request for your personal data to be amended or rectified where it is inaccurate (for example, if you change your name or address) and to have incomplete personal data completed.

To update personal data submitted to us, please email us at vatify@pinion.services or, where appropriate, contact us via the relevant website registration page or by amending the personal details held on applications. When practically possible, once we are informed that any personal data processed by us is no longer accurate, we will make updates, as appropriate, based on your updated information.

Your right to erasure / right to be forgotten

You have the right to obtain deletion of your personal data in the following cases:

  • the personal data are no longer necessary in relation to the purposes for which they were collected and processed;
  • our lawful basis for processing is consent, you withdraw consent and we have no other lawful basis for the processing;
  • our lawful basis for processing is that the processing is necessary for a legitimate interest pursued by us, you object to our processing and we do not have overriding legitimate grounds;
  • you object to our processing for direct marketing purposes;
  • your personal data have been unlawfully processed; and
  • your personal data must be erased to comply with a legal obligation to which we are subject.

To request deletion of your personal data, please email us at vatify@pinion.services .

Your right to restrict processing

You have the right to restrict our processing of your personal data in the following cases:

  • for a period enabling us to verify the accuracy of the personal data where you have contested the accuracy of the personal data
  • your personal data have been unlawfully processed and you request restriction of processing instead of deletion;
  • the personal data are no longer necessary in relation to the purposes for which they were collected and processed but the personal data are required by you to establish, exercise or defend legal claims; and
  • for a period enabling us to verify whether the legitimate grounds relied on by us override your interests (where you have objected to processing based on it being necessary for the pursuit of a legitimate interest identified by us).

To restrict our processing of your personal data, please email us at vatify@pinion.services .

Your right to object to processing

You have the right to object to our processing of your personal data in the following cases:

  • our lawful basis for processing is that the processing is necessary for a legitimate interest pursued by us; and
  • our processing for direct marketing purposes.

To object to our processing of your personal data, please email us at vatify@pinion.services .

Your right to data portability

You have a right to receive your personal data provided to us and have the right to send the data to another organisation (or ask us to do so if technically feasible) where our lawful basis for processing the personal data is consent or necessity for the performance of our contract with you and the processing is carried out by automated means.

To exercise your right to data portability, please email us at vatify@pinion.services .

Your right to withdraw consent

Where we process personal data based on consent, individuals have a right to withdraw consent at any time.  We do not generally process personal data based on consent (as we can usually rely on another legal basis). Where we rely on consent for processing, to withdraw your consent please email us at vatify@pinion.services or, to stop receiving an email from a Pinion marketing list, please click on the unsubscribe link in the relevant email received from us.  Please see the “Use of personal data” section of this privacy statement for further details about our processing of personal data based on consent.   

Complaints

We hope that you won't ever need to, but if you do want to complain about our use of personal data, please send an email with the details of your complaint to vatify@pinion.services .   We will look into and respond to any complaints we receive.

You also have the right to lodge a complaint with the supervisory authority in your country of residence, place of work or the country in which an alleged infringement of data protection law has occurred within the EU.  The Information Commissioner's Office (“ICO”) is the UK data protection regulator/supervisory authority. For further information on your rights and how to complain to the ICO, please refer to the ICO website.