1.1 We are committed to safeguarding the privacy of our website visitors, service users, individual customers, and customer personnel.
1.2 This policy applies where we are acting as a data controller with respect to the personal data of such persons; in other words, where we determine the purposes and means of the processing of that personal data.
1.3 Our website incorporates privacy controls which affect how we will process your personal data. By using the privacy controls, you can specify whether you would like to receive direct marketing communications and limit the collection, sharing and publication of your personal data.
1.5 In this policy, "we", "us" and "our" refer to Procurato Ltd.
2. The personal data that we collect
2.1 In this Section 2 we have set out the general categories of personal data that we process and, in the case of personal data that we did not obtain directly from you, information about the source and specific categories of that data.
2.2 We may process data enabling us to get in touch with you ("contact data") only where you will add that information directly yourself and thereby providing us with consent to contact you. The contact data may include your name, email address, telephone number, postal address. The source of the contact data is you and/or your employer.
2.3 Although we currently do not, we may process in the future your website user account data ("account data"). The account data may include your account identifier, name, email address, business name, account creation and modification dates, website settings and marketing preferences. The primary source of the account data is [you and/or your employer, although some elements of the account data may be generated by our website. If you log into our website using a social media account, we will obtain elements of the account data from the relevant social media account provider.
2.4 We may process data about your use of our website and services ("usage data"). The usage data may include your IP address, geographical location, browser type and version, operating system, referral source, length of visit, page views and website navigation paths, as well as information about the timing, frequency and pattern of your service use. The source of the usage data is our analytics tracking system.
3. Purposes of processing and legal bases
3.1 In this Section 3, we have set out the purposes for which we may process personal data and the legal bases of the processing.
3.2 Operations - We may process your personal data for the purposes of operating our website, the processing and communication where you have provided us with such details. The legal basis for this processing is our legitimate interests, namely the proper administration of our website, services and business.
3.3 Relationships and communications - We may process contact data, account data, transaction data and/or communication data for [the purposes of managing our relationships, communicating with you (excluding communicating for the purposes of direct marketing) by email, SMS, telephone, providing support services and complaint handling. The legal basis for this processing is our legitimate interests, namely communications with our website visitors, service users, individual customers and customer personnel, the maintenance of relationships, and the proper administration of our website, services and business.
3.4 Direct marketing - We may process contact data, account data and/or transaction data for the purposes of creating, targeting and sending direct marketing communications by email, SMS and making contact by telephone for marketing-related purposes. The legal basis for this processing is consent OR our legitimate interests, namely promoting our business and communicating marketing messages and offers to our website visitors and service users.
3.5 Research and analysis - We may process usage data and/or transaction data for [the purposes of researching and analysing the use of our website and services, as well as researching and analysing other interactions with our business. The legal basis for this processing is consent OR our legitimate interests, namely monitoring, supporting, improving and securing our website, services and business generally.
3.6 Record keeping - We may process your personal data for the purposes of creating and maintaining our databases, back-up copies of our databases and our business records generally. The legal basis for this processing is our legitimate interests, namely ensuring that we have access to all the information we need to properly and efficiently run our business in accordance with this policy.
3.7 Security - We may process your personal data for the purposes of security and the prevention of fraud and other criminal activity. The legal basis of this processing is our legitimate interests, namely [the protection of our website, services and business, and the protection of others.
3.8 Insurance and risk management - We may process your personal data where necessary for the purposes of obtaining or maintaining insurance coverage, managing risks and/or obtaining professional advice. The legal basis for this processing is our legitimate interests, namely the proper protection of our business against risks.
3.9 Legal claims - We may process your personal data where necessary for the establishment, exercise or defence of legal claims, whether in court proceedings or in an administrative or out-of-court procedure. The legal basis for this processing is our legitimate interests, namely the protection and assertion of our legal rights, your legal rights and the legal rights of others.
3.10 Legal compliance and vital interests - We may also process your personal data where such processing is necessary for compliance with a legal obligation to which we are subject or in order to protect your vital interests or the vital interests of another natural person.
4. Providing your personal data to others
4.1 We may disclose your personal data to our insurers and/or professional advisers insofar as reasonably necessary for the purposes of obtaining or maintaining insurance coverage, managing risks, obtaining professional advice.
4.2 Your personal data held in our website database OR will be stored on the servers of our hosting services providers G-suite.
4.3 We may disclose your data to our suppliers or subcontractors insofar as reasonably necessary for the proper operation of our website and where data is provided directly by you and for the purposes outlined in 3.5.
4.4 In addition to the specific disclosures of personal data set out in this Section 4, we may disclose your personal data where such disclosure is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person. We may also disclose your personal data where such disclosure is necessary for the establishment, exercise, or defence of legal claims, whether in court proceedings or in an administrative or out-of-court procedure.
5. International transfers of your personal data
5.1 In this Section 6, we provide information about the circumstances in which your personal data may be transferred to countries outside the United Kingdom and the European Economic Area (EEA).
5.2 The hosting facilities for our website are situated in UK. The competent data protection authorities have made an "adequacy decision" with respect to the data protection laws of each of these countries. Transfers to any future countries will be protected by appropriate safeguards, namely the use of standard data protection clauses adopted or approved by the competent data protection authorities.
5.3 You acknowledge that [personal data that you submit for publication through our website or services may be available, via the internet, around the world. We cannot prevent the use (or misuse) of such personal data by others.
6. Retaining and deleting personal data
6.1 This Section 6 sets out our data retention policies and procedures, which are designed to help ensure that we comply with our legal obligations in relation to the retention and deletion of personal data.
6.2 Personal data that we process for any purpose or purposes shall not be kept for longer than is necessary for that purpose or those purposes.
6.3 We will retain your personal data as follows
(a) contact data will be retained for a minimum period of 6 months following the date of the most recent contact between you and us, and for a maximum period of 2 years following that date;
(d) communication data will be retained for a minimum period of 6 months following the date of the communication in question, and for a maximum period of 12 months following that date;
(e) usage data will be retained for 24 months following the date of collection.
6.4 Notwithstanding the other provisions of this Section 6, we may retain your personal data where such retention is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person.
7. Your rights
7.1 In this Section 7, we have listed the rights that you have under data protection law.
7.2 Your principal rights under data protection law are:
(a) the right to access - you can ask for copies of your personal data;
(b) the right to rectification - you can ask us to rectify inaccurate personal data and to complete incomplete personal data;
(c) the right to erasure - you can ask us to erase your personal data;
(d) the right to restrict processing - you can ask us to restrict the processing of your personal data;
(e) the right to object to processing - you can object to the processing of your personal data;
(f) the right to data portability - you can ask that we transfer your personal data to another organisation or to you;
(g) the right to complain to a supervisory authority - you can complain about our processing of your personal data; and
(h) the right to withdraw consent - to the extent that the legal basis of our processing of your personal data is consent, you can withdraw that consent.
7.3 These rights are subject to certain limitations and exceptions. You can learn more about the rights of data subjects by visiting https://ico.org.uk/for-organisations/guide-to-data-protection/guide-to-the-general-data-protection-regulation-gdpr/individual-rights/.
7.4 You may exercise any of your rights in relation to your personal data by written notice to us, using the contact details set out below.
8. About cookies
8.1 A cookie is a file containing an identifier (a string of letters and numbers) that is sent by a web server to a web browser and is stored by the browser. The identifier is then sent back to the server each time the browser requests a page from the server.
8.2 Cookies may be either "persistent" cookies or "session" cookies: a persistent cookie will be stored by a web browser and will remain valid until its set expiry date, unless deleted by the user before the expiry date; a session cookie, on the other hand, will expire at the end of the user session, when the web browser is closed.
8.3 Cookies may not contain any information that personally identifies a user, but personal data that we store about you may be linked to the information stored in and obtained from cookies.
9. Cookies that we use
10. Cookies used by our service providers
11. Managing cookies
11.1 Most browsers allow you to refuse to accept cookies and to delete cookies. The methods for doing so vary from browser to browser, and from version to version. You can however obtain up-to-date information about blocking and deleting cookies via these links:
(a) https://support.google.com/chrome/answer/95647 (Chrome);
(d) https://support.microsoft.com/en-gb/help/17442/windows-internet-explorer-delete-manage-cookies (Internet Explorer);
11.2 Blocking all cookies will have a negative impact upon the usability of many websites.
11.3 If you block cookies, you will not be able to use all the features on our website.
12.1 We may update this policy from time to time by publishing a new version on our website.
12.2 You should check this page occasionally to ensure you are happy with any changes to this policy.
13. Our details
13.1 This website is owned and operated by Procurato LTD.
13.2 We are registered in England and Wales under registration number 09358098 and our registered office is at 306 Bank Studios, Park Royal Road, London, England, NW10 7JH.
13.3 You can contact us:
(a) by post, to the postal address given above;
(b) using our website contact form;
(c) by telephone, on the contact number published on our website; or
(d) by email, using the email address published on our website.
14. Data protection officer
14.1 Our data protection officer's contact details are: Marco Marambe (email@example.com)