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Privacy Policy

Last update: 17th January 2023

If you are a Customer, you can view our Data Processing agreement here.

1. Who we are

Your privacy is important to us. It is Paiger Limited’s policy to respect your privacy regarding any personal information we may collect from you across our website, http://paiger.co, and other sites we own and operate (Websites). This privacy policy (Policy) sets out the types of personal data we collect and use when you access and visit our Websites and how we may use that data.

2. What personal data we collect and why we collect it

2.1. Where this Policy refers to ‘personal data’ it is referring to data about you from which you could be identified – such as your name, your date of birth, your contact details and even your IP address. 

2.2.By law, all organisations who process your personal data in the UK are obliged to process your personal data in certain ways and to ensure that you are given an appropriate amount of information about how they use it. You also have various rights to seek information from those organisations about how they are using your data, and to prevent them from processing it unlawfully.

2.3. Please note that our Websites are not directed at children under the age of 18 (each a “Child” or “Children”) and we do not knowingly collect personal data about Children. If you believe we have collected personal data about your Child, you may contact us at datadeletion@paiger.co and request that we cease processing data about your Child.

2.4. We collect personal data on our own behalf and are also provided personal data by our customers. The personal data we are provided by our customers is processed in accordance with the Data Processing Agreement found here.

We also collect and enrich contact data using Cognism. More information can be found here: https://www.cognism.com/compliance

2.5. The personal data we collect from you may include:

2.5.1. Identity Data which includes your name and gender.

2.5.2. Contact Data which includes your e-mail address, billing address and mobile telephone number

2.5.3.Transaction Data which includes details about payments to and from you and other details or services you have purchased from us (if you are a sole trader.)

2.5.4. Technical Data which includes your IP address, your login data and browser type and version.

2.5.5. Profile Data which includes your username and password, your interests, preferences, feedback and survey responses.

2.5.6. Usage Data which includes information about how you use the Websites

2.5.7. Marketing and Communications Data which includes your preferences in receiving marketing from us

2.6. 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.

2.7. We collect personal data from direct interactions with you (or our customers) and from automated technologies. We may occasionally also partner with third parties in relation to our marketing and promotions and collect personal data this way.

2.8. We only ask for personal information when we need it to provide a service to you or our customers, comply with a legal or regulatory obligation or when it is in our legitimate interests to do so (and your interests do not outweigh ours.) We collect it by fair and lawful means, with your knowledge. We also let you know why we’re collecting it and how it will be used. Here are some examples:

Activity
Examples of the types of personal data we may collect
Lawful basis for processing
To register you as a customer and deliver services to you.
Identity, contact, financial, and transaction information.
Performance of a contract with you.
To manage our relationship with you including notifying you of any changes to the Website or services provided on the Website
Identity, contact, profile and marketing communications information.
Performance of a contract with you.
To administer and protect our business and this Website (including troubleshooting, data analysis and system testing.)
Identity, contact and technical information.
Legitimate Interests and to comply with a legal obligation.
To deliver relevant Website content and advertisements to you.
Identity, contact, profile, usage, marketing and communications and technical information.
Performance of a contract with you and Legitimate Interests, your Consent as provided when you signed up on our website.
To use data analytics to improve the Website, services, marketing, customer relationships and experiences.
Technical and usage information.
Legitimate Interests.

2.9. We only retain personal information for as long as necessary. 

2.10. 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.

2.11. We may 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 website feature. 

2.12. What personal data we store, we’ll protect using commercially reasonable technical and organisational measures in order to prevent loss and theft, as well as unauthorised access, disclosure, copying, use or modification.

2.13. To unsubscribe from marketing emails at any time, please click on the unsubscribe link at the bottom of any marketing email. You may also contact us or the third party directly if you do not wish to receive any marketing materials from us or them. 

2.14. We don’t share any personally identifying information publicly or with third-parties, except when required to do so by law or in the following limited circumstances:

2.14.1. we may share your personal data with any member of our company group, which means our subsidiaries, our ultimate holding company and its subsidiaries, as defined in section 1159 of the UK Companies Act 2006;

2.14.2. with selected third parties to which we sub-contract to provide various services and/or aspects of the Websites’ functionality, such as where third-party plugins provide functionality such as message boards or image hosting services (see “Service Providers” below); and 

2.14.3. with analytics and search engine providers that assist us in the improvement and optimisation of this Website as described above.

2.14.4. if we were to sell or buy any business or assets, in which case we might disclose your personal data to the prospective seller or buyer of such business or assets as part of that transaction; 

2.14.5. if Paiger Limited or substantially all of its assets are acquired by a third party, in which case personal data held by us about our customers and contacts will be one of the transferred assets; 

2.14.6. if we are under a duty to disclose or share your personal data in order to comply with any legal obligation, or if we are asked to provide your details to a lawful authority in order to aid in the investigation of crime or disorder; and/or 

2.14.7. in order to enforce or apply a contract or to protect the rights, property, or safety of our company, our customers, or others.

2.15. Our service providers provide us with a variety of administrative, statistical, and technical services. We will only provide service providers with the minimum amount of personal data they need to fulfil the services we request, and we stipulate that they protect this data and do not use it for any other purpose. We take these relationships seriously and oblige all of our data processors to sign contracts with us that clearly set out their commitment to respecting individual rights, and their commitments to assisting us to help you exercise your rights as a data subject. We do not allow our third-party service providers to use your personal data for their own purposes. The following is a list of our major service providers:

  • MailJet (USA) – https://www.mailjet.com – used to send email communications to customers.
  • VooDoo SMS (UK) – https://voodoosms.com – used to send and receive SMS communications to/from customers
  • Twilio (USA) – https://www.twilio.com/ – used to send and receive SMS communications to customers.
  • Digital Ocean (USA) – https://www.digitalocean.com/ – used for data hosting and servers that power the Services
  • Amazon Web Services (USA) – https://aws.amazon.com – used for data hosting and servers that power the Services
  • SnapShooter (UK) – https://snapshooter.io – used for offsite database backups.
  • Google (Gmail & Data Studio) – used for email & reporting
  • Hubspot – https://www.hubspot.com/ – used as a CRM and email marketing tool
  • June.so – https://www.june.so/ – used for product analytics
  • Bonsai.io – https://bonsai.io/ – used as a data warehouse
  • Rchilli.com – https://www.rchilli.com/ used as a parsing tool

2.16. We do not process personal data outside of the UK and EU.

2.17. Our Websites may link to external sites that are not operated by us. Please be aware that we have no control over the content and practices of these websites, and cannot accept responsibility or liability for their compliance with data protection law. We strongly advise that you read the privacy policies of such Websites and satisfy yourself about their policy before sharing any personal data.

2.18. You are free to refuse processing of your personal data , with the understanding that we may be unable to provide you with some of your desired services.

2.19. Your continued use of our Websites will be regarded as acceptance of our practices around privacy and personal information. If, for any reason, you do not agree to the terms of this Policy, please stop using this Website.

2.20. 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.

2.21. If you have any questions about how we process personal data, feel free to contact us.

2.22. We reserve the right to revise or amend this Policy at any time to reflect changes to our business or changes in the law.  Where these changes are significant we will endeavour to let users of the Websites know. However, it is your responsibility to check this Policy before each use of our Websites – for ease of reference the top of this Policy indicates the date on which it was last updated.