Privacy Policy

Privacy Policy

1. Introduction
2. The Types of Personal Information We Collect
3. How We Collect Your Personal Data
4. How We Use Your Information
5. Disclosures of Your Personal Data
6. International Transfers
7. Data Security
8. Data Retention
9. Your Legal Rights
10. Third-party Links
11. Cookies

1. Introduction:

This Privacy Policy helps you understand what Personal data we collect, why we collect it, what we do with it and the choices you have, including how to access and update information. It applies to information we collect in relation to:

  • Users of our websites
  • People who use our products and services
  • Employees, Franchisees or representatives of organisations who use our services or supply us with goods or services
  • People who contact us via any medium (e.g. through our websites, by email, telephone, Live Chat, post, Facebook, Youtube, Twitter or any social media)

Please read this Privacy Policy carefully and ensure that you understand it. Your acceptance of our Privacy Policy is deemed to occur upon your first use of our Site. If you do not accept or agree to this Privacy Policy you may wish to cease viewing / using this website. By providing us with your data, you warrant to us that you are over 13 years of age.

Policy key definitions:

  • "I", "our", "us", or "we" refer to the business, PC PAL
  • "you", "the user" refer to the person(s) using this website
  • GDPR means General Data Protection Act
  • Cookies mean small files stored on a users computer or device

Controller and Information About Us:

This Privacy Policy applies to all of our companies that trade as PC PAL which includes PC PAL Franchising Ltd and all those trading as a franchisee of PC PAL Franchising Ltd.  Please be aware that:

  • Each PC PAL Franchisee is an independent limited company or sole trader within the PC PAL Network. Details of each Franchisee are available from the individual Franchisee or on http://www.pcpal.co.uk webpage for their area. 
  • PC PAL Franchisees are all committed to protecting your privacy but, just to be clear, each PC PAL Franchisee is an independent business and is responsible for the operation of its own business and compliance with data protection laws.

PC PAL is a trading name of PC PAL Franchising Ltd, a company registered in England and Wales (Company Registration number 05772348 and VAT number GB920744045) and is the controller and responsible for your personal data (collectively referred to as "PC PAL", "we", "us" or "our" in this Privacy notice). Our Site is owned and operated by PC PAL Franchising Ltd. Franchise operations which may be referred to in our websites operate as independent businesses and will have their own Privacy Policy.

We have appointed a data privacy manager who is responsible for overseeing questions in relation to this Privacy Notice. 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 below:

Postal Address: FAO Jat Mann, Data Privacy Manager, PC PAL Franchising Ltd, 139 Seven Star Road, Solihull, West Midlands B91 2BN.

Email: marketing@pcpal.co.uk

Complaints:

You have the right to make a complaint at any time to the Information Commissioner's Office (ICO), the UK supervisory authority for data protection issues (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.

Changes to the privacy notice and your duty to inform us of changes:

We reserve the right to update this privacy notice at any time. 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 by emailing us at marketing@pcpal.co.uk.

Third-party links:

Our website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy notice of every website you visit.

 

2. The Types of Personal Information We Collect:

Personal data means any information capable of identifying an individual. It does not include anonymised data.

We may process certain types of personal data about you as follows:

Type of data May Include
(a) Identity Data
  • first name
  • maiden name
  • last name
  • username
  • marital status
  • title
  • date of birth
  • gender
(b) Contact Data
  • billing address
  • delivery address
  • email address
  • telephone numbers
(c) Financial Data
  • your bank account details
  • payment card details
(d) Transaction Data
  • details about payments between us
  • other details of purchases made by you
  • we record some calls to our contact centres
(e) Technical Data
  • your login data
  • internet protocol addresses
  • browser type and version
  • browser plug-in types and versions
  • time zone setting and location
  • operating system and platform
  • Internet Security and Anti Virus provider and status
  • Online Backup provider and status
  • Internet Service Provider
  • other technology on the devices you use to access this site
(f) Profile Data
  • include your username and password
  • purchases or orders
  • your interests, preferences
  • feedback and survey responses
(g) Usage Data information about how you use our website, products and services
(h) Marketing and Communications Data may include your preferences in receiving marketing communications from us and our third parties and your communication preferences

 

We may also process Aggregated Data from your personal data but this data does not reveal your identity and as such in itself is not personal data. An example of this is where we review your Usage Data to work out the percentage of website users using a specific feature of our site. If we link the Aggregated Data with your personal data so that you can be identified from it, then it is treated as personal data.

Sensitive Data:

We do not collect any Sensitive Data about you. Sensitive data refers to data that 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. We do not collect any information about criminal convictions and offences.

Where we are required to collect personal data by law, or under the terms of the contract between us and you do not provide us with that data when requested, we may not be able to perform the contract (for example, to deliver goods or services to you). If you don’t provide us with the requested data, we may have to cancel a product or service you have ordered but if we do, we will notify you at the time.

 

3. How We Collect Your Personal Data:

We collect data about you through a variety of different methods including:

Type of data Description
(i) Direct interactions You may give us your personal data by filling in forms or by corresponding with us by post, phone, email, online chat, social media or otherwise. This includes personal data you provide when you

  • apply for our products or services;
  • create an account on our website;
  • subscribe to our service or publications;
  • request marketing to be sent to you;
  • enter a competition, promotion or survey; or
  • give us some feedback.
ii) Automated technologies or interactions. As you interact with our website, we may automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies and other similar technologies. Please see our Cookie Policy for further details.
(iii) Third parties or publicly available sources
  • may include your bank account and payment card details from our payment gateway providers
  • Identity and Contact Data from publicly availably sources such as Companies House and the Electoral Register based inside the EU
  • search information provides such as Linked In based inside the EU
(iv) Technical Data from the following parties:

  • analytics providers such as Google based outside the EU
  • advertising networks such as Facebook based outside the EU

 

4. How We Use Your Information:

We will only use your personal data when legally permitted. The most common uses of your personal data are:

  • Where we need to perform the contract between us.
  • Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
  • Where we need to comply with a legal or regulatory obligation.

Generally, we do not rely on consent as a legal ground for processing your personal data, other than in relation to sending marketing communications to you via email or text message. You have the right to withdraw consent to marketing at any time by emailing us at marketing@pcpal.co.uk

Purposes for processing your personal data:

Set out in the table below is a description of the ways we intend to use your personal data and the legal grounds on which we will process such data. We have also explained what our legitimate interests are where relevant.

We may process your personal data for more than one lawful ground, depending on the specific purpose for which we are using your data. Please email us at marketing@pcpal.co.uk if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below.

Purpose/Activity: Type of data Lawful basis for processing including basis of legitimate interest
To register you as a new customer (a) Identity
(b) Contact
Performance of a contract with you
To process and deliver your order including:
(a) Manage payments, fees and charges
(b) Collect and recover money owed to us
(c) Provision of mobile, tablet and surface repair services
(a) Identity
(b) Contact
(c) Financial
(d) Transaction
(e) Marketing and Communications
(a) Performance of a contract with you
(b) Necessary for our legitimate interests (to recover debts due to us)
To manage our relationship with you or your organisation which will include:
(a) Notifying you about changes to our terms or privacy policy
(b) Asking you to leave a review or take a survey
(a) Identity
(b) Contact
(c) Profile
(d) Marketing and Communications
(a) Performance of a contract with you
(b) Necessary to comply with a legal obligation
(c) Necessary for our legitimate interests (to keep our records updated and to study how customers use our products/services)
To enable you to partake in a prize draw, competition or complete a survey (a) Identity
(b) Contact
(c) Profile
(d) Usage
(e) Marketing and Communications
(a) Performance of a contract with you
(b) Necessary for our legitimate interests (to study how customers use our products/services, to develop them and grow our business)
To administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data) (a) Identity
(b) Contact
(c) Technical
(a) Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise)
(b) Necessary to comply with a legal obligation
To deliver relevant website content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you (a) Identity
(b) Contact
(c) Profile
(d) Usage
(e) Marketing and Communications
(f) Technical
Necessary for our legitimate interests (to study 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 (a) Technical
(b) Usage
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 (a) Identity
(b) Contact
(c) Technical
(d) Usage
(e) Profile
Necessary for our legitimate interests (to develop our products/services and grow our business)

 

Marketing communications:

You will receive marketing communications from us if you have:

  • requested information from us or purchased goods or services from us; or 
  • if you provided us with your details when you entered a competition or registered for a promotion or free resources; and
  • in each case, you have not opted out of receiving that marketing.
  • We will get your express opt-in consent before we share your personal data with any third party for marketing purposes.
  • You can ask us or third parties to stop sending you marketing messages at any time by emailing us at marketing@pcpal.co.uk.
  • Where you opt out of receiving our marketing communications, this will not apply to personal data provided to us as a result of a product/service purchase, warranty registration, product/service experience or other transactions.

Change of purpose:

We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to find out more about how the processing for the new purpose is compatible with the original purpose, please email us at marketing@pcpal.co.uk.

If we need to use your personal data for a purpose unrelated to the purpose for which we collected the data, we will notify you and we will explain the legal ground of processing.

We may process your personal data without your knowledge or consent where this is required or permitted by law.

 

5. Disclosures Of Your Personal Data:

We may have to share your personal data with the parties set out below for the purposes set out in the table in paragraph 4 above:

  • Our franchisees - Your local PC PAL service provider.
  • Service providers who provide IT and system administration services.
  • We may share your data with other companies in Our group Marketing and Sales activities. This includes our Franchisees.
  • Professional advisers including lawyers, bankers, auditors and insurers who provide consultancy, banking, legal, insurance and accounting services.
  • HM Revenue & Customs, regulators and other authorities based in the United Kingdom and other relevant jurisdictions who require reporting of processing activities in certain circumstances.
  • Our Accountancy supplier and our online Accountancy package supplier.
  • Third parties to whom we sell, transfer, or merge parts of our business or our assets.

We require all third parties to whom we transfer your data to respect the security of your personal data and to treat it in accordance with the law. We only allow such third parties to process your personal data for specified purposes and in accordance with our instructions.

 

6. International Transfers:

Countries outside of the European Economic Area (EEA) do not always offer the same levels of protection to your personal data, so European law has prohibited transfers of personal data outside of the EEA unless the transfer meets certain criteria.

Many of our third parties service providers are based outside the European Economic Area (EEA) so their processing of your personal data will involve a transfer of data outside the EEA.

Whenever we transfer your personal data out of the EEA, we do our best to ensure a similar degree of security of data by ensuring at least one of the following safeguards is in place:

  • We will only transfer your personal data to countries that the European Commission have approved as providing an adequate level of protection for personal data by; or
  • Where we use certain service providers, we may use specific contracts or codes of conduct or certification mechanisms approved by the European Commission which give personal data the same protection it has in Europe; or
  • If we use US-based providers that are part of EU-US Privacy Shield, we may transfer data to them, as they have equivalent safeguards in place.

If none of the above safeguards is available, we may request your explicit consent to the specific transfer. You will have the right to withdraw this consent at any time.

 

7. Data Security:

We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know such data. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.

We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

 

8. Data Retention:

We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.

To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.

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 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.

 

Under certain circumstances, you have rights under data protection laws in relation to your personal data. These include the right to:

  • Request access to your personal data.
  • Request correction of your personal data.
  • Request erasure of your personal data.
  • Object to processing of your personal data.
  • Request restriction of processing your personal data.
  • Request transfer of your personal data.
  • Right to withdraw consent.

You can see more about these rights at:

https://ico.org.uk/for-organisations/guide-to-the-general-data-protection-regulation-gdpr/individual-rights/

If you wish to exercise any of the rights set out above, please email us at marketing@pcpal.co.uk.

You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.

We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response

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 a number of requests. In this case, we will notify you and keep you updated.

 

This website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy notice of every website you visit.

 

11. Cookies:

You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of this website may become inaccessible or not function properly. For more information about the cookies we use, please see http://www.pcpal.co.uk/cookie-policy.

 

Version 2.0. May 2018

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