Privacy Policy

Place Informatics Ltd are committed to protecting the privacy and security of personal data. 

We are a data and technology business that uses non-identifiable and publicly available anonymous data about people and places on an aggregated basis to provide useful analysis that helps make peoples’ lives better.

We also hold a limited amount of data about people we deal with directly, the use of which is outlined in this policy.

1. Important information

This Privacy Policy supplements the other notices and terms (including our website terms of use and Place Informatics Ltd Licences and Contracts) and is not intended to override them.

Place Informatics Ltd is the controller of data provided or collected by our online services and therefore responsible for your personal data.

To make it as easy as possible to understand this Privacy Policy, we have included at the end of this document a list of some of the legal terms used, examples of types of personal data we collect, how we use it, the lawful basis for processing this kind of data and further details of your rights.

Our online services are not intended for children and we do not knowingly collect data relating to children.

Data Protection Contact

We have a data privacy manager (DPM) who can help you if you have any questions about this Privacy Policy, including any requests to exercise your legal rights, please contact our DPM in writing using the address below:

Email address: FAO legal@placeinformatics.com  

Postal address: Data Protection Manager, Place Informatics Ltd, Cotton Court, Church Street, Preston, PR1 3BY.

You have the right to make a complaint at any time to the ICO (www.ico.org.uk). However, we would appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.

Changes

We may update this Privacy Policy from time to time and any changes will be made to this page.  If you do not accept any changes we make please stop using our online services.

This Privacy Policy was last updated 1st December 2021.

It is important that the data we hold about you is accurate and current, therefore please keep us informed of any changes to your personal data.

Third-party links

Our online services contain links to third-party websites, plug-ins and applications. By clicking on these links or enabling connections you may be allowing third parties to collect or share your personal data. We have no control these third-party websites, plug-ins or applications and are not responsible for their privacy notices, therefore you should also read their privacy notices to understand what personal data they collect about you and how they use it.

2. The type of data we collect about you

We may collect, use, store and transfer the types of personal data about you listed in Part 1 of the Schedule.

We also collect, use and share aggregated data. However, if we combine aggregated data with your personal data so that it can directly or indirectly identify you, we treat this as your personal data.

We do not collect any special categories of personal data or any information about criminal convictions and offences.

Failure to provide personal data

If we are required by law, or under the terms of a contract we have with you, to collect your personal data and you fail to provide it, we may not be able to enter into any contract with you or perform the contract with you and we may have to restrict your access to our online service. We will notify you of this at the relevant time.

3. How personal data is collected

We collect personal data in the following ways:

direct interactions 

you may provide personal data when you complete online forms,  create or require us to create a user account for our products, sign up to receive our newsletters, join our mailing list or otherwise or correspond with us (by post, phone or email)

automated technology

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 including Facebook tags. We may also receive technical data about you if you visit other websites which use our cookies or interact with our services (for example Facebook and LinkedIn). Please see our cookie notice for further details

publicly available sources

we may collect personal data from publicly availably sources

third parties

we may receive personal data from: (a)  analytics providers based inside and outside the EU (such as Google); (b) advertising networks such as Google and Facebook (based inside and outside the EU) and (c) our suppliers, which include website support and maintenance providers and email marketing service providers (such as Mailchimp)

4. How we use your personal data

We will only use your personal data when the law allows us to. Most commonly, we will use your personal data:

  • to provide our online services to you;
  • to comply with a legal obligation; and
  • 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.

Part 2 of the Schedule sets out the lawful basis we will rely on to process your personal data.

We may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your information.

Marketing

We may analyse your personal data to form a view on what products or services we think may be of interest to you.  Please note that you can withdraw your consent at any time by clicking the unsubscribe button in the particular email or by contacting us. 

We will not share your personal data with third parties for their marketing purposes.

Even if you opt out of receiving marketing, we may still use your personal data for other purposes provided we have a lawful basis to do so.

Change of purpose

We will only use your personal data for the purpose that we originally collected it for, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose.

If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to use your personal data in this way.

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

5. Sharing your personal data

We share your personal data with third parties (further details of which are set out in Part 4 of the Schedule).  Where we engage third parties to process data or our behalf, we will ensure wherever possible by entering into appropriate agreements with such third parties, that they take such measures to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only allow them to process your personal data for specified purposes and in accordance with our instructions.

6. International transfers

Some of our external third parties 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 ensure a similar degree of protection is afforded to it by ensuring they are of reputable standing and committed to protecting your privacy and we require at least one of the following safeguards to be implemented:

  • the country has deemed to provide an adequate level of protection for personal data by the European Commission or your data has been transferred to;
  • specific contracts approved by the European Commission are in place with the service provider which give personal data the same protection it has in Europe; or
  • the transfer is to a US based service providers under the Privacy Shield.

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. We also limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know and they can only process your personal data on our instructions and will be subject to a duty of confidentiality.

We have procedures in place 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.  However, we may be legally required to keep certain information (including contact, identity, financial and transaction data) for up to six years.

We may also anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes. We can use anonymised information indefinitely without further notice to you.

9. Your legal rights

You have certain rights in certain circumstances under data protection law.  These are set out in full in Part 3 of the Schedule.  If you wish to exercise any of your rights, please contact us.

You will not have to pay a fee to exercise any of your rights. However, if your request is clearly unfounded, repetitive or excessive, we may charge a reasonable fee for this information or refuse to comply with your request.

We may request specific information from you to help us confirm your identity when you contact us. This is a security measure to ensure that personal data is not disclosed to any person who does not have the right to receive it.

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.

 

Schedule

Part 1 Types of personal data

contact data

email address and telephone numbers

identity data

first name, maiden name, last name, username or similar identifier

marketing and communication data

your preferences in receiving marketing from us

profile data

your username, password and preferences

technical data

internet protocol (IP) 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

 Part 2 Lawful basis for processing and processing activities

The lawful basis upon which we may rely on to process your personal data are:

consent

you have given your express consent for us to process your personal data for a specific purpose

contract

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

legal obligation

the processing is necessary for us to comply with legal or regulatory obligation

legitimate interests

the processing is necessary for our or a third party’s legitimate interest e.g. in order for us to provide the best service to you. Before we process your personal data on this basis we make sure we consider and balance any potential impact on you, and we will not use your personal data on this basis where such impact outweighs our interest

 

Set out below are specific details of the processing activities we undertake with your personal data and the lawful basis for doing this.

Purpose/Activity

Type of data

Lawful basis for processing

to register you as a new user of our systems and manage our relationship with you

identity, profile & contact

to perform our contract with you

to manage our relationship with you and notifying you about changes to our Terms or Privacy Notice

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 analysing 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 IT services, network security, to prevent fraud and in the context of a business reorganisation 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 our 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 in relation to your personal data:

access your data

you can ask for access to and a copy of your personal data and can check we are lawfully processing it

correction

you can ask us to correct any incomplete or inaccurate personal data we hold about you

erasure

you can ask us to delete or remove your personal 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 personal data to comply with local law.

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

Object

you can object to the processing of your personal data where:

(a)      where we are relying on our legitimate interest (or those of a third party) as the basis for processing your personal data, if you feel it impacts on your fundamental rights and freedoms;

(b)     where we are processing your personal data for direct marketing purposes.

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

restrict processing

you can ask us to us to suspend or restrict the processing of your personal data, if:

(a)      you want us to establish the accuracy of your personal data;

(b)     our use of your personal data is unlawful, but you do not want us to erase it;

(c)      you need us to hold your personal 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 personal 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 personal 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 contact with you, to you or a third party. We will provide your personal 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 personal data). This does not affect the lawfulness of any processing carried out before you withdraw your consent

 

Part 4 Third Parties

service providers

acting as processors or controllers based in the EEA but also around the world who provide hosting services, analytical services,  IT support and system administration services

third parties 

third parties whom we may choose to sell, transfer, or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this Privacy Policy

 Part 5 Glossary

aggregated data

information such as statistical or demographic data which may be derived from personal data but which cannot by itself identify a data subject

controller

a body that determines the purposes and means of processing personal data

data subject

an individual living person identified by personal data (which will generally be you)

personal data

information identifying a data subject from that data alone or with other data we may hold but it does not include anonymised or aggregated data

processor

a body that is responsible for processing personal data on behalf of a controller

special categories of personal data

information about race, ethnicity, political opinions, religious or philosophical beliefs, trade union membership, health, genetic, biometric data, sex life, sexual orientation

ICO

Information Commissioner’s Office, the UK’s supervisory authority for data protection issues