Pradera Limited understands that your privacy is important to you and that you care about how your personal data is used. We respect and value the privacy of all of our clients and will only collect and use personal data in ways that are described here, and in a way that is consistent with our obligations and your rights under the law.
Information About Us
Registered in England under company number 03786152.
Registered address: Eldon House, 2-3 Eldon Street, London, EC2M 7LS.
What Does This Notice Cover?
This Privacy Information explains how we use your personal data: how it is collected, how it is held, and how it is processed. It also explains your rights under the law relating to your personal data.
What is Personal Data?
Personal data is defined by the General Data Protection Regulation (EU Regulation 2016/679) (the “GDPR”) as ‘any information relating to an identifiable person who can be directly or indirectly identified in particular by reference to an identifier’.
Personal data is, in simpler terms, any information about you that enables you to be identified. Personal data covers obvious information such as your name and contact details, but it also covers less obvious information such as identification numbers, electronic location data, and other online identifiers.
The personal data that we use is set out in Part 5, below.
What Are My Rights?
Under the GDPR, you have the following rights, which we will always work to uphold:
The right to be informed about our collection and use of your personal data. This Privacy Notice should tell you everything you need to know, but you can always contact us to find out more or to ask any questions using the details in Part 11.
The right to access the personal data we hold about you. Part 10 will tell you how to do this.
The right to have your personal data rectified if any of your personal data held by us is inaccurate or incomplete. Please contact us using the details in Part 11 to find out more.
The right to be forgotten, i.e. the right to ask us to delete or otherwise dispose of any of your personal data that we have. Please contact us using the details in Part 11 to find out more.
The right to restrict (i.e. prevent) the processing of your personal data.
The right to object to us using your personal data for a particular purpose or purposes.
The right to data portability. This means that, if you have provided personal data to us directly, we are using it with your consent or for the performance of a contract, and that data is processed using automated means, you can ask us for a copy of that personal data to re-use with another service or business in many cases.
Rights relating to automated decision-making and profiling. We do not use your personal data in this way.
For more information about our use of your personal data or exercising your rights as outlined above, please contact us using the details provided in Part 11.
Further information about your rights can also be obtained from the Information Commissioner’s Office or your local Citizens Advice Bureau.
If you have any cause for complaint about our use of your personal data, you have the right to lodge a complaint with the Information Commissioner’s Office.
What Personal Data Do You Collect?
We may collect some or all of the following personal data (this may vary according to your relationship with us):
Information you have given to us by filling in forms or by communicating with us, including name, address, title, contact details including email address and mobile telephone number, date of birth, any communications you may have with us (including reporting problems with our site), preferences as to any methods and types of marketing information you have consented to receive.
Information we collect from or observe about you when you use our website:
When you use a computer, tablet, smart phone or other device to access our websites, we may collect information about the device and how you use it.
How Do You Use My Personal Data?
Under the GDPR, we must always have a lawful basis for using personal data. This may be because the data is necessary for our performance of a contract with you, because you have consented to our use of your personal data, or because it is in our legitimate business interests to use it. Your personal data may be used for one of the following purposes:
Providing and managing your account.
Supplying our services to you. Your personal details are required in order for us to enter into a contract with you.
Personalising and tailoring our services for you.
Communicating with you. This may include responding to emails or calls from you.
Supplying you with information by email and/or post that you have opted-in to (you may unsubscribe or opt-out at any time by pressing the unsubscribing button at the rear of our newsletters
With your permission and/or where permitted by law, we may also use your personal data for marketing purposes, which may include contacting you by email and/or telephone and/or post with information, news, and offers on our services. You will not be sent any unlawful marketing or spam. We will always work to fully protect your rights and comply with our obligations under the GDPR and the Privacy and Electronic Communications (EC Directive) Regulations 2003, and you will always have the opportunity to opt-out.
How Long Will You Keep My Personal Data?
We will not keep your personal data for any longer than is necessary in light of the reason(s) for which it was first collected. Unless legally required to retained for a longer timeframe, your personal data will therefore be kept for the following periods (or, where there is no fixed period, the following factors will be used to determine how long it is kept):
Your main business contact details will be kept for 12 months after the end of using our services unless agreed otherwise;
Contact with you such as emails providing advice will be held for 7 years after the end of using our services.
We will retain your details if you have unsubscribed from marketing to ensure that we respect your withdrawal of consent on an ongoing basis.
How and Where Do You Store or Transfer My Personal Data?
We will only store or transfer your personal data in the EU. This means that it will be fully protected under the GDPR.
We share your data within the group of companies of which we are a part. This will not involve the transfer of personal data outside the EEA. Our group ensures that personal data is protected by requiring all companies within the group to follow the same rules with respect to personal data usage. These are known as “binding corporate rules”. More information on binding corporate rules is available from the European Commission.
The security of your personal data is essential to us, and to protect your data, we take a number of important measures set out in our Data Protection Policy.
Do You Share My Personal Data?
We may share your personal data with other companies in our group for providing the services which are suitable to you. This includes subsidiary companies.
In some limited circumstances, we may be legally required to share certain personal data, which might include yours, if we are involved in legal proceedings or complying with legal obligations, a court order, or the instructions of a government authority.
How Can I Access My Personal Data?
If you want to know what personal data we have about you, you can ask us for details of that personal data and for a copy of it (where any such personal data is held). This is known as a “subject access request”.
All subject access requests should be made in writing and sent to the email or postal addresses shown in Part 11.
There is not normally any charge for a subject access request. If your request is ‘manifestly unfounded or excessive’ (for example, if you make repetitive requests) a fee may be charged to cover our administrative costs in responding.
We will respond to your subject access request within one month of receiving it. Normally, we aim to provide a complete response, including a copy of your personal data within that time. In some cases, however, particularly if your request is more complex, more time may be required up to a maximum of three months from the date we receive your request. You will be kept fully informed of our progress.
We may require additional information to either confirm your identity before we can process your request and/or to assist us in responding to your request.
If you are unhappy with the outcome of your request or with our processing of your personal data, you are entitled to lodge a complaint with the Information Commissioner’s Office (ICO), whose website is www.ico.org.uk.