Privacy Policy
BACKGROUND:
PAVE Insight Ltd 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 everyone who visits this website www.paveinsight.com (“Our Site”) 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.
Please read this Privacy Policy carefully and ensure that you understand it.
1. Definitions and Interpretation
In this Policy the following terms shall have the following meanings:
- “Account”: means an account required to access and/or use certain areas and features of Our Site;
- “Cookie”: means a small text file placed on your computer or device by Our Site when you visit certain parts of Our Site and/or when you use certain features of Our Site. Details of the Cookies used by Our Site are set out in Part 14 below; and
- “Cookie Law”: means the relevant parts of the Privacy and Electronic Communications (EC Directive) Regulations 2003.
2. Information About Us
Our Site is owned and operated by PAVE Insight Ltd, a limited company registered in England under company number 15183946.
- Registered address: Unit 8 Wingbury Courtyard, Leighton Rd, Wingrave, Bucks, HP22 4LW.
- Representative: Andrew Jackson.
- Contact Us
3. What Does This Policy Cover?
This Privacy Policy applies only to your use of Our Site. Our Site may contain links to other websites. Please note that we have no control over how your data is collected, stored, or used by other websites and we advise you to check the privacy policies of any such websites before providing any data to them.
4. What Is Personal Data?
Personal data is defined by the UK GDPR and the Data Protection Act 2018 (collectively “the Data Protection Legislation”) 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.
5. What Are My Rights?
Under the Data Protection Legislation, 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 Policy 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 15.
- The right to access the personal data we hold about you. Part 13 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 15 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 hold. Please contact us using the details in Part 15 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 withdraw consent. This means that if we are relying on your consent as the legal basis for using your personal data, you are free to withdraw that consent at any time.
- 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.
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 15.
It is important that your personal data is kept accurate and up-to-date. If any of the personal data we hold about you changes, please keep us informed as long as we have that data.
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. We would welcome the opportunity to resolve your concerns ourselves, however, so please contact us first using the details in Part 15.
6. What Data Do You Collect and How?
Depending upon your use of Our Site, we may collect and hold some or all of the personal and non-personal data set out in the table below, using the methods also set out in the table. Please also see Part 14 for more information about our use of Cookies and similar technologies. We do not collect any ‘special category’ or ‘sensitive’ personal data, personal data relating to children, or data relating to criminal convictions and/or offences.
| Data Collected | How We Collect the Data |
|---|---|
| Identity Information including Forename, Surname, and Title | Registration form for any of PAVE Insight’s subscription services. |
| Contact information including email address, telephone number, and physical address | Registration form for any of PAVE Insight’s subscription services. |
| Business information including company name, job title, industry sector | Registration form for any of PAVE Insight’s subscription services. |
| Payment information including card details, bank account numbers | During payment process for the purchasing of goods and services in PAVE Insight’s web store. |
| Profile information including preferences, interests, login details, purchase history | User login page and user sign-up form(s). |
| Technical information including IP address, browser type and version, operating system | Browser Cookies. |
7. How Do You Use My Personal Data?
Under the Data Protection Legislation, we must always have a lawful basis for using personal data. The following table describes how we may use your personal data and our lawful bases for doing so:
| What We Do | What Data We Use | Our Lawful Basis |
|---|---|---|
| Registering you on Our Site | Identity information, Contact information | Collecting identity and contact information for registration on our site serves our legitimate interest in creating personalised accounts, enabling access to exclusive business insights, and facilitating direct communication with users. |
| Providing and managing your Account | Identity information, Contact information, Profile information, Technical information | Using identity, contact, profile, and technical information is essential for managing your account, rooted in our legitimate interest to offer personalised content, ensure security, and enhance overall user experience on our business insights website. |
| Providing and managing your access to Our Site | Identity information, Contact information, Payment information, Business information, Profile information, Technical information | We have a legitimate interest to manage valid accounts and ensure that they can access our site so that services are provided to the individual as set and/or purchased by the user’s profile and technical information. |
| Personalising and tailoring your experience on Our Site | Identity information, Contact information, Business information, Profile information, Technical information | We have the legitimate interest in collecting such data in order to safeguard that the experience for legitimate users is consistent and accurate in relation to each user's subscription level and preference settings. |
| Administering Our Site | Identity information, Contact information, Payment information, Business information, Profile information, Technical information | Collecting identity, contact, profile, payment, business, and technical information underpins our legitimate interest in administering our site, facilitating transactions, personalising your experience, and ensuring the security and optimal performance of our subscription services on our website. |
| Administering our business | Identity information, Contact information, Payment information, Business information, Profile information, Technical information | To administer our business effectively, we collect identity, contact, payment, business insights, profile, and technical information underpinned by our legitimate interest in providing personalised services, ensuring transaction security, managing customer relations, optimising our operational efficiency, and enhancing user experience. |
| Supplying our products and services to you | Identity information, Contact information, Payment information, Business information, Profile information, Technical information | Collecting identity, contact, profile, payment, business, and technical information aligns with our legitimate interest in supplying our products and services to you, ensuring we can deliver tailored insights, process transactions securely, and provide a personalised experience (as per user preferences) on our subscription-based business insights website. |
| Managing payments for our products and services | Identity information, Contact information, Payment information, Business information | Processing your identity, contact, payment, and business information under the basis of legitimate interest is essential for managing payments for our products and services, ensuring a smooth transaction process on our subscription-based products. |
| Personalising and tailoring our products and services for you | Identity information, Contact information, Payment information, Business information, Profile information, Technical information | Our legitimate interest in processing identity, contact, profile, payment, business, and technical information enables us to personalise and tailor our products and services for you, enhancing your experience on our subscription-based business insights website. |
| Communicating with you | Identity information, Contact information, Profile information, Business information | Our legitimate interest justifies the use of identity, contact, profile, and business information for communicating with you, ensuring we can deliver important updates, service information, personalised insights, request feedback, and engage in communications as and when customer support is required. |
| Supplying you with information by email that you have opted-in-to (you may opt-out at any time by clicking the unsubscribe link embedded in each email) | Identity information, Contact information, Profile information, Technical information | Utilising identity, contact, profile, and technical information is of legitimate interest to us and enables us to supply you with information by email that you have opted in to receiving. |
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, telephone, text message, or post with information, news, and offers on our products and 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 Data Protection Legislation and the Privacy and Electronic Communications (EC Directive) Regulations 2003, and you will always have the opportunity to opt-out. We will always obtain your express opt-in consent before sharing your personal data with third parties for marketing purposes, and you will be able to opt-out at any time.
Third Parties whose content appears on Our Site may use third-party Cookies as detailed below in Part 14. Please refer to Part 14 for more information on controlling cookies. Please note that we do not control the activities of such third parties nor the data that they collect and use themselves, and we advise you to check the privacy policies of any such third parties.
We use the following automated systems for carrying out certain kinds of decision-making and profiling. If at any point you wish to query any action that we take on the basis of this or wish to request ‘human intervention’ (i.e., have someone review the action themselves rather than relying only on the automated method), the Data Protection Legislation gives you the right to do so. Please contact us to find out more using the details in Part 15.
The rationale behind the automated decision-making is:
- to enable or otherwise improve the decision-making process;
- to grant Users fair and unbiased treatment based on consistent and uniform criteria;
- to reduce the potential harm derived from human error, personal bias, and the like which may potentially lead to discrimination or imbalance in the treatment of individuals etc.;
- to reduce the risk of User's failure to meet their obligation under a contract.
To find out more about the purposes, the third-party services (if any), and any specific rationale for automated decisions used within this Application, Users can check the relevant sections in this document.
We will only use your personal data for the purpose(s) for which it was originally collected unless we reasonably believe that another purpose is compatible with that or those original purpose(s) and need to use your personal data for that purpose. If we do use your personal data in this way and you wish us to explain how the new purpose is compatible with the original, please contact us using the details in Part 15.
If we need to use your personal data for a purpose that is unrelated to or incompatible with the purpose(s) for which it was originally collected, we will inform you and explain the legal basis which allows us to do so.
In some circumstances, where permitted or required by law, we may process your personal data without your knowledge or consent. This will only be done within the bounds of the Data Protection Legislation and your legal rights.
8. 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. 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):
| Type of Data | How Long We Keep It |
|---|---|
| Identity information | We will review on an annual basis all identity information. Where any user account that contains identity information is logged as having been inactive for a period of 12 months or more prior to the date of annual review, we will notify the user via the related contact details and provide notice to delete the account within 90 days unless activity is recorded on the account (i.e., the user logs in to the website within the 90-day period after the communication is sent). Should the account be inactive due to a subscription cancellation, the identity information relating to the user account will be deleted no more than 1 year (365 days) after the cancellation of the account. Identity information will be required to be retained for accounting/audit purposes, therefore if the data is no longer necessary for accounting purposes, the identity information will be anonymised provided that it is possible to do so without impeding the ability of the specific identity information to allow PAVE Insight to carry out its legal obligations to HMRC for financial reporting purposes (i.e., invoice evidence for the purpose of external audit). If the user requests deletion of their identity information and there are no other overriding legal or contractual obligations to retain it, the information will be deleted no more than 1 year (365 days) after the cancellation of the account or the deletion request, whichever comes first. |
| Contact information and Business information | No fixed period: we will review on an annual basis all identity records. Where any user record is logged as having been inactive for a period of 12 months or more, we will notify the user via the related contact details and provide notice to delete the account within 90 days unless activity is recorded once more on the account (i.e., the user logs in to the website within the 90-day period after the communication is sent). Should the account be inactive due to a subscription cancellation, any contact or business information will be anonymised no more than 1 year (365 days) after the cancellation of the account. If the user requests deletion of their contact or business information and there are no overriding legal or contractual obligations to retain it, the personal elements of the information will be anonymised no more than 1 year (365 days) after the cancellation of the account or the deletion request, whichever comes first. |
| Payment information | Minimum 7 years: we will review on an annual basis from the 7th year all payment information and records. If the data is no longer necessary for accounting purposes, the payment information and records will be anonymised provided that it is possible to do so without undermining the ability of the specific payment information and records to facilitate the legal obligations PAVE Insight has to HMRC for financial reporting purposes (i.e., invoice evidence for the purpose of external audit). |
| Technical information | No fixed period: we will review on an annual basis all technical information relating to user accounts. Where the technical information is of value to PAVE Insight’s ongoing business activities (i.e., data pertaining to how a browser type interacts with the website), yet the associated user account is to be deleted, PAVE Insight will anonymise the technical data so that no personal data is contained within the ongoing record. If the user requests deletion of their technical information and there are no overriding legal or contractual obligations to retain the technical information nor any way in which the data can be anonymised so that it can continue to be used for legitimate purposes, the technical information will be deleted no more than 1 year (365 days) after the cancellation of the account or the deletion request, whichever comes first. |
| Profile information | No fixed period: we will review on an annual basis all profile information relating to user accounts. Where the profile information is of value to PAVE Insight’s ongoing business activities (i.e., data pertaining to trends in subject areas or product types), yet the associated user account is to be deleted, PAVE Insight will anonymise the profile data so that no personal data is contained within the ongoing record. If the user requests deletion of their data and there are no overriding legal or contractual obligations to retain the profile information nor any way in which the profile information can be anonymised so that it can continue to be used for legitimate purposes, the profile information will be deleted no more than 1 year (365 days) after the cancellation of the account or the deletion request, whichever comes first. |
9. How and Where Do You Store or Transfer My Personal Data?
We will store some of your personal data in the UK. This means that it will be fully protected under the Data Protection Legislation.
AND
We will only store your personal data within the European Economic Area (the “EEA”). The EEA consists of all EU member states plus Norway, Iceland, and Liechtenstein. This means that your personal data will be fully protected under the EU GDPR and/or to equivalent standards by law. Transfers of personal data to the EEA from the UK are permitted without additional safeguards.
10. Do You Share My Personal Data?
We will not share any of your personal data with any third parties for any purposes, subject to the following exceptions.
- If we sell, transfer, or merge parts of our business or assets, your personal data may be transferred to a third party. Any new owner of our business may continue to use your personal data in the same way(s) that we have used it as specified in this Privacy Policy.
- 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.
If any of your personal data is shared with a third party as described above, we will take steps to ensure that your personal data is handled safely, securely, and in accordance with your rights, our obligations, and the third party’s obligations under the law as described above in Part 9.
If any personal data is transferred outside of the UK, we will take suitable steps in order to ensure that your personal data is treated just as safely and securely as it would be within the UK and under the Data Protection Legislation as explained above in Part 9.
If we sell, transfer, or merge parts of our business or assets, your personal data may be transferred to a third party. Any new
owner of our business may continue to use your personal data in the same way(s) that we have used it as specified in this Privacy Policy.
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.
11. How Can I Control My Personal Data?
In addition to your rights under the Data Protection Legislation set out in Part 5, when you submit personal data via our Site, you may be given options to restrict our use of your personal data. In particular, we aim to give you strong controls on our use of your data for direct marketing purposes (including the ability to opt-out of receiving emails from us, which you may do by unsubscribing using the links provided in our emails and at the point of providing your details, and by managing your Account).
You may also wish to sign up to one or more of the preference services operating in the UK: The Telephone Preference Service (“the TPS”), the Corporate Telephone Preference Service (“the CTPS”), and the Mailing Preference Service (“the MPS”). These may help to prevent you from receiving unsolicited marketing. Please note, however, that these services will not prevent you from receiving marketing communications that you have consented to receiving.
12. Can I Withhold Information?
You may access certain areas of Our Site without providing any personal data at all. However, to use all features and functions available on Our Site, you will be required to submit or allow for the collection of certain data.
You may restrict our use of Cookies. For more information see Part 14.
13. 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 15.
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 21 days (less than one month) and in any case not more than 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.
14. How Do You Use Cookies?
Our Site may place and access certain first-party Cookies on your computer or device. First-party Cookies are those placed directly by us and are used only by us. We use Cookies to facilitate and improve your experience of Our Site and to provide and improve our products and services. We have carefully chosen these Cookies and have taken steps to ensure that your privacy and personal data is protected and respected at all times.
By using Our Site, you may also receive certain third-party Cookies on your computer or device. Third-party Cookies are those placed by websites, services, and/or parties other than us. These Cookies are not integral to the functioning of Our Site and your use and experience of Our Site will not be impaired by refusing consent to them.
All Cookies used by and on Our Site are used in accordance with current Cookie Law.
Before Cookies are placed on your computer or device, you will be shown a pop-up requesting your consent to set those Cookies. By giving your consent to the placing of Cookies, you are enabling us to provide the best possible experience and service to you. You may, if you wish, deny consent to the placing of Cookies; however, certain features of Our Site may not function fully or as intended.
Certain features of Our Site depend on Cookies to function. Cookie Law deems these Cookies to be “strictly necessary”. Your consent will not be sought to place these Cookies, but it is still important that you are aware of them. You may still block these Cookies by changing your internet browser’s settings, but please be aware that Our Site may not work properly if you do so. We have taken great care to ensure that your privacy is not at risk by allowing them.
Our Site uses analytics services provided by Google. Website analytics refers to a set of tools used to collect and analyse anonymous usage information, enabling us to better understand how Our Site is used. This in turn enables us to improve Our Site and the products or services offered through it.
The analytics service(s) used by Our Site use(s) Cookies to gather the required information. You do not have to allow us to use these Cookies, however, whilst our use of them does not pose any risk to your privacy or your safe use of Our Site, it does enable us to continually improve Our Site, making it a better and more useful experience for you.
The analytics service(s) used by Our Site use(s) are detailed at the following link: Cookie information for Google's ad products
In addition to the controls that we provide, you can choose to enable or disable Cookies in your internet browser. Most internet browsers also enable you to choose whether you wish to disable all Cookies or only third-party Cookies. By default, most internet browsers accept Cookies, but this can be changed. For further details, please consult the help menu in your internet browser or the documentation that came with your device.
You can choose to delete Cookies on your computer or device at any time, however, you may lose any information that enables you to access Our Site more quickly and efficiently, including but not limited to login and personalisation settings.
It is recommended that you keep your internet browser and operating system up-to-date and that you consult the help and guidance provided by the developer of your internet browser and manufacturer of your computer or device if you are unsure about adjusting your privacy settings.
15. How Do I Contact You?
To contact us about anything to do with your personal data and data protection, including to make a subject access request, please use the following details (for the attention of Data Protection Officer):
16. Changes to this Privacy Policy
We may change this Privacy Policy from time to time. This may be necessary, for example, if the law changes, or if we change our business in a way that affects personal data protection.
Any changes will be immediately posted on Our Site and you will be deemed to have accepted the terms of the Privacy Policy on your first use of Our Site following the alterations. We recommend that you check this page regularly to keep up-to-date. This Privacy Policy was last updated on 27/03/2024.
PAVE Insight Ltd Website Privacy Policy 2024©