Last updated: 25 May 2018
http://www.pdpuk.com (‘Website’) is provided by The Personal Development Point Ltd (‘we’/’us’/’our’). In doing so, we may be in a position to receive and process personal information relating to you. As the controller of this information, we’re providing this Privacy Notice (‘Notice’) to explain our approach to personal information. This Notice forms part of our Terms & Conditions, which governs the use of this Website.
Sometimes, when you take a new service or product from us, or discuss taking a new service or product but decide against it, we might wish to provide you with further information about similar services or products by email or other written electronic communication. In that situation, we’ll always give you the opportunity to refuse to receive that further information and you can change your mind at any point (opt-out) by contacting our Data Protection Officer (DPO) as set in clause 1.4. We’ll endeavour to remind you of your right to opt-out on each occasion that we provide such information.
1. Identity and contact details
1.1. Registered number: 05765799
1.2. Registered office: 3 Ashdown Grove, Liverpool, Merseyside, L26 6LR
1.4. Our Data Protection Officer (DPO) would welcome communication from you regarding any matter relating to data protection and can be contacted by email at firstname.lastname@example.org.
2. When we’re allowed to collect information from you
We will only collect personal information relating to you if one of the following conditions have been satisfied:
2.1. You have clearly told us that you are content for us to collect that information for the certain purpose or purposes that we will have specified.
2.2. The processing is necessary for the performance a contract that we have with you.
2.3. The processing is necessary so that we can comply with the law.
2.4. The processing is necessary to protect someone’s life.
2.5. The processing is necessary for performance of a task that’s in the public interest.
2.6. The processing is necessary for our or another’s legitimate interest – but in this case, we’ll balance those interests against your interests.
3. How to consent
3.1. At the point of collecting the information, we’ll endeavour to explain how we intend to use the information and which of these purposes apply. If we rely on consent, we’ll provide you with the opportunity to tell us that you’re happy to provide the information.
3.2. If at any point in time you change your mind and decide that you don’t consent, please let us know and we’ll endeavour to stop processing your information in a specified manner, or we’ll delete your data if there is no continuing reason for possessing it.
3.3. If you don’t consent to a particular bit of processing, we’ll endeavour to ensure that the Website and our service continue to operate without the need for that information.
4. Information we expect to collect from you
4.1. We envisage asking for the following types of information from you:
|Information Type||Purpose & Related Details||Justification|
|Contact Information (Name, Email, Telephone)||We ask for this to verify your identity when you contact us.||It’s necessary for the performance of a contract with you|
4.2. We may collect personal information about you from a number of sources, including the following:
4.2.1. From you when you agree to take a service or product from us, in which case this may include your contact details, date of birth, how you will pay for the product or service and your bank details.
4.2.2. From you when you contact us with an enquiry or in response to a communication from us, in which case, this may tell us something about how you use our services.
4.2.3. From documents that are available to the public, such as the electoral register.
4.2.4. From third parties to whom you have provided information with your consent to pass it
on to other organisations or persons – when we receive such information, we will let you know as soon as is reasonably practicable.
4.3. If you refuse to provide information requested, then if that information is necessary for a service we provide to you we may need to stop providing that service.
4.4. At the time of collecting information, by whichever method is used, we’ll endeavour to alert you and inform you about our purposes and legal basis for processing that information, as well as whether we intend to share the information with anyone else or send it outside of the European Economic Area. If at any point you think we’ve invited you to provide information without explaining why, feel free to object and ask for our reasons.
5. Using your personal information
5.1. Data protection, privacy and security are important to us, and we shall only use your personal information for specified purposes and shall not keep such personal information longer than is necessary to fulfil these purposes. The following are examples of such purposes. We have also indicated below which GDPR justification applies, however it will depend on the circumstances of each case. At the time of collecting, we will provide further information, and you may always ask for further information from us.
5.1.1. To help us to identify you when you contact us. This will normally be necessary for the performance our contract.
5.1.2. To help us to identify accounts, services and/or products which you could have from us or selected partners from time to time. We may do this by automatic means using a scoring system, which uses the personal information you’ve provided and/or any information we hold about you and personal information from third party agencies (including credit reference agencies). We will only use your information for this purpose if you agree to it.
5.1.3. To help us to administer and to contact you about improved administration of any accounts, services and products we have provided before, do provide now or will or may provide in the future. This will often be necessary, but sometimes the improvements will not be necessary in which case we will ask whether you agree.
5.1.4. To allow us to carry out marketing analysis and customer profiling (including with transactional information), conduct research, including creating statistical and testing information. This will sometimes require that you consent, but will sometimes be exempt as market research.
5.1.5. To help to prevent and detect fraud or loss. This will only be done in certain circumstances when we consider it necessary or the law requires it.
5.1.6. To allow us to contact you by written electronic means (such as email, text or multimedia messages) about products and services offered by us where:
18.104.22.168. these products are similar to those you have already purchased from us,
22.214.171.124. you were given the opportunity to opt out of being contacted by us at the time your personal information was originally collected by us and at the time of our subsequent communications with you, and
126.96.36.199. you have not opted out of us contacting you.
5.1.7. To allow us to contact you in any way (including mail, email, telephone, visit, text or multimedia messages) about products and services offered by us and selected partners where you have expressly consented to us doing so.
5.1.8. We may monitor and record communications with you (including phone conversations and emails) for quality assurance and compliance.
188.8.131.52. Before doing that, we will always tell you of our intentions and of the specific purpose in making the recording. Sometimes such recordings will be necessary to comply with the law. Alternatively, sometimes the recording will be necessary for our legitimate interest, but in that case, we’ll only record the call if our interest outweighs yours. This will depend on all the circumstances, in particular, the importance of the information and whether we can obtain the information another way that’s less intrusive.
184.108.40.206. If we think the recording would be useful for us but that it’s not necessary we’ll ask whether you consent to the recording, and will provide an option for you to tell us that you consent. In those situations, if you don’t consent, the call will either automatically end or will not be recorded.
5.1.9. When it’s required by law, we’ll check your details with fraud prevention agencies. If you provide false or inaccurate information and we suspect fraud, we intend to record this.
5.2. We will not disclose your personal information to any third party except in accordance with this Notice, and in particular in these circumstances:
5.2.1. They will be processing the data on our behalf as a data processor (where we’ll be the data controller). In that situation, we’ll always have a contract with the data processor as set out in the GDPR. This contract provides significant restrictions as to how the data processor operates so that you can be confident your data is protected to the same degree as provided in this Notice.
5.2.2. Sometimes it might be necessary to share data with another data controller. Before doing that we’ll always tell you. Note that if we receive information about you from a third party, then as soon as reasonably practicable afterwards we’ll let you know; that’s required by the GDPR.
5.2.3. Alternatively, sometimes we might consider it to be in your interest to send your information to a third party. If that’s the case, we’ll always ask whether you agree before sending.
5.3. Where you give us personal information on behalf of someone else, you confirm that you have provided them with the information set out in this Notice and that they have not objected to such use of their personal information.
5.4. We may allow other people and organisations to use personal information we hold about you in the following circumstances:
5.4.1. If we, or substantially all of our assets, are acquired or are in the process of being acquired by a third party, in which case personal information held by us, about our customers, will be one of the transferred assets.
5.4.2. If we have been legitimately asked to provide information for legal or regulatory purposes or as part of legal proceedings or prospective legal proceedings.
5.4.3. We may employ companies and individuals to perform functions on our behalf and we may disclose your personal information to these parties for the purposes set out above, for example, for fulfilling orders, delivering packages, sending postal mail and email, removing repetitive information from customer lists, analysing data, providing marketing assistance, providing search results and links (including paid listings and links) and providing customer service. Those parties will be bound by strict contractual provisions with us and will only have access to personal information needed to perform their functions, and they may not use it for any other purpose. Further, they must process the personal information in accordance with this Notice and as permitted by the GDPR. From time to time, these other people and organisations to whom we may pass your personal information may be outside the European Economic Area. We will take all steps reasonably necessary to ensure that your personal information is treated securely and in accordance with this Notice and the GDPR.
6. Protecting information
6.1. We have strict security measures to protect personal information.
6.2. We work to protect the security of your information during transmission by using appropriate technology to encrypt information you input.
6.3. We reveal only the last five digits of your credit card numbers when confirming an order. Of course, we transmit the entire credit card number to the appropriate credit card company during order processing.
6.4. We maintain physical, electronic and procedural safeguards in connection with the collection, storage and disclosure of personally identifiable customer information. Our security procedures mean that we may occasionally request proof of identity before we disclose personal information to you.
6.5. It is important for you to protect against unauthorised access to your password and to your computer. Be sure to sign off when you finish using a shared computer.
7. The internet
7.1. If you communicate with us using the internet, we may occasionally email you about our services and products. When you first give us personal information through the Website, we will normally give you the opportunity to say whether you would prefer that we don’t contact you by email. You can also always send us an email (at the address set out below) at any time if you change your mind.
7.2. Please remember that communications over the internet, such as emails and webmails (messages sent through a website), are not secure unless they have been encrypted. Your communications may go through a number of countries before they are delivered – this is the nature of the internet. We cannot accept responsibility for any unauthorised access or loss of personal information that is beyond our control.
8. Cookies and other internet tracking technology
8.2. Where applicable, this section of the Notice also relates to that technology but the term ‘cookie’ is used throughout.
8.3. Some of these cookies are essential to services you’ve requested from us, whereas others are used to improve services for you, for example through:
8.3.1. Letting you navigate between pages efficiently
8.3.2. Enabling a service to recognise your computer so you don’t have to give the same information during one task
8.3.3. Recognising that you have already given a username and password so you don’t need to enter it for every web page requested
8.3.4. Measuring how many people are using services, so they can be made easier to use and that there is enough capacity to ensure they are fast
8.4. To learn more about cookies, you may wish to visit: www.allaboutcookies.org, www.youronlinechoices.eu or www.google.com/policies/technologies/cookies/
8.5. This Website uses, or allows the use of, the following cookies:
• Google Analytics is a web analytics service. Web analytics is the collection, gathering, and analysis of data about the behaviour of visitors to websites. A web analysis service collects, inter alia, data about the website from which a person has come (the so-called referrer), which sub-pages were visited, or how often and for what duration a sub-page was viewed. Web analytics are mainly used for the optimization of a website and in order to carry out a cost-benefit analysis of Internet advertising. For the web analytics through Google Analytics the controller uses the application “_gat. _anonymizeIp”. By means of this application, the IP address of the Internet connection of the data subject is abridged by Google and anonymised when accessing our websites from a Member State of the European Union or another Contracting State to the Agreement on the European Economic Area. The purpose of the Google Analytics component is to analyze the traffic on our website. Google uses the collected data and information, inter alia, to evaluate the use of our website and to provide online reports, which show the activities on our websites, and to provide other services concerning the use of our Internet site for us. Google Analytics places a cookie on the information technology system of the data subject. The definition of cookies is explained above. With the setting of the cookie, Google is enabled to analyze the use of our website. With each call-up to one of the individual pages of this Internet site, which is operated by the controller and into which a Google Analytics component was integrated, the Internet browser on the information technology system of the data subject will automatically submit data through the Google Analytics component for the purpose of online advertising and the settlement of commissions to Google. During the course of this technical procedure, the enterprise Google gains knowledge of personal information, such as the IP address of the data subject, which serves Google, inter alia, to understand the origin of visitors and clicks, and subsequently create commission settlements. The cookie is used to store personal information, such as the access time, the location from which the access was made, and the frequency of visits to our website by the data subject. Google may pass these personal data collected through the technical procedure to third parties.
• Category 2 – performance
• Third party: another website is placing the cookie
• Persistent cookie, expiry: never
• The information will be sent to Google Inc., 1600 Amphitheatre Pkwy, Mountain View, CA 94043-1351, United States so that so that we can analyze the traffic on our website. Google uses the collected data and information, inter alia, to evaluate the use of our website and to provide online reports, which show the activities on our websites, and to provide other services concerning the use of our Internet site for us
• The information from the cookie may be transferred to the US, and the receiving entity is registered with the EU-US Privacy ShieldConsent
Consent Needed – Yes
• On this website, the controller has integrated Google Remarketing services. Google Remarketing is a feature of Google AdWords, which allows an enterprise to display advertising to Internet users who have previously resided on the enterprise’s Internet site. The integration of Google Remarketing, therefore, allows an enterprise to create user-based advertising and thus shows relevant advertisements to interested Internet users. The purpose of Google Remarketing is the insertion of interest-relevant advertising. Google Remarketing allows us to display ads on the Google network or on other websites, which are based on individual needs and matched to the interests of Internet users. Google Remarketing sets a cookie on the information technology system of the data subject. The definition of cookies is explained above. With the setting of the cookie, Google enables a recognition of the visitor of our website if he calls up consecutive web pages, which are also a member of the Google advertising network. With each call-up to an Internet site on which the service has been integrated by Google Remarketing, the web browser of the data subject identifies automatically with Google. During the course of this technical procedure, Google receives personal information, such as the IP address or the surfing behaviour of the user, which Google uses, inter alia, for the insertion of interest relevant advertising. The cookie is used to store personal information, e.g. the Internet pages visited by the data subject. Each time we visit our Internet pages, personal data, including the IP address of the Internet access used by the data subject, is transmitted to Google in the United States of America. These personal data are stored by Google in the United States of America. Google may pass these personal data collected through the technical procedure to third parties. The data subject may, as stated above, prevent the setting of cookies through our website at any time by means of a corresponding adjustment of the web browser used and thus permanently deny the setting of cookies. Such an adjustment to the Internet browser used would also prevent Google from setting a cookie on the information technology system of the data subject. In addition, cookies already in use by Google may be deleted at any time via a web browser or other software programs. In addition, the data subject has the possibility of objecting to the interest-based advertising by Google. For this purpose, the data subject must call up the link to www.google.de/settings/ads and make the desired settings on each Internet browser used by the data subject. Further information and the actual data protection provisions of Google may be retrieved under https://www.google.com/intl/en/policies/privacy/.
• Category 4 – targeting and advertising
• Third party: another website is placing the cookie
• Persistent cookie, expiry: never
• The information will be sent to The information will be sent to Google Inc., 1600 Amphitheatre Pkwy, Mountain View, CA 94043-1351, United States so that so that we can display ads on the Google network or on other websites, which are based on individual needs and matched to the interests of Internet users.
• The information from the cookie may be transferred to the US, and the receiving entity is registered with the EU-US Privacy Shield
Consent Needed – Yes
8.6. The distinctions referred to in the above table are as follows:
8.6.1. First party versus third party cookies – we set first-party cookies ourselves; third party cookies are set by other entities via our Website.
8.6.2. Session versus persistent cookies – session cookies only persist for the duration of that visit; persistent cookies last for longer
8.6.3. Identifying information removed – just because we’ve done this, they will still be personal information if the relevant information can be reassembled
8.6.4. Categories 1-4 found in the ICC UK Cookie guide, as explained below. Category 1 cookies don’t require the user’s consent, though you must still tell them about the cookies. Categories 2-4 do require their specific and informed consent.
|Category 1||Strictly necessary||These cookies are essential in order to enable you to move around the website and use its features, such as accessing secure areas of the website. Without these cookies services you have asked for, like shopping baskets or e-billing, cannot be provided. We include in this category cookies that are used only for electronic communication. (The ICC doesn’t refer to these cookies, but the law is the same.) Note that cookies for which another person is the controller will never be necessary for a service requested of you. On the other hand, if you’ve asked another person to send a cookie on your behalf for an essential feature of your website, that would be category 1.|
|Category 2||Performance||These cookies collect information about how visitors use a website, for instance which pages visitors go to most often, and if they get error messages from web pages. This information is only used to improve how a website works.|
|Category 3||Functionality||These cookies allow the website to remember choices you make (such as your user name, language or the region you are in) and provide enhanced, more personal features. For instance, a website may be able to provide you with local weather reports or traffic news by storing in a cookie the region in which you are currently located. These cookies can also be used to remember changes you have made to text size, fonts and other parts of web pages that you can customise. They may also be used to provide services you have asked for such as a live chat session.|
|Category 4||Targeting and advertising||These cookies are used to deliver adverts more relevant to you and your interests. They are also used to limit the number of times you see an advertisement as well as help measure the effectiveness of the advertising campaign. They are usually placed by advertising networks with the website operator’s permission. They remember that you have visited a website and this information is shared with other organisations such as advertisers. Quite often targeting or advertising cookies will be linked to site functionality provided by the other organisation.|
8.7. As with any other information we may collect from you, we’ll work to protect the security of your information during transmission by using by using appropriate technology to encrypt information you input.
8.9. We exclude all liability for loss that you may incur when using these third-party websites.
9. Further information
9.1. If you would like any more information or you have any comments about this Notice, please write to our Data Protection Officer as detailed in clause 1.4.
9.2. Please note that we may have to amend this Notice on occasion, for example, if we change the cookies that we use. If we do that, we will publish the amended version on the Website. In that situation, we will endeavour to alert you to the change, but it’s also your responsibility to check regularly to determine whether this Notice has changed.
9.3. You can ask us for a copy of this Notice by writing to the above address or by emailing us at email@example.com. This Notice applies to personal information we hold about individuals. It does not apply to information we hold about companies and other organisations.
9.4. If you would like access to the personal information that we hold about you, you can do this by emailing us at firstname.lastname@example.org or writing to us at the address noted above. There is not normally a fee for such a request, however, if the request is unfounded, repetitive or excessive we may request a fee or refuse to comply with your request. You can also ask us to send the personal information we hold about you to another controller.
9.5. We aim to keep the personal information we hold about you accurate and up to date. If you tell us that we’re holding any inaccurate or incomplete personal information about you, we will promptly amend, complete or delete it accordingly. Please email us at email@example.com or write to us at the address above to update your personal information. You have the right to complain to the Information Commissioner’s Office if we don’t do this.
9.6. You can ask us to delete the personal information that we hold about you if we relied on your consent in holding that information or if it’s no longer necessary. You can also restrict or object to our processing of your personal information in certain circumstances. You can do this by emailing us at firstname.lastname@example.org or writing to us at the address noted above.
9.7. We will tell you if there is a breach, or a likely breach, of your data protection rights.