Policy key definitions:
“our”, “us”, or “we” refer to the business, (penposh Network Ltd).
“you”, “the user” refer to the person(s) using this website.
GDPR means General Data Protection Act.
ICO means Information Commissioner’s Office.
Cookies mean small files stored on a users computer or device.
Processing of your personal data:
Under the GDPR (General Data Protection Regulation) we control and process any personal information about you electronically using the following lawful bases;
A. Data safeguard:
The Privacy of our website visitors is very important to us, and we are committed to safeguarding it. This policy explains what we will do with your personal information.
B. Collecting personal information:
The following types of personal information may be collected, stored, and used:
information about your computer including your IP address, geographical location, browser type and version, and operating system;
information about your visits to and use of this website including the referral source, length of visit, page views, and website navigation paths;
information, such as your email address, that you enter when you register with our website;
information that you enter when you create a profile on our website—for example, your name, profile pictures, gender, birthday, relationship status, interests and hobbies, educational details, and employment details;
information, such as your name and email address, that you enter in order to set up subscriptions to our emails and/or newsletters;
information that you enter while using the services on our website;
information that is generated while using our website, including when, how often, and under what circumstances you use it;
information relating to anything you purchase, services you use, or transactions you make through our website, which includes your name, address, telephone number, email address, and credit card details;
information that you post to our website with the intention of publishing it on the internet, which includes your username, profile pictures, and the content of your posts;
information contained in any communications that you send to us by email or through our website, including its communication content and metadata;
any other personal information that you send to us.
Before you disclose to us the personal information of another person, you must obtain that person’s consent to both the disclosure and the processing of that personal information in accordance with this policy.
C. Using your personal information:
Personal information submitted to us through our website will be used for the purposes specified in this policy or on the relevant pages of the website. We may use your personal information for the following:
Administering our website and business.
personalising our website for you.
enabling your use of the services available on our website.
sending you goods purchased through our website.
supplying services purchased through our website.
sending statements, invoices, and payment reminders to you, and collecting payments from you.
sending you non-marketing commercial communications.
sending you email notifications that you have specifically requested.
sending you our email newsletter, if you have requested it (you can inform us at any time if you no longer require the newsletter)
sending you marketing communications relating to our business or the businesses of carefully-selected third parties which we think may be of interest to you, by post or, where you have specifically agreed to this, by email or similar technology (you can inform us at any time if you no longer require marketing communications)
providing third parties with statistical information about our users (but those third parties will not be able to identify any individual user from that information); dealing with inquiries and complaints made by or about you relating to our website.
keeping our website secure and prevent fraud.
verifying compliance with the terms and conditions governing the use of our website (including monitoring private messages sent through our website private messaging service) and other uses.
If you submit personal information for publication on our website, we will publish and otherwise use that information in accordance with the license you grant to us.
Your privacy settings can be used to limit the publication of your information on our website and can be adjusted using privacy controls on the website.
We will not, without your express consent, supply your personal information to any third party for their or any other third party’s direct marketing.
D. Disclosing personal information:
We may disclose your personal information to any of our employees, officers, insurers, professional advisers, agents, suppliers, or subcontractors as reasonably necessary for the purposes set out in this policy.
We may disclose your personal information to any member of our group of companies (this means our subsidiaries, our ultimate holding company and all its subsidiaries) as reasonably necessary for the purposes set out in this policy.
We may disclose your personal information:
To the extent that we are required to do so by law;
in connection with any ongoing or prospective legal proceedings in order to establish, exercise, or defend our legal rights (including providing information to others for the purposes of fraud prevention and reducing credit risk);
to the purchaser (or prospective purchaser) of any business or asset that we are (or are contemplating) selling; and to any person who we reasonably believe may apply to a court or other competent authority for disclosure of that personal information where, in our reasonable opinion, such court or authority would be reasonably likely to order disclosure of that personal information.
Except as provided in this policy, we will not provide your personal information to third parties.
E. International data transfers:
Information that we collect may be stored, processed in, and transferred between any of the countries in which we operate in order to enable us to use the information in accordance with this policy.
Information that we collect may be transferred to the following countries which do not have data protection laws equivalent to those in force in the European Economic Area: the United States of America, Russia, Japan, China, and India.
Personal information that you publish on our website or submit for publication on our website may be available, via the internet, around the world. We cannot prevent the use or misuse of such information by others.
You expressly agree to the transfers of personal information described in this Section E .
F. Retaining personal information:
This Section F sets out our data retention policies and procedure, which are designed to help ensure that we comply with our legal obligations regarding the retention and deletion of personal information.
Personal information that we process for any purpose or purposes shall not be kept for longer than is necessary for that purpose or those purposes.
Without prejudice to article F-2, we will usually delete personal data falling within the categories set out below at the date/time set out below:
personal data type (log data)will be deleted, effective; 24th and 25th of May between the hours of 3.00pm & 4.00pm } every 5th month in a year. All retained data will be deleted withing 12 months period.
Keep in mind that search engines and other third parties may still retain copies of your public information, like your profile information and public shares, even after you have deleted the information from our services or deactivated your account.
Notwithstanding the other provisions of this Section F, we will retain documents (including electronic documents) containing personal data:
to the extent that we are required to do so by law;
if we believe that the documents may be relevant to any ongoing or prospective legal proceedings; and
in order to establish, exercise, or defend our legal rights (including providing information to others for the purposes of fraud prevention and reducing credit risk).
G. Security of your personal information:
We will take reasonable technical and organizational precautions to prevent the loss, misuse, or alteration of your personal information.
We will store all the personal information you provide on our secure (password- and firewall-protected) servers.
All electronic financial transactions entered into through our website will be protected by encryption technology.
You acknowledge that the transmission of information over the internet is inherently insecure, and we cannot guarantee the security of data sent over the internet.
You are responsible for keeping the password you use for accessing our website confidential; we will not ask you for your password (except when you log in to our website).
We may update this policy from time to time by publishing a new version on our website. You should check this page occasionally to ensure you understand any changes to this policy. We may notify you of changes to this policy by email or through the private messaging system on our website.
I. Your rights:
Your individual rights
Under the GDPR your rights are as follows:
the right to be informed about how your data is processed
the right of access to your data
the right to rectification of your data
the right to erasure of your data
the right to restrict processing of your data
the right to data portability
the right to object; and
the right not to be subject to automated decision-making including profiling.
You also have the right to complain to the ICO [www.ico.org.uk] if you feel there is a problem with the way we are handling your data.
We handle subject access requests in accordance with the GDPR.
You may instruct us to provide you with any personal information we hold about you; provision of such information will be subject to the following:
The supply of appropriate evidence of your identity (Drivers licence or international passport) for this purpose, we usually accept a photocopy of your passport certified by a notary plus an original copy of a utility bill showing your current address).
We may withhold personal information that you request to the extent permitted by law.
You may instruct us at any time not to process your personal information for marketing purposes.
In practice, you will usually either expressly agree in advance to our use of your personal information for marketing purposes, or we will provide you with an opportunity to opt out of the use of your personal information for marketing purposes.
J. Third party websites:
Our website includes hyperlinks and details of third party websites. We have no control over and are not responsible for the privacy policies and practices of third parties.
K. Updating information:
Please let us know if the personal information that we hold about you needs to be corrected or updated.
The names of the cookies that we use on our website, and the purposes for which they are used, are set out below:
we use Google Analytics and Adwords on our website to recognise a computer when a user visits the website, track users as they navigate the website, enable the use of a shopping cart on the website,improve the website’s usability,analyse the use of the website,administer the website, prevent fraud and improve the security of the website and personalise the website for each user / target advertisements which may be of particular interest to specific users or describe purposes.
Most browsers allow you to refuse to accept cookies—for example:
in Internet Explorer (version 10) you can block cookies using the cookie handling override settings available by clicking “Tools,” “Internet Options,” “Privacy,” and then “Advanced”;
in Firefox (version 24) you can block all cookies by clicking “Tools,” “Options,” “Privacy,” selecting “Use custom settings for history” from the drop-down menu, and unticking “Accept cookies from sites”; and
in Chrome (version 29), you can block all cookies by accessing the “Customise and control” menu, and clicking “Settings,” “Show advanced settings,” and “Content settings,” and then selecting “Block sites from setting any data” under the “Cookies” heading.
Blocking all cookies will have a negative impact upon the usability of many websites. If you block cookies, you will not be able to use all the features on our website.
You can delete cookies already stored on your computer—for example:
in Internet Explorer (version 10), you must manually delete cookie files (you can find instructions for doing so at http://support.microsoft.com/kb/278835 );
in Firefox (version 24), you can delete cookies by clicking “Tools,” “Options,” and “Privacy”, then selecting “Use custom settings for history”, clicking “Show Cookies,” and then clicking “Remove All Cookies”; and
in Chrome (version 29), you can delete all cookies by accessing the “Customize and control” menu, and clicking “Settings,” “Show advanced settings,” and “Clear browsing data,” and then selecting “Delete cookies and other site and plug-in data” before clicking “Clear browsing data.”
Deleting cookies will have a negative impact on the usability of many websites.
M. Sponsored links, affiliate tracking & commissions:
Clickable sponsored or affiliate links may be displayed as a website URL like this;
Clicking on any adverts, sponsored or affiliate links may track your actions by using a cookie saved to your device. You can read more about cookies on this website above. Your actions are usually recorded as a referral from our website by this cookie. In most cases we earn a very small commission from the advertiser or advertising partner, at no cost to you, whether you make a purchase on their website or not.
We use advertising partners in these ways to help generate an income from the website, which allows us to continue our work and provide you with the best overall experience and valued information.
If you have any concerns about this we suggest you do not click on any adverts, sponsored or affiliate links found throughout the website.
N. Email marketing messages & subscription:
Under the GDPR we use the consent lawful basis for anyone subscribing to our newsletter or marketing mailing list. We only collect certain data about you, as detailed in the “Processing of your personal data” above. Any email marketing messages we send are done so through an EMS, email marketing service provider. An EMS is a third party service provider of software or applications that allows marketers to send out email marketing campaigns to a list of users.
Email marketing messages that we send may contain tracking beacons or tracked clickable links or similar server technologies in order to track subscriber activity within email marketing messages. Where used, such marketing messages may record a range of data such as; times, dates, I.P addresses, opens, clicks, forwards, geographic and demographic data. Such data, within its limitations will show the activity each subscriber made for that email campaign.
Any email marketing messages we send are in accordance with the GDPR and the PECR. We provide you with an easy method to withdraw your consent (unsubscribe) or manage your preferences / the information we hold about you at any time. See any marketing messages for instructions on how to unsubscribe or manage your preferences, you can also unsubscribe from all posher EMS by contacting the EMS provider.
Our EMS provider is; [penposh network Ent. You can email us at firstname.lastname@example.org or use he contact form to reach us.
We hold the following information about you within our EMS system;
Subscription time & date.
O. Children and Our Services:
Our services are not directed to children, and you may not use our services if you are under the age of 14, You must also be old enough to consent to the processing of your personal data in your country (in some countries we may allow your parent or guardian to do so on your behalf). You must be at least 16 years of age to use Penposh.
P. Affiliates and Change of Ownership: