This is the privacy notice of Perfect Moment (UK) Ltd. In this document, “we”, “our”, or “us” refer to Perfect Moment (UK) Ltd. We are the controller and are responsible for your personal information.
This is a notice to inform you of our policy about all information that we record about you. This policy applies to you if you use our website, are a customer or a business partner or contact us directly. It sets out the conditions under which we may process any information that we process about you whether such information is collect from you, or otherwise provided to us. It covers information that identifies you either directly or indirectly (“personal information”). In the context of the law and this notice, “process” means collect, store, transfer, use or otherwise act on information.
We undertake to preserve the confidentiality of all confidential information you provide to us, and hope that you reciprocate.
Except as set out below, we do not share, or sell, or disclose to a third party, any information collected through our website.
1. The bases on which we process information about you
The law requires us to determine under which of six defined bases we process different categories of your personal information, and to notify you of the basis for each category.
If a basis on which we process your personal information is no longer relevant then we shall immediately stop processing your data.
If the basis changes then if required by law we shall notify you of the change and of any new basis under which we have determined that we can legally continue to process your information.
1.1. Information we process because we have a contractual obligation with you
When you create an account on our website, buy a product or service from us, or otherwise agree to our terms and conditions, a contract is formed between you and us.
In order to carry out our obligations under that contract we must process the information you give us. Some of this information may be personal information.
Such personal information may include your name, contact details and the information of purchases you have made with us or services we have provided you.
We may use you personal information in order to:
1.1.1. verify your identity for security purposes; 1.1.2. sell products to you; 1.1.3. provide you with our services; 1.1.4. provide you with suggestions and advice on products, services and how to obtain the most from using our website (provided we have a lawful basis to do so).
We process this information on the basis there is a contract between us, or that you have requested we use the information before we enter into a legal contract.
Additionally, we may aggregate this information in a general way and use it to provide class information, for example to monitor our performance with respect to a particular service we provide. If we use it for this purpose, you as an individual will not be personally identifiable.
We shall continue to process this information until the contract between us ends or is terminated by either party under the terms of the contract or until we no longer have a lawful basis to process the personal information.
1.2. Information we process with your consent
Through certain actions when otherwise there is no contractual relationship between us, such as when you browse our website or ask us to provide you more information about our business, including our products and services, you provide your consent for us to process your personal information.
We continue to process your information on this basis until you withdraw your consent or it can be reasonably assumed that your consent no longer exists.
1.3. Information we process for the purposes of legitimate interests
We may process information on the basis there is a legitimate interest to do so, either for us or a third party.
Where we process your information on this basis, we do after having given careful consideration to:
1.3.1. whether the same objective could be achieved through other means; 1.3.2. whether processing (or not processing) might cause you harm; 1.3.3. whether you would expect us to process your data, and whether you would, in the round, consider it reasonable to do so.
For example, we may process your data on this basis for the purposes of:
1.3.4. record-keeping for the proper and necessary administration of our organisational or business; 1.3.5. responding to unsolicited communication from you to which we believe you would expect a response; 1.3.6. protecting and asserting the legal rights of any party; 1.3.7. insuring against or obtaining professional advice that is required to manage out risk; or 1.3.8. protecting your interests where we believe we have a duty to do so.
1.4 Information we process because we have a legal obligation
We are subject to the law like everyone else. Sometimes, we must process your information in order to comply with a statutory or other legal obligation.
For example, we may be required to give information to legal authorities if they so request or if they have the proper authorisation such as a search warrant or court order.
This may include your personal information.
2. Specific uses of information you provide us
2.1. Aggregated data
2.2. Information relating to your method of payment
Payment information is never taken by us or transferred to us either through our website or otherwise. Our employees and contractors never have access to it.
At the point of payment, you are transferred to a secure page on the website of SagePay and Paypal payment service providers. That page may be branded to look like a page on our website, but it is not controlled by us.
2.3. Sending a message to our support team
When you contact us, whether by telephone, through our website or by e-mail, we collect the data you have given to us in order to reply with the information you need.
We record your request and our reply in order to increase the efficiency of our business and to respond to your request.
We keep personal information associated with your message, such as your name and email address so as to be able to track our communications with you to provide a high quality service.
We may aggregate information relating to your complaint in order to compile statistics showing information obtained from complaints to assess the level of service we provide, but not in a way that could identify you or any other person.
2.5. Business partner information
You may provide us with in your capacity as a business partner. Such information may allow us to recognise visitors that you have referred to us. We will only use information provided by you for the purpose for which it was provided.
We undertake to preserve the confidentiality of the information and of the terms of our relationship. The relationship with our business partners shall be governed by any contract we have in place with them.
Cookies are small text files that are placed on your computer or device by your web browser when you visit any website. They allow information gathered on one web page to be stored until it is needed for use on another, allowing a website to provide you with a personalised experience and the website owner with statistics about how you use the website.
Some cookies may last for a defined period of time, such as one day or until you close your browser. Others last indefinitely.
You can block cookies by activating the setting on your browser that allows you to refuse the setting of all or some cookies. However, if you use your browser settings to block all cookies (including essential cookies) you may not be able to access all or parts of our website.
3.1. to track how you use our website; 3.2. to record whether you have seen specific messages we display on our website; 3.3. to keep you signed in our site; 3.4. to record your answers to surveys and questionnaires on our site while you complete them; 3.5. to customise content and advertising;
Personal identifiers from your browsing activity
Requests by your web browser to our servers for web pages and other content on our website are recorded.
We record information such as your geographical location, your Internet service provider and your IP address. We also record information about the software you are using to browse our website, such as the type of computer or device and the screen resolution.
We use this information in aggregate to assess the popularity of the webpages on our website and how we perform in providing content to you.
If combined with other information we know about you from previous visits, the data possibly could be used to identify you personally, even if you are not signed in to our website.
4. Our use of re-marketing
Re-marketing involves placing a cookie on your computer when you browse our website in order to be able to serve to you an advert for our products or services when you visit some other website.
5. Disclosure and sharing of your information
Internal third parties which may include other companies within the Perfect Moment group; and
External third parties which include:
Services providers acting as processors based within the UK, EU or internationally including payment providers, IT and system administration services;
Professional advisers including lawyers, bankers, auditors and insurers based in the UK, EU or internationally who provide consultancy, banking, legal, insurance and accounting services;
HM Revenue & Customers, regulators and other authorities who require reporting of processing activities in certain circumstances;
We require all third parties to respect the security of your personal information and to treat it in accordance with all applicable law. We do not allow our third-party service providers or partners to use your personal information for their own purposes and only permit them to process your personal information for specified purposes and in accordance with our instructions.
5.1. Credit reference
To assist in combating fraud, we share information with credit reference agencies, so far as it relates to clients or customers who instruct their credit card issuer to cancel payment to us without having first provided an acceptable reason to us and given us the opportunity to refund their money.
5.2. Data may be processed outside the United Kingdom or European Union
Our website is hosted in the United Kingdom
We may also use outsourced services in countries outside the European Union from time to time. Accordingly data obtained within the UK or any other country could be processed outside the European Union.
We use the following safeguards with respect to data transferred outside the UK or the European Union:
5.2.1. the country to which we are transferring personal information has been deemed adequate by the Information Commissioner’s Officer or the European Commission (as recognised by the Information Commissioner’s Office); 5.2.2. the data protection clauses in our contracts with data processors or data controllers based outside the UK include standard contractual clauses approved by the Information Commissioner’s Office.
6. Data subject rights
Under applicable data protection law, you have rights of which we would like to make you aware. The rights available to you depend on our reason for processing your personal information. If you wish to exercise your rights as a data subject you may send us a request at firstname.lastname@example.org.
When we receive any request to access, edit or delete personal identifiable information we shall first take reasonable steps to verify your identity before granting you access or otherwise taking any action. This is important to safeguard your information.
6.1. Access to your personal information
At any time you may review or update personally identifiable information that we hold about you, by signing in to your account on our website.
You have a right to ask us for copies of your personal information.
6.2. Rectification of your information
You have a right to ask us to rectify information we hold about you that you think is inaccurate. You also have the right to ask us to complete information you think is incomplete.
6.3. Removal of your information
You have the right to request that the personal information we hold on you is erased in certain circumstances.
6.4. Objection to processing
You have the right to object to processing if we are able to process your information on the basis of our legitimate interest.
6.5. Data portability
For information that you have given us, you have the right to ask that we transfer the information you gave us to another organisation, or give it to you. This right only applies if we are processing information based on your consent or under the terms of a contract we have with you.
6.6. Restriction of processing
You have a right to ask us to restrict the processing of your personal information in certain circumstances.
7. Other matters
7.1. Use of site by children
We do not sell products or provide services for purchase by children, nor do we market to children. If you are under 18, you may use our website only with consent from a parent or guardian.
7.2. Encryption of data sent between us
We use Secure Sockets Layer (SSL) certificates to verify our identity to your browser and to encrypt any data you give us.
Whenever information is transferred between us, you can check that it is done so using SSL by looking for a closed padlock symbol or other trust mark in your browser’s URL bar or toolbar.
7.3. How you can complain
7.4. Retention period for personal data
Except as otherwise mentioned in this privacy notice, we keep your personal information only for as long as required by us:
7.4.1. to provide you with the services you have requested; 7.4.2. to comply with other law, including for the period demanded by our tax authorities; 7.4.3. to support a claim or defence in court.
In any event, we will not retain any personal information for longer than is necessary to fulfil the purpose for which it was collected.
7.5. Compliance with the law
We may update this privacy notice from time to time as necessary. The terms that apply to you are those posted here on our website on the day you use our website. We advise you to print a copy for your records.
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