Privacy Policy

Privacy Notice

This Privacy Notice applies to personal data processing under Pagabo Ltd, which is a company within ‘Pagabo Group’ of companies. This privacy notice and should be read in conjunction with ‘Pagabo Group’ Privacy Notice’, as it provides additional information regarding specific personal data processing by Pagabo Ltd.

This privacy notice applies to the following brands, products, and/or services, owned, delivered, and operated within Pagabo Ltd:

• Pagabo

Pagabo Ltd (herein ‘we’ or ‘us’ or ‘our’ or ‘Company’) gather and process personal information in accordance with this privacy notice, and ‘Pagabo Group’ Privacy Notice as the main data controller, in compliance with the relevant United Kingdom data protection laws. This notice provides you with the necessary information regarding your rights and our obligations, and explains how, why, and when we process your personal data.

Company’s registered office is at 55 Whitefriargate, Hull, HU1 2HU, and we are a company registered in England and Wales under company number 08787322. We are registered on the Information Commissioner’s Office Register; registration number ZB685017, and act as a data controller when processing your personal data. We have an appointed ‘responsible person’, based within the main data controller, whose role is for the oversight of, and compliance with, data protection law, and they can be contacted via dataprivacy@pagabogroup.com, or by telephone using 01482 975883 and asking for the ’responsible person for data protection’, or you can address your letter post, FAO the DP Responsible Person, Pagabo Group, 55 Whitefriargate, Hull, United Kingdom, HU1 2HU.

Information that we collect

We process your personal information to meet our legal, statutory, and contractual obligations, and to provide you with our products and services, or when you are applying to us about employment. We will never collect any unnecessary personal data from you and do not process your information in any way, other than as specified in this privacy notice, or Pagabo Group privacy notice.

Personal data processed as part of Company’s internal functions and processes:

• Name, gender (should you choose to give it), birth dates, etc.
• Personal identifiers, e.g., National Insurance number, work IDs, etc.
• Home address and personal contact information, phone, email, etc.
• Business contact and email details, phone, email, etc.

Personal data processed as part of operating our Online Programmes and Applications:

• Business contact and email details, phone, email, etc.

We collect information in the following ways:

Via online enquiry forms on our website, via emailed enquiries, via career applications, via general correspondence, via telephone enquiries, and/or during the use of any our products, services, etc. We may also collect personal data from one of Pagabo Group’s other companies, where they are requested by the you to pass this to us for enquiry contact, or where they believe that it is in the legitimate interest of your company, where our products/services may be of specific benefit to the operation of your company.

How we use your personal data

We take your data privacy very seriously and will never disclose, share, or sell your data without your consent, unless required to do so by law, or only with Pagabo Group’s other companies, where we have identified that it is your company’s legitimate interest to know about products/service. We only retain your data for as long as is necessary and for the purpose(s) specified in this notice. Where you have consented to us providing you with promotional offers and marketing, you are free to withdraw this consent at any time.  The purposes and reasons for processing your personal data are detailed below:

• We collect and store your personal data when responding to your enquiry via our website, through social media, applications, the telephone or in person.
• We collect and store your personal data in providing our products and/or services and when responding to enquiries relating to these.
  • This includes processing personal data within our products/services to which your company will have subscribed and use.
  • This may include processing personal data within our products/services in communications between other persons of your company, when using our products/services.
• We collect and store your personal data a part of fulfilling a contract with you as a contractor working with us or as an employee of our company.
• We collect and store your personal data as part of our legal obligation for business accounting and taxation purposes.

We, may occasionally send you marketing information where we have assessed that it is beneficial to you as a client, in your business’s interests, and/or in our interests. Such information will be non-intrusive and is processed on the grounds of legitimate interests.

Your Rights

You have the right to access any personal information that we process about you and to request information about:

• What personal data we hold about you.
• The purposes of the processing.
• The categories of personal data concerned.
• The recipients to whom the personal data has/will be disclosed.
• How long we intend to store your personal data for.
• Where we did not collect the data directly from you, information about the source of that data.

If you believe that we hold any incomplete or inaccurate data about you, you have the right to ask us to correct and/or complete the information and we will strive to do so as quickly as possible; unless there is a valid reason for not doing so, at which point you will be notified.

You also have the right to request erasure of your personal data or to restrict processing (where applicable) in accordance with the data protection laws; as well as to object to any direct marketing from us. Where applicable, you have the right to data portability of your information and the right to be informed about any automated decision-making we may use.

If we receive a request from you to exercise any of the above rights, we may ask you to verify your identity before acting on the request; this is to ensure that your data is protected and kept secure.

Sharing and Disclosing Your Personal Information

We do not share or disclose any of your personal information outside Pagabo Group without your consent other than for the purposes specified in this notice or where there is a legal requirement. We use some third parties to provide the services to our business functions that enable us to deliver our services to you.

All third-party processors acting on our behalf only process or access your data in accordance with instructions from us and comply fully with this privacy notice, data protection law and any other appropriate confidentiality and security measures.

These third parties may include our legal and accountancy professionals, our network and infrastructure support providers, and our contractors supporting our product development and programming, and where these parties are required to access personal data, they will do so under a legal contract or an agreement known as a Data Protection Agreement, depending upon their contractual status.

Safeguarding Measures

We take your data privacy seriously and take every reasonable measure and precaution to protect and secure your personal data. We work hard to protect you and your information from unauthorised access, alteration, disclosure, or destruction and have several layers of information security measures in place, including but not limited to:

• SSL, TLS, encryptions, pseudonymisation, restricted access, network authentication, firewalls, anti-virus/malware etc.
• Two-factor authentication (O365).
• Data is encrypted at rest and in transit.

 

Transfers outside the United Kingdom

Personal data of United Kingdom data subjects is protected by the United Kingdom General Data Protection Regulation (UK GDPR) but some other countries may not necessarily have the same high standard of protection for your personal data.

We do not process or transfer personal data outside of the United Kingdom and where any of our contractors operate from overseas locations, they are restricted to working on data and information, inside a secure environment located in the United Kingdom.

 

Consequences of Not Providing Your Data

You are not obligated to provide your personal information to us however, as this information is required for us to provide you with our products/services or respond to your enquiries, we will not be able to offer some or all our products/services without it.

The Group and Group Companies use UK based services for processing internal data and information, and utilises servers based in the European Union (EU) for delivering our products and services to our clients. These are located at two locations within the EU, one for delivery of the product / service access, and the other for handling data back-ups, and secure file transfers.

These transfers to EU based processors (servers), are permitted under UK data protection law on the basis of Adequacy.

How Long we Keep your Data

We only retain personal information for as long as is necessary and we have strict review and retention policies in place to meet these obligations. As an example, we are required under United Kingdom tax law to keep your basic personal data (name, address, contact details) for a minimum of 6 years plus the current year, after which time it will be destroyed.

Where you have consented to us using your details for direct marketing, we will keep such data until you notify us otherwise and/or withdraw your consent.

Your personal data is retained until such time as the contract ends and/or you delete your data. It is possible that some limited personal data may be retained after your close your account on a product for a limited period, where required under a specific lawful basis such as, fulfilling a legal obligation, and this will be retained for no longer than is required for that purpose.

Lodging A Complaint

We only process your personal information in compliance with this privacy notice and in accordance with the relevant data protection laws. If, however you wish to raise a complaint regarding the processing of your personal data or are unsatisfied with how we have handled your information, you have the right to lodge a complaint with the UK supervisory authority, the Information Commissioner’s Office (ICO).

To contact the Pagabo Ltd (Company) / Pagabo Group:

• Postal contact: FAO the DP Responsible Person, Pagabo Ltd, 55 Whitefriargate, Hull, United Kingdom, HU1 2HU.
• Telephone: 01482 975883 and asking for the ’responsible person for data protection’.
• Email: dataprivacy@pagabogroup.com

To contact the Information Commissioner’s Office:

• Postal contact: Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF
• Telephone: 0303 123 1113 (local rate) or 01625 545 745 if you prefer to use a national rate number
• Fax: 01625 524 510
• Website Complaint Submission: https://ico.org.uk/make-a-complaint/

Cookie Policy

Effective Date: 27-Jul-2023
Last Updated: 27-Jul-2023

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