This policy was last reviewed February 2022.
Place Innovation Ltd ("we", "us". “our”) take your privacy seriously. We are committed to keeping your information secure and managing it in accordance with our legal responsibilities, under the General Data Protection Regulation (Regulation (EC) 2016/679 (“GDPR”) in the European Union (“EU”). Place Innovation Limited is registered with the Information Commissioners Office (ICO) in accordance with our legal responsibilities. Our ICO registration number is ZA840434.
This policy outlines how Place Innovation Ltd collects, processes, stores and uses data. It also describes your choices regarding use, access, and correction of your personal information.
2. Who this policy applies to
This policy applies to anyone: using our websites; taking part in our research; enquiring about our services; who is a client; who is an associate.
3. Data gathering and usage
We collect data in the following ways:
3.1 Through our website
The primary purpose of our websites is to provide you with information regarding the services provided by Place Innovation Ltd and its activities.
We may process data about your use of our websites ("usage data"). The usage data may include your IP address, geographical location, browser type and version, operating system, referral source, length of visit, page views and website navigation paths, as well as information about the timing, frequency and pattern of your service use. The source of the usage data is Google Analytics.
More information about the ways in which Google collect and process your personal data can be found here and you can opt-out of Google Analytics here. This usage data may be processed for the purposes of analysing the use of the website and services. We may make usage data available privately or publicly to help others to understand who is making use of our websites and how. Data will be aggregated and the personal data of individual users will not be identifiable.
Our website and emails may include hyperlinks to third party websites. We are not responsible for the privacy policies and practices of third parties.
You may delete and block all cookies, or just certain types of cookies, via your browser settings. However, if you choose to block or delete cookies, this may affect the functionality of the website.
3.2 Through online forms or emails
We may process information submitted through the Contact form on our website or from emails sent to us (“submitted data”). Submitted data may be processed in relation to delivery of a specific service and/or promoting news and information from third parties which we believe might be of interest to you.
3.3 Through service delivery
We may process personal data that is provided in the course of the use of our services ("service data"). The service data may include name, email address, postal address, service preferences, basic financial information and any correspondence. The source of the service data comes from clients/ potential clients during the negotiation and delivery of services.
We may also collate other forms of information which is in the public domain to assist with carrying out the services. Information may include published financial accounts, information on websites, information and reports on other websites and other forms of media and social media.
The service data may be processed for the purposes of providing our services, ensuring the security of our information and services, maintaining back-ups of our databases and files and for communicating with clients. We may generate information relating to clients whilst undertaking services, such as conducting interviews with service users and staff, and new documents or products.
We may administer online, paper form or telephone surveys on behalf of our clients using survey tools on our websites or through online survey providers. By providing responses to surveys respondents acknowledge that the information they provide will be processed in accordance with this policy.
4. Compliance and legal claims
In addition to the specific purposes for which we may collect and process personal data as set out in section 3 we may also process personal data where such processing is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person.
We will only use personal information in accordance with this Policy, or where we are required or authorised by law to disclose your information to others or, have your permission to do so.
We may process any of personal data identified in the other provisions of this policy where necessary for the establishment, exercise, or defence, of legal claims, whether in court proceedings or in an administrative, or out-of-court, procedure. The legal basis for this processing is our legitimate interests, namely the protection and assertion of our legal rights, your legal rights and the legal rights of others.
5. Other People’s Personal Data
Please be aware that we are not responsible for the data processing activities of others, such as our clients. We will take every reasonable endeavour to ensure suppliers will manage data in accordance with the law.
6. Passing data to third parties
We may pass your data to other third parties as part of our provision of services to that party but will seek specific consent from you in order to do this. We will not subscribe individuals to services, newsletters and updates other than those they have consented to.
It may be necessary to disclose personal data to Associates working on our behalf for the purposes of effectively carrying out services. Associates will be required to uphold this policy when working on our behalf.
We may also disclose your personal data where such disclosure is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person.
Users acknowledge that personal data submitted for publication through our websites or other services may be publicly available, via the internet, around the world. We cannot prevent the use (or misuse) of such personal data by others. Options to contribute personal data, and therefore engage with the activity, without being publicly identified will be made available where possible.
7. Sensitive data
From time to time, we may seek consent to process sensitive personal data in respect of certain specific and limited purposes. We will always do this before processing any sensitive personal data: racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership, data concerning health or sex life and sexual orientation, genetic and/or biometric data. Do not provide us with sensitive personal data unless it is specifically requested, and we have your consent.
8. Retaining and deleting personal data
We keep your personal data for as long as required to provide our services, and in accordance with legal, tax and accounting requirements. Where personal data is no longer required, we will ensure it is disposed of in a secure manner. Where required by law, we will notify users when this has happened.
9. Security of personal data
We will take appropriate technical and organisational precautions to secure your personal data and to prevent the loss, misuse, or alteration of your personal data. We will store all your personal data on secure servers, personal computers, and mobile devices, and in secure manual record-keeping systems.
10. Rights under data protection law
Users have the right to request copies of their personal data held by us. If they think any of that data is inaccurate, they may also ask us to correct it. They may also have a right, in certain circumstances, to require us to stop processing personal data. Also, they have the right to ask us to transfer personal data to someone they nominate for their own purposes. They may exercise any of their rights in relation to personal data by contacting us using the email or postal address below.
Nobody is obliged to provide any personal data to us. However, please note that this may mean we will have difficulty in providing the full range of services to you.
Remember, consent previously given may be withdrawn at any time. Also, users have the right to ask us to stop processing any personal data and to have it erased. Where personal data has been removed we reserve the right to maintain basic personal data such as your name, address and email address to ensure that personal data isn’t processed by us in the future.
11. Contacting us and Complaints