Last updated: 24/01/2022 (Version 1.1)

Introduction

For simplicity, throughout this notice ‘we’ and ‘us’ means Primo Interactive Limited Ltd t/a “Primo Postcodes”. Our Registered Office is: Regus House, Herons Way, Chester Business Park, Chester, Cheshire CH4 9QR and we are registered in England & Wales (#5739392).

We take your privacy seriously. This privacy policy describes how and why we obtain, store and process data which can identify you. We may update this policy from time to time and shall indicate above when changes have been made.

1. Definitions

Our data protection declaration is based on the terms of the General Data Protection Regulation (EU) 2016/679 (“GDPR”). Throughout this data protection declaration the following terms are used, inter alia:

a) Personal data

“Personal data” is defined as any information relating to an identifiable natural person who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an on-line identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.

b) Visitors

A “visitor” is defined as any identifiable natural person, whose personal data is processed by the Data Controller responsible for the processing.

c) Data processing

“Data processing” comprises any operation, or set of operations, which is performed on personal data, or on sets of personal data, whether or not by automated means, such as collection, recording, organising, structuring, storing, adapting, altering, retrieving, consulting, using, disclosing by transmission, disseminating or otherwise making available, aligning, combining, restricting, erasing or destroying.

d) Restriction of processing

“Restriction of processing” is defined as the marking of stored personal data with the aim of limiting their processing in the future.

e) Profiling

“Profiling” is any form of automated processing of personal data to evaluate certain personal aspects relating to a natural person, in particular to analyse or predict aspects concerning that natural person's performance at work, economic situation, health, personal preferences, interests, reliability, behaviour, location or movements.

f) Pseudonymisation

“Pseudonymisation” is the processing of personal data such that the it can no longer be attributed to a specific visitor without the use of additional information, provided that such additional information is kept separately and is subject to technical and organisational measures to ensure that the personal data are not attributed to an identifiable natural person.

g) Data Controller

The “Data Controller” is the natural or legal person, public authority, agency or other entity which, alone or jointly with others, determines the purposes and means of the processing of personal data.

h) Processor

The “Processor” is a natural or legal person, public authority, agency or other body which processes personal data on behalf of the Data Controller.

i) Recipient

The “Recipient” is a natural or legal person, public authority, agency or other entity, to which the personal data are disclosed, whether a third party or not. However, public authorities which may receive personal data in the framework of a particular inquiry in accordance with Union or Member State law shall not be regarded as recipients; the processing of those data by those public authorities shall be in compliance with the applicable data protection rules according to the purposes of the processing.

j) Third party

A “Third party” is a natural or legal person, public authority, agency or entity other than the visitor, data controller, processor and persons who, under the direct authority of the data controller or processor, are authorised to process personal data.

k) Consent

The “Consent” of the visitor is any freely given, specific, informed and unambiguous indication of the visitor's wishes by which they, by a statement or by a clear affirmative action, signifies agreement to the processing of personal data relating to themselves.

2. Name and Address of the Data Controller

The Data Controller for the purposes of the GDPR, other data protection laws applicable in Member states of the European Union and other provisions related to data protection is: Primo Interactive Limited Ltd, Regus House, Herons Way, Chester Business Park, Cheshire CH4 9QR

3. Collection of general data and information

Our websites collect a series of general data and information when a visitor or automated system requests them. This general data and information are stored in log files. Collected information may include:

a) the browser types and versions used,
b) the operating system used by the accessing system,
c) the url from which an accessing system reaches our websites (the “referrer”),
d) the date and time of access,
e) an Internet protocol address (“IP address”),
f) the Internet service provider (“ISP”) of the accessing system, and
g) any other similar data and information that may be used in the event of attacks or attempted attacks against our information technology systems or those of our suppliers.

When using these general data and information, we do not draw any conclusions about the visitor. Rather, this information is needed to:

a) deliver the content of our websites correctly,
b) optimise the content of our websites as well as its advertisement,
c) ensure the long-term viability of our information technology systems and websites technology, and
d) provide law enforcement authorities with information necessary if and when lawfully requested.

Therefore, we analyse anonymously collected data and information statistically in order to provide an optimal level of protection for the personal data we process. The anonymous data of the server log files are stored separately from all personal data provided by a visitor.

4. Registration on our websites

The visitor has the possibility to register on the websites of the Data Controller with the provision of personal data. Which personal data are transmitted to the Data Controller is determined by the respective input mask used for the registration. The personal data entered by the visitor are collected and stored exclusively for internal use by the Data Controller, and for his own purposes. The Data Controller may request transfer to one or more processors (e.g. a parcel service or payment processor) that also uses personal data for an internal purpose which is attributable to the Data Controller.

By registering on the websites of the Data Controller, the IP address assigned by the ISP and used by the visitor, date and time of the registration are also stored. The storage of this data takes place against the background that this is the only way to prevent the misuse of our services, and, if necessary, to make it possible to investigate committed offences. Insofar, the storage of this data is necessary to secure the Data Controller. This data is not passed on to third parties unless there is a statutory obligation to pass on the data, or if the transfer serves the aim of criminal prosecution.

The registration of the visitor, with the voluntary provision of personal data, is intended to enable the Data Controller to offer the visitor contents or services that may only be offered to registered users due to the nature of the matter in question. Registered persons are free to change the personal data specified during the registration at any time, or to have them completely deleted from the data records of the Data Controller.

The Data Controller shall, at any time, provide information upon request to each visitor as to what personal data are stored about the visitor. In addition, the Data Controller shall correct or erase personal data at the request or indication of the visitor, insofar as there are no statutory storage obligations. The entirety of the Data Controller’s employees are available to the visitor in this respect as contact persons.

5. Contact possibility via the websites

Our websites contain information and/or functionality, enabling communication with us. If a visitor contacts the Data Controller using this information and/or functionality, the personal data transmitted by the visitor are automatically stored. Such personal data transmitted on a voluntary basis by a visitor to the Data Controller are stored for the purpose of processing or contacting the visitor.

6. Routine erasure and blocking of personal data

The Data Controller shall process and store the personal data of the visitor only for the period necessary to achieve the purpose of storage, or as far as this is granted by the European legislator or other legislators in laws or regulations to which the Data Controller is subject to.

If the storage purpose is not applicable, or if a storage period prescribed by the European legislator or another competent legislator expires, the personal data are routinely blocked or erased in accordance with legal requirements.

7. Rights of the visitor

Each visitor shall have the right granted by the European legislator to obtain the following from the Data Controller:

a) Right of confirmation

Confirmation as to whether or not personal data concerning themselves are being processed. If a visitor wishes to avail themselves of this right of confirmation, they may, at any time, contact us.

b) Right of access

Free information about their personal data stored at any time and a copy of this information. Furthermore, the European directives and regulations grant the visitor access to the following information:

a) the purposes of the processing;
b) the categories of personal data concerned;
c) the recipients or categories of recipients to whom the personal data have been or will be disclosed, in particular recipients in third countries or international organisations;
d) where possible, the envisaged period for which the personal data will be stored, or, if not possible, the criteria used to determine that period;
e) the existence of the right to request from the Data Controller rectification or erasure of personal data, or restriction of processing of personal data concerning the visitor, or to object to such processing;
f) the existence of the right to lodge a complaint with a supervisory authority;
g) where the personal data are not collected from the visitor, any available information as to their source;
h) the existence of automated decision-making, including profiling, referred to in Article 22(1) and (4) of the GDPR and, at least in those cases, meaningful information about the logic involved, as well as the significance and envisaged consequences of such processing for the visitor.

Furthermore, the visitor shall have a right to obtain information as to whether personal data are transferred to a third country or to an international organisation. Where this is the case, the visitor shall have the right to be informed of the appropriate safeguards relating to the transfer.

If a visitor wishes to avail himself of this right of access, they may, at any time, contact us.

c) Right to rectification

Each visitor shall have the right granted by the European legislator to obtain from the Data Controller without undue delay the rectification of inaccurate personal data concerning themselves. Taking into account the purposes of the processing, the visitor shall have the right to have incomplete personal data completed, including by means of providing a supplementary statement.

If a visitor wishes to exercise this right to rectification, they may, at any time, contact us.

d) Right to erasure (Right to be forgotten)

Each visitor shall have the right granted by the European legislator to obtain from the Data Controller the erasure of personal data concerning themselves without undue delay, and the Data Controller shall have the obligation to erase personal data without undue delay where one of the following grounds applies, as long as the processing is not necessary:

a) The personal data is no longer necessary in relation to the purposes for which they were collected or otherwise processed.
b) The visitor withdraws consent to which the processing is based according to point (a) of Article 6(1) of the GDPR, or point (a) of Article 9(2) of the GDPR, and where there is no other legal ground for the processing.
c) The visitor objects to the processing pursuant to Article 21(1) of the GDPR and there are no overriding legitimate grounds for the processing, or the visitor objects to the processing pursuant to Article 21(2) of the GDPR.
d) The personal data have been unlawfully processed.
e) The personal data must be erased for compliance with a legal obligation in Union or Member State law to which the Data Controller is subject.

If one of the aforementioned reasons applies, and a visitor wishes to request the erasure of personal data stored us, they may, at any time, contact us. Upon receipt, we will promptly ensure that the erasure request is complied with immediately.

Where the Data Controller has made personal data public and is obliged pursuant to Article 17(1) to erase the personal data, the Data Controller, taking account of available technology and the cost of implementation, shall take reasonable steps, including technical measures, to inform other Data Controllers processing the personal data that the visitor has requested erasure by such Data Controllers of any links to, or copy or replication of, those personal data, as far as processing is not required. We will arrange the necessary measures in individual cases.

e) Right of restriction of processing

Each visitor shall have the right granted by the European legislator to obtain from the Data Controller restriction of processing where one of the following applies:

a) The accuracy of the personal data is contested by the visitor, for a period enabling the Data Controller to verify the accuracy of the personal data.
b) The processing is unlawful and the visitor opposes the erasure of the personal data and requests instead the restriction of their use instead.
c) The Data Controller no longer needs the personal data for the purposes of the processing, but they are required by the visitor for the establishment, exercise or defence of legal claims.
d) The visitor has objected to processing pursuant to Article 21(1) of the GDPR pending the verification whether the legitimate grounds of the Data Controller override those of the visitor.

If one of the aforementioned conditions is met, and a visitor wishes to request the restriction of the processing of personal data stored by us, they may at any time contact us. Upon request, we will arrange the restriction of the processing.

f) Right to data portability

Each visitor shall have the right granted by the European legislator, to receive the personal data concerning themselves, which was provided to a Data Controller, in a structured, commonly used and machine-readable format. they shall have the right to transmit those data to another Data Controller without hindrance from the Data Controller to which the personal data have been provided, as long as the processing is based on consent pursuant to point (a) of Article 6(1) of the GDPR or point (a) of Article 9(2) of the GDPR, or on a contract pursuant to point (b) of Article 6(1) of the GDPR, and the processing is carried out by automated means, as long as the processing is not necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in the Data Controller.

Furthermore, in exercising their right to data portability pursuant to Article 20(1) of the GDPR, the visitor shall have the right to have personal data transmitted directly from one Data Controller to another, where technically feasible and when doing so does not adversely affect the rights and freedoms of others.

In order to assert the right to data portability, the visitor may at any time contact us.

g) Right to object

Each visitor shall have the right granted by the European legislator to object, on grounds relating to their particular situation, at any time, to processing of personal data concerning themselves, which is based on point (e) or (f) of Article 6(1) of the GDPR. This also applies to profiling based on these provisions.

We shall no longer process the personal data in the event of the objection, unless we can demonstrate compelling legitimate grounds for the processing which override the interests, rights and freedoms of the visitor, or for the establishment, exercise or defence of legal claims.

If we process personal data for direct marketing purposes, the visitor shall have the right to object at any time to processing of personal data concerning themselves for such purposes. This applies to profiling to the extent that it is related to such direct marketing. If the visitor objects to the processing of their data for marketing purposes, we will no longer process the personal data for these purposes.

In addition, the visitor has the right, on grounds relating to their particular situation, to object to processing of personal data concerning themselves by us for scientific or historical research purposes, or for statistical purposes pursuant to Article 89(1) of the GDPR, unless the processing is necessary for the performance of a task carried out for reasons of public interest.

In order to exercise the right to object, the visitor may contact us. In addition, the visitor is free in the context of the use of information society services, and notwithstanding Directive 2002/58/EC, to use their right to object by automated means using technical specifications.

h) Automated individual decision-making, including profiling

Each visitor shall have the right granted by the European legislator not to be subject to a decision based solely on automated processing, including profiling, which produces legal effects concerning themselves, or similarly significantly affects themselves, as long as the decision:

a) is not is necessary for entering into, or the performance of, a contract between the visitor and a Data Controller, or
b) is not authorised by Union or Member State law to which the Data Controller is subject and which also lays down suitable measures to safeguard the visitor's rights and freedoms and legitimate interests, or
c) is not based on the visitor's explicit consent.

If the decision:

a) is necessary for entering into, or the performance of, a contract between the visitor and a Data Controller, or
b) it is based on the visitor's explicit consent,

We will implement suitable measures to safeguard the visitor's rights and freedoms and legitimate interests, at least the right to obtain human intervention on the part of the Data Controller, to express their point of view and contest the decision.

If the visitor wishes to exercise the rights concerning automated individual decision-making, they may, at any time, contact us.

i) Right to withdraw data protection consent

Each visitor shall have the right granted by the European legislator to withdraw their consent to processing of their personal data at any time. If the visitor wishes to exercise the right to withdraw the consent, they may, at any time, contact us.

8. Legal basis for the processing

Art. 6(1) lit. a GDPR serves as the legal basis for processing operations for which we obtain consent for a specific processing purpose. If the processing of personal data is necessary for the performance of a contract to which the visitor is party, as is the case, for example, when processing operations are necessary for the supply of goods or to provide any other service, the processing is based on Article 6(1) lit. b GDPR. The same applies to such processing operations which are necessary for carrying out pre-contractual measures, for example in the case of inquiries concerning our products or services. If we are subject to a legal obligation by which processing of personal data is required, such as for the fulfilment of tax obligations, the processing is based on Art. 6(1) lit. c GDPR. In rare cases, the processing of personal data may be necessary to protect the vital interests of the visitor or of another natural person. Then the processing would be based on Art. 6(1) lit. d GDPR. Finally, processing operations could be based on Article 6(1) lit. f GDPR. This legal basis is used for processing operations which are not covered by any of the above mentioned legal grounds, if processing is necessary for the purposes of the legitimate interests pursued by us or by a third party, except where such interests are overridden by the interests or fundamental rights and freedoms of the visitor which require protection of personal data. Such processing operations are particularly permissible because they have been specifically mentioned by the European legislator. He considered that a legitimate interest could be assumed if the visitor is a client of the Data Controller (Recital 47 Sentence 2 GDPR).

9. The legitimate interests pursued by the Data Controller or by a third party

Where the processing of personal data is based on Article 6(1) lit. f GDPR our legitimate interest is to carry out our business in favour of the well-being of all our employees and/shareholders and/or our fiduciary duties as directors.

10. Period for which the personal data will be stored

The criteria used to determine the period of storage of personal data is the respective statutory retention period. After expiration of that period, the corresponding data is routinely deleted, as long as it is no longer necessary for the fulfilment of the contract or the initiation of a contract.

11. Provision of personal data as statutory or contractual requirement; Requirement necessary to enter into a contract; Obligation of the visitor to provide the personal data; possible consequences of failure to provide such data

We clarify that the provision of personal data is partly required by law (e.g. tax regulations) or can also result from contractual provisions (e.g. information on the contractual partner). Sometimes it may be necessary to conclude a contract that the visitor provides us with personal data, which must subsequently be processed by us. The visitor is, for example, obliged to provide us with personal data when we sign a contract with them. The non-provision of the personal data would have the consequence that the contract with the visitor could not be concluded. Before personal data is provided by the visitor, the visitor must contact us. We will clarify to the visitor whether the provision of the personal data is required by law or contract or is necessary for the conclusion of the contract, whether there is an obligation to provide the personal data and the consequences of non-provision of the personal data.

12. Complaints

We seek to resolve directly all complaints about how we handle your personal information. Please contact us with any complaints. We endeavour to respond within 3 working days. You also have the right to lodge a complaint with the Information Commissioner’s Office at: Information Commissioner’s Office, Wycliffe House, Water Lane, Wilmslow, Cheshire SK9 5AF.