This Privacy Policy sets out the basis on which Proterms Limited will process personal information provided to us, this information is also referred to as ‘personal data’. Proterms Limited is referred to throughout as “we”, “us”, “our” and “ours”.

We take our obligations in respect of the privacy of personal data very seriously and we will only process personal information as detailed in this policy, unless we inform you otherwise. In order to ensure that the personal data we hold is accurate and up to date, we request that you inform us of any relevant changes to the personal information we hold about you.

We provide online platform and content services and we are also an employer. Our primary business activity is provision of online contract creation, issue and information storage. For the purposes of this Privacy Policy, our commercial activities and services are referred to as ‘Online  Services’, and our actual or potential customers are referred to as ‘Customers’.

The person responsible for data protection matters within our organisation is Adriana Joseph and can be contacted at

Proterms Limited

Unit 6-7 Dubarry House

Hove Park Villas

Hove

BN3 6AF

0845 646 0775

This email address is being protected from spambots. You need JavaScript enabled to view it.

We may collect your personal data in the course of our dealings and this may include the following:

  • Your contact information, which may include your full name, job role, contact telephone number and email
  • Your statements and opinions about other personnel or our services g. a reference, or feedback
  • Information relating to our relationship with you or the party for whom you work including records of any meetings or discussions
  • Your marketing preferences
  • Information about your relationship with a customer or ours
  • Information about your viewing of a document stored on our online portal

We may obtain your personal data from the following sources (please note that this list is not exhaustive):

  • You, including where you have provided us with your contact details or other information for the purposes of using our Services
  • Staff or other representatives of the organisation you represent
  • Marketing databases
  • Social media
  • The public domain
  • Conversations, with you or others, on the telephone or video conferencing (which may be recorded) or in meetings
  • Notes following a conversation, with you or others, or meetings you attend
  • Third party referrals
  • Data used by a customer of ours for issue of a document stored online

How we will use your personal data:

We will process your personal data in the context of your dealings with a customer of ours or your dealings with us. Processing may include:

  • Collecting and storing your personal data, whether in manual or electronic files
  • Using the data to communicate with you
  • Sending information to third parties with whom we have or intend to enter into arrangements which are related to our Services
  • Actions necessary to further any obligation on us pursuant to a contract between ourselves and a third party you work for or a customer of ours
  • Collating market or sector specific information and providing the same to our customers
  • Providing information to regulatory authorities or statutory bodies and our legal or other professional advisers including insurers
  • Retaining records of our dealings with you and the organisation whom you represent
  • Establishing quality, training and compliance with our obligations and best practice

Why we process your personal data:

1. Compliance with legal obligations (regulatory and statutory obligations)

We must comply with a number of statutory and regulatory obligations relating to business generally, for example tax, bribery and fraud/crime prevention legislation, and co-operating with regulatory authorities such as HMRC. In order to comply with these obligations we may be required to process personal data.

2. Our legitimate interests (carrying on the commercial activity relating to the provision of our Services):

In providing our Services, we will carry out some processing of personal data  which is necessary for the purpose of our legitimate interests, which include:

  • Using your personal data:
    • to contact you regarding our Services
    • to collate market information or trends including providing analysis to potential or actual Customers
    • as otherwise necessary to provide our Services and/or to meet our obligations towards either the party whom you represent, or other Customers or suppliers
    • to personalise your experience and our offering, whether via our website or otherwise
  • Retaining records of our dealings and transactions and where applicable, use such records for the purposes of:
    • establishing compliance with contractual obligations with our customers or suppliers
    • recording your use of our online platform
    • addressing any query or dispute that may arise including establishing, exercising or defending any legal claims
    • protecting our reputation
    • protecting our Intellectual Property, and other rights
    • maintaining a back up of our system, solely for the purpose of being able to restore the system to a particular point in the event of a system failure or security breach
    • evaluating quality and compliance including compliance with this Privacy Policy
    • determining staff training and system requirements

For our commercial viability and to pursue these legitimate interests, we may continue to process your personal information for as long as we consider reasonably appropriate for these purposes.

3. Consent

We may process your personal data on the basis that you have consented to us doing so for a specific purpose, for example, if you have provided your contact details in order that we may use these to provide you with details of our services you may have consented to our processing of the data for that purpose. In other cases you may have provided your written or verbal consent to the use of your data for a specific reason, or in connection with or to provide information about our online services.

You may withdraw your consent to our processing of your personal data for a particular purpose at any stage. However, please note that we may continue to retain, or otherwise use your personal information thereafter where we have a legitimate interest or a legal or contractual obligation to do so. Our processing in that respect will be limited to what is necessary in furtherance of those interests or obligations.  Withdrawal of consent will not have any effect on the lawfulness of any processing based on consent before its withdrawal.

 What if we obtain your personal data from a third party?

As part of our business activity we may obtain your data from third party sources, some information being publicly available but others being from third parties with whom we have business dealings including our customers. From time to time we may also receive personal data about you from, colleagues and former employers, or from persons for whom you have provided services or been otherwise engaged.

Where information from third party sources is of no use to us we shall discard it, however we may maintain a limited record in order to avoid the duplication of process. Where we consider that information may be of use to us in pursuance of the provision of our Services, any processing will be in accordance with this Privacy Policy. You do have the right to object to processing, please see Section  ‘Your rights’ below.

Sensitive Personal Data (SPD)

Sensitive personal data is information which is intensely personal to you and is usually irrelevant to our dealings with you in respect of our Services. Examples of SPD include information which reveals your political, religious or philosophical beliefs, sexual orientation, race or ethnic origin, or information relating to your health.

Regardless of the basis for your dealings with us, we request that you do not provide us with any sensitive personal data unless absolutely necessary. However, to the extent that you do provide us with any sensitive personal data, such as data which you choose to share with us in conversation, we shall only use that personal data for the purposes of our relationship with you or for the provision of our Services. This will be for one or more of the following reasons:

  • You have explicitly consented to the processing
  • Where processing is necessary for the purpose of obligations or rights under employment, social security or social protection law
  • To maintain records of our dealings to address any later dispute, including but not limited to the establishment, exercise or defence of any legal claims

Who we share personal data with:

We shall not share your personal data unless we are entitled to do so. The categories of persons with whom we may share your personal information include:

  • Third parties necessary for the provision of our Services
  • Any regulatory authority or statutory body pursuant to a request for information or any legal obligation which applies to us
  • Parties who process data on our behalf, which may include
    • outsourced payroll providers
    • IT support
    • storage service providers including cloud providers
  • Legal and professional advisers
  • Insurers
  • Organisations linked to us who provide related or connected services, including but not limited to Lawspeed Limited.

Transfer of data to other jurisdictions

In the course of the provision of our Services we may transfer data to countries or international organisations outside of the EEA. This may, for example, be to third parties who provide support services to us.  Where information is to be so transferred, it may be to a country in respect of which there is an adequacy decision from the EU Commission. However, if this is not the case, it is our policy to take steps to identify risks and in so far as is reasonably practicable, ensure that appropriate safeguards are in place. Details relating to specific countries or organisations are available on request.

If you do not wish to provide us with necessary data

There may be circumstances where we require you to provide data which is necessary in order for us to meet statutory or contractual obligations, or perform our Services. If you do not wish to provide us with information we request then please notify us.

Group companies & transfer

In the event  of a sale, merger, liquidation, receivership or the transfer of all or part of our assets to a third party, we may need to transfer your information to a third party. Any transfer will be subject to the agreement of the third party to this Privacy Policy and any processing being only in accordance with this Privacy Policy.

Data Security and Confidentiality

It is our policy to ensure, in so far as is reasonably practicable, that our systems and records are secure and not accessible to unauthorised third parties in line with contemporary practice.

Cookies

We use cookies on this web site. Cookies are small amounts of information that we transfer to your computer’s hard drive through your web browser. They tell us when you have visited our site and where you have been. They do not identify you personally, just the presence of your browser. Cookies make it easier for you to log on and use the site during future visits. They also enable us to provide you with a more personalised service. Should you wish to do so, your browser’s help section should be able to warn you before accepting cookies and how to filter or disable them, although in the latter case, you may not be able to use certain features on our site.

Retaining your data

Except where we need to retain your data to protect our Intellectual Property rights, in most circumstances your data will not be retained for more than 6 years from the last point at which we provided any Services to you or the company that you represent or otherwise engaged with you and it is our policy to only store your personal  data for as long as is reasonably necessary for us to comply with our legal obligations and for our legitimate business interests.  Where we need to protect our Intellectual Property, we may retain data for longer than a 6 year period. This applies, for example, where the data relates to or is contained within any records including emails relating to the licensing or use of any documentation or products from us, We may also retain data for a longer period where we have a legal or contractual obligation to do so, or where we form the view that there is otherwise a continued basis to do so, for example where we are subject to a legal obligation which applies for a longer period.

If however you believe that we should delete your personal data at an earlier date, please inform us in writing of your reasons.  Please see Section ‘Your Rights’ below.

Changes to this Privacy Policy

This Privacy Policy is regularly reviewed and may be updated from time to time to reflect changes in our business, or legal or commercial practice.  Where an update is relevant to our processing of your data, we shall notify you of the same.

Your rights

We take the protection of your personal data very seriously and it is important that you know your rights within that context, which include rights to:

  • Request a copy of the personal data that we hold
  • Object to our processing of your data where that processing is based upon legitimate interest and there are no compelling grounds for the continued processing of that data
  • Request that we restrict processing of your data in certain circumstances
  • Request that data is erased where the continued use of that data cannot be justified
  • Object to any decision, which significantly affects you, being taken solely by a computer or via another automated process
  • Withdraw your consent to our processing of your personal data for a particular purpose at any stage. However, please note that we may continue to retain, or otherwise use your personal information thereafter where we have a legitimate interest or a legal or contractual obligation to do so. Our processing in that respect will be limited to what is necessary in furtherance of those interests or obligations
  • Request that inaccurate or incomplete data is rectified
  • Request that data provided directly by you and processed by automated means is transferred to you or another controller; this right only being applicable where our processing of your data is based either on your consent or in performance of a contract
  • Make a complaint to the Information Commissioner’s Office Request that direct marketing by us to you is stopped

Please note that should you exercise your right to request that we erase data or cease any processing activity, we may retain a record of this request and the action taken in order to both evidence our compliance, and to take steps to minimise the prospect of any data being processed in the future should it be received again from a third party source.

If you have any questions concerning your rights or should you wish to exercise any of these rights please contact Adriana Joseph.

Complaints

If you are dissatisfied about any aspect of the way in which your data is processed you may, in the first instance refer the matter to Adriana Joseph. This does not affect your right to make a complaint to the Information Commissioner’s Office.