Privacy Policy

1. Background

Pilcro understands that your privacy is important to you and that you care about how your personal data is used. We respect and value the privacy of everyone who visits this website, https://www.pilcro.com (“Our Site”), and will only collect and use personal data in ways that are described here, and in a way that is consistent with our obligations and your rights under the law.

Please read this Privacy Policy carefully and ensure that you understand it. Your acceptance of this Privacy Policy is deemed to occur upon your first use of Our Site and you will be required to read and accept this Privacy Policy when signing into Pilcro with your Google account. If you do not accept and agree with this Privacy Policy, you must stop using Our Site immediately.

1. Definitions and Intepretation

In this Policy the following terms shall have the following meanings:

“Account” means an account required to access and/or use certain areas and features of Our Site;

“Cookie” means a small text file placed on your computer or device by Our Site when you visit certain parts of Our Site and/or when you use certain features of Our Site. Details of the Cookies used by Our Site are set out in our separate Cookie Policy.

2. Information About Us

Our Site is owned and operated by Pilcro - Take the Pen Limited, a private limited company registered in England & Wales with company number 10748525.

Our registered office is at Unit 2.01, 62 Shoreditch High Street, Shoreditch High Street, London, England, E1 6JJ.

Our main trading address is the same as our registered office.

Our VAT number is 287 0989 44.

We do not have a Data Protection Officer but our Director responsible is Xanthe Kueppers who can be contacted by email at xanthe@pilcro.com or by post at our registered office.

Our postal address is the same as our registered office.

3. What Does This Policy Cover?

This Privacy Policy applies only to your use of Our Site. Our Site may contain links to other websites. Please note that we have no control over how your data is collected, stored, or used by other websites and we advise you to check the privacy policies of any such websites before providing any data to them.

4. What is Personal Data?

Personal data is defined by the General Data Protection Regulation (EU Regulation 2016/679) (the “GDPR”) as ‘any information relating to an identifiable person who can be directly or indirectly identified in particular by reference to an identifier’.

Personal data is, in simpler terms, any information about you that enables you to be identified. Personal data covers obvious information such as your name and contact details, but it also covers less obvious information such as identification numbers, electronic location data, and other online identifiers.

5. What Are My Rights?

Under the GDPR, you have the following rights, which we will always work to uphold:

The right to be informed about our collection and use of your personal data. This Privacy Policy should tell you everything you need to know, but you can always contact us to find out more or to ask any questions using the details in Part 15.

  • The right to access the personal data we hold about you. Part 13 will tell you how to do this.

  • The right to have your personal data rectified if any of your personal data held by us is inaccurate or incomplete. Please contact us using the details in Part 15 to find out more.

  • The right to be forgotten, i.e. the right to ask us to delete or otherwise dispose of any of your personal data that we have. Please contact us using the details in Part 15 to find out more.

  • The right to restrict (i.e. prevent) the processing of your personal data.

  • The right to object to us using your personal data for a particular purpose or purposes.

  • The right to data portability. This means that, if you have provided personal data to us directly, we are using it with your consent or for the performance of a contract, and that data is processed using automated means, you can ask us for a copy of that personal data to re-use with another service or business in many cases.

  • Rights relating to automated decision-making and profiling. We do not use your personal data in this way.

For more information about our use of your personal data or exercising your rights as outlined above, please contact us using the details provided in Part 15.

Further information about your rights can also be obtained from the Information Commissioner’s Office or your local Citizens Advice Bureau.

If you have any cause for complaint about our use of your personal data, you have the right to lodge a complaint with the Information Commissioner’s Office.

6. What Data Do We Collect?

Depending upon your use of Our Site, we may collect some or all of the following personal and non-personal data (please also see Part 14 on our use of Cookies and similar technologies and our Cookie Policy):

  • Name

  • Email address

  • Telephone number

  • Business name

  • Job title

  • Profession

  • Information about your preferences and interests

  • Web browser type and version

  • Operating system

7. How Do You Use My Personal Data?

Under the GDPR, we must always have a lawful basis for using personal data. This may be because the data is necessary for our performance of a contract with you, because you have consented to our use of your personal data, or because it is in our legitimate business interests to use it. Your personal data may be used for one of the following purposes:

  • Providing and managing your Account;

  • Providing and managing your access to Our Site;

  • Personalising and tailoring your experience on Our Site;

  • Supplying our services to you. Your personal details are required in order for us to enter into a contract with you.

  • Personalising and tailoring our services for you.

  • Communicating with you. This may include responding to emails or calls from you.

  • Supplying you with information by email that you have opted-in to (you may unsubscribe or opt-out at any time by clicking unsubscribe in any email that we send to you).

  • Analysing your use of Our Site and gathering feedback to enable us to continually improve Our Site and your user experience.

  • Collecting reviews, ratings and feedback from you in regard to your use of our services. This review collection process is undertaken by Collect Reviews, who acts as a Data Processor on behalf of Pilcro for the purpose of collecting and publishing this review information. This may involve the transfer of personal data, specifically your name and contact email address, to Collect Reviews for this sole purpose.

With your permission and/or where permitted by law, we may also use your personal data for marketing purposes, which may include contacting you by email with information, news, and offers on our services. You will not be sent any unlawful marketing or spam. We will always work to fully protect your rights and comply with our obligations under the GDPR and the Privacy and Electronic Communications (EC Directive) Regulations 2003, and you will always have the opportunity to opt-out.

Third Parties whose content appears on Our Site may use third-party Cookies, as detailed below in Part 14. Please refer to Part 14 for more information on controlling cookies. Please note that we do not control the activities of such third parties, nor the data that they collect and use themselves, and we advise you to check the privacy policies of any such third parties.

8. How Long Will You Keep My Personal Data?

We will not keep your personal data for any longer than is necessary in light of the reason(s) for which it was first collected. Your personal data will therefore be kept for the following periods (or, where there is no fixed period, the following factors will be used to determine how long it is kept):

Name: for as long as you are an active user, and for a period of 2 years after your account becomes inactive.

Email Address: for as long as you are an active user, and for a period of 2 years after your account becomes inactive. We will also keep a record of any email addresses that have unsubscribed until the relevant mailing list is no longer in use.

Phone number: for as long as you are an active user, and for a period of 2 years after your account becomes inactive.

Information about your preferences and interests: for as long as you are an active user, and for a period of 3 year after your account becomes inactive.

Web browser type and version: for as long as you are an active user, and for a period of 3 years after your account becomes inactive.

Operating system: for as long as you are an active user, and for a period of 3 years after your account becomes inactive.

9. How and Where Do You Store or Transfer My Personal Data?

We may store or transfer some or all of your personal data in countries that are not part of the European Economic Area (the “EEA” consists of all EU member states, plus Norway, Iceland, and Liechtenstein). These are known as “third countries” and may not have data protection laws that are as strong as those in the UK and/or the EEA. This means that we will take additional steps in order to ensure that your personal data is treated just as safely and securely as it would be within the UK and under the GDPR as follows.

We share your data with external third parties, as detailed below in Part 10, that are based outside of the EEA. The following safeguards are applied to such transfers:

  • Where we transfer your data to a third party based in the US, this may be protected if they are part of the EU-US Privacy Shield. This requires that third party to provide data protection to standards similar to those in Europe. More information is available from the European Commission.

  • If possible, we use specific contracts with external third parties that are approved by the European Commission for the transfer of personal data to third countries. These contracts ensure the same levels of personal data protection that would apply under the GDPR. More information is available from the European Commission.

Please contact us using the details below in Part 15 for further information about the particular data protection mechanism used by us when transferring your personal data to a third country.

The security of your personal data is essential to us, and to protect your data, we take a number of important measures, including the following:

  • We check that all our our suppliers are GDPR compliant.

  • We conduct 6 monthly audits of all the data that we have stored to ensure that any data we no longer need to retain can be deleted.

10. Do You Share My Personal Data?

We may sometimes contract with the following third parties to supply certain products or services. These may include payment processing, delivery, and marketing. In some cases, those third parties may require access to some or all of your personal data that we hold.

Hubspot: We use Hubspot as our CRM system. Where we are building a client relationship with you, we will enter your name and email address into Hubspot to record our conversations with you. Hubspot is located in the US.

Chargebee: Chargebee provides our payment processing and subscription management. Chargebee is located in the US.

Google: We use Google drive to store all of our documents, some of which contain your name and email address, and, if we have received it from you, your telephone number. Google also provides our email services. Google is located in the US.

Lemlist: Lemlist provides our email marketing services. Lemlist are located in France.

Slack: We use Slack to share files and to receive information regarding sign-ins so we will store your email address in Slack. Slack is located in the US.

Collect Reviews: We use Collect Reviews for collecting reviews, ratings and feedback from you in regard to your use of our services. This may involve the transfer of personal data, specifically your name and contact email address, to Collect Reviews for this sole purpose.

If any of your personal data is required by a third party, as described above, we will take steps to ensure that your personal data is handled safely, securely, and in accordance with your rights, our obligations, and the third party’s obligations under the law, as described above in Part 9.

If any personal data is transferred outside of the EEA, we will take suitable steps in order to ensure that your personal data is treated just as safely and securely as it would be within the UK and under the GDPR, as explained above in Part 9.

In some limited circumstances, we may be legally required to share certain personal data, which might include yours, if we are involved in legal proceedings or complying with legal obligations, a court order, or the instructions of a government authority.

11. How Can I Control My Personal Data?

In addition to your rights under the GDPR, set out in Part 5, when you submit personal data via Our Site, you may be given options to restrict our use of your personal data. In particular, we aim to give you strong controls on our use of your data for direct marketing purposes (including the ability to opt-out of receiving emails from us which you may do by unsubscribing using the links provided in our emails and, at the point of providing your details).

You may also wish to sign up to one or more of the preference services operating in the UK: The Telephone Preference Service (“the TPS”), the Corporate Telephone Preference Service (“the CTPS”), and the Mailing Preference Service (“the MPS”). These may help to prevent you receiving unsolicited marketing. Please note, however, that these services will not prevent you from receiving marketing communications that you have consented to receiving.

12. Can I Withhold Information?

You may access certain areas of Our Site without providing any personal data at all. However, to use all features and functions available on Our Site you may be required to submit or allow for the collection of certain data.

13. How Can I Access My Personal Data?

If you want to know what personal data we have about you, you can ask us for details of that personal data and for a copy of it (where any such personal data is held). This is known as a “subject access request”.

All subject access requests should be made in writing and sent to the email or postal addresses shown in Part 15.

There is not normally any charge for a subject access request. If your request is ‘manifestly unfounded or excessive’ (for example, if you make repetitive requests) a fee may be charged to cover our administrative costs in responding.

We will respond to your subject access request within one month of receiving it. Normally, we aim to provide a complete response, including a copy of your personal data within that time. In some cases, however, particularly if your request is more complex, more time may be required up to a maximum of three months from the date we receive your request. You will be kept fully informed of our progress.

14.          How Do You Use Cookies?

Our Site may place and access certain first-party Cookies on your computer or device. First-party Cookies are those placed directly by us and are used only by us. We use Cookies to facilitate and improve your experience of Our Site and to provide and improve our services. By using Our Site you may also receive certain third-party Cookies on your computer or device. Third-party Cookies are those placed by websites, services, and/or parties other than us. Third-party Cookies are used on Our Site for advertising services to serve up tailored advertising to you on Our Site, or by third parties providing analytics services to Us. In addition, Our Site uses analytics services provided by Google Analytics, which also use Cookies. Website analytics refers to a set of tools used to collect and analyse usage statistics, enabling us to better understand how people use Our Site. For more details, please refer to our Cookie Policy.

15. How Do I Contact You?

To contact us about anything to do with your personal data and data protection, including to make a subject access request, please use the following details (for the attention of Xanthe Kueppers):

Email address: xanthe@pilcro.com

Postal Address: Unit 2.01, The Tea Building, 62 Shoreditch High Street, London, E16JJ.

16.          Changes to this Privacy Policy

We may change this Privacy Notice from time to time. This may be necessary, for example, if the law changes, or if we change our business in a way that affects personal data protection.

Any changes will be immediately posted on Our Site and you will be deemed to have accepted the terms of the Privacy Policy on your first use of Our Site following the alterations. We recommend that you check this page regularly to keep up-to-date.

© copyright Pilcro - take the pen limited 2019

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