1.         Introduction

We operate this Privacy and Cookies Policy because we are committed to safeguarding the privacy of those using our website (www.progarm.com) and the confidentiality of any information that we collect about you.

We, ProGARM Ltd, are the data controller in respect of all personal data collected via our website.  This Privacy and Cookies Policy sets out how we will use any personal data that we may obtain from you.  Our website is not intended for children and we do not knowingly collect data relating to children.

Whenever you submit your information to us, whether it be by using our website, by email, over the telephone, in person or by any other means, we will collect and use of such information in accordance with the terms of this Privacy and Cookies Policy.  We are committed to ensuring that all personal data we hold is treated properly and in accordance with applicable data protection legislation (which means, for so long as it remains in force, the Data Protection Act 1998, from 25 May 2018 the General Data Protection Regulation unless or until it ceases to be directly applicable in the United Kingdom, and all other laws and regulations from time to time in force in the United Kingdom relating to the processing of personal data).

In accordance with data protection legislation, we are required to explain to you how we will treat any personal data which we collect from or about you.

You have the right to lodge a complaint with the Information Commissioner’s Office (“ICO”) if you have any concerns with regard to the way in which we process your personal data.  We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.

2.         What information do we collect and how do we use it?

You may give us information about you by corresponding with us by phone, e-mail or otherwise, by submitting an enquiry via our website, by purchasing goods from us, by opting in to receive our e-newsletter, or by submitting information for the purposes of being considered for a vacancy.  The information we may collect, use, store and transfer about you includes the following:

a)         name, username or similar identifier (such as social media handle), title and job title (“Identity Data”);

b)         work contact details, address, email address and telephone number(s) (“Contact Data”);

c)         bank account and payment card details (“Financial Data”);

d)         your preferences in receiving marketing from us and your communication preferences (“Marketing Data”).

We may also automatically collect technical data about you (such as internet protocol (IP) address, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access our website) (“Technical Data”) as you interact with our website.  We collect this Technical Data by using cookies and other similar technologies.  Information regarding the cookies used on our website is set out in section 8 below.

We have set out below a description of what personal data you may give us, the ways we use your personal data, and which of the legal bases we rely on to do so.

If we require your information for the purposes of performing a contract with you and you fail to provide this information, or if the information you provide is not accurate, we may not be able to provide our goods to you.

You warrant that any information you supply to us is accurate and up to date, that you will inform us if any such information requires updating, and that if you submit a third party’s details to us you have that third party’s permission to do so.

We will not sell any of your personal data to any third party.

3.         Third Parties

We may share personal data about you:

a)         with third parties who are directly involved in dealing with any request or enquiry made by you, including partners such as logistics companies in fulfilment of any orders placed by you;

b)         where such disclosure is required by law;

c)         with third parties who are providing us with professional advice;

d)         where the disclosure is in connection with any criminal investigation, legal proceedings or prospective legal proceedings where permitted by law;

e)         where the disclosure is in order to establish, exercise or defend our legal rights (including providing information to others for the purposes of fraud prevention and reducing credit risk);

f)          where we are required to enforce our Terms and Conditions and/or Terms of Use; or

g)         where we have stated or informed you otherwise (e.g. on our website).

We will not pass on your information to any third party for the purpose of marketing.

We may also disclose your personal data to third parties in the event that we sell or buy any business or assets (in which case we may disclose your personal data to the prospective seller or buyer of such business or assets) or if we or substantially all of our assets are acquired by a third party, in which case personal data held by us about our clients and subscribers will be one of the transferred assets.

We periodically appoint digital  marketing agents to conduct marketing activity on our behalf, such activity may result in the compliant processing of personal information. Our appointed data processors include:

Prospect Global Ltd (trading as Sopro) Reg. UK Co. 09648733. You can contact Sopro and view their privacy policy here: http://sopro.io.  Sopro are registered with the ICO Reg: ZA346877 their Data Protection Officer can be emailed at: dpo@sopro.io.

We use Leadoo’s tracking service to follow what users are doing on the site and combine this behavioural data with other data we can gather from e.g. chat interactions. Leadoo uses ETag tracking in order to hook together the same user’s behaviour over several sessions. Please check out Leadoo Marketing Technologies Ltd’s Privacy Policy (https://leadoo.com/privacy-policy/) for more information on what is tracked and what your rights are. Leadoo works as the Processor and we work as the Controller for the data in terms of GDPR. You can stop the tracking by emptying your browser’s cache after the visit. For more on how Leadoo works as a GDPR compliant processor, see https://leadoo.com/privacy-policy-processor

4. How do you stop marketing information being sent to you?

If you have given consent or are receiving marketing communications as a result of our legitimate interests, you can ask that such information is no longer sent to you by emailing us at info@progarmcurrent.wpengine.com or writing to ProGARM Limited, Unit 2, Dianthus Business Park, Common Lane, Newport, Brough, East Yorkshire, HU15 2FT or clicking on the appropriate link in the footer of any of our marketing emails.  It may take up to 14 working days to remove you from our marketing lists.

5. Security and International Transfers

We will take all reasonable steps to protect your personal data.  However, the Internet is global and no data transmitted via the Internet can be guaranteed by us to be completely secure during transmission.  We cannot guarantee the security of any data that you disclose online and we will not be responsible for any breach of security unless this is due to our negligence or wilful default.  It is possible that the information you provide to us will be temporarily transferred via a route outside the European Economic Area as it passes between you and us.

6. Your Rights

If you have consented to receive any marketing material from us, you have the right to withdraw your consent at any time.  Please refer to section 4 for further information.

You have a legal right to see a copy of the personal data that we keep about you, subject to certain exemptions.  Requests for such information should be made by email to info@progarmcurrent.wpengine.com or in writing to ProGARM Limited, Unit 2, Dianthus Business Park, Common Lane, Newport, Brough, East Yorkshire, HU15 2FT.

In some circumstances you may also have a right to:

a)         rectify or erase any personal data we hold about you;

b)         restrict our processing of your personal data;

c)         object to us processing your personal data;

d)         data portability in respect of your personal data.

In accordance with applicable data protection legislation, we follow security procedures when we process your personal data.  We may therefore request proof of your identity before disclosing certain information to you or acting on any requests pursuant to this section 6.

Please contact us at the above address if you have any reason to believe that information we hold about you is inaccurate.

7.  How long do we retain your personal data?

We only retain your personal data for as long as we need it and for the purpose for which is was collected.  Whilst taking in to consideration our legal obligations to retain information such as financial records for audit and tax purposes, we will regularly review the length of time we retain your personal data and consider the purpose or purposes for which we hold it.

If you data is no longer needed for such purposes we will update, archive or securely delete your personal data.  For further information on how long we retain your personal data please contact us using the contact details set out in section 6 above.

8.  Cookies

Our website uses “cookies” to ensure you receive the best possible visitor experience.  Cookies are small files which are sent by a web server to an individual’s computer which are then stored on that computer’s hard drive.  A cookie contains text, and is like an identification card which can only be translated by the server it originated from.

Cookies cannot tell us information such as your email address, which we can only collect where you tell us, for example if you submit an enquiry to us.

 

We also use cookies for Hotjar which tracks user experience on our website anonymously to help us improve the site, this involves tracking clicks, scrolls and recording user sessions. The only pieces of information that Hotjar records are while on our website and it’s only our web pages that it can track. For more information please visit – https://www.hotjar.com/legal/policies/privacy.

We use technologies, such as cookies, to customise content and advertising, to provide social media features and to analyse traffic to the site. We also share information about your use of our site with our trusted social media partners. For more information please visit – https://www.facebook.com/about/privacy/.

Most internet browsers allow you to prevent cookies being stored on your computer.  Alternatively, you may be able to configure your browser to accept all cookies or to notify you when a cookie is offered by our server.  You may also be able to delete all cookies currently stored on your web browser.

At ProGARM because of the type of cookies that we use and have specified above we ask everyone visiting the site to review and accept our cookie policy.

For further information about cookies and how they are used, please visit www.aboutcookies.org.

9. How will you know if we make any changes to this Privacy and Cookies Policy?

We may amend this Privacy and Cookies Policy from time to time.  You are bound by any changes we make to this Privacy and Cookies Policy with effect from the date of the change.  If we make any substantial changes to the way in which we use your personal data we will notify you by posting a notice on our website’s homepage.  You can view the current version of our Privacy and Cookies Policy at any time by clicking on the Privacy and Cookies Policy link on our website’s homepage and referring to the date of the policy.

10.   What about third party websites that you can access via our website?

Our website contains links to other websites which are outside our control and are not covered by this Privacy and Cookies Policy.  If you access other websites using the links provided, the operators of those websites may collect personal data from you which will be used in accordance with their respective privacy policies which you should read.  We are not liable for the practices of such third party website operators in respect of your personal data.

You acknowledge that any information that you post using our social media facilities will be viewable by anybody who visits those websites and that such information is also subject to the relevant provider’s Privacy and Cookies Policy.  You are advised to consult each such Privacy and Cookies Policy to see how they will use your data.

11. What is your attitude to Modern Slavery and Human Rights? 

ProGARM is committed to driving out acts of modern-day slavery and human trafficking within its business and from within its supply chains, including subcontractors, and partners.

The Company acknowledges responsibility to the Modern Slavery Act 2015 and will ensure transparency within the organisation and with suppliers of goods and services to the organisation. These as well as the suppliers of services make up the supply chain within ProGARM.

View our complete Modern Slavery and Human Rights Policy here.