Pimloc Privacy Policy

INTRODUCTION

This Privacy Policy aims to provide you with information about how Pimloc Limited collects and processes your personal data through (i) your use of this website (the Site) and (ii) (where you have created an End User Account) your use of the SecureRedact software application hosted at https://app.secureredact.co.uk (App) and any of the services accessible via the Site or the App (Services).

The Site, the App and the Services are operated by Pimloc Limited, a private company incorporated and registered in England and Wales under company number 10067264 (referred to as Pimloc, we, us or our in this policy). Our registered office is located at 6 Oxford Industrial Park, Yarnton, Oxfordshire, England, OX5 1QU and our main trading address is at New Wing, Somerset House, The Strand, London, WC2R 1LA.

This Privacy Policy sets out the basis on which any personal data we collect from you, or that you provide to us, will be processed by us. The App is not intended for children and we do not knowingly collect data relating to children. Please read the following carefully to understand our practices regarding your personal data and how we will treat it.

Pimloc is committed to protecting your privacy. At Pimloc, we appreciate that you do not want the personal information we may hold about you distributed indiscriminately and here we explain how we collect information, what we do with it and what controls you have.

We have appointed a data privacy manager who is responsible for overseeing questions in relation to this privacy Policy. If you have any questions about this privacy notice, including any requests to exercise your legal rights, please contact the data privacy manager using the details set out at the end of this policy.

CHANGES TO THIS PRIVACY POLICY AND YOUR DUTY TO INFORM US OF CHANGES

We keep our privacy policy under regular review.

This version was last updated in July 2022. It may change and if it does, these changes will be posted on this page and, where appropriate, notified to you when you next log in to your End User Account. The updated policy may be displayed on-screen and you may be required to read and accept the changes to continue your use of the App or the Services.

It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during our relationship with you.

THE DATA WE COLLECT ABOUT YOU

We may collect, use, store and transfer different kinds of personal data about you. We explain the categories of personal data that we may collect from you below.

Identity Data: first name, last name, username or similar identifier, title.
Contact Data: billing address, delivery address, email address and telephone numbers.
Financial Data: bank account and payment card details.
Transaction Data: includes details about payments to and from you and details of in-App purchases.
System Data or Device Data: includes the type of device you use, a unique device identifier, your operating system, the type of browser you use, time zone setting.
Content Data: includes information stored in your End User Account, including login information, videos or other digital content.
Profile Data: includes your username and password, in-App purchase history, your preferences, feedback and survey responses.
Usage Data: includes details of your use of the App or your visits to the Site including, but not limited to, traffic data and other communication data, whether this is required for our own billing purposes or otherwise and the resources that you access.
Marketing and Communications Data: includes your preferences in receiving marketing from us and our third parties and your communication preferences.

AGGREGATED DATA

We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data could be derived from your personal data but is not considered personal data in law as this data will not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific App feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy policy.

We do not collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health, and genetic and biometric data). Nor do we collect any information about criminal convictions and offences.

HOW IS YOUR PERSONAL DATA COLLECTED?

We will collect and process the following data about you:

Information you give us. This is information (including Identity, Contact, Financial, and Marketing and Communications Data) you consent to giving us about you by filling in forms on the App Site, or by corresponding with us (for example, by email or chat). It includes information you provide when you register to use the App, subscribe to any of our Services, search for a Service, make an in-App purchase, upload any Video or other digital content to the App, enter a competition, promotion or survey and when you report a problem with the App, our Services, or any of our sites. If you contact us, we will keep a record of that correspondence.
Information we collect about you and your system or device. Each time you visit one of our sites or use our App we will automatically collect personal data including System, Device, Content and Usage Data. We collect this data using cookies and other similar technologies. Please see our cookie policy (https://www.pimloc.com/cookie_policy) for further details.
Information we receive from other sources including third parties and publicly available sources. We will receive personal data about you from various third parties and public sources covering: System and Device Data from (i) analytics providers such as Google based outside the EU; (ii) advertising networks that may be based inside or outside the EU; and (iii) search information providers that may be based inside or outside the EU. Contact, Financial and Transaction Data from providers of technical, payment and delivery services who may be based inside or outside the EU; Identity and Contact Data from data brokers or aggregators who may be based inside or outside the EU; and Identity and Contact Data from publicly available sources such as Companies House and the electoral register based inside the EU.

COOKIES

We use cookies and/or other tracking technologies to distinguish you from other users of the App, the App Site or the Services sites and to remember your preferences. This helps us to provide you with a good experience when you use the App or browse any of our sites and also allows us to improve the App and our sites. For detailed information on the cookies we use, the purposes for which we use them and how you can exercise your choices regarding our use of your cookies, see our cookie policy.

HOW WE USE YOUR PERSONAL DATA

We will only use your personal data when the law allows us to do so (i.e. where we have a Lawful Basis for doing so). Most commonly we will use your personal data in the following circumstances:

Where you have consented before the processing. For these purposes, consent means processing your personal data where you have signified your agreement by a statement or clear opt-in to processing for a specific purpose. Consent will only be valid if it is a freely given, specific, informed and unambiguous indication of what you want. You can withdraw your consent at any time by contacting us.

Where we need to perform a contract we are about to enter or have entered with you. For these purposes, performance of a contract means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.
Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests. For these purposes, our legitimate interests means the interest of our business in conducting and managing our business to enable us to give you the best service/product and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us
Where we need to process your personal data in order to comply with a legal or regulatory obligation that we are subject to.

DIRECT MARKETING

We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising.

Individuals will receive marketing communications from us if you have requested information from us or purchased goods or services from us, agreed to receive marketing material through the App, or if you provided us with your details when you entered a competition or registered for a promotion, or (for business contacts) where we have obtained your data from a data broker or aggregator and, in each case, you have not opted out of receiving that marketing.

Opting Out. You can ask us to stop sending you marketing messages at any time by following the opt-out links on any marketing message sent to you or by contacting us at any time.

PURPOSES FOR WHICH WE WILL USE YOUR PERSONAL DATA

	
		Purpose/Activity
		Type of data
        		Lawful basis for processing
	
		To register you as a new End User and create your End User Account
		Identity, Contact, Financial, Device
		Your consent
	
		To process in-App purchases and deliver Services including managing payments and collecting money owed to us
		Identity, Contact, Financial, Transaction, Device, Marketing and Communications, Location
		Your consent. Performance of a contract with you. Necessary for our legitimate interests (to recover debts due to us).
	
		To manage our relationship with you including notifying you of changes to the App or any Services
		Identity, Contact, Financial, Profile, Marketing and Communications
		Your consent. Performance of a contract with you. Necessary for our legitimate interests (to keep records updated and to analyse how customers use our products/ Services). Necessary to comply with legal obligations (to inform you of any changes to our terms and conditions)

		To enable you to communicate with us, participate in a prize draw, competition or complete a survey
		Identity, Contact, Device, Profile, Marketing and Communications
		Your consent. Performance of a contract with you. Necessary for our legitimate interests (to analyse how customers use our products/Services and to develop them and grow our business)

		To administer and protect our business and this App including troubleshooting, data analysis and system testing
		Identity, Contact, Device
		Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security)
	
		To deliver content and advertisements to you. To make recommendations to you about goods or services which may interest you. To measure and analyse the effectiveness of the advertising we serve you. To monitor trends so we can improve the App
		Identity, Contact, Job title, Company, Device, Content, Profile, Usage, Marketing and Communications, Location
		Consent and/or for our legitimate interests (to develop our products/Services and grow our business)

		To improve the way our systems work and to improve our detection algorithms.
		Identity, Content, Device, Location
		Your consent by opting-in

DISCLOSURES OF YOUR PERSONAL DATA

When you consent to providing us with your personal data, we may also ask you for your consent to share your personal data with our internal third parties (being other companies in the Pimloc Group acting as joint controllers or processors) who provide IT and system administration services and undertake leadership reporting for any of the purposes set out in the table above.

In the event that Pimloc undergoes a reorganisation or is sold to a third party, any personal information Pimloc holds about you may be transferred to that reorganised entity or third party. However none of your personal information will be transferred to a third party prior to a sale or reorganisation completing.

Pimloc may disclose personal information to the appropriate authorities, if required to do so by law or if it believes that such action is necessary to prevent fraud or cyber-crime or to protect and defend the rights, property or personal safety of Pimloc, any of its affiliates, the Site or its visitors.

WHERE IS YOUR INFORMATION STORED?

Generally, information which you submit via the Site or the App is sent to and stored on secure server located in the European Economic Area. This is necessary in order to process your information.

Information submitted by you may be transferred by us to third parties in the circumstances mentioned in this privacy policy, which may be situated outside the European Economic Area. In those circumstances we will not transfer your personal data unless we are satisfied that adequate mechanisms are in place to comply with data protection and privacy laws.

DATA SECURITY

Pimloc places great importance on the security of all personally identifiable information associated with our users. We have security measures in place to attempt to protect against the loss, misuse and alteration of personal information under our control.

All information you provide to us is stored on our secure servers. Any payment transactions carried out by us or our chosen third-party provider of payment processing services will be encrypted using Secured Sockets Layer technology (or equivalent technology). Where we have given you (or where you have chosen) a password that enables you to access certain parts of our sites, you are responsible for keeping this password confidential. We ask you not to share a password with anyone.

Our security and privacy policies are periodically reviewed and enhanced as necessary and only authorised personnel have access to user information. While we cannot ensure or guarantee that loss, misuse or alteration of information will not occur, we use all reasonable efforts to prevent this.

You should bear in mind that transmission of information over the internet is never entirely secure. We cannot guarantee the security of information you transmit to the Site or our Apps and any such transmission is at your own risk.

It is advisable to close your browser when you have finished your user session, and lock your mobile device when not used, to help ensure others do not access your personal information.

DATA RETENTION

By law we have to keep basic information about our customers (including Contact, Identity, Financial and Transaction Data) for six years after they cease being customers for tax purposes.

In some circumstances you can ask us to delete your data: see below for further information.

In some circumstances we will anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes, in which case we may use this information indefinitely without further notice to you.

In the event that you do not use the App for a period of 3 months then we will treat the account as expired and your personal data may be deleted.

Processed Videos will be retained in your End User Account for a period of 60 days. We reserve the right to delete such Processed Videos without further notice to you following the expiry of this period.

EXTERNAL LINKS

The Site and/or the App may, from time to time, contain links to external sites. Pimloc is not responsible for the privacy policies or the content of such sites. Please check these policies before you submit any personal data to these websites or use these services.

YOUR LEGAL RIGHTS

Under certain circumstances you have the following rights under data protection laws in relation to your personal data.

Request access to your personal data (commonly known as a ‘data subject access request’). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios: text: (a) if you want us to establish the data’s accuracy; text: (b) where our use of the data is unlawful but you do not want us to erase it; text: (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or text: (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.

INFORMATION COMMISSIONERS OFFICE

You also have a right to report any breaches of your data protection rights to the Information Commissioners Office. Information Commissioner’s Office, Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF, Helpline number: 0303 123 1113, ICO website: https://www.ico.org.uk.

We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance using the details below.

CONTACT DETAILS

Please email any questions, concerns or comments you have about this privacy policy or any requests concerning your personal data to our data privacy manager at info@pimloc.com.