Added Value Portal Ltd t/a PAGABO 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, www.pagabo.co.uk (“Our Site”), or any information, data supplied relating to projects, contracts or any commercial arrangements [in email, PDF, excel, hard or soft copy] (“Customer Data”) and as described in Parts 5, 6 and 7 below, we do not collect personal data about you unless you contact us. Any personal data we do collect will only be used as permitted by law.
1. Information About Us
Our Site is owned and operated by Added Value Portal Ltd t/a PAGABO, a limited company registered in England under company number 08787322
Registered address: 19 Bowlalley Lane, Hull, England, HU1 1XR.
Main trading address: 19 Bowlalley Lane, Hull, England, HU1 1XR.
Data Protection Officer: N/A As defined by the ICO regulations. We can confirm that GDPR is a standing point on every board meeting agenda, and the directors consider GDPR as part of the normal day to day running of the business.
2. What Does This Policy Cover?
3. 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.
4. What Are My Rights?
Under the GDPR, you have the following rights, which we will always work to uphold:
b) The right to access the personal data we hold about you. Part 10 will tell you how to do this.
c) 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 11 to find out more.
d) 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 11 to find out more. We store limited personal data about users that have/had access to our software solutions and services, and timescales for storing such data is governed by the contract between Added Value Portal Ltd t/a PAGABO and its customer. It is a requirement to store contract data for several years, to assist in defect management and historical records, and these timescales can be changed where the customer requests, and the contract is varied.
e) The right to restrict (i.e. prevent) the processing of your personal data.
f) The right to object to us using your personal data for a particular purpose or purposes.
g) 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.
h) 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 11.
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.
5. What Personal Data Do You Collect?
In order to enter into an agreement with PAGABO we will collect, store and use elements of your personal data. The processing of this personal data is a contractual requirement and is required by PAGABO in order to administer your account and to provide the products and services you have requested from us.
When you approach PAGABO, we will ask your consent to collect and process your personal data. Failure to provide this consent and/or personal data may mean we will be unable to execute the contract and will result in termination of our services.
When engaging PAGABO, you will usually need to disclose to us the following:
- First name
- Company name
- Address (street, street number, postal code, city and country/region)
- Email address
- Company Telephone and mobile number (optional)
We may also monitor, record, store and use any telephone, email or other electronic communications with you for training purposes so that we can check any instructions given to us and to improve the quality of our customer service.
Any personal data we collect from you will not be transferred outside the European Economic Area.
Any member of staff will provide additional personal data to allow for payroll to be processed and to ensure we are compliant with our HMRC and other requirements.
6. Website Cookies
The following data is collected and stored until its automated deletion:
- IP address of the accessing computer/device
- Date, time and duration of your visit
- Name and URL of the accessed pages
- Identification data of the browser and operating system used
- Website from which the data was accessed
- Name of your internet access provider
The nature and content of the information collected via cookies differs, as does the period for which this information is retained. In line with our data protection obligations, we will ensure that this retention period is not excessive, and that the data is only retained for as long as is necessary for the purpose for which it was collected.
The data listed above is only analysed for statistical purposes and for improving our internet presence, then it is deleted. We will not attempt to personally identify you from your IP address unless required to as a matter of law or regulation or in order to protect our, or our other customers’ rights.
Most browsers automatically accept cookies, but you can set your browser options so that you will not receive cookies and you can also delete any existing cookies from your browser.
7. How Do You Use My Personal Data?
If we do collect any personal data, it will be processed and stored securely, for no longer than is necessary in light of the reason(s) for which it was first collected. We will comply with our obligations and safeguard your rights under the GDPR at all times. For more details on security see Part 8, below.
As stated above, we do not generally collect any personal data. If you contact us and we obtain your personal details from your email, we may use them to respond to your email.
Any and all emails (which may contain your personal data), are retained as part of an audit trail to support contract and commercial agreements and variations, and helpdesk and issue resolutions for service and support.
You have the right to withdraw your consent to us using your personal data at any time, and to request that we delete it.
We will not share any of your data with any third parties for any purposes other than storage on an email server.
For any staff members, data may be shared with external agencies including payroll bureaus, government agencies and approved third parties. Where there is a requirement to share data at a personal request, this authorisation will be documented.
8. How and Where Do You Store My Data?
We will only store your personal data in the UK. This means that it will be fully protected under the GDPR.
Please contact us using the details below in Part 11 for further information about the particular data protection mechanism used by us when transferring your personal data to a third country.
Personal data security is essential to us, and to protect personal data, we take the following measures:
a) All internal business applications (Outlook, Excel, OneDrive etc.) are installed locally and where installed externally, are secured using standard login credentials and password.
b) All hosted platforms are only accessible by authorised members of staff using a minimum of login credentials and password, and where appropriate, two factor authentication.
c) We do not store any staff member personal data in hard copy, and any Customer Data may be worked on via hard copy which will be destroyed immediately after completion.
9. Do You Share My Personal Data?
We will not share any of your personal data with any third parties for any purposes, subject to the following exception, and the reasons detailed in part 8 above.
Here at PAGABO we take your privacy seriously and the information we hold about you is confidential. We will only disclose it outside PAGABO when:
- you have given us your consent to do so
- it is necessary for the performance of an agreement of which you will be made aware
- in order to obtain professional advice (e.g. legal advice)
- we or others need to investigate or prevent crime (e.g. to fraud prevention agencies)
- the law permits or requires it
- regulatory or governmental body requests or requires it, even without your consent, or
- there is a duty to the public to reveal the information
In order to administer your contract, we may need to share some of your personal information with other data controllers. This processing is necessary for the purposes of delivering specific services to you. You agree that we can share or use your personal data with any of our appointed agents or suppliers to allow us to provide you services and products you have asked us to provide you under this agreement.
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.
10. 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 11.
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 10 working days and, in any case, not more than 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.
11. 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 Subject Access Request Officer):
Email address: firstname.lastname@example.org.
Telephone number: 01482 975883
Postal Address: 19 Bowlalley Lane, Hull, United Kingdom, HU1 1XR.
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.
Should you wish to discuss a complaint, please feel free to contact us using the details provided above. All complaints will be treated in a confidential manner.
Should you feel unsatisfied with our handling of your data, or about any complaint that you have made to us about our handling of your data, you are entitled to escalate your complaint to a supervisory authority within the European Union. For the United Kingdom, this is the Information Commissioner’s Office (ICO), who is also our lead supervisory authority. Its contact information can be found at https://ico.org.uk/global/contact-us/.