PTI Digital UK Ltd
Website Privacy & Cookies Policies

We at PTI are committed to protecting your privacy. This Privacy Policy governs our data collection, processing and usage practices. It also describes your choices regarding use, access and correction of your personal information. If you do not agree with the data practices described in this Privacy Policy, you should not use the website.

We periodically update this Privacy Policy. We will post any privacy policy changes on this page and, if the changes are significant, we will provide a more prominent notice by sending you an email notification.

While we will notify you of any material changes to this Privacy Policy prior to the changes becoming effective, we encourage you to review this Privacy Policy periodically. We will also keep prior versions of this Privacy Policy in an archive for your review.

The General Data Protection Regulation (GDPR) seeks to protect and enhance the rights of data subjects. These rights cover the safeguarding of personal data, protection against the unlawful processing of personal data and the unrestricted movement of personal data within the EU. It should be noted that GDPR does not apply to information already in the public domain.

If you have any questions about this Privacy Policy or our treatment of the information you provide us, please write to us by email at daniel.brown@ptidigitalgroup.com

PTI is pleased to provide the following Privacy Notice:

When You Visit our Websites
You are free to explore the website without providing any Personal Information about yourself.

“Personal Information” 
This refers to any information that you voluntarily submit to us and that identifies you personally, including contact information, such as your name, e-mail address, company name, address, phone number, and other information about yourself or your business. Personal Information can also include information about any transactions, both free and paid, that you enter into on the Websites, and information about you that is available on the internet, such as from Facebook, LinkedIn, Twitter and Google, or publicly available information that we acquire from service providers.

Log Files 
When you use our services our view content provided by us, we automatically collect information about your computer hardware and software. This information can include your IP address, browser type, domain names, internet service provider (ISP), the files viewed on our site (e.g., HTML pages, graphics, etc.), operating system, clickstream data, access times and referring website addresses.

Information we collect from third parties 
From time to time, we may receive Personal Information about you from third party sources including partners with which we offer co-branded services or engage in joint marketing activities, and publicly available sources such as social media websites.

Information About Children 
The Websites are not intended for or targeted at children under 16, and we do not knowingly or intentionally collect information about children under 16 If you believe that we have collected information about a child under 16, please contact us at daniel.brown@ptidigitalgroup.com, so that we may delete the information.

Compliance with Our Privacy Policy
We use the information we collect only in compliance with this Privacy Policy. We Never Sell Personal Information. We will never sell your Personal Information to any third party.

Use of Personal Information 
In addition to the uses identified elsewhere in this Privacy Policy, we may use your Personal Information to:

• improve your browsing experience by personalizing the Websites
• send information or content to you which we think may be of interest to you by post, email, or other means and send you marketing communications relating to our business;
• promote use of our services to you and share promotional and information content with you in accordance with your communication preferences;
• provide other companies with statistical information about our users — but this information will not be used to identify any individual user;
• send information to you regarding changes to our Customer Terms of Service, Privacy Policy including the Cookie Policy or other legal agreements
• meet legal requirements.

We may, from time to time, contact you on behalf of external business partners about a particular offering that may be of interest to you. In those cases, we do not transfer your Personal Information to the third party.

Customer Testimonials and Comments 
We post customer testimonials and comments on our Websites, which may contain Personal Information. We obtain each customer’s consent via email prior to posting the customer’s name and testimonial.

Security of your Personal Information 
We use a variety of security technologies and procedures to help protect your Personal Information from unauthorized access, use or disclosure. We secure the Personal Information you provide on computer servers in a controlled, secure environment, protected from unauthorized access, use or disclosure. All Personal Information is protected using appropriate physical, technical and organizational measures.

Social Media Features 
Our Websites include Social Media Features, such as the Facebook Like button and Widgets, such as the Share This button or interactive mini-programs that run on our sites. These features may collect your IP address, which page you are visiting on our sites, and may set a cookie to enable the feature to function properly. Social Media Features and Widgets are either hosted by a third party or hosted directly on our Websites. This Privacy Policy does not apply to these features.  Your interactions with these features are governed by the privacy policy and other policies of the companies providing them.

External Websites 
Our Websites provide links to other websites. We do not control, and are not responsible for, the content or practices of these other websites. Our provision of such links does not constitute our endorsement of these other websites, their content, their owners, or their practices. This Privacy Policy does not apply to these other websites, which are subject to any privacy and other policies they may have.

Public Forums 
We offer publicly accessible message boards, blogs, and community forums. Please keep in mind that if you directly disclose any information through our public message boards, blogs, or forums, this information may be collected and used by others. We will correct or delete any information you have posted on the Websites if you so request, as described in “Opting Out and Unsubscribing” below.

Retention of Personal Information 
How long we keep information we collect about you depends on the type of information. as described in further detail below.  After such time, we will either delete or anonymize your information or, if this is not possible, then we will securely store your information and isolate it from any further use until deletion is possible.

We retain Personal Information that you provide to us where we have an ongoing legitimate business need to do so.

When we have no ongoing legitimate business need to process your Personal Information, we securely delete the information or anonymise it or, if this is not possible, then we will securely store your Personal Information and isolate it from any further processing until deletion is possible. We will delete this information from the servers at an earlier date if you so request, as described in “To Unsubscribe from Our Communications” below.

If you have elected to receive marketing communications from us, we retain information about your marketing preferences for a reasonable period of time from the date you last expressed interest in our content, products, or services, such as when you last opened an email from us.  We retain information derived from cookies and other tracking technologies for a reasonable period of time from the date such information was created.

Cookies and Similar Technologies

Cookies 
PTI use cookies or similar technologies (such as web beacons) to analyse trends, administer the website, track users’ movements around the website, and to gather demographic information about our user base as a whole.

Cookie Policy 
This website, and / or social media sites (“Sites”) uses cookies to improve the Sites performance and enhance the user experience. This policy explains how this is done. By continuing to browse the Sites, you are agreeing to our use of cookies.

What Are Cookies? 
Cookies are small files which a website may put on your computer or mobile device when you first visit a site or page. The cookie will help the website to recognise your device the next time you visit. Cookies serve many functions. For example, they can help us to remember your username and preferences, analyse how well our website is performing, or even allow us to recommend content we believe will be most relevant to you.

Cookies contain personal information. Most cookies do not collect information that identifies you and will instead collect more general information such as how users arrive at and use our websites, or a user’s general location.

Category 1: Strictly Necessary Cookies 
These are required for the operation of the Sites. For example, to remember the previous actions so you can navigate back to previous pages.

These cookies are essential in order to move around the Sites and use their features, such as accessing areas of the Sites. Without these cookies, services you have asked for, like shopping baskets, cannot be provided

Category 2: Analytical or Performance Cookies 
These cookies collect anonymous information about how visitors use the Sites. These cookies collect information about how you use the Sites, for instance which pages you go to most often.

These cookies do not collect information that identifies you. All information these cookies collect is aggregated and therefore anonymous. It is only used to improve how the Sites work and understand what interests our users.

Category 3: Functionality Cookies 
These are used to recognise users when they return to the Sites. They remember user choices and enable the personalisation of content.

These cookies allow the Sites to remember choices you make (such as your user name, language or the region you are in) and provide enhanced, more personal features. They may also be used to provide services such as remembering whether you have already responded to a questionnaire. The information these cookies collect may be anonymised and they cannot track your browsing activity on other websites.

Category 4: Targeting Cookies 
These cookies collect information about your browsing habits in order to make advertising relevant to you and your interests.

These cookies are used to deliver adverts more relevant to you and your interests. They are also used to limit the number of times you see an advertisement as well as help measure the effectiveness of the advertising campaign. They are usually placed by advertising networks with our permission. They remember which websites or Sites you have visited and this information is shared with other organisations such as advertisers. Quite often targeting or advertising cookies will be linked to site functionality provided by the other organisation.

Advertising 
We partner with a third party ad network to either display advertising on our Web site or to manage our advertising on other sites. Our ad network partner uses cookies and Web beacons to collect information about your activities on this and other Web sites to provide you targeted advertising based upon your interests.  If you wish to not have this information used for the purpose of serving you targeted ads, you may opt-out by clicking here: http://preferences.truste.com/ (or if located in the European Union, by clicking here: http://www.youronlinechoices.eu/). Please note this does not opt you out of being served advertising.  You will continue to receive generic ads.

Reviewing, Correcting and Removing Your Personal Information 
You have the following data protection rights:

• You can request access, correction, updates or deletion of your personal information.
• You can object to processing of your personal information, ask us to restrict processing of your personal information or request portability of your personal information.
• If we have collected and process your personal information with your consent, then you can withdraw your consent at any time. Withdrawing your consent will not affect the lawfulness of any processing we conducted prior to your withdrawal, nor will it affect processing of your personal information conducted in reliance on lawful processing grounds other than consent.
• You have the right to complain to a data protection authority about our collection and use of your personal information.
• To exercise any of these rights, please contact us at daniel.brown@ptidigitalgroup.com. We will respond to your request to change, correct, or delete your information within a reasonable timeframe and notify you of the action we have taken.

Your Rights as a Data Subject

At any point whilst PTI is in possession of or processing your personal data, all data subjects have the following rights:

• Right of access – you have the right to request a copy of the information that we hold about you
• Right of rectification – you have a right to correct data that we hold about you that is inaccurate or incomplete
• Right to be forgotten – in certain circumstances you can ask for the data we hold about you to be erased from our records
• Right to restriction of processing – where certain conditions apply you have a right to restrict the processing
• Right of portability – you have the right to have the data we hold about you transferred to another organisation
• Right to object – you have the right to object to certain types of processing such as direct marketing
• Right to object to automated processing, including profiling – you also have the right not to be subject to the legal effects of automated processing or profiling

In the event that PTI refuses your request under rights of access, we will provide you with a reason as to why, which you have the right to legally challenge.

PTI, at your request, can confirm what information it holds about you and how it is processed.
You can request the following information:

• Identity and the contact details of the person or organisation that has determined how and why to process your data
• Contact details of the Data Privacy Officer, where applicable
• The purpose of the processing as well as the legal basis for processing
• If the processing is based on the legitimate interests of PTI or a third party such as one of its clients, information about those interests
• The categories of personal data collected, stored and processed
• Recipient(s) or categories of recipients that the data is/will be disclosed to
• How long the data will be stored
• Details of your rights to correct, erase, restrict or object to such processing
• Information about your right to withdraw consent at any time
• How to lodge a complaint with the supervisory authority (Data Protection Regulator)
• Whether the provision of personal data is a statutory or contractual requirement, or a requirement necessary to enter into a contract, as well as whether you are obliged to provide the personal data and the possible consequences of failing to provide such data
• The source of personal data if it wasn’t collected directly from you
• Any details and information of automated decision making, such as profiling, and any meaningful information about the logic involved, as well as the significance and expected consequences of such processing
• To access what personal data is held, identification will be required

PTI will accept the following forms of ID when information on your personal data is requested:

• A copy of your national ID card
• Driving license, passport
• Birth certificate and a utility bill not older than three months

A minimum of one piece of photographic ID listed above and a supporting document is required.

If PTI is dissatisfied with the quality, further information may be sought before personal data can be released.

All requests should be made to daniel.brown@ptidigitalgroup.com

Complaints
In the event that you wish to make a compliant about how your personal data is being processed by PTI or its partners, you have the right to complain to the PTI Data Privacy Officer in the first instance, or the PTI as an escalation point. If you do not get a response within 30 days you can complain to the Data Protection Regulator.

To Unsubscribe From Our Communications 
You may unsubscribe from our marketing communications by clicking on the “unsubscribe” link located on the bottom of our e-mails, updating your communication preferences, or by sending us email us at daniel.brown@ptidigitalgroup.com

Contact 
Data Protection Officer (DPO)
Daniel Brown
daniel.brown@ptidigitalgroup.com

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