Protel Associates Limited (“Protel”, “we”, “us” or “our”) is a company incorporated in England and Wales with company number 03499257. Our registered office is Carleton House, 266-268 Stratford Road, Shirley, Solihull B90 3AD.
This policy sets out the basis on which any personal data we collect from individuals, or that we obtain from other sources, will be processed. This includes personal data we use in connection with:
• the provision of our services and reports; and
• services made available within our website at www.myprotel.co.uk (“MyProtel”) unless expressly stated to the contrary; and
• use of our website at www.protelprojects.com
For the purpose of data protection laws, the data controller is Protel Associates Limited of Carleton House, 266-268 Stratford Road, Shirley, Solihull B90 3AD. We are registered as a data controller with the Information Commissioner’s Office under number ZA202984.
1. BASIS FOR PROCESSING PERSONAL DATA
1.1. Paragraphs 1.2. to 1.6. below explain how and why we process an individual’s personal data, as well as the legal basis on which we carry out this processing.
1.2. To provide industry reports:
1.2.1. We provide a subscription service whereby we provide our industry supplier customers with reports that deliver insight into capital expenditure activity across various process industry sectors. The reports notify our customers of relevant capital expenditure projects on which they may wish to bid and/or supply. The reports contain names and contact details for potential decision makers involved in a project. This is personal data obtained from publically available sources. Our use of personal data in these circumstances is limited to sharing personal data with our customers who are the recipients of our reports.
1.2.2. The legal basis on which we process personal data in these circumstances is the legitimate interest of businesses having readily available and reliable information about capital expenditure projects in respect of which they may wish to provide goods and/or services.
1.2.3. Once a Protel customer is in receipt of our report which contains personal data, it shall be the responsibility of the customer to ensure that it processes that same personal data in compliance with applicable privacy and data protection laws. This is made clear by us in the terms and conditions for the services.
1.3. To make our website better:
1.3.1. We may also process personal data in order to provide a more tailored experience, including using personal data to make sure our website is displayed in the most effective way for the device users are using. This processing means that our services will be more tailored to users.
1.3.2. We also use various third party cookies to help us improve our website (excluding MyProtel) but we will not share personal data with the third party analytics and search engine providers that assist us in the improvement and optimisation of our website.
1.3.3. We will also process personal data for the purposes of making our website more secure, and to administer our website and for internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes.
1.3.4. The legal basis on which we process personal data in these circumstances is our legitimate interest to provide our customers with the best information services we can, and to ensure that our website is kept secure.
1.3.5. The use of any non-essential cookies is subject to individual consent. Individuals can also prevent us from using their personal data in this way by using the ‘do not track’ functionality in their internet browser. If individuals enable such ‘do not track’ functionality, our website may be less tailored to their needs and preferences.
1.4. For marketing purposes:
1.4.1. Where individuals have opted in to receive marketing communications from us, we will process their personal data to provide them with marketing communications in line with the preferences they have provided.
1.4.2. The legal basis on which we process personal data for marketing purposes is consent. Individuals are not under any obligation to provide us with their personal data for marketing purposes, and they can withdraw their consent to personal data being processed in this way at any time by contacting us at email@example.com or, where relevant, by following the unsubscribe link in any marketing communication they receive from us. If individuals do choose to withdraw consent, this will not mean that our processing of personal data before they withdrew consent was unlawful.
1.5. If our business is sold:
1.5.1. We will transfer individual personal data to a third party:
184.108.40.206. in the event that we sell or buy any business or assets, in which case we will disclose personal data to the prospective seller or buyer of such business or assets (at all times in accordance with all applicable data protection laws); or
220.127.116.11. if Protel or substantially all of its assets are acquired by a third party, in which case personal data held by Protel about its customers will be one of the assets transferred to the purchaser,
18.104.22.168. in each case, the legal basis on which we process data in these circumstances is our legitimate interest to ensure our business can be continued by a purchaser. If individuals object to our use of personal data in this way, the relevant seller or buyer of our business may not be able to provide services.
1.6. In certain circumstances we may also need to share personal data if we are under a duty to disclose or share personal data in order to comply with any legal obligation.
2. CATEGORIES OF INFORMATION WE COLLECT FROM INDIVIDUALS
2.1. We will collect and process the following personal data:
2.1.1. Information individuals give us: This is information about individuals that is supplied when filling in forms on our website, using our MyProtel services or by corresponding with us by phone, e-mail or otherwise. It includes information provided when registering to use our services, participate in social media functions on our website, and when problems are reported with our website or services. The information may include names, addresses, email addresses and phone numbers.
2.1.2. Information we collect: With regard to visits to our website (excluding MyProtel) we will automatically collect the following information:
22.214.171.124. technical information, including the Internet Protocol (IP) address used to connect computers to the internet, login information, browser type and version, time zone setting, browser plug-in types and versions, screen resolution, operating system and platform; and
126.96.36.199. information about visits, including the full Uniform Resource Locators (URL), clickstream to, through and from our website (including date and time), page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs) and methods used to browse away from the page.
2.1.3. Information we receive from other sources: We are also working closely with third parties (including, for example, business partners, sub-contractors, advertising networks, analytics providers, hosting providers and search information providers) from whom we may also receive information about individuals in connection with our service.
2.2. We do not process any special categories of personal data, meaning personal data revealing:
2.2.1. racial or ethnic origin;
2.2.2. political opinions; religious or philosophical beliefs;
2.2.3. trade union membership;
2.2.4. genetic or biometric data that uniquely identifies individuals; or
2.2.5. data concerning an individual’s health, sex life or sexual orientation.
2.3. We do not process data relating to criminal convictions unless legally obliged to do so.
3.2. A cookie is a small file of letters and numbers that we store on an individual’s browser or the hard drive of their computer. We only use (and store) non-essential cookies on an individual’s computer’s browser or hard drive if the individual provides their consent.
|_ga||Used to distinguish users.||2 years||Full explanation of Google Analytics cookie usage available here.|
|_gid||Used to distinguish users.||24 hours|
|_gat||Used to throttle request rate.||1 minute|
|AMP_TOKEN||Contains a token that can be used to retrieve a Client ID from AMP Client ID service. Other possible values indicate opt-out, inflight request or an error retrieving a Client ID from AMP Client ID service.||30 seconds to 1 year|
|_gac_ < property-id >||Contains campaign related information for the user. If you have linked your Google Analytics and AdWords accounts, AdWords website conversion tags will read this cookie unless you opt-out.||90 days|
3.4. Individuals can block cookies by activating the setting on their browser that allows individuals to refuse the setting of all or some cookies. However, if individuals use their browser settings to block all cookies (including essential cookies) they may not be able to access all or parts of our website.
3.5. Except for essential cookies, all cookies will expire as outlined under the expiration column in the table included in paragraph 3.2.
4. USES MADE OF THE INFORMATION
4.1. We will combine the information individuals provide to us with information we collect about them. We will use this information and the combined information for the purposes set out above (depending on the types of information we receive).
5. WHERE WE STORE PERSONAL DATA
5.1. The data that we collect from individuals will be stored in (and will not be transferred out of) the European Economic Area.
5.2. All information individuals provide to us is stored on secure servers. Where we have given individuals (or where individuals have chosen) a password which enables individuals to access certain parts of our website, the individuals are responsible for keeping this password confidential. Individuals must not share their password with anyone.
6. PERIOD OF STORAGE
6.1. Where we have included individuals’ personal data in our reports, these details will be deleted from electronic copies accessible to our customers no later than one (1) year after the report was last updated or where the individual concerned requests erasure.
6.2. Where we process individuals’ data in connection with the purchase of services we will retain any data relating to the contract for services for a period of six (6) years after the services were performed, to ensure that we are able to assist with any questions or feedback in relation to our services or to enforce, or protect, or defend our legal rights.
6.3. Where we have processed personal data to provide marketing communications with consent, we may contact individuals at least every twelve (12) months to ensure they are happy to continue receiving such communications. If individuals tell us that they no longer wish to receive such communications, their personal data will be removed from our lists.
7. RIGHTS UNDER DATA PROTECTION LAWS
7.1. Right to object
7.1.1. Individuals have the right to object to us processing their personal data where we are processing personal data:
188.8.131.52. based on our legitimate interests (as set out at sections 1.2, 1.3 and 1.5 above). If individuals ask us to stop processing their personal data on this basis, we will stop processing their personal data unless we can demonstrate compelling grounds as to why the processing should continue in accordance with data protection laws; and
184.108.40.206. for direct marking purposes. If individuals ask us to stop processing their personal data on this basis, we will stop.
7.2. Right of access
7.2.1. Individuals have the right to receive confirmation as to whether their personal data is being processed by us, as well as various other information relating to our use of their personal data. Individuals also have the right to access their personal data which we are processing.
7.3. Right to rectification
7.3.1. Individuals have the right to require us to rectify any inaccurate personal data we hold about them. Individuals also have the right to have incomplete personal data we hold about them completed, by providing a supplementary statement to us.
7.4. Right to restriction
7.4.1. Individuals have the right to restrict our processing of their personal data where:
220.127.116.11. the accuracy of the personal data is being contested by them;
18.104.22.168. the processing by us of their personal data is unlawful, but the individual does not want the relevant personal data erased;
22.214.171.124. we no longer need to process their personal data for the agreed purposes, but the individual wants to preserve their personal data for the establishment, exercise or defence of legal claims; or
126.96.36.199. we are processing their data on the basis of our legitimate interest (as set out at sections 1.2, 1.3 and 1.5 above) and the individual:
188.8.131.52.1. objects to our processing on the basis of our legitimate interest under section 184.108.40.206 above; and
220.127.116.11.2. wants processing of the relevant personal data to be restricted until it can be determined whether our legitimate interest overrides their legitimate interest.
7.4.2. Where any exercise by an individual of their right to restriction determines that our processing of particular personal data are to be restricted, we will then only process the relevant personal data in accordance with their consent and, in addition, for storage purposes and for the purpose of legal claims.
7.5. Right to data portability
7.5.1. Individuals have the right to receive their personal data in structured, standard machine readable format and the right to transmit such personal data to another controller.
7.6. Right to erasure
7.6.1. Individuals have the right to require we erase their personal data which we are processing where one of the following grounds applies:
18.104.22.168. the processing is no longer necessary in relation to the purposes for which their personal data was collected or otherwise processed;
22.214.171.124. our processing of their personal data is based on their consent, the individual has subsequently withdrawn their consent and there is no other legal ground we can use to process their personal data;
126.96.36.199. individuals object to the processing as set out in section 188.8.131.52 of this policy and we have no overriding legitimate interest for our processing;
184.108.40.206. the personal data have been unlawfully processed; and
220.127.116.11. the erasure is required for compliance with a law to which we are subject.
7.7. Individuals have the right to lodge a complaint with the Information Commissioner’s Office, the supervisory authority for data protection issues in England and Wales.
7.8. Exercising rights
7.8.1. Individuals can exercise such rights by contacting us at firstname.lastname@example.org or email@example.com.
8. LINKS ON OUR WEBSITE
8.1. Our website may, from time to time, contain links to and from the websites of our partner networks and affiliates. Our service connects individuals to different websites. If individuals follow a link to any of these websites or use our service, please note that the individual has left our website and these websites have their own privacy policies. We do not accept any responsibility or liability for these policies or websites. Please check these policies before submitting any personal data to these websites.