PLEROMA GLOBAL PRIVACY POLICY
1 Introduction
1.1 Thank you for visiting our website. This privacy standard sets out how the Pleroma Global group of companies (“Pleroma Global” or “We”) processes the personal information of our website visitors,and clients. It also describes the cookies we may use and send to your computer or mobile device. Please note that this privacy standard is not an exclusive description of how Pleroma Global processes the personal information of individuals.
1.2 If you use Pleroma Global’ products or services further information will be provided as part of the engagement process.
1.3 If you are an employee, worker or contractor of Pleroma Global,the information about how we handle your personal information as an employee is located on the Pleroma Global intranet and will have been notified to you.
1.4 If you are a prospective employee or job applicant of Pleroma Global, we will provide you with information about how we handle your personal information for recruitment purposes in our “Recruitment Privacy Statement.” This will be provided to you if you commence our electronic application form or any other of our recruitment initiatives.
1.5 If you have any questions about this privacy policy or any other privacy polices mentioned above please contact the Pleroma Global via our contact form.
2 How We Collect personal information
2.1 We will collect and store your personal information when you interact with our website or, as a customer, request our products or services. We collect personal information in writing, by telephone, by e-mail and by online applications.
2.2 Pleroma Global collects personal information directly from the individual to whom it relates, except where that individual has consented to Pleroma Global collecting the personal information from a third party or the law otherwise permits Pleroma Global to do so.
3 what personal information do we hold about you
3.1 Personal information means any information relating to a person that enables them to be identified either directly or indirectly. Personal information that we hold about you may include your:
3.1.1 name;
3.1.2 address;
3.1.3 email address;
3.1.4 phone number;
3.1.5 IP address; and
3.1.6 Location data.
3.2 If you are a client, personal information that we hold about you may include the same information listed in clause 3.1 above, along with your language, gender, and date of birth, fax and social network accounts. We may also process your function/job title within the company and your work email address and your company’s name, postal address, VAT and/or company number
3.3 In order to improve the services or products we offer to clients, we may also obtain additional relevant personal information about you. This can be public information, e.g. official publications, or information which we obtain via third parties and that we use for the purposes mentioned in this privacy policy. For example, we may use such personal information to verify the accuracy of our personal information in our databases or to tailor our marketing services more accurately to you. Public information about you can consist of information published on the World Wide Web or personal information that you have made public (for example, on your social media profile).
3.4 We will take reasonable steps to ensure the personal information that we store is accurate, complete and up-to-date.
4 How we use your Information
4.1 We will use your personal data, and may share your personal data with other parties acting on our behalf, for one or more of the following purposes:
4.1.1 to conduct research about the use of our website;
4.1.2 to assess and respond to a complaint you might make to us;
4.1.3 for our own administrative purposes, including training our staff, conducting internal audits or transferring assets as part of a sale, purchase or investment in the business;
4.1.4 if you are a client, to carry out our contract with you;
4.1.5 for market research purposes;
4.1.6 to conduct investigations of suspicious or harmful activity; and
4.1.7 Tocomply with Pleroma Global’sregulatory and legal obligations.
4.2 We do not sell your personal information to others.
4.3 If we wish to use your personal information for a purpose beyond that for which it was originally provided, we will ask for your consent or seek to rely on another valid legal ground to process your personal information in accordance with the applicable law.
5 information for marketing purposes
5.1 Where you have consented to us using your personal data for marketing purposes, we may use your information to conduct marketing and data analysis or to send you updates and news concerning Pleroma Global and its business partners.
5.2 If at any time after you have consented to us using your information for marketing purposes and you wish us to stop using your information for these purposes, please contact us via our contact page.
6 GROUNDS FOR PROCESSING
6.1 To process your data lawfully we need to rely on one or more valid legal grounds. The grounds we may rely upon include:
6.1.1 Your consent to particular processing activities. For example, where you have consented to us using your information for marketing purposes;
6.1.2 Our legitimate interests as a business (except where your interests or fundamental rights override these). For example, it is within our legitimate interests to use your data to prevent or detect fraud or abuses of our website;
6.1.3 Our compliance with a legal obligation to which Pleroma Global is subject. For example, we have a duty to investigate and respond to complaints made against us and may need to process your personal information as part of such investigation; or
6.1.4 If you are a customer, because processing your personal data is necessary for the performance of a contract.
7 DISCLOSURE OF YOUR PERSONAL INFORMATION
7.1 There are circumstances where we may wish to disclose or are compelled to disclose your personal data to third parties. This will only take place in accordance with the applicable law and for the purposes listed above. These scenarios include disclosure:
7.1.1 to our subsidiaries, branches or associated offices;
7.1.2 to our outsourced service providers or suppliers to facilitate the provision of our services, for example, the disclosure to our data centre provider for the safe keeping of your personal data;
7.1.3 to third party service providers and consultants in order to protect the security or integrity of our business, including our databases and systems and for business continuity reasons;
7.1.4 to another legal entity, on a temporary or permanent basis, for the purposes of a joint venture, collaboration, financing, sale, merger, reorganisation, change of legal form, dissolution or similar event. In the case of a merger or sale, your personal data will be permanently transferred to a successor company;
7.1.5 to legal advisors who may need to manage or litigate a claim;
7.1.6 to public authorities where we are required by law to do so; and
7.1.7 To any other third party where you have provided your consent.
8 INTERNATIONAL TRANSFER OF PERSONAL DATA
8.1 We may transfer your personal data to a third party in countries outside the EU for further processing in accordance with the purposes set out in this policy. In particular, your personal data may be transferred throughout the Pleroma Globalgroup and to our outsourced service providers located abroad. In these circumstances we will, as required by applicable law, ensure that your privacy rights are adequately protected by appropriate technical, organisation, contractual or other lawful means. Please contact us via our contact pagefor a copy of the safeguards which we have put in place to protect your personal data and privacy rights in these circumstances.
8.2 We may disclose your information to any person as required by law and specifically to any government agency if we believe in good faith that we must do so to comply with the law or that doing so is required to prevent, detect, investigate or remedy improper conduct potentially affecting Pleroma Global.
9 RETENTION OF PERSONAL INFORMATION
Your personal information will be retained for as long as it is necessary to carry out the purposes set out in this privacy policy (unless longer retention is required by the applicable law). However, we will not retain any of your personal information beyond this period and the retention of your personal information will be subject to periodic review. We may keep an anonymised form of your personal information, which will no longer refer to you, for statistical purposes without time limits, to the extent that we have a legitimate and lawful interest in doing so.
10 Confidentiality and Security
10.1 Pleroma Global is committed to:
10.1.1 seeking to safeguard all personal information that you provide to us;
10.1.2 seeking to ensure that it remains confidential and secure; and
10.1.3 Taking all reasonable steps to ensure that personal privacy is respected.
10.2 All our data is stored in written or electronic form on our servers and computers and in various physical locations. We maintain physical, electronic and procedural safeguards to protect your personal information from misuse, unauthorised access or disclosure and loss or corruption by computer viruses and other sources of harm. We restrict access to personal information to those staff members, joint venture partners, subsidiary companies and third parties who need to know that information for the purposes set out in this privacy policy.
10.3 By giving us information or allowing it to be collected, to the fullest extent permitted by law, you agree that you will not make any claims against, and that Pleroma Global will not be held liable for, any claims, losses or damages which may result, directly or indirectly, from collection of that information, including from misuse, unauthorised access or disclosure and loss or corruption by computer viruses and other sources of harm to the information we collect.
11 YOUR RIGHTS with regards to your personal information
11.1 Data protection law provides individuals with certain rights, including the right to: access, rectify, withdraw consent, erase, restrict, transport, and object to the processing of, their personal information. Individuals also have the right to lodge a complaint with the relevant information protection authority if they believe that their personal information is not being processed in accordance with the law. Further information about your rights is set out below:
Right to obtain a copy of your personal information. You have the right to obtain a copy of the personal information we hold about you. All requests for access to personal information should be made via our contact form. You may be required to submit a proof of your identity and a fee in some circumstance
11.2 Right to rectification. Youmay request that we rectify any inaccurate and/or complete any incomplete personal information.If we disagree and believe the information to be accurate and complete, we will advise you and include a notation on the record that you dispute the information’s accuracy. Requests for corrections or supplements to all other personal information should be madevia our contact page. We will respond to your request to correct or supplement your personal information within a reasonable time period and, in any event, within any time period specified in relevant laws.
11.3 Right to withdraw consent. You may, as permitted by law, withdraw your consent to the processing of your personal information at any time. Such withdrawal will not affect the lawfulness of processing based on your previous consent. Please note that if you withdraw your consent, you may not be able to benefit from certain service features for which the processing of your personal information is essential.
11.4 Right to object to processing. Youmay, as permitted by law, request that we stop processing your personal information.
11.5 Right to erasure. Youmay request that we erase your personal information and we will comply, unless there is a lawful reason for not doing so.
11.6 Your right to lodge a complaint with the supervisory authority. We suggest that you contact us via our contact page about any questions or if you have a complaint in relation to how we process your personal information. However, you do have the right to contact the relevant supervisory authority in the relevant country directly.
12 Links
Our website provides hyperlinks to websites owned and controlled by others. Pleroma Global is not responsible for the privacy practices of any website that it does not own or otherwise control.
13 Third Parties
Where you submit information on behalf of another person, you confirm that you have made that person aware of how we may collect, use and disclose their information, the reason you have provided it, how they can contact us, the terms of this policy and that they have consented to such collection, use and disclosure.
14 Compliance with Privacy Laws
14.1 Pleroma Global complies with the data protection and privacy laws to which it is subject. You should satisfy yourself that you are familiar with those laws, including any exceptions which may apply under them. You should also be aware that privacy laws in various jurisdictions may change from time to time.
14.2 Except to the extent expressly stated otherwise in this policy, Pleroma Global accepts no obligations with respect to the handling of personal information other than those mandated by law in the country which has, or counties which have jurisdiction over Pleroma Global in any given circumstances.
15 Cookies
15.1 This section of the policy explains what cookies are, why we use them and what you may do if you wish to restrict, remove or refuse to accept cookies.
15.2 By continuing to use this website, you agree to the use of cookies for the purposes set out in this policy.
What is a cookie?
15.3 A cookie is a small text file downloaded onto your computer or mobile device when you access a website, including this website. Cookies are widely used to make websites work, or work more efficiently, as well as to provide information to the website’s owners and third parties.
15.4 Cookies allow a website to recognise your computer or mobile device. Cookies do not identify you as an individual, but do identify the computer or mobile device you use to access the Internet and can therefore be used to collect information about your use of the Internet. Cookies do not allow access to any information stored on your computer or mobile device.
Why do we use cookies?
15.5 We use cookies for the following purposes:
15.5.1 To determine the number of visitors to our website and to identify how visitors move around the site and, in particular, which pages they visit. This allows us to improve our website and our services.
15.5.2 to determine from where in the world our website is being visited so that we can ensure sufficient coverage and
15.5.3 To collect information, where available, about your computer or mobile device for system administration purposes, such as your IP address, operating system and browser type.
15.5.4 We will only use information collected through the use of cookies to evaluate our website’s effectiveness and to improve your experience when you visit it. Cookies are not used by us to identify who you are or send you targeted advertising.
Controlling and deleting cookies
15.6 When you accessed this website, cookies were sent to your web browser and stored on your computer or mobile device.
15.7 If you wish to restrict, remove or refuse to accept cookies which are set by any website (including this website), you should do this through the browser settings for each browser you use to access the Internet. The Help function within your browser should tell you how to do so.
15.8 To opt out of being tracked by Google Analytics across all websites visit http://tools.google.com/dlpage/gaoptout.
15.9 For further information about how to restrict, remove, and refuse to accept cookies, visit www.aboutcookies.org or www.allaboutcookies.org.
15.10 Note, however, that in some cases, restricting, removing or refusing to accept cookies may reduce the functionality of, or prevent access to, this and other websites.
16 Changes to this Policy
As we strive to improve our practices, we may review this policy from time to time. We reserve the right to change this policy at any time and to notify you of those changes by posting an updated version of this policy on our website. It is your responsibility to check our policy each time before you access our website for any changes.