Privacy Notice

Privacy Notice & Cookies

Last updated May 2018

We want you to know that when you use our organisation you can trust us with your information. We are determined to do nothing that would infringe your rights or undermine your trust. This Privacy Notice describes the information we collect about you, how it is used and shared, and your rights regarding it.

Data Controller

We are registered with the Information Commissioner’s Office (ICO) as a Data Controller for the personal data that we hold and process. Our registered address is 153 Upper Newtownards Road, Belfast BT4 3HX and our Company registration number is NI026898.

Data Collection

All of the information that we hold about you is provided to us by yourself when you seek to use our services.

To the extent permissible under applicable law, we collect information about you and any other party whose details you provide to us when you:

• register to use our website, applications or services (including free trials); this may include your name (including business name), address, email address and telephone number. We may also ask you to provide additional information about your business and your preferences;
• complete online forms (including call back requests), take part in surveys, post on our message boards, post any blogs, enter any competitions or prize draws, download information such as white papers or other publications or participate in any other interactive areas that appear on our website or within our application or service;
• interact with us using social media;
• contact us offline, for example, by telephone, sms, email or post.

Our lawful basis for processing your information

The General Data Protection Regulation (GDPR) requires all organisations that process personal data to have a Lawful Basis for doing so. The Lawful Bases identified in the GDPR are:

• Consent of the data subject.
• Performance of a contract with the data subject or to take steps to enter into a contract.
• Compliance with a legal obligation.
• To protect the vital interests of a data subject or another person.
• Performance of a task carried out in the public interest or in the exercise of official authority vested in the controller.
• The legitimate interests of ourselves, or a third party, except where such interests are overridden by the interests, rights or freedoms of the data subject.

Examples of legitimate interests include:

• Where the data subject is a client or in the service of the controller;
• Transmission within a group of undertakings for internal administrative purposes;
• Processing necessary to ensure network and information security, including preventing unauthorised access;
• Processing for direct marketing purposes, or to prevent fraud; and
• Reporting possible criminal acts or threats to public security.

Our Lawful Basis is performance of a contract with the data subject and our Legitimate Interests are where the data subject is a customer or an employee of the controller, and processing for direct marketing purposes.

We use your information to:

Provide goods, services, quotations, and information to you;
Process or support payments for goods and services;
Communicate with you about products, services, promotions, studies, surveys, news, updates and events; which may be useful to you based on your use of our applications and services
Process promotions/competitions, including prizes, and send you information about our services and those of our business partners;
Investigate or address legal proceedings relating to your use of our services/products, or as otherwise allowed by applicable law.


We do not use automated decision-making in the processing of your personal data.

We collect and process both personal data and special categories of personal data as defined in the GDPR. This includes:

Customer/client data

• Name.
• Email.
• Phone number.
• Address.
• Payment or bank details.
• Location details.
• Device IP address.

Employee Data

• Name.
• Email.
• Phone number.
• Address.
• Payment or bank details.
• Date of birth.
• Family & next-of-kin details.
• Religion (only in Northern Ireland, required for FEC form).

We may share your personal data with:

• Partners, including system implementers and developers.
• Our legal advisors in the event of a dispute or other legal matter.
• Law enforcement officials, government authorities, or other third parties to meet our legal obligations.
• Any other party where we ask you and you consent to the sharing.

Transfers to third countries and international organisations

We do not transfer any personal data to third countries or international organisations.

We retain your personal data while you remain a customer or an employee, unless you ask us to delete it. Our Retention and Disposal Policy (copy available on request) details how long we hold data for and how we dispose of it when it no longer needs to be held. We will delete or anonymise your information at your request unless:

• There is an unresolved issue, such as claim or dispute;
• We are legally required to; or
• There are overriding legitimate business interests, including but not limited to fraud prevention and protecting customers' safety and security.

Your Rights

The General Data Protection Regulation gives you specific rights around your personal data. For example, you have to be informed about the information we hold and what we use it for, you can ask for a copy of the personal information we hold about you, you can ask us to correct any inaccuracies with the personal data we hold, you can ask us to stop sending you direct mail, or emails, or in some circumstances ask us to stop processing your details. Finally, if we do something irregular or improper with your personal data you can seek compensation for any distress you are caused or loss you have incurred. You can find out more information from the ICO’s website http://ico.org.uk/for_the_public/personal_information and this is the organisation that you can complain to if you are unhappy with how we deal with you.

Accessing and Correcting Your Information

You may request access to, correction of, or a copy of your information by emailing us at privacy@pinnacle-online.com or by writing to our Data Protection Representative at Pinnacle, 153 Upper Newtownards Road, Belfast BT4 3HX.

Marketing Opt-Outs

You may opt out of receiving emails and other messages from our organisation by following the instructions in those messages.

Cookies

Cookies are small text files that are stored on your browser or device by websites, apps, online media, and advertisements. We use cookies to:

• Validate users;
• Remember user preferences and settings;
• Determine the frequency of accessing our content;
• Measure the effectiveness of advertising campaigns; and
• Analyse site visits and trends.

Cookies provide us with the data that we can use to improve our service to you. Cookies themselves do not personally identify users although they do identify a user’s IP address.

How to disable cookies

You may if you wish restrict or block cookies, however if you disable cookies you may find this affects your ability to use certain parts of our website, applications or services.

For more information on cookies and how to accept, delete or reject cookies then go to http://www.youronlinechoices.com/uk/faqs website.

Updates to our Privacy Notice

We will always update this Privacy Notice on our website, so please refer to it when you visit the website (the “last updated” reference tells you when we last updated our Privacy Notice).