Parcel SafePlace Privacy Policy

Privacy Policy

We take your privacy very seriously.Please read this privacy policy carefully as it contains important information on who we are and how and why we collect, store, use and share your personal information. It also explains your rights in relation to your personal information and how to contact us or supervisory authorities in the event you have a complaint.We collect, use and are responsible for certain personal information about you. When we do so we are subject to the General Data Protection Regulation, which applies across the European Union (including in the United Kingdom) and we are responsible as ‘controller’ of that personal information for the purposes of those laws. Key termsIt would be helpful to start by explaining some key terms used in this policy:

We, us, our: Parcel Safe Place Limited
Personal information: Any information relating to an identified or identifiable individual

Personal information we collect about youWe may collect and use the following personal information about you:

your name and contact information, including email address and telephone number;
your delivery history;
Camera / CCTV images;

This personal information is required to provide the services to you.How your personal information is collectedWe collect most of this personal information directly from you—in person, by telephone, text or email and/or via our website and apps. However, we may also collect information:

from the landlord at the property where the [Parcel Room] is situated;
from cookies on our website—for more information on our use of cookies, please see our cookies policy; and
via our IT systems, eg:
- the Parcel Room door entry system;
- CCTV and access control systems;
- communications systems including email;

How and why we use your personal informationUnder data protection law, we can only use your personal information if we have a proper reason for doing so, eg:

to comply with our legal and regulatory obligations;
for the performance of our contract with you or to take steps at your request before entering into a contract;
for our legitimate interests or those of a third party; or
where you have given consent.

A legitimate interest is when we have a business or commercial reason to use your information, so long as this is not overridden by your own rights and interests.The table below explains what we use (process) your personal information for and our reasons for doing so: What we use your personal information for | Our reasonsTo provide our services to you | For the performance of our contract with you or to take steps at your request before entering into a contract
To prevent and detect fraud against you or the theft of packages from the Parcel Room | For our legitimate interests or those of a third party, ie to minimise fraud/theft that could be damaging for us and for you
Gathering and providing information required by or relating to audits, enquiries or investigations by regulatory bodies | To comply with our legal and regulatory obligations
Statistical analysis to help us manage our business, eg in relation to customer base, services or other efficiency measures | For our legitimate interests or those of a third party, ie to be as efficient as we can so we can deliver the best service for you at the best price
Preventing unauthorised access and modifications to systems | For our legitimate interests or those of a third party, ie to prevent and detect criminal activity that could be damaging for us and for youTo comply with our legal and regulatory obligations
Updating customer records | For the performance of our contract with you or to take steps at your request before entering into a contractTo comply with our legal and regulatory obligationsFor our legitimate interests or those of a third party, eg making sure that we can keep in touch with our customers about deliveries to a Parcel Room and new services
Statutory returns | To comply with our legal and regulatory obligations
Marketing our services to:—existing and former customers; and—third parties who have previously expressed an interest in our services. | For our legitimate interests or those of a third party, ie to promote our business to existing and former customers Promotional communicationsWe may use your personal information to send you updates (by email, text message, telephone or post) about our services, including exclusive offers, promotions or new services.We have a legitimate interest in processing your personal information for promotional purposes (see above ‘How and why we use your personal information’). This means we do not usually need your consent to send you promotional communications. However, where consent is needed, we will ask for this consent separately and clearly.We will always treat your personal information with the utmost respect and never share it with other organisations for marketing purposes. Who we share your personal information withWe may share your personal information with your landlord when required to address any questions from them regarding access to the Parcel room.We may disclose and exchange information with law enforcement agencies and regulatory bodies to comply with our legal and regulatory obligations.We may also need to share some personal information with other parties, such as potential buyers of some or all of our business or during a re-structuring. Usually, information will be anonymised but this may not always be possible. The recipient of the information will be bound by confidentiality obligations. Where your personal information is heldWe hold your details on secure servers that are based in the UK. How long your personal information will be keptWe will keep your personal information while you have an account with us or we are providing services to you. Thereafter, we will keep your personal information for as long as is necessary:

to respond to any questions, complaints or claims made by you or on your behalf;
to show that we treated you fairly;
to keep records required by law.

We will not retain your personal information for longer than necessary for the purposes set out in this policy. Different retention periods apply for different types of personal information.When it is no longer necessary to retain your personal information, we will delete or anonymise it. Your rightsYou have the following rights, which you can exercise free of charge: Access | The right to be provided with a copy of your personal information (the right of access)
Rectification | The right to require us to correct any mistakes in your personal information
To be forgotten | The right to require us to delete your personal information—in certain situations
Restriction of processing | The right to require us to restrict processing of your personal information—in certain circumstances, eg if you contest the accuracy of the data
Data portability | The right to receive the personal information you provided to us, in a structured, commonly used and machine-readable format and/or transmit that data to a third party—in certain situations
To object | The right to object:—at any time to your personal information being processed for direct marketing (including profiling);—in certain other situations to our continued processing of your personal information, eg processing carried out for the purpose of our legitimate interests.
Not to be subject to automated individual decision-making | The right not to be subject to a decision based solely on automated processing (including profiling) that produces legal effects concerning you or similarly significantly affects you For further information on each of those rights, including the circumstances in which they apply, please contact us or see the Guidance from the UK Information Commissioner’s Office (ICO) on individuals’ rights under the General Data Protection Regulation.If you would like to exercise any of those rights, please:

email, call or write to us — see below: ‘How to contact us’; and
let us have enough information to identify you (eg your full name, address and customer or matter reference number)
let us have proof of your identity and address (a copy of your driving licence or passport and a recent utility or credit card bill); and
let us know what right you want to exercise and the information to which your request relates.

Keeping your personal information secureWe have appropriate security measures to prevent personal information from being accidentally lost, or used or accessed unlawfully. We limit access to your personal information to those who have a genuine business need to access it. Those processing your information will do so only in an authorised manner and are subject to a duty of confidentiality.We also have procedures in place to deal with any suspected data security breach. We will notify you and any applicable regulator of a suspected data security breach where we are legally required to do so. How to complainWe hope that we can resolve any query or concern you may raise about our use of your information.The General Data Protection Regulation also gives you right to lodge a complaint with a supervisory authority, in particular in the European Union (or European Economic Area) state where you work, normally live or where any alleged infringement of data protection laws occurred. The supervisory authority in the UK is the Information Commissioner who may be contacted at https://ico.org.uk/concerns or telephone: 0303 123 1113. Changes to this privacy policyThis privacy notice was last updated on 14/08/2018We may change this privacy notice from time to time—when we do we will inform you via the email address you signed up with. How to contact usPlease contact us by post, email or telephone if you have any questions about this privacy policy or the information we hold about you. admin@parcelsafeplace.com020 3823 6942 Parcel SafePlace1 Miles Ward CourtMarket PlaceHalesworthSuffolkIP19 8AY Do you need extra help?If you would like this notice in another format (for example audio, large print, braille), please contact us.

Promotional offers from us

We may use your Identity, Contact, Technical, Usage and Profile Data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which products, services and offers may be relevant for you (we call this marketing).

You will receive marketing communications from us if you have requested information from us or purchased goods or services from us or if you provided us with your details when you entered a competition or registered for a promotion and, in each case, you have not opted out of receiving that marketing.

Third-party marketing

We will get your express opt-in consent before we share your personal data with any company outside PingLocker Ltd for marketing purposes.

Opting out

You can ask us or third parties to stop sending you marketing messages at any time by logging into the website and checking or unchecking relevant boxes to adjust your marketing preferences or by following the opt-out links on any marketing message sent to you.

Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of a product/service purchase, warranty registration, product/service experience, updates or other transactions.

Cookies

You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of this website may become inaccessible or not function properly.

Change of purpose

We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.

If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.

Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

5. Disclosures of your personal data

We may have to share your personal data with the parties set out below for the purposes set out in the table in paragraph 4 above.

External Third Parties as set out in the Glossary.
Retargeting software vendors, email service providers and social media platforms such as Facebook to deliver relevant website content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you
Web analytics and user experience software providers such as Google to improve our website, products/services, marketing, customer experiences
Personalisation tool vendors that allow us to make suggestions and recommendations to you about goods or services that may be of interest to you
Third parties to whom we may choose to provide our Services and process Orders, sell, transfer, or merge parts of our business or our assets. As we develop our businesses, we might sell, buy or merge businesses or assets. In the event of a corporate sale, merger, reorganisation, sale of assets, dissolution, or similar event, the Information may be part of the transferred assets and/or the new owners may use your personal data in the same way as set out in this privacy notice.

We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.

6. International transfers

We do not transfer your personal data outside the European Economic Area (EEA). If we decide to transfer your personal data out of the EEA in future for whatever reason, we will ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:

We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data by the European Commission. For further details, see European Commission: Adequacy of the protection of personal data in non-EU countries
Where we use certain service providers, we may use specific contracts approved by the European Commission which give personal data the same protection it has in Europe. For further details, see European Commission: Model contracts for the transfer of personal data to third countries.
Where we use providers based in the US, we may transfer data to them if they are part of the Privacy Shield which requires them to provide similar protection to personal data shared between the Europe and the US. For further details, see European Commission: EU-US Privacy Shield.

7. Data security

We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.

We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

You are also responsible for the security of your Personal Information. You should choose a password of sufficient length and complexity when you use our Services and keep your password confidential. If you think there has been unauthorised access to or use of your account, please contact us immediately at compliance@pinglocker.com.

8. Data retention

How long will you use my personal data for?

We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.

To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.

In some circumstances we may anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes in which case we may use this information indefinitely without further notice to you.

9. Your legal rights

Under certain circumstances, you have rights under data protection laws in relation to your personal data.

Request access to your personal data.
Request correction of your personal data.
Request erasure of your personal data.
Object to processing of your personal data.
Request restriction of processing your personal data.
Request transfer of your personal data.
Right to withdraw consent.

If you wish to exercise any of the rights set out above, please contact us at compliance@pinglocker.com

No fee usually required

You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.

What we may need from you

We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

Time limit to respond

We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.

10. Glossary
LAWFUL BASIS

Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give you the best service/product and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us.

Performance of Contract means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.

Comply with a legal or regulatory obligation means processing your personal data where it is necessary for compliance with a legal or regulatory obligation that we are subject to.

THIRD PARTIES

Internal Third Parties

Other companies, such as our software partner, Blackbell Inc, acting as joint controllers or processors and who are based within the EU and provide IT and system administration services and undertake leadership reporting.

External Third Parties

Service providers acting as processors based within the EU who provide products, services, IT and system administration services.
Professional advisers acting as processors or joint controllers including lawyers, bankers, auditors and insurers based within the EU who provide consultancy, banking, legal, insurance and accounting services.
HM Revenue & Customs, regulators and other authorities based in the European Economic Area who require reporting of processing activities in certain circumstances.
Market research agencies, list brokers, fraud prevention agencies.

YOUR LEGAL RIGHTS

You have the right to:

Request access to your personal data (commonly known as a “data subject access request”). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.

Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.

Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.

Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.

Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios: (a) if you want us to establish the data's accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.

Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.

Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.

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