This Privacy and Cookies Policy relates to websites and apps operated as Pozitiva Ltd and for any websites and apps of any associated trading styles of Pozitiva Ltd. Pozitiva Ltd is a company established in England, company number 11745626, with a registered address of 11 Werneth Road, Woodley, Stockport, United Kingdom, SK6 1HW. Throughout this policy, when we refer to “we”, “us” or “our”, we are referring to all trading styles operating as a part of Pozitiva Ltd. In compliance with the General Data Protection Regulations (GDPR) (EU) 2016/679, Pozitiva Ltd is the data controller and is responsible for processing your personal data.
Information we collect
By using our website and when interacting with us via any medium we may collect and process the following data about you:
- Usage data, such as the details of your visits to our website and the resources that you access including but not limited to traffic data, location data, blog statistics and other communication data.
- Technical data, such as your internet protocol (IP) address, your log in information, browser type and version, time zone settings, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access this website.
- Personally identifiable data that you provide to us, be it in forms on our website, over the telephone or via any other medium of contact. An example of personally identifiable data is, but not limited to, your name, address, e-mail and phone number. Information you provide when applying for a job or to provide us with services.
- Information we may receive from third parties that we work closely with, for example, business partners, subcontractors, advertising networks, analytics providers, search information providers, credit reference agencies, etc.
- Information provided to us when you communicate with us for any reason.
- Information collected from third party or public sources such as, but not limited to, the Electoral Register and analytics providers.
- Social media data where you have opted to sign up to a service using a facebook single-sign-on service. By using this service you are agreeing to Facebook sharing certain information with us from your profile, including but not limited to, your name, profile picture and a list of your friends. You can control the access you allow us to have by maintaining your privacy settings within the relevant social media platform.
Where we need to collect personal data from you, be it by law or under the terms of a contract, we may be unable to fulfil that contract should you fail to provide the data to us when required.
In accordance with the COPPA (Children’s Online Privacy Protection Act), we put every effort into not collecting any personal data of any person under the age of 13. Anyone under the age of 13 should not provide us with any information and should arrange for a parent or guardian to provide such information on their behalf. Additionally, our products and services are not intended for anyone under the age of 18. Any purchase intended for anyone under the age of 18 should be purchased by a parent or guardian.
Our lawful basis for processing your data
We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:
- Consent – Where you have provided us with consent to do so
- Contract – Where you have entered into a contract with us
- Legitimate Interest - Where we or our selected partners have a legitimate interest to do so that is not overridden by your own interests or rights.
- Legal or Regulatory Obligations - Where we have a legal obligation to do so
Use of your information
The information that we collect and store about you is primarily used to enable us to provide our website and services to you. In addition, we may use the information for the following purposes:
- Business Administration: To administrate our site, internal operations, troubleshooting, system security updates and maintenance, data analysis, testing research, stats and surveys
- Competitions, Awards, Events, Product Trials & Surveys: To allow you to participate in any of these services; to allow us to communicate with you about such services; to send you any awards or products.
- Enquiries and Customer Service: to contact you in relation to any enquiries put forward by you; to contact you in relation to your account, subscription, and/or orders you’ve made; to notify you of any material changes to our terms or this Privacy and Cookies Policy; to ask you to partake in a survey or to leave a review; and to send you any communication related to our services.
- Purchases and Contractual Fulfilments: To process and deliver any purchases you’ve made; to provide you with services you’ve purchased; to manage any payments, fees and charges and to recover any monies owed to us.
- Performance: To monitor campaign performance, such as but not limited to, click rates and to gain insight into our customers for both ourselves and any business partners.
- Advertisements and Marketing: To provide you with information related to products or services that we offer; to monitor the performance of adverts and marketing.
- Aggregation and Anonymisation: To aggregate your data from multiple sources and anonymise your data for your personal privacy, allowing us to sell advertising and conduct a statistical analysis for the purpose of monitoring business partnerships.
- Personalisation: To personalise any content, communications, and services to you and to personalise the advertisements that we present to you on any of our sites. To do this we will combine the different information we have on you from various sources, such as but not limited to, your contact information and your activity when using any of our sites.
- Retargeting: To present advertisement on a third-party site, such as facebook, related to a product that you have viewed on our site.
Any such contact could be made via, but is not limited to, telephone, E-mail, SMS, post and direct message
Storing and transferring of your personal data
Data that is provided to us is stored on secure servers. Details relating to any transactions entered into via our website will be encrypted to ensure its safety. The transmission of information via the internet is not completely secure and there we cannot guarantee the security of data sent to us electronically and the transmission of such data is entirely at your own risk.
Sharing your personal data
We may share your personal data with third party companies associated with Pozitiva Ltd where reasonably necessary. Some situations where this may be necessary are as follows:
- In compliance with any legal obligations we’re subject to
- In the event we enter into a purchase or sale agreement of any business or assets
- In the event our business or assets are acquired by a third party
- Companies such as HM Revenue & Customs, regulators and other authorities.
- To process an order, request, service, or prize
- To seeking professional advice
- For IT services, both inside and outside of the European Union.
Where we employ a third party to process your data in order to fulfil an order, request or service requested by you will be subject to a contractual agreement which will protect the security of your data.
Credit/debit card details will not be stored and as such will not be sold, shared, rented or leased to any third party.
Sharing your anonymised data
We may also share your anonymised data with third parties such as advertisers, advertising networks, advertising servers and content recommendation services. This is to allow us to personalise our advertising both on our sites and on third party sites. Identifiable data such as your names, address, DOB, etc will not be shared.
Third Party Links
You might find links to third party websites on our website, such as partner networks, advisers, affiliates or any other links. We cannot be held accountable for the privacy and protection of any personal data that you provide on any of these third party websites. These websites should have their own privacy policies which you should check. We do not accept any responsibility or liability for their policies whatsoever as we have no control over them.
For tax purposes, and in compliance with the law, we will keep any transactional and financial data for seven years from the date you cease being a customer.
The time in which we retain your personal data will be determined based on the service that we have provided and our legal requirements, and as such the time period could vary as a result of this assessment. During our assessment we will consider the type of data that we hold; the risks associated with that data; the purpose for which we hold and process that data; any legal obligations that we have for keeping that data.
Changes to this policy
This Privacy and Cookies Policy came into effect on 11/11/20. We reserve the right to update or change this Policy at any time and those changes will be in effect at the point when those changes have been published. It is recommended that you continuously check this policy to remain updated of any changes. Use of this site following any changes will represent your acknowledgement of any changes.
If there is a significant change to this policy, we may inform you of this change via your registered email address or via a portal that you may have with us.
Under the Data Protection Act laws, you have the following rights in respect of your personal data:
- To request a copy of your personal data
- To request that we correct any of your personal data
- To request that we erase your personal data
- To remove your consent to processing of your personal data, where the lawful basis for processing your data was consent
- To request a restriction in the processing of your personal data
- To object to any further processing of your personal data
- To request a transfer of your personal data to another data controller
You have the right to submit a complaint to the Information Commissioner’s Office (ICO) at any point at www.ico.org.uk. However, we would appreciate an opportunity to resolve any of your concerns before you approach them.
Should you have a request regarding the processing of your personal data, please email us on ***