PURPLE BEAR GROUP
PRIVACY POLICY
Introduction
Welcome to the privacy notice of www.purplebeargroup.com
This website is operated by Portfolio Leadership Solutions Limited.
Portfolio Leadership Solutions Limited respects your privacy and is committed to protecting your personal data.
The use of this website is possible without the provision by you of personal data.
If you submit personal data to us it will be maintained in accordance with this policy. We ask that you read this website privacy policy carefully as it contains important information on who we are, how and why we collect, store, use and share personal information, your rights in relation to your personal information and on how to contact us and supervisory authorities in the event you have a complaint.
This website privacy policy is divided into the following sections:
· Who we are and how to contact us
· Our website
· Our collection and use of your personal information
· Our legal basis for processing your information
· Transfer of your information out of the UK and EEA
· Your rights
· Keeping your personal information secure
· Data retention
· How to complain
· Changes to this website privacy policy
· Do you need extra help?
Where we are and how to contact us
This website is operated by Portfolio Leadership Solutions Limited.
We operate this website on behalf our ourselves, Making Positive Connections Limited, Infinite Networking Limited, Purple Bear Properties Limited, Purple Bear Property Investments Limited and Wendy and Justin Walton, that together form “Purple Bear Group”.
We collect, use and are responsible for certain personal information about you. When we do so we are regulated under the General Data Protection Regulation which applies across the European Union and the United Kingdom and we are responsible as ‘controller’ of that personal information for the purposes of those laws.
Portfolio Leadership Solutions Limited is the controller and responsible for your personal data (collectively referred to as “Company”, “we”, “us”, or “our” in this privacy notice). This means that Portfolio Leadership Solutions Limited determines the purposes for which, and the manner in which your data is processed.
We have appointed a Data Protection Officer who is responsible for overseeing questions in relation to this privacy notice. If you have any questions about this privacy notice, including any requests to exercise your legal rights, please contact the data privacy manager using the details set out below.
Our full details are:
Full name of Data Controller: Portfolio Leadership Solutions Limited
Name of Data Protection Officer: Justin Walton
Email address: contactus@purplebeargroup.com
Postal address: 71-75 Shelton Street, London, WC2H 9JQ
Telephone: 07748 181494
You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk).
We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.
Our Website
This privacy policy relates to your use of our website, www.purplebeargroup.com . This privacy policy applies only to the actions of Portfolio Leadership Solutions Limited and users with respect to this website. It does not extend to any websites that can be accessed from this website, including, but not limited to any links we may provide to social media websites.
Our Collection and Use of Your Personal Information
We may collect, store and use the following kinds of personal information:
· Information that you provide to us when contacting us;
· Information that you provide to us for the purpose of subscribing to our website services, email notifications and/or newsletters;
· Any other information that you choose to send to us.
· Personal information submitted to us via this website will be used for the purposes specified in this privacy policy or in relevant parts of the website.
We may use this personal information to:
· If applicable, send statements and invoices to you, and collect payments from you;
· Send you general (non-marketing) communications;
· Send you email notifications which you have specifically requested;
· Send to you our newsletter and other marketing communications relating to our business which we think may be of interest to you by post or, where you have specifically agreed to this, by email or similar technology (you can inform us at any time if you no longer require marketing communications by contacting us at contactus@purplebeargroup.com);
· Deal with enquiries and complaints made by or about you relating to the website;
· Internal record keeping;
· Improvement of our services.
We will not without your express consent provide your personal information to any third parties for the purpose of direct marketing.
Your personal data that we process for any purpose or purposes shall not be kept for longer than is necessary for that purpose or those purposes. We do not use cookies.
Our Legal Basis for Processing Your Personal Information
When we use your personal information, we are required to have a legal basis for doing so.
There are various different legal bases on which we may rely, depending on what personal information we process and why.
The legal bases we may rely on include:
· consent: where you have given us clear consent for us to process your personal information for a specific purpose
· contract: where our use of your personal information is necessary for a contract we have with you, or because you have asked us to take specific steps before entering into a contract
· legal obligation: where our use of your personal information is necessary for us to comply with the law (not including contractual obligations)
· vital interests: where our use of your personal information is necessary to protect you or someone else’s life
· legitimate interests: where our use of your personal information is necessary for our legitimate interests or the legitimate interests of a third party (unless there is a good reason to protect your personal information which overrides our legitimate interests).
We will share personal information with law enforcement or other authorities if required by applicable law.
We will not share your personal information with any other third party.
Transfer Of Your Information Out Of The UK and EEA
Information that we collect may be stored and processed in and transferred between any of the countries in which we operate in order to enable us to use the information in accordance with the privacy policy.
Information which you provide will not be transferred to countries which do not have data protection laws equivalent to those in force in the European Economic Area without your express written consent. Where such transfers take place, we will take appropriate and adequate steps to ensure the safety of the data to be transferred.
Your Rights
You have the following rights in relation to your data:
· Right to access: the right to request (i) copies of the information we hold about you at any time, or (ii) that we modify, update or delete such information. If we provide you with access to the information we hold about you, we will not charge you for this, unless your request is “manifestly unfounded or excessive”. Where we are legally permitted to do so, we may refuse your request. If we refuse your request, we will tell you the reasons why.
· Right to correct: the right to have your data rectified if it is inaccurate or incomplete.
· Right to erase: the right to request that we delete or remove your data from our systems.
· Right to restrict our use of your data: the right to “block” us from using your data or limit the way in which we can use it.
· Right to data portability: the right to request that we move, copy or transfer for your data;
· Right to object: the right to object to our use of your data including where we use it for our legitimate reasons.
Keeping Your Personal Information Secure
We have appropriate security measures in place to prevent personal information from being accidentally lost, or used or accessed in an unauthorised way. We limit access to your personal information to those who have a genuine business need to know 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. If you want detailed information from Get Safe Online on how to protect your information and your computers and devices against fraud, identity theft, viruses and many other online problems, please visit www.getsafeonline.org. Get Safe Online is supported by HM Government and leading businesses.
How to complain
We hope that we or our Data Protection Officer can resolve any query or concern you raise about our use of your information.
The General Data Protection Regulation also gives you the right to lodge a complaint with a supervisory authority, in particular in a European Economic Area state or in the United Kingdom if you work, normally live or if any alleged infringement of data protection laws occurred in the relevant state. The supervisory authority in the UK is the Information Commissioner who may be contacted at https://ico.org.uk/concerns/
Changes to this website policy
This website privacy policy was updated on 31 March 2023.
We may change this website privacy policy from time to time, by posting a new version on our website. You should check this page occasionally to ensure you are happy with any changes. You are deemed to have accepted the terms of the privacy policy on your first use of the website following the alterations.
Do You need extra help?
If you would like this website privacy policy in another format (for example: audio, large print, braille) please contact us at contactus@purplebeargroup.com