PRIMA EKUITI (UK) Limited
PRIVACY NOTICE
Introduction
References to "our", "us", "we" or "PEUK" within this Privacy Notice are to Prima Ekuiti (UK) Limited and its group companies, as applicable.
This Privacy Notice governs the collection and use of personal information by PEUK. For more information about us, please see: http://www.primaekuiti.co.uk/
We are committed to protecting your privacy and ensuring the highest level of security for your personal information. This Privacy Notice explains the types of personal information we collect; how we use that information; who we share it with; how we protect that information; and your legal rights. We are committed to abiding by this Privacy Notice, as well as the requirements of applicable laws, in the operation of our business.
You should read this Privacy Notice together with any other privacy policy we may provide you on specific occasions when collecting or processing personal data about you, so that you are fully aware of how and why we are using your data. This Privacy Notice supplements other such notices and is not intended to override them.
For the purpose of applicable data protection laws, the data controller is Prima Ekuiti (UK) Limited of Suite 2, 9th Floor, Berkeley Square House, Berkeley Square, London, W1J 6DD. This means that Prima Ekuiti is responsible for determining how and why your personal data is processed.
Please note that our website is not intended for minors and we do not knowingly collect data relating to minors.
Contents
Below is a table of Contents of this Privacy Notice. Please select to skip directly to the different sections of this Privacy Notice to understand our practices and your rights with respect to your information:
Information covered by this Privacy Notice
Third-party sources and publicly available sources
Website usage information and other information collected automatically
How we use personal information
With whom we share personal information
Where we store your personal information
How long we keep your personal information for
Your choices/your privacy rights
How we collect information
Information covered by this Privacy Notice
This Privacy Notice explains how we collect and process personal information. In this Privacy Notice, "personal data" or "personal information" means information that (either in isolation or in combination with other information) enables you to be identified as an individual or recognised directly or indirectly. This may include, but is not limited to, your name, company name, postal address, email address, phone number, company, location, details of the preferences you express to us, your comments and questions, and technical information from the devices you use to access our website.
Information you provide to us
We may collect personal information from you when you access our website, contact us, communicate with us or otherwise provide information to us, including:
· name;
· job title, company name;
· contact information (including email address, phone number, postal address);
· information relating to your online browsing activities on the PEUK website;
· your communication preferences; and
· any other personal data contained within correspondence and communications between you and PEUK (which may include name, age, gender, and education history).
In some cases, you may provide personal information to us about another person. In such cases, it is your responsibility to ensure that you have the authorisation of such person to provide us with such information.
Third-party sources and publicly available sources
We also work closely with third parties (such as business partners and sub-contractors), who may provide us with information which we may combine with the information you have provided to us. We process all personal data we obtain from such other sources in accordance with this Privacy Notice.
Website usage information and other information collected automatically
When you visit our website, we may use cookies and other technologies to automatically collect the following information:
· Technical information, including your IP address, browser type and version, device identifier, location and time zone setting, browser plug-in types and versions, operating system and platform, page response times and download errors;
· information about your visit, including the websites you visit before and after our website; and
· length of visits to certain pages, page interaction information (such as scrolling, clicks and mouseovers) and methods used to browse away from the page.
To learn more about how we use cookies and how to control which cookies are used, please see our Cookie Policy available at [insert link once published].
How we use personal information
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:
· Where we need to perform a contract we are about to enter into or have entered into with you.
· Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
· Where we need to comply with a legal obligation.
· With your consent if required by data protection laws.
We use the personal information we collect from and about you for a variety of purposes and based on one or more legal justifications, as set out below:
Purpose
Information
Justification
To manage our relationship with you, including:
- responding to your comments, queries and other correspondence
- notifying you about changes to our terms or to this Privacy Notice.
We will require certain personal information (such as name, email address, postal address, telephone number, IP address, website usage information, location (country), company name, and any additional personal data provided by you via email or phone) to manage our relationship with you.
· Necessary for our legitimate interests (to operate our business effectively and respond to your queries).
· Performance of a contract, where we have a contract with you or are about to enter into a contract with you.
To maintain our internal records.
We will keep records of your personal information, including but not limited to your name, address, and communication preferences, in order to administer our business.
· Necessary for our legitimate interests (to administer our business).
· Compliance with our legal obligations, where we are required to retain the information by law.
To keep our website safe and secure.
We may need to process your personal information in order to keep our website safe and secure and protect against illegal or fraudulent activity such as cyberattacks.
· Necessary for our legitimate interests (to detect and prevent fraud, other crimes, and the misuse of our website).
· Compliance with our legal obligations.
To collect and analyse information on your recent visits to our website and how you move around different sections of our website.
We may keep collect personal information such as browser type and version, device identifier, location and time zone setting, browser plug-in types and versions, operating system and platform, page response times and download errors, websites you visit before and after our website, length of visits to certain pages, page interaction information and methods used to browse away from the page in order to understand how people use our website so that we can make improvements.
· Necessary for our legitimate interests (to review the performance of our website in order to improve its functionality).
To keep an up-to-date suppression list where you have asked not to be contacted, in order for us to not inadvertently re-contact you.
We understand that you may prefer for us not to contact you with details of our products, services, or promotions. We keep records of your preferences to ensure that we do not contact you if you have asked us not to. We may need to process certain of your personal information (such as your name and email address) in order to do this.
· Necessary for our legitimate interests (to maintain an up-to-date suppression list and ensure that we do not contact you where you have asked us not to).
With whom we share personal information
Your personal information is intended for PEUK, and may be shared with third parties in certain circumstances.
Our website may, from time to time, contain links to and from the websites of our partners, or affiliates. If you follow a link to any of these websites, please note that these websites have their own privacy notices and that we have no control over how they may collect or use your personal information. You should check the privacy notices of third-party websites before you submit any personal information to them.
We may share your personal information with the following third party organisations:
· PEUK's group of companies. We may share your personal information among our group of companies or companies we are affiliated to, in order to administer our business, respond to your questions, and conduct the other activities described in this Privacy Notice.
· Our service providers. We use other companies or contractors ("Service Providers") to perform services on our behalf. We may share personal information with the following categories of Service Provider:
· Infrastructure and IT service providers;
· Insurance companies;
· Legal advisors;
· Auditors; and
· Accountants.
In the course of providing such services, these Service Providers may have access to your personal information. However, we will only provide our Service Providers with the information that is necessary for them to perform the services, and we ask them not to use your information for any other purpose. We will always use our best efforts to ensure that all the Service Providers we work with will keep your personal information secure.
· Third parties permitted by law. In certain circumstances, we may be required to disclose or share your personal information in order to comply with a legal or regulatory obligation (for example, we may be required to disclose personal information to the police, regulators, government agencies or to judicial or administrative authorities). We may also disclose your personal information to third parties where disclosure is necessary for our legitimate interests of protecting or defending our legal rights or where required to do so by Malaysian authorities.
· Third parties connected with business transfers. We may transfer your personal information to third parties in connection with a reorganisation, restructuring, merger, acquisition or transfer of assets. In the event of such a change, we will ask the receiving party to treat your personal information in a manner consistent with this Privacy Notice.
Where we store your personal information
The personal information that we collect from you may be transferred to, and stored at, a destination outside the European Economic Area ("EEA") and/or the UK. It may also be processed by staff operating outside the EEA and/or the UK and who work for us or for one of our Service Providers.
If PEUK sends your information to a country that is not in the EEA and/or the UK, we will take all steps reasonably necessary to ensure that your personal information is protected in accordance with applicable data protection laws, including, where required, entering into EU standard contractual clauses (or equivalent measures) with the party outside the EEA or UK (as applicable) receiving the personal information.
How long we keep your personal information for
We will only retain your personal data for as long as it is reasonably necessary for the purpose for which that data was collected and to the extent permitted by applicable laws (including for the purpose of satisfying any legal, regulatory, tax, accounting or reporting requirements). We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you. When we no longer need to use your information, we will remove it from our systems and records and / or take steps to promptly anonymise it so that you can no longer be identified from it.
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, regulatory, tax, accounting, or other requirements.
Security
We have implemented technical and organisational security measures in an effort to safeguard personal information in our control, including limiting access to personal information only to employees and authorised Service Providers who need to know such information for the purposes described in this Privacy Notice, as well as other technical, administrative and physical safeguards.
While we endeavour to always protect our systems, sites, operations and information against unauthorised access, use, modification and disclosure, due to the inherent nature of the Internet as an open global communications vehicle and other risk factors, we cannot guarantee that any information, during transmission or while stored on our systems, will be absolutely safe from intrusion by others, such as hackers.
Your choices/your privacy rights (if you are in the EEA or the UK)
If you are in the EEA or the UK, you have various rights in connection with our processing of your personal information, each of which is explained below.
· Access. You have the right to request a copy of the personal information we are processing about you. For your own privacy and security, in our discretion we may require you to prove your identity before providing the requested information.
· Rectification. You have the right to have incomplete or inaccurate personal information that we process about you rectified.
· Deletion. You have the right to request that we delete personal information that we process about you, except we are not obliged to do so if we need to retain such data in order to comply with a legal obligation or to establish, exercise or defend legal claims.
· Restriction. You have the right to restrict our processing of your personal information where you believe such data to be inaccurate, our processing is unlawful or that we no longer need to process such data for a particular purpose, but where we are not able to delete the data due to a legal or other obligation or because you do not wish for us to delete it. In such case, we would mark stored personal information with the aim of limiting particular processing for particular purposes in accordance with your request, or otherwise restrict its processing.
· Portability. You have the right to obtain personal information we hold about you, in a structured, electronic format, and to transmit such data to another data controller, where this is (a) personal information which you have provided to us, and (b) if we are processing that data on the basis of your consent or to perform a contract with you and (c) the data is processed by automated means. Additionally, you have the right to require us to transmit such personal data directly to another controller, where technically feasible. This right is not applicable if it adversely affects the rights and freedoms of others.
· Objection. Where the legal justification for our processing of your personal information is our legitimate interest, you have the right to object to such processing on grounds relating to your particular situation. We will abide by your request unless we have compelling legitimate grounds for the processing which override your interests and rights, or if we need to continue to process the data for the establishment, exercise or defence of a legal claim.
· Withdrawing Consent. If you have consented to our processing of your personal information, you have the right to withdraw your consent at any time, free of charge. This includes where you wish to opt out from marketing messages.
You can make a request to exercise any of these rights in relation to your personal information by sending the request by mail to Prima Ekuiti (UK) Limited, Suite 2, 9th Floor, Berkeley Square House, Berkeley Square, London, W1J 6DD or email to privacy@primaekuiti.co.uk. Please note that we may require you to prove your identity before providing the requested information. 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.
You also have the right to lodge a complaint with the local data protection authority if you believe that we have not complied with our data protection obligations. If you are based in, or the issue relates to, the UK, the Information Commissioner’s Office can be contacted as follows:
Telephone: +44 0303 123 1113
Email: casework@ico.org.uk
Website: www.ico.org.uk
Web-form: www.ico.org.uk/concerns/
Address: Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF
If you are based or the issue you would like to complain about took place elsewhere in the European Economic Area (EEA), please click here : http://ec.europa.eu/newsroom/article29/item-detail.cfm?item_id=612080 for a list of local data protection authorities in the countries within the EEA in which we operate.
Note that the rights outlined above only extend to personal information.
Changes to this Privacy Notice
This Privacy Notice is written in English and may be translated into other languages. In the event of any inconsistency between the English version and the translated version of this notice, the English version shall prevail.
We reserve the right to change our Privacy Notice from time to time. If we decide to change our Privacy Notice we will notify you of these changes via an alert on the home page of our global website.
Contact us
If you have any questions about this Privacy Notice and/or about the privacy policies and practices of our service providers, please contact us at privacy@primaekuiti.co.uk, or at: Prima Ekuiti (UK) Limited, Suite 2, 9th Floor, Berkeley Square House, Berkeley Square, London, W1J 6DD.