About us

SPML is part of the Punter Southall group of businesses and we are the data controller in respect of your personal data. This means that we are responsible for deciding how and why we hold and use your personal data. If you want to contact us directly our business contact details are:

Registered office:

11 Strand, London

WC2N 5HR

(under company number 06194826)

Telephone:

020 3327 5500

Group website:

www.puntersouthall.com

Our Data Protection Officer is Richard Garmon-Jones and can be contacted using the details above or by emailing data.protection@puntersouthallgroup.com.

Personal data we may collect

The specific types of personal information we may collect, and use, will depend upon your use of our sites and services, as well as the information you choose to provide. We will only collect your personal data in line with applicable laws.

We collect your personal data in various ways:

• Directly from you, when you choose to sign up for our mailings or other services or products, when you browse our sites, attend our events (online or in person), complete our surveys, or contribute to our publications and/or at our events.
• Automatically when you visit our sites including, but not limited to, traffic data, location data, other communication data, and the resources you access.

The types of personal information we may collect from you include:

• Name, phone number, email address.
• Address (current or permanent).
• Job title or position and company name (where applicable).
• Marketing preferences.
• Call recordings and/or voicemails.
• Comments, opinions and photos, but only if attending our events, completing our surveys, or contributing to our publications.

Aggregate and/or anonymous data

We may aggregate and/or anonymise any personal information collected through the facilities offered so that such information can no longer be linked to you or your device. We may use this information for any purpose and may share this data with our third parties.

Personal data we obtain from third parties

We may collate publicly available data from third parties and add this into our contact and company records for you.

Why we collect and use your personal data

We, or our data processors, use your information for various purposes depending on the types of information we have collected from and about you and the specific facilities, services or products you use. In particular, we collect and process your information for the following purposes:

• To provide you with newsletters, information about our forthcoming events and marketing communications.
• To contact you in response to your enquiry about products and/or services we offer.
• To allow you to participate in interactive features of our service, where you choose to do so.
• To enter into contracts with you and carry out our obligations arising from any contracts entered into between you and us, including to provide you with the products and/or services you have requested.
• To enhance and improve our services and ensure the security of our site(s) facilities.
• To analyse marketing campaigns.
• To report a problem with our site(s).
• To notify you about any changes to our service.
• For record keeping and staff training purposes.

Our legal basis for processing your data

We only process personal data where we have a legal basis to do so. Please note that we may process your personal data for more than one legal ground, depending on the specific purpose for using your data. The legal bases for using your information are as follows:

• Where you make an enquiry, ask a question or request information on a service or product, or report a problem, we rely on the lawful bases of processing of legitimate interest or performance of a contract to use your information.
• Where we provide you with site facilities, services or products you’ve requested, use of your information is necessary to provide those, or to perform our obligations under the terms of any contract we have with you.
• Where we collect your information automatically, or you respond to a survey, we use your information for our legitimate business interests.  Our legitimate interests are to provide security for our sites, operate our business and provide our services and products, ensure safe environments for our staff and visitors to our offices, comply with legal requirements and defend our legal rights, prevent fraud, and to provide our facilities, services or products in the best way for our clients and ourselves.
• Where you agree to receive marketing communications from us via our sites or otherwise, we rely on the lawful basis of your consent.

Who we share your personal data with

In providing our site facilities, services and products to you, we may share your personal information with our service providers. These include the organisations that provide, develop and support our telecommunications and IT infrastructure including our sites and contacts management systems, as well as other professional service providers. We have written contracts with these processors which include essential protections for your data.

Where we process your personal data outside the EEA

We do not seek to transfer and process your data outside the United Kingdom or European Economic Area (“EEA”). However, on some occasions it may be that some of our service providers are based, or provide part of their services, from outside the EEA. If that ever occurs, we will always look to ensure that the data is protected in one of the ways approved under Data Protection Laws.

You can obtain further information regarding the mechanisms used to safeguard your data by contacting our Data Protection Officer at the contact details listed above.

How long we will keep your personal data

We will only keep your personal data for as long as we need to in order to fulfil the purposes for which it was collected, as set out in this privacy policy, and for as long as we are required to keep it by law.

To ensure we meet our obligations we have a designated data retention policy that indicates when personal information should be disposed of. For more information on this, contact our Data Protection Officer, Richard Garmon-Jones. We securely dispose of personal data when it is no longer needed.

If you have opted out of receiving all email marketing communications, we will suppress your data so that we do not, unknowingly, send you marketing emails.

Cookies and similar technologies

When we collect information automatically (see above), we and our service providers use internet server logs, cookies, tags, software development kit, tracking pixels and other similar tracking technologies. We use these technologies in order to offer you a more tailored experience in the future, by understanding and remembering your particular browsing preferences. As we adopt additional technologies, we may also gather information through other methods.

We also use cookies to measure the effectiveness of our marketing communications, for example they tell us if you have opened a particular marketing email. For more information on the cookies we use, the purposes for which we use them and how you can control them please refer to our Cookies Policy.

Marketing and research

You have choices when it comes to receiving marketing communications and taking part in market research. We will send you relevant news about our products and services in a number of ways including by email, but only if you have previously agreed to receive these marketing communications. You can unsubscribe at any time using the ‘Unsubscribe’ button on any of our emails, or by contacting us online, by phone, or in writing.

We would also like to hear your views to help us to improve our services and products so we may contact you for market research purposes. You always have the choice about whether to take part in our market research.

How to access and control your personal data: your rights

You have certain rights with respect to your information which are summarised below. Some of the rights are complex; therefore, not all details are included in the summary:

• Right to be informed: at the time your information is collected, you should be given, or can ask for information about how your information is collected and used. A copy of this privacy policy can be printed via your website browser.
• Right of access: you can ask for copies of all the information that we process about you.
• Right to rectification: you can ask to have inaccurate information held about you corrected.
• Right to erasure: you can ask for the information held about you to be erased (subject to certain criteria).
• Right to restriction of processing: you can ask us to stop processing your information (under certain circumstances).
• Right to data portability: you can, under certain circumstances, request that we transmit your personal information to another provider of services;
• Right to object: you can object to your information being processed if our legal basis for processing your information is based on a “legitimate interests”. To check whether we use your information for “legitimate interests” see the section “Why we collect and use your personal data”.

If you would like to exercise any of your rights mentioned above, you can do so by writing or emailing our Data Protection Officer at the address detailed above.

Automated decision making

We do not undertake any full automated decision making (i.e. without human intervention) in relation to you.

Your right to withdraw consent

Where you have provided consent for us to process your information, you can withdraw your consent at any time. Please note that withdrawal will not affect the lawfulness of processing prior to you withdrawing your consent.

You can withdraw your consent to our use of your data by contacting our Data Protection Officer as detailed above.

Where you have consented to receive marketing communications, you can also withdraw your consent to receive our emails by using the unsubscribe button on any marketing email received from us.

Your right to make a complaint

If you have a complaint about the way we process your personal information or think that we have not complied with your rights, this is also something we’d like to resolve with you directly if possible. In the first instance, please contact our Data Protection Officer as detailed above.

While we would always wish to have the opportunity to address your data privacy complaint, you also have the right to refer it to the ICO:

The Information Commissioners Office:
Wycliffe House
Water Lane
Wilmslow

Cheshire
SK9 5AF

Telephone:

0303 123 1113 or 01625 545745
Fax:

01625 524510
Website:

www.ico.org.uk

Changes to this policy

You will be informed of changes to this policy by dedicated service emails or by notification on our sites.