Privacy Policy

INTRODUCTION

Welcome to Red Hot Penny Limited’s (“Red Hot Penny”) privacy notice.

Red Hot Penny respects your privacy and is committed to protecting your personal data. This privacy notice will inform you of how we look after your personal data when you visit our website and tell you about your privacy rights and how the law protects you. Please read the policy carefully. By continuing to use our site and by submitting personal data to us, you are agreeing to the terms of this privacy policy.

 

1. IMPORTANT INFORMATION AND WHO WE ARE

1.1 PURPOSE OF THIS PRIVACY NOTICE

This privacy notice aims to give you information on how Red Hot Penny collects and processes your personal data through your use of this website.

It is important that you read this privacy notice together with any other privacy notice or fair processing notice we may provide on specific occasions when we are 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 the other notices and is not intended to override them.

1.2 CONTROLLER

Red Hot Penny Limited (company number: 09605163) having its registered office at Beechey House, 87 Church Street, Crowthorne, Berkshire, England, RG45 7AW is the controller and responsible for your personal data (collectively referred to as Red Hot Penny, “we”, “us” or “our” in this privacy notice).

We have appointed a data protection officer (DPO) 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 rights, please contact the DPO using the details set out below.

1.3 CONTACT DETAILS

Full name of legal entity: Red Hot Penny Limited
DPO: Darren Bull
Email address: dpo@redhotpenny.com
Postal address: Beechey House, 87 Church Street, Crowthorne, Berkshire, England, RG45 7AW

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.

1.4 CHANGES TO THE PRIVACY NOTICE AND YOUR DUTY TO INFORM US OF CHANGES

We keep our privacy policy under regular review and we will update it from time to time. We will inform you via email or via the site if the changes are significant. This version was last updated on 29th March 2019.

It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.

1.5 THIRD-PARTY LINKS

This website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements.

 

2. THE DATA WE COLLECT ABOUT YOU

Personal data is any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data) and it is used only to assist us in providing an effective service on this website. We monitor the use of this website through the use of cookies.

We may collect, use, store, share and transfer different kinds of personal data about you which we have grouped together follows:

  • Contact information, such as your name, job title including your business address, where you have provided this to us, telephone number, mobile phone number and email address;
  • Marketing and Communications Data includes your preferences in receiving marketing;
  • Usage Data includes information about how you use our website;
  • from us and your communication preferences; and/or
  • Aggregated Data includes statistical or demographic data for any purpose. It may be derived from your personal data but is not considered personal data in law as this data does not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature.

 

3. HOW IS YOUR PERSONAL DATA COLLECTED?

We may collect personal data about you in a number of circumstances, including

  • when you provide it to us e.g. by contacting us for marketing services or signing up for content such as our newsletters.
  • from your use of our website, using cookies and
  • When you sign up to receive personal data from us ; or
  • When your organisation offers to provide services to us.

In some circumstances, we collect personal data about you from a third party source.

 

4. HOW WE USE YOUR PERSONAL DATA

We will only use your personal data when the law allows us to, in the following circumstances:

  • where you have given us consent by express permission to process personal data for a specified purpose.
  • where we need to use it to perform the 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.

 

5. PURPOSES FOR WHICH WE WILL USE YOUR PERSONAL DATA

We may use your personal data for the following purposes only:

  • Managing and administering your organisation’s business relationship with Red Hot Penny, including processing payments, billing and support services;
  • Providing marketing advice or other services or things you may have requested, including on-line services or solutions as instructed or requested by you or your organisation;
  • To analyse and improve our services and communications to you;
  • For monitoring and assessing compliance with our policies and standards;
  • For any purpose related and/or ancillary to any of the above or any other purpose for which your personal data was provided to us.

Where you have expressly given us your consent, we may process your personal data also for the following purposes:

  • Communicating with you through the channels you have approved to keep you up to date on the latest marketing developments, announcements, and other information about Red Hot Penny services as well as events and projects;
  • Customer surveys, marketing campaigns, market analysis, other promotional activities or events; or
  • Collecting information about your preferences to create a user profile to personalise and foster the quality of our communication and interaction with you (for example, by way of newsletter tracking or website analytics).

 

6. MARKETING

We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising.

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 services from us and, in each case, you have not opted out of receiving that marketing.

 

7. OPTING OUT

You can ask us to stop sending you marketing messages at any time by Contacting us at any time. 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, or other transactions.

 

8. COOKIES

A cookie is a small file of letters and numbers that we put on your computer if you agree. These cookies allow us to distinguish you from other users of our website, which helps us to provide you with a good experience when you view or use our website and also allows us to improve our site.

We provide detailed information about cookies and how to manage them within our Cookie Policy. If you disable or refuse cookies, please note that some parts of the website may become inaccessible or not function properly.

 

9. 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.

 

10. 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:

  • Internal Third Parties: other companies in our group who are based in the EU.
  • External Third Parties: service providers, partners and sub-contractors based in the EU or Worldwide, professional advisers based in the EU.
  • Third parties to whom we may choose to sell, transfer, or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy notice.
  • Other parties such as HM Revenue & Customs and law enforcement agencies where we are under a duty to comply with a legal obligation, or to protect our rights, or to protect the rights, property or safety Red Hot Penny, our customers or others.

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.

 

11. INTERNATIONAL TRANSFERS

We do not transfer your personal data outside the European Economic Area (EEA).

 

12. DATA SECURITY

We will take appropriate technical and organisational measures to keep your personal data confidential and secure in accordance with our internal procedures covering the storage, disclosure of and access to personal data. Personal data may be kept on our personal data technology systems, those of our contractors or in paper files.

 

13. 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 you can ask us to delete your data: see Request erasure below for further information.

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.

 

14. YOUR LEGAL RIGHTS

Subject to certain legal conditions, you have the right to request a copy of the personal data about you which we hold, to have any inaccurate personal data corrected and to object to or restrict our using your personal data. You may also make a complaint if you have a concern about our handling of your personal data.

If you wish to do any of the above please Contact Us. We may request that you prove your identity by providing us with a copy of a valid means of identification in order for us to comply with our security obligations and to prevent unauthorised disclosure of data. We reserve the right to charge you a reasonable administrative fee for any manifestly unfounded or excessive requests concerning your access to your data, and for any additional copies of the personal data you request from us.

We will consider any requests or complaints which we receive and provide you with a response in a timely manner. If you are not satisfied with our response, you may take your complaint to the relevant privacy regulator. We will provide you with details of your regulator upon request.