Privacy Policy

At Pangolin Ltd we take the issue of your Privacy very seriously.  You share your data with us so that we can help your company reach its potential and that is a privilege and responsibility we take very seriously. The following Privacy Policy details what personal data we collect as a company, and how, as a company we deal with it.  Please read the following carefully to understand our views and practices regarding your personal data and how we will treat it.  For the purposes of data protection legislation, the data controller is Pangolin Ltd of 2 Finsbury Avenue, London. Our ICO registration number is ZA341509.

Who we are and what we do

Pangolin Ltd is a consultancy firm, helping start-ups and SMEs across different sectors find the best solutions to their problems. With a focus on Data Protection, Data Security, Dispute Resolution and general advice, Pangolin allows clients to reach their true potential. 

• We collect personal data of the following types of people to allow us to undertake our business;
• You our customer and your employees we interact with;
• Your personal and company data which you share with us when you enquire about using the Pangolin service
• If you are a private individual or sole trader we may have your personal data;
• Supplier contacts to support our services;
• Our own Employees, consultants, temporary workers; and
• Any information you give us about you to carry out our core business and ancillary activities.

Information you give to us or we collect about you. 

This is information about you that you give us by filling in forms/ sending emails to us our Pangolin Ltd website (our Site)  or by corresponding with us by phone, e-mail or otherwise. It includes information you provide when you register to use our site, to enter our database, enquire for our services, or complete a feedback survey, and when you report a problem with our site.  It also includes any personal data you may provide to a third party on behalf of whom we process your data for. This includes:

• Name;
• Address;
• Company Information;
• Due diligence information;
• Personal data of your employees;
• Correspondence history; 
• Supporting information for consultancy services; and
• Associated photographic information and evidence.

This is stored in our systems and will be only used to the extent permitted by you.

Information we collect about you when you visit our website. 

With regard to each of your visits to our site or system we will may collect information such as technical information, including the Internet Protocol (IP) address used to connect your computer to the Internet, your login information if applicable, browser type and version, browser plug-in types and versions, operating system and platform.

Purposes of the processing and the legal basis for the processing

We use information held about you in the following ways:

To carry out our obligations arising from any contracts we intend to enter into or have entered into between you and us and to provide you with the information, products and services that you request from us in terms of your specific business needs.

The core service we offer to our customers is , consisting of the following:

Our legal basis for the processing of personal data is our legitimate business interests, described in more detail below, although we will also rely on contract, legal obligation and consent for specific uses of data.

Our Legitimate Business Interests

Our legitimate interests in collecting and retaining your personal data is described below:

As a consultancy our legitimate interest includes for the purposes strictly necessary to allow our  clients to reach their potential.

In particular we rely on our legitimate business interest of improvement of client businesses to retain data on certain companies to ensure they stay secure & compliant.

This includes retaining such information on an ongoing basis so that we can continue to help our partners and clients in the future

Fulfil a legal obligation

We rely on the fulfilment of a legal obligation if we are to disclose any data relating to our clients as part for a criminal or civil investigation by the relevant authorities as required by the law.

Consent

We rely on your consent to retain your data. Your personal details will not be used in ways to which you have not consented, either via implied or explicit consent.  All personal data provided by our prospective clients through this web site is provided under explicit consent (via our web forms) or implied consent via other mediums.

Other Uses we will make of your data:

• Use of our website;
• To notify you about changes to our service;
• To ensure that content from our site is presented in the most effective manner for you and for your computer.
• We will use this information:
• To administer our site and for internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes;
• To improve our site to ensure that content is presented in the most effective manner for you and for your computer; 
• To allow you to participate in interactive features of our service, when you choose to do so; 
• As part of our efforts to keep our site safe and secure; 
• To measure or understand the effectiveness of advertising we serve to you and others, and to deliver relevant advertising to you; 
• To make suggestions and recommendations to you and other users of our site about goods or services that may interest you or them.

Cookies  

Our website uses cookies to distinguish you from other users of our website. This helps us to provide you with a good experience when you browse our website and also allows us to improve our site. For detailed information on the cookies we use and the purposes for which we use them see our Cookie notice.

Disclosure of your information inside and outside of the EEA

Information may be accessed by those who have travelled or reside outside of the EEA, however we do currently envisage making any. 

As a global service we may also transfer data outside of the EEA to service providers located in such areas, in such circumstances we will seek to ensure that appropriate safeguards are put in place, and perform the necessary due diligence.Selected third parties may include:

• Clients, business partners, suppliers and sub-contractors for the performance and compliance obligations of any contract we enter into with them or you;
• Subcontractors including email marketing specialists, event organisers, payment and other financial service providers;
• Analytics and search engine providers that assist us in the improvement and optimisation of our site.

There are certain third parties we work with to help us to delivery to you the best service we can. In order to achieve this we use a number of third party tools which are carefully chosen to assist us in providing the best service we can, including:

• Amazon Web Services, our hosting partner. We use Amazon, a top tier data hosting service, to host our service and keep  our data safe.
• Xero accountancy software to manage accounts and payment systems.
• G:Suite to manage our documents and emails and to keep our data secure.
• LinkedIn to contact with other companies to develop business opportunities.
• Slack communication system.
• Business partners, suppliers and sub-contractors for the provision of the Pangolin Ltd service to you.
• Analytics and search engine providers that assist us in the improvement and optimisation of our site.

We will disclose your personal information to third parties:

In the event that we sell or buy any business or assets, in which case we will disclose your personal data to the prospective seller or buyer of such business or assets.

If Pangolin Ltd or substantially all of its assets are acquired by a third party, in which case personal data held by it about its customers will be one of the transferred assets.

If we are under a duty to disclose or share your personal data in order to comply with any legal obligation, and other agreements; or to protect the rights, property, or safety of Pangolin Ltd, our customers, or others. This includes exchanging information with other companies and organisations.

The lawful basis for the third party processing will include:

• Their own legitimate business interests in processing your personal data,
• Satisfaction of their contractual obligations to us as both a data controller and data processor;
• for the purpose of a contract in place or in contemplation;
• To fulfil our legal obligations.

Where we store and process your personal data  

The data that we collect from you will be stored Amazon servers within the EEA however it may be transferred to, and accessed, in destinations outside the European Economic Area (”EEA”).

It may be transferred to third parties outside of the EEA for the purpose of fulfilling our services. It may also be processed by staff operating outside the EEA who work for us or for one of our suppliers. This includes staff engaged in, among other things, our services and the provision of support services. By submitting your personal data and that of your users you agree to this transfer, storing or processing. Pangolin Ltd LTD will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this privacy notice.

All information you provide to us is stored on our secure servers. Any payment transactions will be encrypted using SSL technology or through bank transfer. Where we have given you (or where you have chosen) a password which enables you to access certain parts of our system, you are responsible for keeping this password confidential. We ask you not to share a password with anyone.

Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted to our site; any transmission is at your own risk. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorised access.

Retention of your data

We understand our legal duty to retain accurate data and only retain personal data for as long as we need it for our legitimate business interests and that you are happy for us to do so. Accordingly, we regularly review our use of data with the aim of removing data that we no longer have a legitimate business interest in maintaining.

At the end of our contract with you we will delete data in line with our contractual provisions/ as agreed, however please note that any machine learning over processes and techniques will stay with us as part of our IP.

Your rights  

You have the right to ask us not to process your personal data for marketing purposes. We will usually inform you (before collecting your data) if we intend to use your data for such purposes or if we intend to disclose your information to any third party for such purposes and we will collect express consent from you if legally required prior to using your personal data for marketing purposes.

The GDPR provides you with the following rights to:

Request correction

Of the personal information that we hold about you. This enables you to have any incomplete or inaccurate information we hold about you corrected.

Request erasure

Of your personal information. This enables you to ask us to delete or remove personal information where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal information where you have exercised your right to object to processing (see below).

Object to processing

Of your personal information where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground. You also have the right to object where we are processing your personal information for direct marketing purposes.

Request the restriction of processing

Of your personal information. This enables you to ask us to suspend the processing of personal information about you, for example if you want us to establish its accuracy or the reason for processing it.

Request the transfer

Of your personal information to another party in certain formats, if practicable.

Make a complaint

To a supervisory body which in the United Kingdom is the Information Commissioner’s Office. 

Password Restrictions

At Pangolin Ltd Limited we require all passwords to be changed at regular intervals and to be of minimum complexities. We would ask that if you are a user of our system that you keep your password safe and report any loss/breach of your passwords to us as soon as practically possible.

Access to information

The Data Protection Act 2018 and the GDPR give you the right to access information held about you. We also encourage you to contact us to ensure your data is accurate and complete.

Your right of access can be exercised in accordance with the Act (and the GDPR once it is in force).

A subject access request should be submitted to our Data Protection Officer. No fee will apply as laid down by the GDPR.

Changes to our privacy notice

Any changes we make to our privacy notice in the future will be posted on this page and, where appropriate, notified to you by e-mail. Please check back frequently to see any updates or changes to our privacy notice.

Contact

If you have any questions or require further information please do not hesitate to contact us on Mike@pangolindpc.co.uk .