Last Updated: July 14, 2020
- Information About Us
PENG is provided by Ecospend Technologies Limited, a limited company registered in England under company number 11114967. Registered address: 1 Bray Place, London, UK, SW3 3LL. We are certified by the Financial Conduct Authority, registration number 829713.
- What Does This Policy Cover?
- What Is Personal Data?
Personal data is defined by the General Data Protection Regulation (EU Regulation 2016/679) (the “GDPR”) and the Data Protection Act 2018 (collectively, the Data Protection Legislation) as any information relating to an identifiable person who can be directly or indirectly identified in particular by reference to an identifier. Personal data is, in simpler terms, any information about you that enables you to be identified. Personal data covers obvious information such as your name and contact details, but it also covers less obvious information such as identification numbers, electronic location data, and other online identifiers.
- What Are My Rights?
- What Data Do You Collect and How?
Depending upon your use of PENG, we may collect and hold some or all of the personal and non-personal data set out in the table below, using the methods also set out in the table. We do not collect any special category or sensitive personal data AND/OR personal data relating to children AND/OR data relating to criminal convictions and/or offences.
Data Collected: Identity Information including name and email
How We Collect the Data: User Input
Data Collected: Technical information including IP address and browser type
How We Collect the Data: System and Analytics Tools
- How Do You Use My Personal Data?
Under the Data Protection Legislation, we must always have a lawful basis for using personal data. The following table describes how we may use your personal data, and our lawful bases for doing so:
What We Do: Communicating with you or supplying you with information by email that you have opted-in-to (you may opt-out at any time), What Data We Use: Email , Our Lawful Basis : We want to make you aware of: The outcome of the actions you make on PENG, company updates and new products.
With your permission and/or where permitted by law, we may also use your personal data for marketing purposes, which may include contacting you by email with information, news, and offers on our products and services. You will not be sent any unlawful marketing or spam. We will always work to fully protect your rights and comply with our obligations under the Data Protection Legislation and the Privacy and Electronic Communications (EC Directive) Regulations 2003, and you will always have the opportunity to opt-out. We will always obtain your express opt-in consent before sharing your personal data with third parties for marketing purposes and you will be able to opt-out at any time.
- How Long Will You Keep My Personal Data?
We will not keep your personal data for any longer than is necessary in light of the reason(s) for which it was first collected. Your personal data will therefore be kept for the following periods (or, where there is no fixed period, the following factors will be used to determine how long it is kept):
Type of Data: Identity Information including Name and Email address
How Long We Keep It: Until you opt-out
Type of Data: Technical information including IP address and browser and browser type
How Long We Keep It: Until you opt-out
- How and Where Do You Store or Transfer My Personal Data?
We will only store or transfer your personal data within the UK. This means that it will be fully protected under GDPR Legislation.
- Do You Share My Personal Data?
- Can I Withhold Information?
You may access certain areas of PENG without providing any personal data at all. However, to use all features and functions available on PENG you may be required to submit or allow for the collection of certain data.
- How Can I Access My Personal Data?
If you want to know what personal data, we have about you, you can ask us for details of that personal data and for a copy of it (where any such personal data is held). This is known as a subject access request or SAR. All subject access requests should be made in writing and sent to the email or postal addresses shown in Part 12. To make this as easy as possible for you, a Subject Access Request Form is available for you to use.
You do not have to use this form, but it is the easiest way to tell us everything we need to know to respond to your request as quickly as possible. There is not normally any charge for a subject access request. If your request is manifestly unfounded or excessive (for example, if you make repetitive requests) a fee may be charged to cover our administrative costs in responding. We will respond to your subject access request within three weeks and, in any case, not more than one month of receiving it. Normally, we aim to provide a complete response, including a copy of your personal data within that time. In some cases, however, particularly if your request is more complex, more time may be required up to a maximum of three months from the date we receive your request. You will be kept fully informed of our progress.
- How Do I Contact You?
To contact us about anything to do with your personal data and data protection, including to make a subject access request, please use the following details [(for the attention of Data Protection Officer, Ecospend Technologies Limited:
Email address: firstname.lastname@example.org.
Postal Address: 1 Bray Place, London, SW3 3LL.