Thank you for visiting our website at www.pineapplepartnerships.com.
This Policy sets out the basis on which any personal information provided to us by you, or received by us from third parties, will be used by us. Please read this Policy carefully and ensure that you understand our rights and responsibilities under it.
In this Policy, when we refer to Pineapple, or “we”/”us, we mean Pineapple Sustainable Partnerships Limited, a company registered in England and Wales under company number 10624252 and have our registered office at Stocks Lane Farmhouse, 29 Stocks Lane, Steventon, Abingdon OXON OX13 6SS.
This policy implements the changes introduced by the General Data Protection Regulations (GDPR). Any revisions we make to our Policy in the future will be posted on this page.
Please check back frequently to see any updates or changes to our Policy.
We are committed to protecting and respecting your privacy.
INFORMATION WE COLLECT AND HOW
"Personal information" is any information that can be used to identify you or that we can link to you and which we have in our possession or control. Such information is defined by the GDPR as “any information relating to an identified or identifiable natural person; an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person”
INFORMATION WE OBTAIN FROM YOU
We may process information contained in or relating to any communication that you send to us (such as when you sign up for our newsletter, events, or enquire about our services), whether through the Site, by email, through social media, or otherwise. All of this information together is correspondence information. This may include the communication content and metadata associated with the communication, as well as any contact details you provide to us such as your name, your employer or business name, email address, phone number, job title, address or social media username. We process correspondence information for the purposes of communicating with you and record-keeping.
In connection with our provision of products and services, we may process information contained in any enquiry you submit to us indicating your interest in our services or business (enquiry information), such as the contents of your enquiry and any contact details you provide to us such as your name, email address, phone number, job title or address. We process enquiry information for the purposes of addressing your enquiry and providing you with occasional news about our services and operations.
Client Set-Up Information
Where we enter into a business relationship with you so as to provide services, we may process information for the purposes of setting you up as a client on our systems, such as your name and contact details. We may also process personal information contained within the correspondence and documentation, whether created by us or provided to us. We call this Client Set-Up Information and we process it for the purposes of providing our professional services and for record keeping purposes.
When you apply for a role with us you may provide us with your full name, date of birth, nationality, education and qualification details, your gender, your CV, photograph, passport details, marital status, home address and home telephone number, mobile telephone number, utility bill and other details set out in your application. We will process this information for the purposes of communicating with you and progressing your application.
We may contact you directly via LinkedIn, Twitter and other social media sites to obtain your email address. This is so that we can conduct a business discussion with you relating to our projects, products and services. We will not send you marketing mailings unless you have consented to do so.
We may process information about your use of the Site (usage information). This may include your geographical location, browser type and version, operating system, referral source, length of visit, page views and website navigation paths, as well as information about the timing, frequency and pattern of your use. This information is obtained through Google Analytics and will be aggregated and anonymised in such a way that it contains no information pertaining to any identifiable individual at all. Whilst it is not actually personal information, we have addressed it for completeness in this Policy. We process usage information for the purpose of improving our Site.
We may process information relating to transactions, such as bank account details, contact details or transaction information in relation to payments made by us to you or by you to us (transaction information). This may include your contact details, any bank account or sort code information provided for the purposes of making payment, and the transaction details (such as POs or invoices). The transaction information may be processed for the purpose of supplying or receiving and administering the relevant services and keeping proper records of those transactions, and for making and receiving payments.
INFORMATION WE OBTAIN FROM OTHERS
Your personal information may be provided to us by someone other than you: for example, by your employer, by an organisation with whom you and we are both dealing or by someone who wishes to refer you to us or vice versa. Normally this information will be correspondence information, enquiry information or client set-up information as described above and will be processed by us for the purposes described above.
If you apply for a position with us we may collect personal information relating to past employment, qualifications and education, opinions from third parties about you, past employment history and other details about you, which will be provided to us by a third party that provides background screening services to us.
If we collect or receive your personal information in the context of our provision of services we might receive information from third parties such as your employer, other parties relevant to the services we are providing (e.g. counterparties in transactions) and others such as regulators and authorities. That information could include your name, contact details, employment details and other information relevant to the services that we are providing to partners / clients.
HOW WE USE THE INFORMATION WE COLLECT
We will process information with particular regard to Article 6 GDPR:
For the performance of a contract with you, or to take steps at your request prior to entering into a contract with you (Article 6(1)(b) GDPR). This may be our basis for processing correspondence information, enquiry information,client set-up information and transaction information.
For our legitimate interests (Article 6(1)(f) GDPR). This may be our basis for processing:
correspondence and client-set up information (as we have an interest in properly administering our business and communications);
enquiry information (as we have an interest in developing our business with interested parties).
transaction information (as we have an interest in making and receiving payments promptly and in recovering debts).
any personal information identified in the other provisions of this Policy where necessary in connection with legal claims (as we have an interest in the protection and assertion of our legal rights, your legal rights and the legal rights of others).
any of the personal information identified in the other provisions of this Policy in connection with backups of any element of our IT systems or databases containing that personal information (as we have an interest in ensuring the resilience of our IT systems and the integrity and recoverability of our information).
We may also process any of your personal information where such processing is necessary for compliance with a legal obligation to which we are subject (Article 6(c) GDPR), or in order to protect your vital interests or the vital interests of another individual (Article 6(d) GDPR).
HOW WE SHARE INFORMATION
We share personal information with our data processors, such as accounting software platform, payroll bureau, email platform, shared server, online file server and website provider. As a result, your personal information may be transferred to locations outside Europe as well as within it for the purposes described above.
We may disclose your personal information to our insurers and/or professional advisers as necessary for the purposes of obtaining and maintaining insurance coverage, managing risks, obtaining professional advice and managing legal disputes.
We may disclose personal information to our suppliers or subcontractors in connection with the uses above. For example, we may disclose any personal information in our possession to suppliers which host the servers on which our information is stored or transaction information and other relevant personal information for the purposes of debt recovery.
We only permit third parties to process your personal information for specified purposes and in accordance with our instructions, so for example third parties relevant to the services we provide.
We may also have to disclose your personal information in order to comply with any legal obligation, or to protect the rights, property, or safety of us, our clients, or others.
In the event that we sell or buy any business or assets, we may have disclose your personal information to the prospective seller or buyer of such business or assets.
If we, or substantially all of our assets, are acquired by a third party, in which case personal information held by it about its customers may be one of the transferred assets.
RETENTION AND DELETION OF YOUR INFORMATION
Personal information that we process for any purposes shall not be kept for longer than is necessary for those purposes.
We will retain and delete your personal information as follows:
Usage information (which is anonymised, and not personal information) may be retained by us indefinitely.
Enquiry and correspondence information will be retained for the period of the enquiry, chain of correspondence or business relationship and then deleted after twelve months.
Client set-up and transaction information will be retained for six years after performance of the relevant service or transaction.
Keeping your information secure is of great importance to us. We limit access to your personal information to those employees or advisors who have a business need to know. They will only process your information on our instructions. In the unlikely event of any personal data breach we will notify you.
Whilst we do our best to ensure the security of personal information provided to us (and to use only reputable service providers), any transmission of data 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.
You have a number of principal rights under Sections 2, 3 and 4 of the GDPR, which have been summarised below.
You may find it helpful to read the guidance published by the Information Commissioner’s Office (www.ico.org.uk) for a more comprehensive understanding of your rights:
The right to access - right to obtain confirmation as to whether or not personal information concerning you is being processed, and where that is the case, access to the personal information. This right includes the provision of information such as, the purposes of the processing, categories of personal information concerned, recipients or categories of recipient to whom the personal information have been or will be disclosed.
The right to rectification - the right to obtain without undue delay the rectification of inaccurate personal information concerning you, and any incomplete information completed.
The right to erasure - you have the right for personal information to be erased without undue delay where you withdraw consent for the processing, or the personal information is no longer necessary in relation to the purposes for which they were collected or otherwise processed or unlawfully processed or for the purpose of regulatory compliance.
The right to restrict processing - You have the right to restrict processing in certain circumstances. Where processing has been restricted on this basis, we may continue to store your personal information and will observe the restrictions on processing except in the case of processing permitted by applicable law (for example, in connection with legal claims or for reasons of public interest).
The right to object to processing - You have the right to object to our processing of your personal information, unless we can demonstrate compelling legitimate grounds for the processing which override your interests, rights and freedoms of or for the establishment, exercise or defence of legal claims You also have the right to object to our processing of your personal information for direct marketing purposes. If you do, we will stop processing your personal information for this purpose.
The right to data portability - you have the right to receive personal information concerning you, which you have provided to us, in a structured, commonly used and machine-readable format. However, this right does not apply where it would adversely affect the rights and freedoms of others.
The right to complain to a supervisory authority - If you consider that our processing of your personal information infringes data protection laws.
THIRD PARTY WEBSITE LINKS
Our website may contain links to third party websites and/or make reference to third party service providers and other entities. If you follow a link to any third party website or deal with any third party entity referred to on our website, then please note that these third parties may have their own privacy and cookie policies, and we are not responsible for their use of any personal information which you may provide to them. You should ensure that you have read and understood any relevant policies.
If you have any questions, comments or requests then you can contact us:
Thank you for visiting our site.
Last reviewed: May 2018