Our website address is: https://propella.uk. Propella.uk is a subsidary of The Pay Index Limited (www.thepayindex.com)
1. Information About Us
The Pay Index is owned and operated by The Pay Index Limited, a limited company registered in England under company number 12098755 and with its registered address c/o Haines Watts (Berkhamsted) Ltd at 4 Claridge Court Lower Kings Road, Berkhamsted, Hertfordshire HP4 2AF, UK.
2. What Does This Policy Cover?
3. 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, along with superseding legislation, “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. It does not include data where the identity has been removed (anonymous data).
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.
4. What Data we collect about you?
We may collect, use, store and transfer different kinds of personal data about you which is captured as encrypted. We have grouped together such data as follows:
- Identity Data includes name (optional), username or similar identifier and gender.
- Contact Data includes billing address, email address and telephone number (where appropriate).
- Transaction Data includes details about payments to and from you and other details of products and services you have purchased from us.
- Technical Data includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, and other technology on the devices you use to access this website.
- Profile Data includes your username and password, purchases or orders made by you, preferences, feedback and survey responses.
- Usage Data includes information about how you use our website, products and services.
- Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.
We do not collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health, and genetic and biometric data). Nor do we collect any information about criminal convictions and offences.
5. How is Your Personal Data Collected
We use different methods to collect data from and about you including through:
- Direct interactions. You may give us your Identity and Contact Data by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:
- apply for our products or services;
- create an account on our website;
- subscribe to our service or publications;
- request marketing to be sent to you;
- enter a competition, promotion or survey; or
- give us feedback or contact us.
- Automated technologies or interactions. As you interact with our website, we will automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies, and other similar technologies. We may also receive Technical Data about you if you visit other websites employing our cookies. Please see below how we use our cookies for further details.
- Third parties or publicly available sources. We will receive personal data about you from various third parties and public sources as set out below:
Technical Data from the following parties:
(a) our partners;
(b) analytics providers;
(c) advertising networks; and
(d) search information providers.
- Contact and Transaction Data from providers of technical, payment and delivery services.
- Identity and Contact Data from data brokers or aggregators.
- Identity and Contact Data from our partners and publicly available sources.
6. Purposes for Which We Use Your Personal Data?
Under the Data Protection Legislation, we must always have a lawful basis for using personal data.
Most commonly, we will use your personal data in the following circumstances:
- where we need 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.
The following table describes how we will use your personal data, the purposes for which we use your personal data, and our lawful basis for doing so.
Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below
|What We Do||What Data We Use||Our Lawful Basis|
|Registering you on The Pay Index.||Login details and/or contact details||Legitimate Interests, Performance of Contract|
|Providing and managing your Account||Login details and/or contact details||Legitimate Interests, Performance of Contract|
|Providing and managing your access to The Pay Index||Login details and/or contact details||Legitimate Interests, Performance of Contract|
|Administering The Pay Index||Non-personal data/ anonymised personal data submitted to The Pay Index||Suitable separation and anonymisation means that it is not subject to the Data Protection Legislation.|
|Supplying services to you[and providing certain information to our partners]||Name/ contact details and/or log-in details||Legitimate Interests, Performance of Contract|
|Managing payments for our services and collecting and recovering money owed to us||Name and contact details along of accounts payable person along with/ details of method of payment||Legitimate Interests, Performance of Contract|
|Communicating with you||Name/ contact details and/or log-in details||Legitimate interests, Performance of Contract|
|Protecting our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)||Name/ contact details/ technical||Legitimate Interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise), necessary to comply with a legal obligation|
|Using data analytics to improve our website, products/services, marketing, customer relationships and experiences||Technical/usage||Legitimate Interests (to define types of customers for our products and services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy)|
|Making suggestions and recommendations to you about products or services that may be of interest to you||Name/ contact details/ log-in details/ technical/usage||Legitimate Interests, Performance of Contract|
With your permission and/or where permitted by law, we may also use your personal data to communicate with our partners and for marketing purposes, which may include contacting you with information, news, and offers on our 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 by following the opt-out links on any marketing message sent to you. You have the right to withdraw consent to marketing at any time by contacting us.
We will not use your personal data in any automated decision making and/or automated profiling. We will only use your personal data for the purpose(s) for which it was originally collected unless we reasonably believe that another purpose is compatible with that or those original purpose(s) and need to use your personal data for that purpose. If we do use your personal data in this way and you wish us to explain how the new purpose is compatible with the original, please contact us.
If we need to use your personal data for a purpose that is unrelated to, or incompatible with, the purpose(s) for which it was originally collected, we will inform you and explain the legal basis which allows us to do so.
7. 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.
8. Data Security
We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.
We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.
9. 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, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.
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, regulatory, tax, accounting or other requirements.
10. Location of My Personal Data?
Generally, we will only store or transfer your personal data within the European Economic Area (the “EEA”). The EEA consists of all EU member states, plus Norway, Iceland, and Liechtenstein. This means that your personal data will be fully protected under the Data Protection Legislation including the GDPR and/or to equivalent standards by law.
From time to time, we may store or transfer some or all of your personal data in countries that are not part of the EEA. These are known as “third countries” and may not have data protection laws that are as strong as those in the UK and/or the EEA. This means that we will take additional steps in order to ensure that your personal data is treated just as safely and securely as it would be within the UK and under the Data Protection Legislation as follows:
- If and to the extent that we share your personal data within group companies, of which we are a part, and this involves the transfer of personal data outside the EEA, our group shall ensure that personal data is protected by requiring all companies within the group to follow the same rules with respect to personal data usage. These are known as “binding corporate rules” and ensure compliance with the Data Protection Legislation.
- If and to the extent that we share your personal data with external third parties that are based outside of the EEA, the following safeguards are applied to such transfers to ensure compliance with the Data Protection Legislation:
- we will only transfer your personal data to third countries whose levels of data protection are deemed ‘adequate’ by the European Commission; and/or
- we will use specific contracts terms with external third parties to require the same levels of personal data protection that would apply under the Data Protection Legislation; and/or
- if and to the extent that we transfer your personal data to a third party based in the US, the data may be protected by the recipient’s registration under the EU-US Privacy Shield and/or by our imposition of the Standard Contract Clauses. This requires that third party to provide data protection to standards similar to those in Europe.
Please contact us for further information about the particular data protection mechanism(s) used by us when transferring your personal data to a third country.
11. Do You Share My Personal Data?
We will not share any of your personal data with any third parties for any purposes, subject to the following exceptions:
- In some limited circumstances, we may be legally required to share certain personal data, which might include yours, if we are involved in legal proceedings or complying with legal obligations, a court order, or the instructions of a government authority.
- We may sometimes contract with third parties for the supply of certain services, such as web-hosting and data storage.
If any of your personal data is shared with a third party, as described above, we will take steps to ensure that your personal data is handled safely, securely, and in accordance with your rights, our obligations, and the third party’s obligations under the law, as described above.
If any personal data is transferred outside of the EEA, we will take suitable steps in order to ensure that your personal data is treated just as safely and securely as it would be within the UK and under the Data Protection Legislation, as explained above. 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.
12. How Can I Control My Personal Data?
In addition to your rights under the Data Protection Legislation, when you submit personal data via The Pay Index, you may be given options to restrict our use of your personal data. [Jamie, is this what TPI will allow candidates to do?] In particular, we aim to give you strong controls on our use of your data for direct marketing purposes including the ability to opt-out of receiving emails from us which you may do by unsubscribing using the links provided in our emails and/ or at the point of providing your details and by managing your Account.
You may also wish to sign up to one or more of the preference services operating in the UK: The Telephone Preference Service (“the TPS”), the Corporate Telephone Preference Service (“the CTPS”), and the Mailing Preference Service (“the MPS”). These may help to prevent you receiving unsolicited marketing. Please note, however, that these services will not prevent you from receiving marketing communications that you have consented to receiving.
13. Can I Withhold Information?
You may access certain areas of The Pay Index without providing any personal data at all. However, to use all features and functions available on The Pay Index you may be required to submit or allow for the collection of certain data.
14. 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”.
All subject access requests should be made in writing and sent to the email or postal addresses provided in the section below “How Do I contact You?”.
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 one month of receiving it or otherwise as required by the Data Protection Legislation. 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.
The Pay Index may place and access certain first-party Cookies on your computer or device. First-party Cookies are those placed directly by us and are used only by us. Third-party cookies might also be provided by third-party services providers used by us in our provision of the site, as described above. Such Cookies are used to facilitate and improve your experience of The Pay Index and to provide and improve our services. If and to the extent that Cookies are placed by us, have carefully chosen these Cookies and have taken steps to ensure that your privacy and personal data is protected and respected at all times.
All Cookies used by and on The Pay Index are used in accordance with current Cookie Law.
You can choose to enable or disable Cookies in your internet browser and/or when a pop-up requests your consent however certain features of The Pay Index may not function fully or as intended.
Most internet browsers also enable you to choose whether you wish to disable all Cookies or only third-party Cookies. By default, most internet browsers accept Cookies, but this can be changed. For further details, please consult the help menu in your internet browser or the documentation that came with your device.
You can choose to delete Cookies on your computer or device at any time, however you may lose any information that enables you to access The Pay Index more quickly and efficiently including, but not limited to, login and personalisation settings.
It is recommended that you keep your internet browser and operating system up-to-date and that you consult the help and guidance provided by the developer of your internet browser and manufacturer of your computer or device if you are unsure about adjusting your privacy settings.
16. How Do I Contact You?
Full name of legal entity: The Pay Index
Email address: firstname.lastname@example.org
Postal address: C/O Haines Watts (Berkhamsted) Ltd
4 Claridge Court
Lower Kings Road
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.
17. What We May Need From You?
We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.
19. What Are My Rights?
Under the Data Protection Legislation, you have the following rights, which we will always work to uphold:
- The right to access the personal data we hold about you. See below for more details about how to do this.
- The right to have your personal data rectified if any of your personal data held by us is inaccurate or incomplete. Please contact us to find out more.
- The right to be forgotten, i.e. the right to ask us to delete or otherwise dispose of any of your personal data that we hold. Please contact us to find out more.
- The right to restrict (i.e. prevent) the processing of your personal data.
- The right to object to us using your personal data for a particular purpose or purposes.
- The right to withdraw consent. This means that, if we are relying on your consent as the legal basis for using your personal data, you are free to withdraw that consent at any time.
- The right to data portability. This means that, if you have provided personal data to us directly, we are using it with your consent or for the performance of a contract, and that data is processed using automated means, you can ask us for a copy of that personal data to re-use with another service or business in many cases.
- Rights relating to automated decision-making and profiling. We do not use your personal data in this way.
For more information about our use of your personal data or exercising your rights as outlined above, please contact us.
It is important that your personal data is kept accurate and up-to-date. If any of the personal data we hold about you changes, please keep us informed as long as we have that data.
If you have any cause for complaint about our use of your personal data, you have the right to lodge a complaint with the Information Commissioner’s Office. However, we welcome the opportunity to resolve your concerns ourselves, so please contact us first.
In this Policy the following terms shall have the following meanings:
|“Account”||means an account required to access and/or use certain areas and features of The Pay Index;|
|“Comply with a legal obligation”||means processing your personal data where it is necessary for compliance with a legal obligation that we are subject to;|
|“Cookie”“CTPS”“EEA”||means a small text file placed on your computer or device by The Pay Index when you visit certain parts of The Pay Index and/or when you use certain features of The Pay Index. Details of the Cookies used by The Pay Index are set out in paragraph 15; please refer to definition in paragraph 12; please refer to definition in paragraph 10;|
|“Legitimate Interest”||means the interest of our business in conducting and managing our business to enable us to give you the best service/product and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us;|
|“GDPR”“MPS”“Performance of Contract”“TPS”||please refer to definition in paragraph 3; please refer to definition in paragraph 12; Performance of Contract means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract; please refer to definition in paragraph 12.|