Last updated: May 25, 2018
PriApps Limited, and its international subsidiaries (referred to herein as PriApps) are committed to protecting the personal information that you provide to PriApps, in adherence to Data Protection Legislation (defined below) and best business practice.
This Privacy Notice describes PriApps’ practices in relation to the use of its websites, web portals and FTP servers (“Websites”) and the related products, applications and services offered by PriApps. This Privacy Notice sets out how PriApps uses and protects any personal data that you provide to PriApps, including personal data provided through its Websites.
PriApps provides software products and services to its customers and as a result may collect and process personal data about individuals (“Services”).
PriApps maintains the same practices with data that is collected off-line and this notice may be relied upon with respect to those methods of data collection and use.
PriApps may modify or update its Privacy Notice at any time without prior notice. You can check the “Last updated” date above to see when the notice was last changed.
HOW TO CONTACT PRIAPPS
If you have any questions regarding your personal data and how PriApps may use it, including any queries relating to this Privacy Notice, please contact us by email at firstname.lastname@example.org or by writing to us at PriApps Limited, The Shetlands, Theale Road, Burghfield, Reading, RG30 3TN, United Kingdom.
It is important that the personal data PriApps holds about you is accurate and current. Please keep PriApps informed if your personal data changes during your relationship with PriApps.
PriApps’ data protection and privacy measures are governed by the (i) the General Data Protection Regulation ((EU) 2016/679) (“GDPR”) and any national implementing laws, regulations and secondary legislation, as amended or updated from time to time, in the UK and then (ii) any successor legislation to the GDPR or the Data Protection Act 1998 (“Data Protection Legislation“).
For the purpose of Data Protection Legislation:
- where personal data is provided directly to PriApps through use of its Websites, email, or other means where PriApps is determining the way in which that personal data is processed, then PriApps will be a data controller of such information; and
- where PriApps is provided personal data in its capacity of providing Services to its customers, then PriApps will only process that personal data in accordance with the instructions of its customers and PriApps will therefore act as a data processor in respect of such personal data; PriApps’ customer will be the data controller of that personal data for that purpose.
INFORMATION WE COLLECT
Personal data means any data or information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).
PriApps will only collect basic personal data about you, such as your name, email address, business type, work address, job title (“identity data”) and any product/solution interests that you have shared (“preferences data”) and information relating to your use of PriApps Websites (“usage data”). Unless otherwise agreed with you, this information will not include any special categories of personal information (often known as “sensitive personal data”).
PriApps uses different methods to collect personal data from and about you including through:
- Direct interactions. You may give PriApps your contact information by filling in forms or by corresponding with PriApps by post, phone, email or otherwise. This includes personal data you provide when PriApps provides its Services; or
- Third parties or publicly available sources. PriApps may receive personal data about you from various third parties and public sources such as:
- Contact, Financial and Transaction Data from providers of technical, payment and delivery services including third party debt agencies; and
- Identity and Contact Data from publicly available sources such as Companies House
When visiting a PriApps Website, information is captured using cookies.
Cookies are small text files that may be placed on your computer or other mobile or handheld device (e.g. smart phone or tablet) via your internet browser when you visit our website. The cookies will help the website to recognize you the next time you visit which will enable us to improve your use of our website, providing you with a better service.
There are two types of cookies used by PriApps, which vary according to the length of time they remain active:
Temporary or (“session”) cookies
These cookies are created when you visit a website but are set to expire immediately. This means that they will not be read again in future. They are deleted, or overwritten, the next time you visit the website.
These cookies are stored on your computer or device and are read again each time you visit the website which created that particular cookie. A permanent cookie will expire on a given date or can be deleted manually.
We use both of the above types of cookies and some of the cookies used by our website are served by us, and some are served by third parties (Google Analytics, Scorecard Research and ShareThis) who are delivering services on our behalf.
Please note: PriApps does not control the settings of cookies set by third parties. You should check the relevant third party website for more information about these (please see ‘further information’ below).
COOKIES WE USE
We have tried to cover all the cookies that we or our technology partners use. Please note that there may be a short delay in updating this list. If you do notice a discrepancy, or think a cookie is missing, please contact us.
The table below shows the cookies used on this website:-
|Google Analytics ||__utma
|These temporary cookies are used to collect information about how visitors use our site. We use the information to put together reports to help us improve the site. The cookies collect information in an anonymous form, including the number of visitors to the site, where visitors have come to the site from and the pages they have visited.|
|Scorecard Research 
|These cookies provide links to social networking sites such as Twitter and Facebook.
These cookies provide the social networking widget found in many of our pages. This widget gives you the tools to bookmark our website, share, tweet and email our content to a friend. These cookies both expire after one year.
 Google Analytics policy – http://www.google.com/analytics/learn/privacy.html
To opt out of being tracked by Google Analytics across all websites visit http://tools.google.com/dlpage/gaoptout
If you’d like to learn more about cookies please visit http://www.allaboutcookies.org
CHANGING YOUR COOKIE SETTINGS
If you want to enable or disable cookies you can change your internet browser settings to do so. To find out further information about cookies and how to manage them please visit http://www.allaboutcookies.org. Please remember – by disabling cookies you may not be able to take full advantage of our website.
IF YOU FAIL TO PROVIDE PERSONAL DATA
Where PriApps needs to collect personal data by law, or under the terms of a contract PriApps has with you (or our customer whom PriApps acts for) and you fail to provide that data when requested, PriApps may not be able to perform the contract it has or is trying to enter. In this case, PriApps may have to cancel the Services but it will notify you (or where appropriate, its customer) if this is the case at the time.
HOW WE USE INFORMATION THAT WE COLLECT
PriApps will only use your personal data when the law allows it to, i.e. if PriApps has a legal basis for doing so, as outlined in this Privacy Notice or as notified to you at the time in which PriApps collects your personal data, and for the purposes for which it was collected for, unless PriApps reasonably considers that it needs to use it for another reason and that reason is compatible with the original purpose. If PriApps needs to use your personal data for an unrelated purpose, PriApps will notify you and will explain the legal basis, which allows it to do this. Please note that PriApps may process your personal data without your knowledge or consent, where this is required or permitted by law.
PriApps will use your personal data to carry out its contractual obligations and, in addition, to keep you up-to-date with its products and services that you have expressed an interest in. Where PriApps act as the data controller for customer contact information, it has set out below in the table a description of all the ways it plans to use your personal data, and which of the legal bases PriApps relies on to do so. PriApps has also identified what its legitimate interests are, where appropriate.
Note that PriApps may process your personal data for more than one lawful grounds depending on the specific purpose for which PriApps is using your data. Please contact PriApps if you need details about the specific legal ground that it is relying on to process your personal data where more than one ground has been set out in the table below.
|Purpose/Activity||Type of data||Lawful basis for processing including basis of legitimate interest|
|To register you or the company that you are connected to as a new customer and verify your identity (where required)||Identity / contact data||Performance of a contract Consent (for use of special categories of data, if applicable)|
|To perform credit checks||Identity / contact data||Legitimate interests|
|To process and deliver the Services including:
(a) Manage accounts, payments, fees and charges
(b) Contacting you and corresponding about the Services
|Identity / contact data||Performance of a contract
Necessary for PriApps’ legitimate interests (to recover debts due to PriApps)
|To respond to queries and enquiries||Identity / contact data||Legitimate interests|
|To undertake marketing to you||Identity / contact / preferences data||Legitimate interests|
Where PriApps acts as a data processor of personal data on behalf of its customers, in accordance with PriApps’ customers’ instructions or in order to comply with a legal or regulatory obligation.
HOW YOUR PERSONAL DATA MAY BE SHARED
Where PriApps acts as the data controller for customer contact information, or where permitted by PriApps’ data controller customers, personal data processed by PriApps may be shared as follows:
- With any member of the PriApps group of companies (as detailed above);
- With permitted third party contractors of PriApps for the purposes of performing its Services;
- Where PriApps is under a duty to disclose your personal data to comply with any legal obligation, or to enforce or apply PriApps’ terms and conditions and other agreements;
- To protect the rights, property, or safety of PriApps, PriApps’ customers, or others. This includes exchanging information with other companies and organisations for the purposes of fraud protection and for compliance with laws; and
- With third parties to whom PriApps may choose to sell, transfer, or merge parts of its business or its assets. Alternatively, PriApps may seek to acquire other businesses or merge with them. If a change happens to PriApps’ business, then the new owners may use your personal data in the same way as set out in this Privacy Notice.
PriApps requires all third parties to respect the security of your personal data and to treat it in accordance with the law. PriApps does not allow its 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 PriApps’ instructions.
PriApps will not share your information for marketing purposes with third party companies outside of its group of companies.
You can choose to unsubscribe from PriApps marketing communications at any time using the unsubscribe option on any electronic communication sent from PriApps. You may continue to receive further communications where a contractual or legitimate interest exists.
PriApps may use third party companies when processing your personal information. If you would like to find out which third party processors are used by PriApps, please contact PriApps as outlined above.
HOW LONG WE KEEP YOUR INFORMATION FOR
Where PriApps acts as a data controller, it will not keep your personal information longer than is necessary for the purpose in which it was provided, unless required by law, or for other legitimate reasons that need it to be retained for longer (for example, if necessary for any legal proceedings). Where PriApps acts as a data processor on behalf of its customers, PriApps will only hold on to personal data for the period notified to PriApps by the data controller customer, or for the period required for the purposes of satisfying any legal, accounting, regulatory or reporting requirements
Under Data Protection Legislation, you have the following rights in certain circumstances:
- The right to be informed – this is information on PriApps’ collection and use of your personal data.
- The right of access – you have the right to be provided with copies of the personal data of you that PriApps is processing as well as confirmation of the processing PriApps is doing. You can do this by sending a “subject access request” to the contact details noted above for PriApps’ consideration.
- The right to rectification – if you think the personal data that PriApps holds on you is wrong, you can inform PriApps and PriApps will fix it.
- The right to erasure (also known as the right to be forgotten) – if you want PriApps to permanently delete the personal data it holds about you then you can ask PriApps to do so.
- The right to restrict processing – if you do not like how PriApps is using your personal data then you can let PriApps know and PriApps will stop processing it in that way.
- The right to data portability – if you want PriApps to pass on your personal data to someone else then please let PriApps know. This transfer should not affect the integrity or otherwise damage your personal data.
- The right to withdraw your consent – you can withdraw your consent for PriApps to process your personal data (if PriApps has relied on your consent to process your personal data) at any time by contacting PriApps. If PriApps has relied only on your consent as the basis to process your personal data then PriApps will stop processing your personal data at the point you withdraw your consent. Please note that if PriApps can also rely on other bases to process your personal data aside from consent then PriApps may do so even if you have withdrawn your consent.
- Rights in relation to automated decision making and profiling – if PriApps use either automated decision making or profiling then you have a right to know. Also, PriApps needs your consent if either of these are used to make a decision that affects you. As with all consent, you can withdraw it at any time.
To exercise any of the above rights please email your request to: email@example.com
Where you exercise your right to erasure or where information is deleted in accordance with PriApps’ retention policy, please note that after the deletion of your personal data, it cannot be recovered, so if you require a copy of this personal data, please request this during the period PriApps retains the data.
Where you exercise your right to request access to the information PriApps processes about you, you will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, PriApps may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive.
Alternatively, PriApps may refuse to comply with your request in these circumstances.
PriApps will try to respond to all legitimate access requests within 30 days. Occasionally it may take longer than 30 days if your request is particularly complex or you have made a number of requests. In this case, PriApps will notify you and keep you updated.
PriApps Websites are not intended for children and PriApps will not knowingly collect any personal data from persons under the age of 18 and will immediately delete any such data subsequently so determined.
HOW TO RAISE A CONCERN ABOUT THE USE OF YOUR PERSONAL INFORMATION
If you have concerns about how PriApps has handled your personal data, including in relation to any of the rights contained herein, please send an email to firstname.lastname@example.org outlining the concerns that you have.
You may also make a complaint to the ICO (the UK supervisory authority). You can find further information about the ICO and their complaints procedure at: https://ico.org.uk/concerns/.
PriApps Websites may collect your Internet Protocol (IP) address. This information is collected for internal security and system administration purposes. This information may also be used to trace the computer used in cases of misuse or unlawful actions in connection with visits to or use of PriApps’ Websites.