In accordance with the General Data Protection Regulation (GDPR), we have implemented this privacy notice to inform you of the types of data we process about you. We also include within this notice the reasons for processing your data, the lawful basis that permits us to process it, how long we keep your data for and your rights regarding your data.

                                                                DATA PROTECTION PRINCIPLES

Under GDPR, all personal data obtained and held by us must be processed according to a set of core principles. In accordance with these principles, we will ensure that:

• processing is fair, lawful and transparent 
   
• data is collected for specific, explicit, and legitimate purposes
   
• data collected is adequate, relevant and limited to what is necessary for the purposes of processing
   
• data is kept accurate and up to date. Data which is found to be inaccurate will be rectified or erased without delay
   
• data is not kept for longer than is necessary for its given purpose
   
• data is processed in a manner that ensures appropriate security of personal data including protection against unauthorised or unlawful processing, accidental loss, destruction or damage by using appropriate technical or organisation measures
   
• we comply with the relevant GDPR procedures for international transferring of personal data
   

                                                                                                      TYPES OF DATA HELD

We keep several categories of personal data about you in order to carry out effective and efficient processes. We keep this data in a file relating to each contractor and we also hold the data within our Secured computer systems, for example, our accounts systems.

  Specifically, We hold the following types of data:

• Personal details such as name, address, phone numbers: this information is provided by you when you use our websites, or when you contact us directly, or when you use or are a recipient PromoPath Limited.
   
• Bank account details: You provide this information yourself when you use our services or provide it to receive a payment
   
• Payment rates: Payments rates of type of service, jobs and any contractual jobs.
   
•  CCTV footage: We will record images of you if you a visit a location where CCTV is in operation.
   
•  Building access card records
   
• Your photograph and Videos: Promopath may receive photographs, images and videos of individuals where these are provided by you. For example, Ride along video testimonials provided by you to upload your image and videos onto one of our websites.
   

                                                                                                         COLLECTING YOUR DATA

You provide several pieces of data to us directly during any contract negotiation period, for example your name and address, and subsequently upon the start of your distribution, engagement, for example, your bank details.

In some cases, we will collect data about you from third parties, such as intermediaries who may act as an introducer.

Personal data is kept in files or within the Company’s Sales, HR and Secured IT systems.

Purpose: Providing services to you where there is a contract, agreement or terms and conditions in place with you. We need to process your data to provide these services to you in accordance with that contract or agreement.

Enhancing our customers' experience of our services and websites. For example, we use information on your visits to our websites to evaluate and understand how different people navigate our websites and how long they spend on particular pages. Legitimate Interests – we sometimes need to process personal data to understand how you use our services so we can enhance them.

Market research and analysis, and the development of new services. For example, we may develop new services or new data services for business customers (for the purposes of maintaining accurate address data, Services for identity verification or fraud prevention purposes, and for helping businesses to target their marketing). Legitimate Interests – we sometimes need to process personal data to develop new services we can offer you and others.

                                                                                           LAWFUL BASIS FOR PROCESSING

The law on data protection allows us to process your data for certain reasons only. In the main, we process your data in order to comply with a legal requirement, in order to perform the contract OR terms and conditions we have with you or in pursuit of our legitimate interests.

The information below categorizes the types of data processing we undertake and the lawful basis we rely on.

               Activity requiring your data                                                                   Lawful basis

Carry out the contract that we have entered into with you e.g. using your     - Performance of the contract OR terms and condition

name, contact details

Ensuring either party receive payment                                                                  - Performance of the contract OR terms and conditions.

Making decisions about who to enter into a contract with                                 - Our legitimate interests

Business planning and restructuring exercises                                                    - Our legitimate interests

Dealing with legal claims made against us                                                           - Our legitimate interests

Preventing fraud                                                                                                          - Our legitimate interests

Ensuring our administrative and IT systems are secure and robust against    - Our legitimate interests

unauthorized access

                                                                                           FAILURE TO PROVIDE DATA

Your failure to provide us with data may mean that we are unable to fulfil the service towards you and our requirements for entering into a contract with you or performing the contract that we have entered into.
 

                                                                                     WHO WE SHARE YOUR DATA WITH

Employees within our company who have responsibility for recruitment, sales, administration of payment and contractual benefits and the carrying out performance related procedures will have access to your data which is relevant to their function. All employees with such responsibility have been trained in ensuring data is processing in line with GDPR.  

Data is shared with third parties for the following reasons: e.g. for the administration of payroll, design, print and marketing purposes. We may also share your data with third parties as part of a Company sale or restructure, or for other reasons to comply with a legal obligation upon us. We have a data processing agreement in place with such third parties to ensure data is not compromised. Third parties must implement appropriate technical and organizational measures to ensure the security of your data. We do not share your data with bodies outside of the European Economic Area.

                                                                                                   PROTECTING YOUR DATA

We are aware of the requirement to ensure your data is protected against accidental loss or disclosure, destruction and abuse. We have implemented processes to guard against such. 

                                                                                                        RETENTION PERIODS

We only keep your data for as long as we need it for, which will be at least for the duration of your engagement with us though in some cases we will keep your data for a period after your engagement has ended.

                                                                                          AUTOMATED DECISION MAKING

Automated decision-making means making decision about you using no human involvement e.g. using computerized filtering equipment. No decision will be made about you solely on the basis of automated decision making (where a decision is taken about you using an electronic system without human involvement) which has a significant impact on you.
 

                                                                                                     DATA SUBJECT RIGHTS 

You have the following rights in relation to the personal data we hold on you:

• the right to be informed about the data we hold on you and what we do with it
   
• the right of access to the data we hold on you. More information on this can be found in our separate policy on Subject Access Requests
   
• the right for any inaccuracies in the data we hold on you, however they come to light, to be corrected. This is also known as ‘rectification’
   
• the right to have data deleted in certain circumstances. This is also known as ‘erasure’
   
• the right to restrict the processing of the data
   
• the right to transfer the data we hold on you to another party. This is also known as ‘portability’
   
• the right to object to the inclusion of any information
   
• the right to regulate any automated decision-making and profiling of personal data.
   

More information can be found on each of these rights in our separate policy on your rights in relation to your data upon the request.
 

                                                                                                              CONSENT

Where you have provided consent to our use of your data, you also have the right to withdraw that consent at any time. This means that we will stop processing your data. 

                                                                                                   MAKING A COMPLAINT

If you think your data rights have been breached, you are able to raise a complaint with the Information Commissioner (ICO). You can contact Promopath

                                                                                         DATA PROTECTION COMPLIANCE

You can contact PromoPath Data Protection Officer at Address: 4 Old Lodge Place St Margarets Road Twickenham, TW1 1RQ United Kingdom

                                                                                                 JHB Adventures Limited 

Email:info@promopath.co.uk

                                                                                             CHANGES TO OUR PRIVACY POLICY

We will keep our privacy policy under regular review and will place any updates on this webpage. This privacy policy was last updated on 24 May 2018.