Purpose of this privacy notice
Pangolin PR Limited, including each of its affiliates and subsidiaries (collectively, “Pangolin“, “we“, or “us“) respects your privacy and is committed to protecting your personal data. This privacy notice explains how we collect and process the personal data that you provide to us through your use of our website located at https://pangolinpr.com/ (Website) and through our communications. Where we refer to “personal data”, it means “personal data” as defined in the UK’s version of the EU’s General Data Protection Regulation 2016/679 which has been amended and transposed into the UK law by way of the Data Protection Act 2018 (DPA)and the Data Protection, Privacy and Electronic Communications (Amendments etc) (EU Exit) Regulations 2019 (SI 2019/419).
Please also see the Glossary that gives the meaning of some of the terms used in this privacy notice. This privacy notice applies in addition to any other agreement that you might enter into with us.
Pangolin is the “controller” which means that we are responsible for deciding how we hold and use personal data about you. We are required under data protection laws to notify you of the information contained in this privacy notice. It is important that you read and retain this notice so that you are aware of how and why we are using your personal data and what your rights are under data protection laws.
If you have any questions about this privacy notice or would like to enforce any rights that you may have under applicable data protection laws, please contact us at:
Will Cookson, Founder
Address: Unit 3.15 Clerkenwell Workshops 31 Clerkenwell Close, London, United Kingdom, EC1R 0A
If you believe we are using your personal data unlawfully, please contact us in the first instance. You have the right to make a complaint at any time to the UK supervisory authority for data protection issues, the Information Commissioners Office (“ICO”), or other relevant supervisory authority.
Changes to this privacy notice and your duty to inform us of changes
We keep this privacy notice under regular review. This version was last updated on 7 September 2021. We reserve the right to update this privacy notice and we will provide you with a new privacy notice when we make substantial updates. It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.
Third-party links and service providers
Our Website and communications may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. We encourage you to read the privacy notice of every website you visit.
The data we collect about you
Personal data means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data). We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:
- Identity Data includes first name, last name, job title.
- Contact Data includes email address and telephone number.
- 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 our Website.
- Usage Data includes information about how you use our Website.
- Marketing and Communications Data includes your preferences in receiving marketing from us and your communications preferences.
We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data could be derived from your personal data but is not considered personal data in law as this data will not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific Website feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy notice.
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. Our Website is not intended for children and we do not knowingly collect data relating to children.
If you fail to provide personal data
Where we need to collect personal data by law, or in order to provide you with information that you have requested from us, and you fail to provide that personal data when requested, we may not be able to provide you with that information.
How is your personal data collected?
We use different methods to collect personal data from and about you, including through:
- Direct interactions. You may give us your Identity, Contact or Marketing and Communications Data by filling in forms or by corresponding with us by email, phone or otherwise.
- Automated technologies or interactions. We will automatically collect Technical and Usage Data about your equipment, browsing actions and patterns as you interact with our Website. We collect this personal data by using cookies, server logs and other similar technologies.
- Third parties or publicly available sources. In some instances we may collect personal data from third parties, some of which may be based outside the UK or the EU. We will only collect personal data this way where such information is publicly available or for legitimate business purposes, for example Technical Data from analytics providers such as Google.
- Strictly necessary cookies. These are cookies that are required for the operation of our Website.
- Analytical or performance cookies. These allow us to recognise and count the number of visitors and to see how visitors move around our Website when they are using it. This helps us to improve the way our Website works, for example, by ensuring that users are finding what they are looking for easily.
- Functionality cookies. These are used to recognise you when you return to our Website. This enables us to personalise our content for you and remember your preferences (for example, your choice of language or region).
- Targeting cookies. These cookies record your visit to our Website, the pages you have visited and the links you have followed. We will use this information to make our Website and the advertising displayed on it more relevant to your interests.
You can block cookies by activating the setting on your browser that allows you to refuse the setting of all or some cookies. However, if you use your browser settings to block all cookies (including essential cookies) you may not be able to access all or parts of our Website.
How we use your personal data
We will only use your personal data when the law allows us to do so. Most commonly, we will use your personal data in the following circumstances:
- 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 or regulatory obligation.
- Where we have obtained your consent.
Please see the Glossary to find out more about the types of lawful basis that we will rely on to process your personal data.
Purposes for which we will use your personal data
We have set out below, in a table format, a non-exhaustive description of the ways we plan to process your personal data and which of the lawful bases we rely on to do so. We have also identified what our legitimate interests are where appropriate. We may process your personal data on more than one lawful ground.
|Purpose/Activity||Type of data||Lawful basis for processing including basis of legitimate interest|
|To provide you with information that you have requested from us (e.g., culture reports, marketing communications)||Identity|
Marketing and Communications
Necessary for our legitimate interests
|To manage our relationship with you, for example:|
(a) Responding to your emails and other communications
(b) Notifying you about changes to our privacy notice
Marketing and Communications
Necessary for our legitimate interests or to comply with a legal obligation
|To deliver relevant Website content to you and measure or understand the effectiveness of the content we serve to you||Identity|
Marketing and Communications
|Necessary for our legitimate interests|
|To use data analytics to improve our Website||Technical|
|Necessary for our legitimate interests|
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 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. We may also process your personal data without your knowledge or consent where this is required or permitted by law.
You will receive marketing communications from us if you have requested information from us and given us your consent. We will not share your personal data with any third party for marketing purposes. You can withdraw your consent at any time by contacting us or by following the opt-out links on any marketing message sent to you.
Disclosures of your personal data
When you consent to providing us with your personal data, you also consent to share your personal data with certain of our third party service providers. We will only share your personal data for our legitimate business purposes relating to our business activities. We require all third parties to respect the security of your personal data and to treat it in accordance with the law. 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.
Examples of third parties that we may share your personal data include:
- Service providers based in the United States who provide analytics services.
- Professional advisers including lawyers and auditors based in the UK who provide legal and accounting services.
- Regulators based in the UK who require reporting in certain circumstances.
Some of our third parties, for example analytics service providers, may be based outside of the UK or the EU, so their processing of your personal data will involve a transfer of data. Whenever we transfer your personal data internationally, we ensure a similar and adequate degree of protection is afforded to it by ensuring safeguards are implemented, for example:
- We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data (for example, by the ICO or the European Commission).
- Where we use certain service providers, we may use specific standard contracts which give personal data the necessary level of protection (for example, model clauses approved by the ICO or the European Commission).
Please contact us if you want further information on how we transfer your personal data internationally.
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. All information you provide to us is stored on our or our third party’s secure servers. 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.
We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, 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. In some circumstances we will anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes, in which case we may use this information indefinitely without further notice to you.
Your legal rights
Under certain circumstances, you have rights under data protection laws in relation to your personal data and to check that we are lawfully processing it.
Request access to your personal data (commonly known as a “data subject access request”). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with applicable laws. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios:
- If you want us to establish the data’s accuracy;
- Where our use of the data is unlawful but you do not want us to erase it;
- Where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or
- You have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format.
Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain services to you. We will advise you if this is the case at the time you withdraw your consent.
If you wish to exercise any of the rights set out above, please contact us using the contact details stated above.
Automated decision-making. You will not be subject to decisions that will have a significant impact on you based solely on automated decision-making, unless we have a lawful basis for doing so and we have notified you. We do not envisage that any decisions will be taken about you using automated means, however we will notify you in writing if this position changes.
No fee usually required. You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we could refuse to comply with your request in these circumstances.
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 the information (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.
Time limit to respond. We try to respond to all legitimate requests as soon as is reasonably practicable and in any event within the statutory time-limits. It could take us longer if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.
Consent means processing your personal data where you have signified your agreement by a statement or clear opt-in to processing for a specific purpose. Consent will only be valid if it is a freely given, specific, informed and unambiguous indication of what you want. You can withdraw your consent at any time by contacting us.
Legitimate interest means the interest of our business in conducting and managing our business. 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.
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.