WEBSITE PRIVACY POLICY

This website is brought to you by Pro-Noctis Limited (‘the Company’). We take the privacy of our website users very seriously. We ask that you read this Privacy Policy (‘the Policy’) carefully as it contains important information about how we will use your personal data.

Where we are based outside the European Economic Area, we have nominated a representative and this can be obtained by contacting the Company.

PERSONAL DATA WE MAY COLLECT ABOUT YOU

We may obtain personal data about you (such as your name, address, telephone number, and other contact details) whenever you complete an online form.

For example, we will obtain your personal data when you contact us for any reason. We may also obtain sensitive personal data about you if you volunteer it during the completion of an online form. If you volunteer such information, you will be consenting to our processing it for the purpose of contacting you to discuss our services and any other related reason.

We may monitor your use of this website through the use of cookies and similar tracking devices. For example, we may monitor how many times you visit, which pages you go to, traffic data, location data and the originating domain name of a user’s internet service provider. This information helps us to build a profile of our users. Some of this data will be aggregated or statistical, which means that we will not be able to identify you individually. For further information on our use of cookies, please see our Cookie policy.

Occasionally we may receive information about you from other sources which we will add to the information we already hold about you in order to help us provide services, improve and personalise our service to you.

HOW WE USE YOUR PERSONAL DATA

We will use your personal data for the purposes described in the data protection notice that was given to you at the time your data were obtained. These purposes include:

• to help us identify you and any accounts you hold with us;
• administration;
• research, statistical analysis and behavioural analysis;
• client profiling and analysing your purchasing preferences;
• marketing—see ‘Marketing and opting out’, below;
• fraud prevention and detection;
• billing;
• customising this website and its content to your particular preferences;
• to notify you of any changes to this website or to our services that may affect you;
• security vetting;
• improving our services; and

MARKETING AND OPTING OUT

If you have given permission, we may contact you by mail, telephone, SMS, text, fax, email about our services and any other related services and products, that may be of interest to you. If you prefer not to receive any direct marketing communications from us, you can opt out at any time. See further ‘Your rights’, below.

If you have given permission, we may share your personal data with organisations who are our business partners and we or they may contact you (unless you have asked us or them not to do so) by mail, telephone, SMS, text, fax, email about our services and any other related services and products that may be of interest to you. If you prefer not to receive any further direct marketing communications from us or our business partners, you can opt out at any time. See further ‘Your rights’, below.

DISCLOSURE OF YOUR PERSONAL DATA

We may disclose your personal data to:

• other companies within our group;
• our agents and service providers;
• law enforcement agencies in connection with any investigation to help prevent unlawful activity;
• our business partners in accordance with the ‘Marketing and opting out’ section above; and

KEEPING YOUR DATA SECURE

We will use technical and organisational measures to safeguard your personal data, for example:

• access to your account is controlled by a password and username that are unique to you
• we store your personal data on secure servers
• payment details are encrypted using SSL technology

While we will use all reasonable efforts to safeguard your personal data, you acknowledge that the use of the internet is not entirely secure and for this reason we cannot guarantee the security or integrity of any personal data that are transferred from you or to you via the internet.

MONITORING

We may at any time monitor and record communications with you (such as telephone conversations and emails) for the purpose of quality assurance, training, fraud prevention and compliance.

KYC CHECKING

To enable us and other companies in our group to make decisions about you and any related person and for fraud prevention and money laundering purposes, we may undertake any relevant KYC checks. We may disclose information about how you conduct to any relevant authorities for fraud prevention, and money laundering purposes. If you provide false or inaccurate information and we suspect fraud or money laundering we will record this.

INFORMATION ABOUT OTHER INDIVIDUALS

If you give us information on behalf of someone else, you confirm that the other person has appointed you to act on his/her behalf and has agreed that you can:

• give consent on his/her behalf to the processing of his/her personal data;
• receive on his/her behalf any data protection notices;
• give consent to the transfer of his/her personal data abroad; and
• give consent to the processing of his/her information and personal data.

TRANSFERS OF DATA OUT OF THE EEA

We may need to transfer your personal data to any subsidiary of the Company around the world and some of which are located outside the European Economic Area, for the purpose of set out in this policy. Rest assured that we will always ensure any transfer is subject to appropriate security measures to safeguard your personal data. Any transfer of your data will be subject to a European Commission approved contract that will safeguard your privacy rights and give you remedies in the unlikely event of a security breach.

YOUR RIGHTS

You have the right, subject to the payment of a small fee (currently £10), to request access to personal data that we may process about you. If you wish to exercise this right, you should:

• put your request in writing;
• include proof of your identity and address (e.g. a copy of your driving licence or passport, and a recent utility or credit card bill);
• attach a cheque in the amount of £10 made payable to Pro-Noctis Limited; and
• specify the personal data you want access to, including any account or reference numbers where applicable.

You have the right to require us to correct any inaccuracies in your data free of charge. If you wish to exercise this right, you should:

• put your request in writing;
• provide us with enough information to identify you (e.g. account number, username, registration details); and
• specify the information that is incorrect and what it should be replaced with.

You also have the right to ask us to stop processing your personal data for direct marketing purposes. If you wish to exercise this right, you should:

• put your request in writing (an email sent to our general contact email address with a header that says ‘Unsubscribe’ is acceptable);
• provide us with enough information to identify you; and
• if your objection is not to direct marketing in general, but to direct marketing by a particular channel (eg email or telephone), please specify the channel you are objecting to.

OUR CONTACT DETAILS

We welcome your feedback and questions. If you wish to contact us, please send an email to info@pro-noctis.com. Our registered office is 13 Charles II Street, London, England, SW1Y 4QU

We may change this privacy policy from time to time. You should check this policy occasionally to ensure you are aware of the most recent version that will apply each time you access this website.