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1 Introduction

Welcome to the Pilon Limited (Pilon) privacy policy.

Pilon respects your privacy and is committed to protecting your
personal data. This privacy policy will inform you as to how we look
after your personal data when you visit our website (regardless of where
you visit it from) and when you receive services from us. It also tells
you about your privacy rights and how the law protects you.

Please also use the Glossary to understand the meaning of some of the terms used in this privacy policy.

By using this website and/or continuing to receive services fro us,
you signify your acceptance of this policy. If you do not agree to this
policy, please notify us and do not use our website(s). Your continued
acceptance of services from us or use of this website following the
posting of changes to this policy will be deemed as your acceptance of
those changes.

2 Important information and who we are

Purpose of this privacy policy

This privacy policy aims to give you information on how Pilon collects and processes your personal data through:

  • your use of this website, including any data you may provide through
    this website when you complete the contact form on our website.
  • the provision of our services to you as a landlord customer or a
    tenant of a property that we are instructed to carry out works on.

This website is not intended for children and we do not knowingly collect data relating to children.

It is important that you read this privacy policy together with any
other privacy policy or fair processing policy we may provide on
specific occasions when we are collecting or processing personal data
about you so that you are fully aware of how and why we are using your
data. This privacy policy supplements other notices and privacy policies
and is not intended to override them.

Controller

Pilon is the controller and responsible for your personal data for this website (collectively referred to as “we“, “us” or “our” in this privacy policy).

Contact details

If you have any questions about this privacy policy or our privacy practices, please contact us in the following ways:

  • Email address: privacy@pilon.co.uk
  • Telephone number: 01344 206 800

You have the right to make a complaint at any time to the Information
Commissioner’s Office (ICO), the UK regulator 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.

Changes to the privacy policy and your duty to inform us of changes

We keep our privacy policy under regular review. This version was last updated in March 2024.

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

Our website 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. When you leave our website, we encourage you to read
the privacy policy of every website you visit.

3 The data we collect about you

Personal data, or personal information, 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:

  • In the ordinary course of our business with landlord customers and their tenants:
o Identity Data includes first name, maiden name, last name, username or similar identifier, marital status, title, date of birth and gender;
o Contact Data includes billing address, email address and telephone numbers;
o Financial Data includes bank account and payment card details;
o Transaction Data includes details about payments to and from you and other details of services you have purchased from us;
o Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.
  • In the course of operating our online customer portal application:
o Identity Data includes first name, maiden name, last name, username or similar identifier, marital status, title, date of birth and gender;
o Contact Data includes billing address, email address and telephone numbers;
o Financial Data includes bank account and payment card details;
o Transaction Data includes details about payments to and from you and other details of services you have purchased from us;
o Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.
o 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;
o Profile Data includes your username and password, your interests, preferences, feedback and survey responses;
o Usage Data includes information about how you use our website, products and services; and

We also collect, use and share Aggregated Data such as statistical or
demographic data. 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 policy.

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.

If you fail to provide personal data

Where we need to collect personal data by law, or under the terms of a
contract we have with you, and you fail to provide that data when
requested, we may not be able to perform the contract we have or are
trying to enter into with you (for example, to provide you with
services). In this case, we may have to cancel a product or service you
have with us but we will notify you if this is the case at the time.

4 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,
    Contact and Financial Data by filling in forms or by corresponding with
    us by post, phone, email or otherwise. This includes personal data you
    provide when you:
o apply for our products or services;
o create an account on our website or online app;
o subscribe to our service or publications;
o request marketing to be sent to you;
o enter a survey; or
o 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. Please
    see our cookie policy https://pilon.co.uk/cookie-policy/ 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:
o Identity Data and Contact Data in respect of tenants whose propertie we are             working on from the relevant landlord (local authority, housing association,   university, etc) as part of our works assessment and planning process.

o Technical Data from the following parties:

- analytics providers;
- advertising networks; and
- search information providers.

o Contact, Financial and Transaction Data from providers of technical, payment and delivery services.

o Identity and Contact Data from data brokers or aggregators and publically available sources such as Companies House and the Electoral Register.

5 How we use your personal data

We will only use your personal data when the law allows us to. 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; and
  • where we need to comply with a legal obligation.

Please go to the Glossary to find out more about the types of lawful basis that we will rely on to process your personal data.

Generally, we do not rely on consent as a legal basis for processing
your personal data although we will get your consent before sending
third party direct marketing communications to you via email or text
message. You have the right to withdraw consent to marketing at any time
by contacting us.

Purposes for which we will use your personal data

We have set out below, in a table format, a description of all the
ways we plan to use your personal data, and which of the legal bases we
rely on to do so. We have also identified what our legitimate interests
are where appropriate.

Note that we may process your personal data under 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.

Purpose/Activity Type of data Lawful basis for processing including basis of legitimate interest
     
Tenants receiving services/works    
To register you as a new customer (a) Identity
(b) Contact
(a) Necessary for our legitimate interests (to deliver the works and services we are contracted to deliver).
(b) Necessary for the legitimate interests of your landlord (to maintain and enhance their properties).
To process and deliver works and services to you including:
(a) Contact to arrange works or services
(a) Identity
(b) Contact
(c) Marketing and Communications
(a) Necessary for our legitimate interests (to deliver the works and services we are contracted to deliver).
(b) Necessary for the legitimate interests of your landlord (to maintain and enhance their properties).
To manage our relationship with you which will include:
(a) Notifying you about changes to our terms or privacy policy
(b) Asking you to leave a review or take a survey
(a) Identity
(b) Contact
(c) Profile
(d) Marketing and Communications
(a) Necessary to comply with a legal obligation
(b) Necessary for our legitimate interests (to keep our records updated and to study how customers use our products/ services)
To enable you to complete a survey (a) Identity
(b) Contact
(c) Profile
(d) Usage
(e) Marketing and Communications
(a) Necessary for our legitimate interests (to study how customers
use our products/services, to develop them and grow our business)
To administer and protect our business and this website (including
service delivery, handling complaints, troubleshooting, data analysis,
testing, system maintenance, support, reporting and hosting of data)
(a) Identity
(b) Contact
(c) Technical
(a) Necessary for our legitimate interests (for running our
business, provision of works/services, network security, to prevent
fraud and in the context of a business reorganisation or group
restructuring exercise)
(b) Necessary to comply with a legal obligation
To deliver relevant website content and advertisements to you and
measure or understand the effectiveness of the advertising we serve to
you
(a) Identity
(b) Contact
(c) Profile
(d) Usage
(e) Marketing and Communications
(f) Technical
(a) Necessary for our legitimate interests (to study how customers
use our products/services, to develop them, to grow our business and to
inform our marketing strategy)
To use data analytics to improve our website, app products/services, marketing, customer relationships and experiences (a) Technical
(b) Usage
Necessary for our 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)
To make suggestions and recommendations to you about goods or services that may be of interest to you (a) Identity
(b) Contact
(c) Technical
(d) Usage
(e) Profile
(f) Marketing and Communications
Necessary for our legitimate interests (to develop our products/services and grow our business)
Landlord Customers    
To register you as a new customer and record contact details of your staff (a) Identity
(b) Contact
(a) Necessary for our and your legitimate interests (to deliver the works and services promised).
To process and deliver your order including:
(a) Manage payments, fees and charges
(b) Collect and recover money owed to us
(a) Identity
(b) Contact
(c) Financial
(d) Transaction
(e) Marketing and Communications
(a) Necessary for our legitimate interests (to recover debts due to us)
To manage our relationship with you which will include:
(a) Notifying you about changes to our terms or privacy policy
(b) Asking you to leave a review or take a survey
(a) Identity
(b) Contact
(c) Profile
(d) Marketing and Communications
(a) Necessary to comply with a legal obligation
(b) Necessary for our legitimate interests (to keep our records updated and to study how customers use our products/ services)
To enable you to complete a survey (a) Identity
(b) Contact
(c) Profile
(d) Usage
(e) Marketing and Communications
(a) Necessary for our legitimate interests (to study how customers
use our products/ services, to develop them and grow our business)
To administer and protect our business, our app and our website
(including service delivery, handling complaints, troubleshooting, data
analysis, testing, system maintenance, support, reporting and hosting of
data)
(a) Identity
(b) Contact
(c) Technical
(a) Necessary for our legitimate interests (for running our
business, provision of services, administration of IT services, network
security, to prevent fraud and in the context of a business
reorganisation or group restructuring exercise)
(b) Necessary to comply with a legal obligation
To deliver relevant website content and advertisements to you and
measure or understand the effectiveness of the advertising we serve to
you
(a) Identity
(b) Contact
(c) Profile
(d) Usage
(e) Marketing and Communications
(f) Technical
(a) Necessary for our legitimate interests (to study how customers
use our products/services, to develop them, to grow our business and to
inform our marketing strategy)
To use data analytics to improve our website, app, products/services, marketing, customer relationships and experiences (a) Technical
(b) Usage
Necessary for our 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
To make suggestions and recommendations to you about goods or services that may be of interest to you (a) Identity
(b) Contact
(c) Technical
(d) Usage
(e) Profile
(f) Marketing and Communications
Necessary for our legitimate interests (to develop our products/services and grow our business)
     

Marketing

We strive to provide you with choices regarding certain personal data
uses, particularly around marketing and advertising. We have
established following personal data control mechanisms:

  • Promotional offers from us

We may use your Identity, Contact, Technical, Usage and Profile Data
to form a view on what we think you may want or need, or what may be of
interest to you. This is how we decide which products, services and
offers may be relevant for you (we call this marketing).
You will
receive marketing communications from us if you have requested
information from us from us and you have not opted out of receiving that
marketing.

  • Third-party marketing

We will get your express opt-in consent before we share your personal data with any third party for marketing purposes.

  • Opting out

You can ask us or third parties to stop sending you marketing
messages at any time by following the opt-out links on any marketing
message sent to you or by contacting us at any time.
Where you opt
out of receiving these marketing messages, this will not apply to
personal data provided to us as a result of a product/service purchase,
warranty registration, product/service experience or other transactions.

  • Cookies

You can set your browser to refuse all or some browser cookies, or to
alert you when websites set or access cookies. If you disable or refuse
cookies, please note that some parts of our website may become
inaccessible or not function properly. For more information about the
cookies we use, please see https://pilon.co.uk/cookie-policy/

  • 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.

6 Disclosures of your personal data

We may share your personal data with the parties set out below for the purposes set out in the table above:
• Internal Third Parties as set out in the Glossary;
• External Third Parties as set out in the Glossary;

Third parties to whom we may choose to sell, transfer or merge parts of
our business or our assets. Alternatively, we may seek to acquire other
businesses or merge with them. If a change happens to our business,
then the new owners may use your personal data in the same way as set
out in this privacy policy.

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.

7 International transfers

We do not transfer your personal data outside the UK.

In the event that we, or some of our External Third Parties, transfer
or store personal data on servers outside of the UK we take additional
steps to ensure that your information is protected to at least an
equivalent level, as required by applicable data protection laws.

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 Data retention

How long will you use my personal data for?

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.

By law we have to keep basic information about our customers
(including Contact, Identity, Financial and Transaction Data) for six
years after they cease being customers for tax purposes.

In some circumstances you can ask us to delete your data: see your legal rights below for further information.

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.

10 Your legal rights

Under certain circumstances, you have rights under data protection laws in relation to your personal data:

• request access to your personal data;
• request correction of your personal data;
• request erasure of your personal data;
• object to processing of your personal data;
• request restriction of processing your personal data;
• request transfer of your personal data; and
• right to withdraw consent.

These are set out in more detail in the Glossary section below.

If you wish to exercise any of the rights set out above, please contact us.

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 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.

Time limit to respond

We try to respond to all legitimate requests within one month.
Occasionally it could take us longer than a month 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.

11 Glossary

LAWFUL BASIS

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.

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.

THIRD PARTIES

Internal Third Parties

Affiliate companies of Pilon acting as joint controllers or
processors and who are based in the United Kingdom and provide similar
services to Pilon.

External Third Parties

• Service providers acting as processors based in United Kingdom who provide IT and system administration services.

Professional advisers acting as processors or joint controllers
including lawyers, bankers, auditors and insurers based in United
Kingdom who provide consultancy, banking, legal, insurance and
accounting services.
• HM Revenue & Customs, regulators and other
authorities acting as processors or joint controllers based in the
United Kingdom who require reporting of processing activities in certain
circumstances.
• Subcontractors acting as processors or joint
controllers who we instruct in order to carry out works or services on
our behalf.

YOUR LEGAL RIGHTS

You have the right to:

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 local law. 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. You also have the right to object where
we are processing your personal data for direct marketing purposes. 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; and
  • 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. Note that this right only applies to automated
information which you initially provided consent for us to use or where
we used the information to perform a contract with you.

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 products or services to you. We will advise you if this is the
case at the time you withdraw your consent.