Privacy Policy


This is an important notice regarding your privacy and the way in which Portable Multimedia Limited (referred to as “we”, “our” or “us” in this policy) collects and makes use of your personal data. We want to be open and transparent with you, and therefore encourage you to contact us if you have any questions about this policy or the ways in which we use your personal data.


This policy applies to our applicants, business contacts (i.e. clients and prospective clients), customers, suppliers, competition entrants and third parties generally. We take our privacy responsibilities seriously and are committed to protecting and respecting your privacy.
This policy sets out the basis on which any personal data we collect from you, or that you provide to us, will be processed by us. Please read the following carefully to understand our views and practices regarding your personal data and how we will treat it.
For the purpose of applicable privacy legislation, the data controller is Portable Multimedia Limited of Dorna House Two Guildford Road, West End, Woking, England GU24 9PW. Our company registration number is 04038169.
Questions regarding this policy should be directed to our Data Protection Officer who can be contacted at [email protected] The Data Protection Officer is responsible for ensuring compliance with relevant data protection legislation and with this policy. Any questions about the operation of this policy or any concerns that the policy has not been followed should be referred in the first instance to the Data Protection Officer.


1.  What information do we hold about you?


We may collect, store and use personal data about you (referred to throughout this privacy policy as personal information):


Applicants


•   Personal contact details such as your name, title, address, telephone number, e-mail address and your IP address when you visit our website.
•   Recruitment information (including personal information such as copies of your right to work documents, your CV or cover letter which is sent to us as part of the application process).
•   Information provided to us by recruitment agencies in relation to your application for employment with us.


Business contacts


•   Contact details such as your name, title, business telephone number, business e-mail address and your IP address when you visit our website.
•   Information that you provide or we collect during our interactions with you or your employer, such as how long we have done business with you or how long you have worked at your company.
•   Bank details of sole traders.


Customers


•   Personal contact details such as your name, address, telephone number, e-mail address and your IP address when you visit our website.
•   Other personal information you provide to us via our website, for example, by using the LiveChat feature via our “contact” page.
•   Payment information such as credit/ debit card number, expiration date, security code and name as it appears on the card and the address the card is registered to.
•   Personal and payment information that you provide to us at trade shows and expeditions.
•   Details which you provide to us in connection with product warranty registration.
•   Personal information provided to us via our website or social media accounts, for example, by contacting us on Facebook or Twitter.
•   Personal information provided to us during telephone calls which you have made to us and which are recorded.
•   Personal information provided to us by the third party service providers we work with, for example, analytics providers and third party companies providing us with marketing assistance.


Suppliers


•   Personal details such as your name, address, bank account information, telephone number and your IP address where you visit our website.


Competition entrants


•   If you enter or apply to enter any of our competitions or events, personal information including your name, e-mail address, telephone number and bank details (if relevant).
•   Personal information provided where you enter into one of our competitions via one of our corporate partners.


Generally


•   If you visit our offices, images and videos are recorded by the CCTV system in operation on our premises.
•   Information provided to us over the telephone which is recorded when you call our offices.
•   Any personal information provided to us following completion of our ‘Dash Cam Submission Form’.
•   Where you feature in content uploaded to our website ‘Operation Snap’.
•   Where you feature in content uploaded to our social media pages.
•   Where you feature in content provided to us by our dash cam users.
•   Any personal data provided to us at any of the trade shows that we take part in.
•   Any personal information you provide to us during your interactions with us.
•   Information gathered by cookies used on our website. Our website uses cookies to distinguish you from other users of our website. This helps us to provide you with a good experience when you browse and also allows us to improve the way our website works. For detailed information on the cookies we use and the purposes for which we use them please refer to our Cookie Policy.
•   Information provided to us by third party service providers we work with, for example, payment service or analytics providers.


2.  How will we use your personal information and what is the legal ground we rely on for doing so?


We will only use your personal information when the law allows us to. When we use your personal information, we must have a legal ground for doing so. The following are (amongst others) the legal grounds by which we can use your personal information:
•   Where you have provided us with your consent for us to do so;
•   Where we need to perform the contract we have entered into with you or to take steps to enter into a contract with you;
•   Where we need to comply with a legal obligation to which we are subject;
•   Where it is in pursuit of our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
More specifically, we will use your personal information in the following circumstances:


Applicants:


•   To evaluate and progress your application for employment with us – to perform the contract with you or to take steps to enter into a contract with you, and in pursuit of our legitimate interests to verify your suitability for our vacancies.
•   To carry out right to work checks – to comply with a legal obligation.


Business contacts


•   Your contact details – in pursuit of our legitimate interests (to facilitate business between you or your business and us).
•   Your contact details to provide you with information on our products and services. This may include technical information and/or marketing information (where you are an employee of a business) – in pursuit of our legitimate interests in keeping you informed about our products, services and business updates.
•   Your bank details (if you are a sole trader) – to perform a contract with you or take steps to enter into a contract with you.


Customers


•   Dealing with your product related enquiry via remote assistance – in pursuit of our legitimate interests to ensure that your enquiry is dealt with promptly and efficiently
•   Dealing with your enquiry made via the “Contact” page, the LiveChat feature on our website and / or social media – in pursuit of our legitimate interests to ensure your enquiry is dealt with promptly and efficiently.
•   Your contact details to provide you with marketing information on our products and services – where you have provided us with your consent for us to do so.
•   Your personal information that you provide during calls to us – in pursuit of our legitimate interests in order to ensure adequate training and monitoring of our staff.
•   Your payment information – to perform the contract with you or to take steps to enter into a contract with you.
•   Your personal information for product warranty purposes – to perform the contract with you or to take steps to enter into a contract with you
•   Your personal information provided to us via social media platforms – in pursuit of our legitimate interests to ensure that your enquiry is dealt with promptly and efficiently


Suppliers


•   Your personal details – in pursuit of our legitimate interests (to facilitate business between you or your business and us).
Competition entrants
•   Your personal details provided to us in connection with the competition that you have applied to enter into – to perform the contract with you or to take steps to enter into a contract with you.


Generally


•   To ensure our premises are kept secure – in pursuit of our legitimate interests (in ensuring our premises are kept secure and to keep evidence of this).
•   Health and safety purposes – to comply with a legal obligation.
•   Personal data provided to us at trade shows – in pursuit of our legitimate interests to understand who attended the trade show.
•   To administer our website and for internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes – in pursuit of our legitimate interests (to better understand how people interact with our website and solve any issues it may have).
•   To improve our website to ensure that content is presented in the most effective manner for you and your computer – in pursuit of our legitimate interests (to improve our content and your experience).
•   To transfer to third party service providers – in pursuit of our legitimate interests (in outsourcing for effectiveness and efficiency).
•   To contact you if we wish to use your information for a purpose not set out in this policy – to comply with a legal obligation.
•   Information provided to us via dash cam footage – in pursuit of our legitimate interests to promote our products.
•   Your personal information provided to us via social media platforms – in pursuit of our legitimate interests to ensure that your enquiry is dealt with promptly and efficiently.
•   Your personal information provided to us over the telephone – in pursuit of our legitimate interests to ensure that your enquiry is dealt with promptly and efficiently.
•   Personal information provided to us via our Operation Snap website – in pursuit of our legitimate interests to assist South Wales Police in keeping the roads safe.


3.  What happens if there is a change of purpose?


We will only use your personal information 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 information for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.


4.  Which type of third parties might we share your personal information with?


We require third parties to respect the security of your personal information and to treat it in accordance with the law. For example, where we instruct third party service providers, we carry out due diligence on those providers to ensure they treat your personal information as seriously as we do.
We may share your personal information with the following types of third parties:
•   Technical support providers, for example, assisting with our website.
•   Providers assisting us with receipt of payments via our website.
•   Recruitment agencies assisting us with filling our vacancies.
•   Professional advisers such as lawyers, accountants, insurance companies and business analysts.
•   Providers who assist us with shipping, logistics and delivery of our solutions.
•   Providers assisting us with the management of our competitions.
•   Providers which help us collate and organise information effectively and securely.
•   Providers which help us generate and collate surveys and reviews of our products and services.
•   Providers which assist us with marketing by, for example, helping us send marketing mailshots.
•   Third party software hosting companies which provide us with software solutions.
•   Providers which host our servers in their data centres (these are all within Ireland).
•   Our competition partners following your entry.


5.  Data retention



How long will we use your personal information for?


We will only retain your personal information for as long as necessary to fulfil the purposes we collected it for.
We assess the appropriate retention period for different information based on the size, volume, nature and sensitivity of that information, the potential risk of harm to you from unauthorised use or disclosure of that information, the purposes for which we are using that information, applicable legal requirements for holding that information, and whether we can achieve those purpose(s) through other means.


Applicants


•   Where your application for employment with us is successful, we will provide you with further information as to how we use your personal information during the course of your employment.
•   Where your application for employment is unsuccessful, we will keep your personal information, such as your CV and application details, for 6 months.


Business contacts


•   The period we keep your personal information depends on a number of circumstances. For example:
o   Where we have collected your personal information during the course of your and our organisations doing business, we will keep your personal information for as long as this business continues, or for as long as we have a commercial interest in holding your personal information, for example, with a view to doing business in the future.
o   In the case of sole traders, we will keep your bank account details for as long as we do business together or for as long as we have a commercial interest in holding your personal information, for example, with a view to doing business in the future.
o   Where you have provided us with your personal information during the course of making a complaint, we will keep this information for 7 years.
o   Where you use our website and one of our cookies are activated, that cookie will operate for the duration set out in our Cookie Policy.


Customers


•   If you have consented to receiving marketing information, we will keep your personal information for as long as we still have your consent;
•   If you have provided us with your personal information for the purpose of making a complaint or a customer service call, we will keep this information for 7 years.
•   If you have provided us with your personal information for the purposes of product warranty, we will keep this information for 10 years.


Suppliers


•   We will keep your personal information for as long as we and you do business together or for as long as we have a commercial interest in holding your personal information, for example, with a view to doing business in the future.
Competition entrants
•   We will keep your personal information for a period of 6 years after a competition.


Generally


•   Any data collected through our CCTV system is stored for 31 days only.
•   Images and videos of you which are provided to us and uploaded to any of our websites or applications will be deleted on request.
•   Data stored on CamViewer is stored for 30 days only.
•   Our server logs which log IP addresses are deleted after 30 days.
•   Where you provide us with your personal information at a trade event we will keep your personal information for as long as we have a commercial interest in doing so.
•   Where you provide us with your personal information at a trade event for marketing purposes we will keep your information until you withdraw your consent.


6.  Where we store your personal data


Electronic versions of your personal information are stored on our servers in the UK and Ireland.
Where we use third party service providers to assist us, your personal information may also be stored in accordance with their practices and procedures. We require third parties to respect your personal information and to treat it in accordance with the law.
Where your data is transferred outside of the EEA, we will take steps to ensure your personal information is adequately protected.


7.  Rights of access, correction, erasure and restriction



Your rights in connection with your personal information


Under certain circumstances, by law you have the right to:
•   Request access to your personal information (known as a “data subject access request”). This enables you to receive a copy of the personal information we hold about you and to check that we are lawfully processing it.
•   Request correction of the personal information that we hold about you. This enables you to have any incomplete or inaccurate information we hold about you corrected.
•   Request the erasure of your personal information. This enables you to ask us to delete or remove personal information when there is no good reason for us continuing to process it. You also have the right to ask us to stop processing personal information where we are relying on a legitimate interest and there is something about your particular situation which makes you want to object to processing on this ground.
•   Request the restriction of processing of your personal information. This enables you to ask us to suspend the processing of personal information about you, for example if you want us to establish its accuracy or the reason for processing it.
•   Request the transfer of your personal information to another party.
If you want to review, verify, correct or request erasure of your personal information, object to the processing of your personal data, or request that we transfer a copy of your personal information to another party, please contact our Data Protection Officer in writing using the contact details set out at the beginning of this privacy policy.


8.  No fee usually required


You will not have to pay a fee to access your personal information (or to exercise any of the other rights). However, we may charge a reasonable fee if your request for access is clearly unfounded or excessive. Alternatively, we may refuse to comply with the request in such circumstances.


9.  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 any personal information (or to exercise any of your other rights). This is a security measure to ensure that personal information is not disclosed to another person who has no right to receive it.


10. Right to withdraw consent


In the limited circumstances where you may have provided your consent to the collection, processing and transfer of your personal information for a specific purpose, you have the right to withdraw your consent for that specific processing at any time. To withdraw your consent, please contact our Data Protection Officer in writing using the contact details set out at the beginning of this privacy policy.
Where we are providing you with marketing information, you can also change your marketing preferences by using the unsubscribe button at the bottom of our marketing e-mails sent to you.
Once we have received notification that you have withdrawn your consent, we will no longer process your personal information for the purpose or purposes you originally agreed to, unless we have another legitimate basis for doing so.


11. What happens if you fail to provide personal information?


If you fail to provide certain information when requested, we may not be able to perform the contract we have entered into with you (such as providing you with our products or services), or we may be prevented from complying with our legal obligations (such as to ensure the health and safety of visitors to our premises).


12. Right to complain


You have the right to make a complaint if you wish to do so. The organisation with oversight of our processing is the Information Commissioner’s Office, which can be contacted in writing at Information Commissioner’s Office, Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF, by telephone (0303 123 1113) or by e-mail ([email protected]).


13. Changes to this privacy notice


We may change, modify, add or remove portions of this policy at any time, and any changes will become effective immediately.
Any changes we make to our privacy policy will be posted on this page and, where appropriate, notified to you.