Privacy Policy

PRIVACY POLICY

LAST UPDATED AND EFFECTIVE: January 1, 2020

1. Who Is Collecting My Personal Data?
[PDI Limited] (collectively, “Company,” “us,” “we,” or “our”) offers and maintains websites located at [www.pdihctestindev.wpengine.com/global], including all subdomains and subparts (individually, the “Site,” and collectively, the “Sites”). We respect the privacy of everyone who visits the Sites. Our Privacy Policy is an extension of our commitment to combine the highest-quality service with the highest level of integrity in dealing with our visitors and customers. This policy was developed to inform visitors to the Sites about how we handle and use personal information. Privacy is important; we hope you take the time to read this Privacy Policy carefully. UNLESS OTHERWISE STATED HEREIN, BY USING THE SITE(S), YOU AGREE TO THE COLLECTION, USE, AND DISCLOSURE OF INFORMATION IN ACCORDANCE WITH THIS PRIVACY POLICY.

We will regularly assess this Privacy Policy against new technologies, business practices, and our customers’ needs to ensure that you are informed to make choices about how to share and secure your personal data. If you have questions about this privacy statement, our information practices, or your dealings with us, please contact us at [+00 44 (0) 1352 736700] or [optout@pdi-hc.co.uk].

2. What Data Do You Collect?
When you voluntarily provide it to us, we collect information that identifies you (“Personal Data”), such as your:

• Name;
• Email address;
• Address;
• Telephone number;
• Payment information; and
• Email messages to us.

When you visit the Site, we collect data from the device or browser through which you access the Site (“Log Data”), such as:

• Your internet protocol (“IP”) address;
• You browser type;
• Your browser version;
• Statistics on your activities on the Site (such as the date and time of visits, the pages viewed, and the amount of time spent on the Site);
• Information about how you came to the Site; and
• Data collected through cookies or other similar technologies discussed in more detail in our Cookie policy.

Much of this Log Data does not identify you personally. However, we may associate this Log Data with your Personal Data. When we do, we will treat any such combined data as Personal Data until such time as it can no longer be associated with you or used to identify you.

3. How Do We Use Your Personal Data?
Broadly speaking, we use Personal Data for the purposes for which you provided it. If you engage us for services, we will use your name and contact information to fulfill your needs, including billing and delivery if applicable.

If you send us an email, we may use your email address and other information you submit to provide customer service to you.

We may also use your Personal Data or Log Data to administer our internal business activities, such as to design and arrange the Site in the most user-friendly manner and to continually improve the Site to better meet the needs of our customers and prospective customers, to better understand visitors to the Site, to manage your account, to provide customer service, or to make available other products and services to our customers and prospective customers.

In addition, we may use third-party services, such as Google Analytics, that collect, monitor, and analyze Log Data.

4. How Do You Share My Personal Data?
A. No Sale of Personal Data
We are not in the business of selling your Personal Data. We consider this information to be a vital part of our relationship with you. Therefore, we will not sell your Personal Data to third parties, including third-party advertisers. There are, however, certain circumstances in which we may disclose, transfer, or share your Personal Data with certain third parties without further notice to you, as set forth below.

B. Sharing Personal Data With Affiliates, Successors, and Agents
We, like many businesses, sometimes engage other companies to perform certain business-related functions. These companies may include marketing agencies, database service providers, backup and disaster recovery service providers, email service providers, payment processors, and others. When we engage another company to perform such functions, we may provide it with Personal Data, Log Data, or aggregate information about our customers, sales, website traffic patterns, and related website information, in connection with its performance of such functions. We take measures to select service providers that are responsible and afford privacy protections to their customers. However, we cannot make any representations about the practices and policies of these third-party companies.

C. Sharing Data Through Social Media
We may work with social media sites like Facebook, and with application developers who specialize in social commerce so you can connect to us, share your interests, express opinions about products and services, purchase our services or products, and generate interest in our services among members of your social networks.

If you use third-party social media features, we or the third party may collect or share your data, including your Personal Data. We consider information collected from or shared through any such social media features as public information, because the third-party social media sites made it publicly available. If you do not want us to be able to access information about you, including Personal Data, from third-party sites, you must limit data collection and disclosure in the privacy settings on the third-party sites. We reserve the right to remove the Personal Data or other data of any person for any reason we, in our sole discretion, deem appropriate.

D. Legally-Compelled Disclosure of Personal Data
We may disclose your Personal Data if required to do so by law or in our good-faith belief that such action is necessary to:

• comply with a legal obligation;
• protect or defend our rights, interests, or property, or that of third parties;
• prevent or investigate possible wrongdoing in connection with the Site;
• act in urgent circumstances to protect the personal safety of users of the Site or the public; or
• protect against legal liability.

5. What Are My Rights Regarding The Processing Of My Personal Data?
People have different privacy concerns. Our goal is to be clear about what information we collect, so that you can make meaningful choices about how it is used.

You may choose to limit the Personal Data you submit by merely browsing the Site without providing your name or other information. If you do so, you may not be able to use certain functionality of the Site. To register for an account, for example, you must provide your name and email address, as well as other information.

If you would prefer for us not to exchange your name with other companies, please contact us at [optout@pdi-hc.co.uk, +00 44 (0) 1352 736700, PDI Ltd, Aber Park, Flint CH6 5EX].

6. Is My Personal Data Secure?
We are committed to the protection of your information. We may store Personal Data or such information may be stored by third parties to whom we have transferred it in accordance with this Privacy Policy. We take what we believe to be reasonable steps to protect the Personal Data collected via the Site from loss, misuse, unauthorized access, inadvertent disclosure, alteration, and destruction. However, no network, server, database, or internet or e-mail transmission, is ever fully secure or error free. Therefore, you should take special care in deciding what information you send to us electronically. Please keep this in mind when disclosing any Personal Data.

7. How Long Will You Keep My Personal Data?
We may retain your Personal Data as long as you continue to use the Site. However, we may retain Personal Data for an additional period as is permitted or required under applicable laws. Even if we delete your Personal Data, it may persist on backup or archival media for an additional period of time.

8. How Do You Use Cookies?
A. What Are Cookies?
A cookie is a piece of information that is placed on your web browser or device when you access and/or use the Site. Cookies store text and can later be read back by the Site or third parties. Cookies can remember the information you access on one webpage to simplify your subsequent interactions with the Site or to use the information to streamline your transactions on related webpages.

B. What Do You Use Cookies For?
We use cookies to recognize your browser and you as a unique visitor to the Site through an anonymous unique identifier. We use cookies to:
• monitor and analyze how you use the Site;
• remember your preferences to make your online experience easier and more personalized;
• route Site traffic to effectively distribute the Site workload across servers; and
• test new features.
We may use cookies placed by third parties to deliver focused online banner advertisements to you both on and off the Site.

C. How can I manage cookies?
You can manage cookies through your web browser’s “Options” settings. You may be able to be notified when you are receiving new cookies and disable or delete cookies. Please refer to your web browser’s “Help” section for information on whether you can and how to do this.

Many of the third-party technologies that enable targeted banner advertising also allow you to opt out. Such third-party service providers include Adroll, Rubicon, Google, Media Math, Perfect Audience, Quantcast, Retargeter, and Yahoo!, among others. You can control your preferences directly with each such third-party service provider.

You can learn more about cookies at the following third-party websites:

• All About Cookies: http://www.allaboutcookies.org/; and
• Network Advertising Initiative: http://www.networkadvertising.org/

Note that if you disable, delete, or refuse to accept cookies, you may not be able to use some features of the Site and/or some of our pages might not display properly.

9. What Data Is Not Covered By The Privacy Policy?
The limitations in and requirements of this Privacy Policy do not apply to:
A. Third-Party Sites
Any data you disclosed on websites not operated or controlled by us, even though we may provide links to them on the Site or in our emails. We are not responsible for the policies and practices employed by, or the content of, such third-party sites. We suggest contacting those sites directly for information about their privacy policies and practices.

B. Non-Personally Identifiable Data
Any non-personally identifiable data we collect, including, without limitation, Log Data, domain names of your Internet Service Provider, your approximate geographic location, a record of your usage of the Site, the time of your usage, and aggregated Personal Data, but only to the extent the foregoing cannot be used to specifically identify you.

C. Aggregated Personal Data
Any aggregated Personal Data that can no longer be used to identify you will be treated as non-personally identifiable data under this Privacy Policy.

10. Do You Collect The Personal Data Of Children?
We do not intentionally or knowingly collect any Personal Data from children under the age of 18, nor do we target our emails to them. Children under the age of 18 should not submit any Personal Data through the Site. We encourage parents and legal guardians to monitor their children’s use of the internet and instruct them to never provide Personal Data through the Site. If you believe a child under the age of 18 may have provided Personal Data to us through the Site, please contact us at [optout@pdi-hc.co.uk or +00 44 (0) 1352 736700] and we will use reasonable efforts to delete it from the Site and our files.

11. What If We Change This Policy?
The Site and our business may change from time to time. As a result, it may be necessary for us to make changes to this Privacy Policy. We reserve the right, in our sole discretion, to modify or supplement this policy at any time. If a material change to the terms of this policy is made, we will send you an email or post a notice on the Site’s homepage with a link to the new policy. Modifications will be effective thirty (30) days following the date of posting such a notice or such other date as is communicated in any other notice to you. Your continued use of the Site following the effectiveness of any modifications to this Privacy Policy constitutes acceptance by you of those modifications. If any modification to this Privacy Policy is not acceptable to you, you should cease accessing, browsing, and otherwise using the Site and contact us at [optout@pdi-hc.co.uk or +00 44 (0) 1352 736700].

12. Your European Union Privacy Rights
A. Your personal data – What is it?
Personal data relates to a living individual who can be identified from that data. Identification can be by the information alone or in conjunction with any other information in the data controller’s possession, or likely to come into such possession. The processing of personal data for residents of the European Union (“EU”) is governed by the General Data Protection Regulation (the “GDPR”).

B. Who are we?
Company is a data controller of certain personal data. This means it decides how your personal data is processed and for what purposes.

C. How do we process your personal data?
Company complies with its obligations under the GDPR and all other applicable laws by keeping personal data up to date; by storing and destroying it securely; by not collecting or retaining excessive amounts of data; by protecting personal data from loss, misuse, unauthorized access and disclosure and by ensuring that appropriate technical measures are in place to protect personal data.

We use your personal data for the following purposes:

• To maintain our own accounts and records; and
• To inform you of news, events, activities and services provided by Company.

D. What is the legal basis for processing your personal data?
Company has a legitimate interest in your personal data based on your business relationship with Company, and/or it has your explicit consent so that we can keep you informed about news, events, activities and services.

E. Sharing your personal data
Your personal data will be treated as strictly confidential and will only be shared with other entities for the foregoing purposes. We will only share your data with third parties with your consent.

F. How long do we keep your personal data?
We may keep data for as long as reasonably required to meet the purposes described herein. Additionally, we will retain this information as required by law, as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements.

G. Your rights and your personal data
Unless subject to an exemption under the GDPR, you have the following rights with respect to your personal data:

• The right to request a copy of your personal data which Company holds about you;
• The right to request that Company correct any personal data if it is found to be inaccurate or out of date;
• The right to request your personal data is erased where it is no longer necessary for Company to retain such data;
• The right to withdraw your consent to the processing at any time;
• The right to request that Company provide you with your personal data and where possible, to transmit that data directly to another data controller (known as the right to data portability), where applicable;
• The right, where there is a dispute in relation to the accuracy or processing of your personal data, to request a restriction is placed on further processing;
• The right to object to the processing of personal data, where applicable; and
• The right to lodge a complaint with the Information Commissioners Office.

H. Further processing
If we wish to use your personal data for a new purpose, not covered by this Privacy Policy, we will provide you with a new notice explaining this new use prior to commencing the processing and setting out the relevant purposes and processing conditions. Whenever necessary, we will seek your prior consent to the new processing.

I. Contact Details
To exercise all relevant rights, or for more information, please contact us at [optout@pdi-hc.co.uk, +00 44 (0) 1352 736700, PDI Ltd, Aber Park, Flint, CH6 5EX].

You can also contact the Information Commissioners Office at 0303 123 1113, via email at https://ico.org.uk/global/contact-us/email/ or at the Information Commissioner’s Office, Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF.

For residents of Italy, please contact Garante per la protezione dei dati personali at +39-06-696771, via email at garante@gpdp.it, or at Piazza di Monte Citorio, 121, 00186 Roma, Italy.

15. How Can I Resolve A Privacy Dispute With You?
If you have a complaint about our privacy practices, we will take reasonable steps to work with you to attempt to resolve your complaint under the arbitration procedures described in the Site’s Terms of Use. TO THE EXTENT PERMITTED UNDER THE APPLICABLE LAW, BY USING THE SITE, COMPANY AND YOU EACH AGREE TO SETTLE DISPUTES ONLY BY ARBITRATION, INSTEAD OF SUING IN COURT (EXCEPT CERTAIN SMALL CLAIMS). THE RULES IN ARBITRATION ARE DIFFERENT. THERE IS NO JUDGE OR JURY, AND REVIEW IS LIMITED, BUT AN ARBITRATOR CAN AWARD THE SAME DAMAGES, AND MUST HONOR THE SAME LIMITATIONS STATED IN THE AGREEMENT, AS A COURT WOULD. You must first send us a notice of your complaint that includes a written statement of your name, address, and contact information, the facts giving rise to your complaint, and the relief you are requesting (the “Dispute Notice”). The Dispute Notice must be addressed to [PDI Ltd, Aber Park, Flint CH6 5EX], and sent by certified mail. If you do not reach an agreement with us to resolve your privacy complaint within sixty (60) days after the Dispute Notice is received, you may commence an arbitration proceeding.

16. Should I Access This Site If I Am Not A Resident Of The European Union?

The Site is intended for residents of the European Union only. If you are not a resident of the European Union, please cease using and accessing the Site and visit any Company affiliate website(s) intended for your region. For questions regarding which Company affiliate websites are intended for your region, please contact [contact information].