1. Introduction
Your privacy is important to us and we are committed to protecting and respecting your privacy. This Privacy Policy is intended to help you better understand how we collect, use and store your ”Personal Data” – defined as information that can be associated with or which relates to a person and/or could be used to identify a person.
When you use or interact with us through the Services, we may collect Personal Data on our own behalf
Probity Europe will never sell on your Personal Data to third parties and if you choose to consent to receiving marketing emails from Probity Europe you will be able to unsubscribe at any time.
By using any of Probity Europe’s services, you are agreeing to the terms of this Privacy Policy and, as applicable, the Probity Europe’s Terms and Conditions.
Probity Europe Limited is a company incorporated in England and Wales under company number 08446926. Our address is 3, The Barns, London Road, Bourne End. Herts. HP1 2RH
Probity Europe Limited – which we will refer to as ‘Probity’ in the rest of this document.
If you have any questions or concerns at any time you can contact us at the above address or via email [email protected].
2. Personal Data That We Collect
2.1 All Users
Information you provide to us: For all Users we collect Personal Data when you voluntarily provide such information to the Services, such as when you register for access to the Services, contact us with enquiries or browse or use certain parts of the Services. The Personal Data we may collect includes without limitation your name, address, email address and other information that enables Users to be personally identified.
3. How We Use Your Personal Data
We collect and use the Personal Data we collect in a manner that is consistent with this Privacy Policy. We may use the Personal Data as follows:
3.1 Specific Reason
If you provide Personal Data for a certain purpose, we may use the Personal Data in connection with the purpose for which it was provided. For instance, if you contact us by e-mail, we will use the Personal Data you provide to answer your question or resolve your problem and will respond to the email address from which the contact came.
3.2 Access, Use and Provision of Services
If you provide Personal Data in order to obtain access to or use of the Services or any functionality thereof, we will use your Personal Data to provide you with access to or use of the Services or functionality and to analyse your use of such Services or functionality. For instance, if you supply Personal Data relating to your identity to use certain portions of the Services, we will use that information to grant you access to use such Services. Similarly, if you supply Personal Data in the course of an ecommerce transaction, we will use that Personal Data to fulfil that transaction and supply you with the items/events you have purchased.
3.3 Marketing Communications
You will only receive marketing emails from Probity if you have opted in to receive them. We will make sure it is clear when you can make these choices, for example, we have boxes you need to select if you want to receive marketing at checkout. You will always be able to unsubscribe from any marketing emails fat any time.
Probity provides a mailing list signup widget and sign up option at checkout for Customers to join the mailing list. For example, if you are signing up to a mailing list for a band, it will state clearly who that band is. You can opt out at anytime by clicking “unsubscribe” in the email or by contacting [email protected].
3.4 Other Purposes
If we intend to use any Personal Data in any manner that is not consistent with this Privacy Policy, you will be informed of such anticipated use prior to or at the time the Personal Data is collected, or we will obtain your consent subsequent to such collection but prior to such use.
4. How We Disclose And Transfer Your Personal Data
4.1 No Sale
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.
4.2 Business Transfers
As we develop our business, we might sell or buy businesses or assets. In the event of a corporate sale, merger, reorganisation, dissolution or similar event, Personal Data may be part of the transferred assets. You acknowledge and agree that any successor to or acquirer of Probity (or its assets) will continue to have the right to use your Personal Data and other information in accordance with the terms of this Privacy Policy.
4.3 Agents, Consultants and Service Providers
We may share your Personal Data with our contractors and service providers who process Personal Data on behalf of Probity to perform certain business-related functions. These companies include fulfilment providers, payment processors, online chat and email providers, money transfer services, database service providers, backup and disaster recovery service providers and others. When we engage another company to perform such functions, we may provide them with information, including Personal Data, in connection with their performance of such functions.
4.4 Legal Requirements
We may disclose your Personal Data if required to do so by law in order to (for example) respond to a subpoena or request from law enforcement, a court or a government agency (including in response to public authorities to meet national security or law enforcement requirements), or in the good faith belief that such action is necessary to (a) comply with a legal obligation, (b) protect or defend our rights, interests or property or that of third parties, (c) prevent or investigate possible wrongdoing in connection with the Services, (d) act in urgent circumstances to protect the personal safety of Users of the Services or the public, or (e) protect against legal liability.
5. How We Store Your Personal Data
We may store Personal Data itself 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 organisational and technological security measures to protect the Personal Data collected via the Services from loss, misuse, unauthorised use, 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.
6. How You Can Access, Update, Correct or Delete Your Personal Data
You can request access to some of your Personal Data being stored by us. You can also ask us to correct, update or delete any inaccurate Personal Data that we process about them.
If you are a registered User, you can exercise these rights by logging in and visiting the My Account page. Both registered and unregistered Users may also exercise these rights by contacting us directly by email via [email protected] or at the address specified below.
We will consider and respond to all requests in accordance with applicable law.
7. How Long We Retain Your Personal Data
We may retain your Personal Data as long as you are registered to use the Services. You may close your account by contacting [email protected]. 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 for legal, tax or regulatory reasons or for legitimate and lawful business purposes.
8. Your Choices
You have several choices available when it comes to your Personal Data:
9. Limit the Personal Data You Provide
You can browse the Services without providing any Personal Data (other than Automatic Data to the extent it is considered Personal Data under applicable laws) or with limiting the Personal Data you provide. If you choose not to provide any Personal Data or limit the Personal Data you provide, you may not be able to use certain functionality of the Services. For instance, in order to buy items as a Customer, your name, address, billing information and email address will be required by the Merchant.
9.2 Opt Out from Electronic Communications
(a) Merchant Initiated Communications.
Probity may use email tools, such as MailChimp, or other services, to send electronic communications to our email subscription lists. Probity uses the email tools only in accordance with all applicable laws. Probity provides an “Unsubscribe” link on each of these emails, which allows recipients to “opt out” of electronic communications.
(b) Retention.
It may take up to 2 working days for us to process an unsubscribe request. Even after you opt out of all electronic communications, we will retain your Personal Data in accordance with this Privacy Policy, however, we will no longer use it to contact you. However, Merchants who have received your Personal Data in accordance with this Privacy Policy may still use that Personal Data to contact you in accordance with their own privacy policies.
9.3 Do Not Track
We currently do not participate in any “Do Not Track” frameworks that would allow us to respond to signals or other mechanisms from you regarding the collection of your Personal Data.
10. Exclusions
We do not knowingly collect Personal Data from children under the age of thirteen (13). If you are under the age of thirteen (13), please do not submit any Personal Data through the Services. We encourage parents and legal guardians to monitor their children’s Internet usage and to help enforce our Privacy Policy by instructing their children never to provide Personal Data through the Services without their permission. If you have reason to believe that a child under the age of 13 has provided Personal Data to us through the Services, please contact us via [email protected] we will endeavour to delete that information from our databases.
11. Changes To This Privacy Policy
The Services and our business may change from time to time. As a result, at times it may be necessary for us to make changes to this Privacy Policy. We reserve the right, in our sole discretion, to update or modify this Privacy Policy at any time (collectively, “Modifications”). Modifications to this Privacy Policy will be posted to the Site with a change to the “Updated” date at the top of this Privacy Policy. In certain circumstances Probity may, but need not, provide you with additional notice of such Modifications, such as via email or with in-Service notifications. Modifications will be effective thirty (30) days following the “Updated” date or such other date as communicated in any other notice to you.
Please review this policy periodically, and especially before you provide any Personal Data. This Privacy Policy was updated on the date indicated above. Your continued use of the Services following the effectiveness of any Modifications to this Privacy Policy constitutes acceptance of those Modifications. If any Modification to this Privacy Policy is not acceptable to you, you should cease accessing, browsing and otherwise using the Services.
12. Complaints
If you have a complaint about Probity’s privacy practices you should email [email protected] or write to us at:
Probity Europe Limited, 3, The Barns, London Road, Bourne End. HP1 2RH . We will take reasonable steps to work with you to attempt to resolve your complaint.
13. EEA, SWITZERLAND AND UK ONLY
The EU General Data Protection Regulation (GDPR)
In May 2018, a new data privacy law known as the EU General Data Protection Regulation (or the “GDPR”) becomes effective. The GDPR requires Probity and Merchants using the Service to provide Users with more information about the processing of their Personal Data.
Here is what you need to know:
Legal grounds for processing your Personal Data
The GDPR requires us to tell you about the legal ground we’re relying on to process any Personal Data about you. The legal grounds for us processing your Personal Data for the purposes set out in Section 3 above will typically be because:
• you provided your consent (for example for marketing emails);
• it is necessary for our contractual relationship;
• the processing is necessary for us to comply with our legal or regulatory obligations; and/or
• the processing is in our legitimate interest as an ecommerce platform (for example, to protect the security and integrity of our systems and to provide
Personal Data retention
We retain your Personal Data for as long as necessary to provide you with our Services, or for other important purposes such as complying with legal obligations, resolving disputes, and enforcing our agreements. If you have an account with us, we will typically retain your Personal Data for a period of 90 days after you have requested that your account is closed. All Personal Data will be anonymised if your account is inactive for 10 years.
Your rights
Data protection law provides you with rights in respect of Personal Data that we hold about you, including the right to request a copy of the Personal Data, request that we rectify, restrict or delete your Personal Data, object to profiling and unsubscribe from marketing communications.
For the most part, you can you can exercise these rights by contacting [email protected] Please note that requests to exercise data protection rights will be assessed by us on a case-by-case basis.
If you have a complaint about how we handle your Personal Data, please get in touch with us as set forth in Section 14 to explain. If you are not happy with how we have attempted to resolve your complaint, you may contact the relevant data protection authority. In the UK, this is the Information Commissioner’s Office.
Probity acts as a data controller on respect of your personal data.
EU data protection law makes a distinction between organisations that process Personal Data for their own purposes (known as “data controllers”) and organisations that process personal data on behalf of other organisations (known as “data processors”). If you have a question or complaint about how your Personal Data is handled, these should always be directed to the relevant data controller since they are the ones with primary responsibility for your Personal Data.