Platinum Coach Services is committed to protecting and respecting your privacy.
This privacy statement (together with our terms and conditions and any other policies referred to in it) explains what information we gather about you, what and how we use that information, the lawful basis on which that information is used and who if anyone we give that information to. It also sets out your rights and our obligations in relation to your information and who you can contact for more information or queries.
Who this privacy statement applies to and what it covers
This privacy statement sets out how we will collect, handle, store and protect information about you when providing services to you or your/our clients, or performing any other activities that form part of the operation of our business Platinum Coach Services.
This privacy statement also contains information about when we share your personal information with other members of our group and other third parties (for example, third parties carrying out services/activities on our behalf).
In this privacy statement, your information is sometimes called “personal data” or “personal information”. We may also sometimes collectively refer to handling, collecting, protecting and storing your personal information as “processing” such personal information.
We understand the importance of protecting children’s privacy. Our website is not designed for, or intentionally targeted at, children. It is not our policy to intentionally collect or store information about children.
What information we collect
We may collect and process personal data about you because you give it to us, because other people give that data to us (for example, third party service providers that we use/partner to help operate our business) or because it is publicly available.
The personal data that we collect or obtain may include: your name; age; date of birth; gender; e-mail address; home address; country of residence; lifestyle and social circumstances (for example, your pastimes); employment (for example, the organisation you work for, your job title); your IP address; your browser type and language; your access times; complaint details; details of how you use our products and services; details of how you like to interact with us and other similar information.
We may collect and process personal data about you that you give to us, as follows:
- If you provide information to us by filling in forms on our website. This may include information provided at the time of enquiry, subscribing to any of our services, posting material, and sending messages, giving reviews, making or receiving payments through your Platinum Coach Services Account or requesting further services.
- Details of transactions.
- We may ask you for information when you report an issue or concern or we have or receive a complaint or query about you (whether or not a formal dispute is raised).
- We may keep a record of correspondence between you and us.
We may collect and process personal data about you from other sources as follows:
- Where we are provided with personal data about you by any third party such as a service provider, we take steps to ensure that that third party has complied with the privacy laws and regulations relevant to that information; this may include, for example, that the third party has provided you with notice of the collection (and other matters) and has obtained any necessary consent (if applicable) for us to process that information as described in this privacy statement.
Use of personal data
We will use your personal data to fulfil your requests and we will ask only for data that is adequate, relevant and not excessive for those purposes. Where we send you information for any purpose, it may be sent by e-mail or post. When we ask you for personal data it may include the following purposes:
- We may contact you occasionally to inform you of new products and services we will be providing;
- We may send you regular updates on issues we think will be of interest to you;
- We may send you requested information on our products and services;
- We may use your personal data for marketing purposes and market research;
- We may use your personal data internally to provide you with the services offered by us via this website, to administer this website and to help us improve our services.
- We may use your personal data for managing and making information available to our internal trusted partners only
- We may use your personal data to allow you to participate in interactive features of our service
- We may use your personal data to notify you about changes to our services, terms and conditions, policies or website.
- We may use your personal data to manage risk, or to investigate, detect, prevent, and/or remediate fraud, suspected fraud or other potentially illegal or prohibited activities.
- We may use your personal data pursuant to applicable legal or regulatory requirements or to respond to requests and communications from competent authorities (including courts and tribunals).
- We may use your personal data for the services we receive from our professional advisors, such as lawyers, accountants and consultants.
- We may use your personal data for protecting our rights, those of our clients, or protecting those of our affiliates.
None of the information that we request from you is mandatory.
The legal grounds we use for processing personal information
We are not allowed to process personal information if we do not have a valid legal ground. Therefore, we will only process your personal information for the purposes outlined above because:
- Of our legitimate interests in the performance of activities that form part of the operation of our business;
- Of our legitimate interests in the effective and lawful operation of our business so long as such interests are not outweighed by your interests or fundamental rights and freedoms;
- Of the legal and regulatory obligations that we maybe subject to
- The information is required in order to carry out the activities that form part of the operation of our business (e.g. the processing is necessary to perform our contractual obligations towards you).
Examples of the ‘legitimate interests’ referred to above are:
- To verify the accuracy of information provided by a third party;
- To prevent fraud or criminal activity;
- To safeguard the security of our IT systems, architecture and networks.
- To exercise our rights under Articles 16 and 17 of the Charter of Fundamental Rights, including our freedom to conduct a business and right to property.
To the extent that we process any sensitive personal data relating to you for any of the purposes outlined above, we will do so because either: (i) we are required by law to process that data in order to ensure we meet our ‘know your client’ and ‘anti money laundering’ obligations (or other legal obligations imposed on us); (ii) the processing is necessary for the establishment, exercise or defence of legal claims.
We may, from time to time, e-mail or post you information to make you aware of our other similar products and services which may be of interest to you. If you do not wish to receive emails or post from us for these purposes, or if you want to be removed from our electronic mailing list you can either select “unsubscribe” from any of the marketing emails that we send or alternatively contact us.
In order to collect the anonymous data described in the preceding paragraph, we may use temporary “cookies” that remain in the cookies file of your browser until the browser is closed. Cookies by themselves cannot be used to discover the identity of the user. A cookie is a small piece of information which is sent to your browser and stored on your computer’s hard drive. Cookies do not damage your computer. You can set your browser to notify you when you receive a cookie, this enables you to decide if you want to accept it or not.
Disclosure of your personal data
In connection with one or more of the purposes outlined in the “Use of personal data” section above, we may disclose details about you to: our affiliates; third parties that provide services to us and/or our affiliates,
Where appropriate, before disclosing personal data to a third party, we contractually require the third party to take adequate precautions to protect that data and to comply with applicable law.
Protection of your personal data
All Platinum Coach Services personnel accessing personal information must comply with the internal rules and processes in relation to the processing of personal data to protect them and ensure the confidentiality of such information.
Although we use appropriate security measures once we have received your personal data, the transmission of data over the internet (including by e-mail) is never completely secure. We endeavour to protect personal data, but we cannot guarantee the security of data transmitted to us or by us.
You have various rights in relation to your personal data. In particular, you have a right to request a copy of personal data we hold about you
o ask that we update the personal data we hold about you, or correct such personal data that you think is incorrect or incomplete
o ask that we delete personal data that we hold about you, or restrict the way in which we use such personal data
o object to our processing of your personal data
o ask that we restrict our processing of your personal data; and
To exercise any of your rights, or if you have any other questions about our use of your personal data, please contact us at [email protected]
Right to complain
If you are unhappy with the way we handled your personal information or any privacy query or request you have raised with us you also have a right to complain to a data protection authority in the place where you live or work, or in the place where you think an issue in relation to your data has arisen.
Changes to our privacy statement
We may modify or amend this privacy statement from time to time.
To let you know when we make changes to this privacy statement, we will amend the revision date at the end of this page. The new modified or amended privacy statement will apply from that revision date. Therefore, we encourage you to periodically review this statement to be informed about how we are protecting your information.
If you have any questions, comments or requests regarding this privacy statement please contact us at [email protected]
Last updated: May 23, 2018
s set out below, we do not share, or sell, or disclose to a third party, any information collected through our website.
The bases on which we process information about you
The law requires us to determine under which of six defined bases we process different categories of your personal information, and to notify you of the basis for each category.
If a basis on which we process your personal information is no longer relevant then we shall immediately stop processing your data.
If the basis changes then if required by law we shall notify you of the change and of any new basis under which we have determined that we can continue to process your information.
1. Information we process because we have a contractual obligation with you
When you create an account on our website, buy a product or service from us, or otherwise agree to our terms and conditions, a contract is formed between you and us.
In order to carry out our obligations under that contract we must process the information you give us. Some of this information may be personal information.
We may use it in order to:
1.1. verify your identity for security purposes
1.2. sell products to you
1.3. provide you with our services
1.4. provide you with suggestions and advice on products, services and how to obtain the most from using our website
We process this information on the basis there is a contract between us, or that you have requested we use the information before we enter into a legal contract.
Additionally, we may aggregate this information in a general way and use it to provide class information, for example to monitor our performance with respect to a particular service we provide. If we use it for this purpose, you as an individual will not be personally identifiable.
We shall continue to process this information until the contract between us ends or is terminated by either party under the terms of the contract.
2. Information we process with your consent
Through certain actions when otherwise there is no contractual relationship between us, such as when you browse our website or ask us to provide you more information about our business, including our products and services, you provide your consent to us to process information that may be personal information.
Sometimes you might give your consent implicitly, such as when you send us a message by e-mail to which you would reasonably expect us to reply.
Except where you have consented to our use of your information for a specific purpose, we do not use your information in any way that would identify you personally. We may aggregate it in a general way and use it to provide class information, for example to monitor the performance of a particular page on our website.
If you have given us explicit permission to do so, we may from time to time pass your name and contact information to selected associates whom we consider may provide services or products you would find useful.
We continue to process your information on this basis until you withdraw your consent or it can be reasonably assumed that your consent no longer exists.
You may withdraw your consent at any time by instructing us [email protected]. However, if you do so, you may not be able to use our website or our services further.
3. Information we process for the purposes of legitimate interests
We may process information on the basis there is a legitimate interest, either to you or to us, of doing so.
Where we process your information on this basis, we do after having given careful consideration to:
whether the same objective could be achieved through other means
whether processing (or not processing) might cause you harm
whether you would expect us to process your data, and whether you would, in the round, consider it reasonable to do so
For example, we may process your data on this basis for the purposes of:
record-keeping for the proper and necessary administration of our
responding to unsolicited communication from you to which we believe you would expect a response
protecting and asserting the legal rights of any party
insuring against or obtaining professional advice that is required to manage business risk
protecting your interests where we believe we have a duty to do so
4. Information we process because we have a legal obligation
We are subject to the law like everyone else. Sometimes, we must process your information in order to comply with a statutory obligation.
For example, we may be required to give information to legal authorities if they so request or if they have the proper authorisation such as a search warrant or court order.
This may include your personal information.
Specific uses of information you provide to us
5. Complaints regarding content on our website
If you complain about any of the content on our website, we shall investigate your complaint.
If we feel it is justified or if we believe the law requires us to do so, we shall remove the content while we investigate.
Free speech is a fundamental right, so we have to make a judgment as to whose right will be obstructed: yours, or that of the person who posted the content that offends you.
If we think your complaint is vexatious or without any basis, we shall not correspond with you about it.
7. Information relating to your method of payment
Payment information is never taken by us or transferred to us either through our website or otherwise. Our employees and contractors never have access to it.
8. Sending a message to our support team
When you contact us, whether by telephone, through our website or by e-mail, we collect the data you have given to us in order to reply with the information you need.
We record your request and our reply in order to increase the efficiency of our business. We do not keep any personally identifiable information associated with your message, such as your name or email address.
When we receive a complaint, we record all the information you have given to us.
We use that information to resolve your complaint.
If your complaint reasonably requires us to contact some other person, we may decide to give to that other person some of the information contained in your complaint. We do this as infrequently as possible, but it is a matter for our sole discretion as to whether we do give information, and if we do, what that information is.
We may also compile statistics showing information obtained from this source to assess the level of service we provide, but not in a way that could identify you or any other person.
Use of information we collect through automated systems when you visit our website
Cookies are small text files that are placed on your computer’s hard drive by your web browser when you visit any website. They allow information gathered on one web page to be stored until it is needed for use on another, allowing a website to provide you with a personalised experience and the website owner with statistics about how you use the website so that it can be improved.
Some cookies may last for a defined period of time, such as one day or until you close your browser. Others last indefinitely.
Your web browser should allow you to delete any you choose. It also should allow you to prevent or limit their use.
10.1. to track how you use our website
10.2. to record whether you have seen specific messages we display on our website
11. Personal identifiers from your browsing activity
Requests by your web browser to our servers for web pages and other content on our website are recorded.
We record information such as your geographical location, your Internet service provider and your IP address. We also record information about the software you are using to browse our website, such as the type of computer or device and the screen resolution.
We use this information in aggregate to assess the popularity of the webpages on our website and how we perform in providing content to you.
If combined with other information we know about you from previous visits, the data possibly could be used to identify you personally, even if you are not signed in to our website.
12. Our use of re-marketing
Re-marketing involves placing a cookie on your computer when you browse our website in order to be able to serve to you an advert for our products or services when you visit some other website.
Disclosure and sharing of your information
13. Information we obtain from third parties
Although we do not disclose your personal information to any third party (except as set out in this notice), we sometimes receive data that is indirectly made up from your personal information from third parties whose services we use.
No such information is personally identifiable to you and is not shared.
Access to your own information
14. Access to your personal information
14.1. To obtain a copy of any information that is not provided on our website you may send us a request at [email protected]
14.2. After receiving the request, we will tell you when we expect to provide you with the information, and whether we require any fee for providing it to you.
15. Removal of your information
If you wish us to remove personally identifiable information from our website, you may contact us at [email protected]
This may limit the service we can provide to you.
16. Verification of your information
When we receive any request to access, edit or delete personal identifiable information we shall first take reasonable steps to verify your identity before granting you access or otherwise taking any action. This is important to safeguard your information.
17. Use of site by children
17.1. We do not sell products or provide services for purchase by children, nor do we market to children.
17.2. If you are under 18, you may use our website only with consent from a parent or guardian
18. How you can complain
18.2. If a dispute is not settled then we hope you will agree to attempt to resolve it by engaging in good faith with us in a process of mediation or arbitration.
18.3. If you are in any way dissatisfied about how we process your personal information, you have a right to lodge a complaint with the Information Commissioner’s Office. This can be done at https://ico.org.uk/concerns/
19. Retention period for personal data
Except as otherwise mentioned in this privacy notice, we keep your personal information only for as long as required by us:
19.1. to provide you with the services you have requested;
19.2. to comply with other law, including for the period demanded by our tax authorities;
19.3. to support a claim or defence in court.
20. Compliance with the law
However, ultimately it is your choice as to whether you wish to use our website.
We may update this privacy notice from time to time as necessary. The terms that apply to you are those posted here on our website on the day you use our website. We advise you to print a copy for your records.