- The pullmaneditions.com website (referred to as, the “Site”)
- other interactions (e.g., customer service inquiries, user conferences, etc.) you may have with Pullman Editions.
If you do not agree with the terms, do not access or use the Site or any other aspect of Pullman Editions’ business.
- This policy applies to the Company’s employees, contractors and officers.
- The Company has a contract with all Data Processors that it uses in compliance with Article 28 & Article 29 of the GDPR, and ensures that all Data Processors are compliant with Data Protection Legislation.
- The policy does not apply to third party services. Where third party services are used, and the third party is not a Data Processor, no Relevant Data (as defined below) is shared with them, or the Relevant Data has been anonymised such that the GDPR does not apply. Information collected by third parties is governed by their privacy practices. We encourage you to learn about the privacy practices of those third parties.
- This policy applies to Relevant Data received and processed only.
1.1 Relevant Legislation
Along with our business and internal computer systems, this website is designed to comply with the following national and international legislation with regards to data protection and user privacy:
- UK Data Protection Act 1988 (DPA)
- EU Data Protection Directive 1995 (DPD)
- EU General Data Protection Regulation 2018 (GDPR)
This site’s compliance with the above legislation, all of which are stringent in nature, means that this site is likely compliant with the data protection and user privacy legislation set out by many other countries and territories as well. If you are unsure about whether this site is compliant with your own country of residences’ specific data protection and user privacy legislation you should contact our data protection officer for clarification.
1.2 Your Rights
Under the GDPR your rights are as follows. You can read more about your rights in details here;
- the right to be informed;
- the right of access;
- the right to rectification;
- the right to erasure;
- the right to restrict processing;
- the right to data portability;
- the right to object; and
- the right not to be subject to automated decision-making including profiling.
You also have the right to complain to the ICO [www.ico.org.uk] if you feel there is a problem with the way we are handling your data.
We handle subject access requests in accordance with the GDPR.
2.0 Personal Information That This Website Collects and Why We Collect It
This website collects and uses personal information for the following reasons:
2.1 Site visitation tracking
Like most websites, this site uses Google Analytics (GA) to track user interaction. We use this data to determine the number of people using our site, to better understand how they find and use our web pages and to see their journey through the website.
Although GA records data such as your geographical location, device, internet browser and operating system, none of this information personally identifies you to us. GA also records your computer’s IP address which could be used to personally identify you but Google do not grant us access to this. We consider Google to be a third party data processor.
Disabling cookies on your internet browser will stop GA from tracking any part of your visit to pages within this website.
In addition to Google Analytics, this website may collect information (already held in the public domain) attributed to the IP address of the computer or device that is being used to access it.
2.2 Contact forms and email links
Should you choose to contact us using the contact form on our Contact Us page or an email link, none of the data that you supply will be stored by this website or passed to / be processed by any third party data processors. Instead the data will be collated into an email and sent to us over the Simple Mail Transfer Protocol (SMTP). We would suggest that you always consider email as an insecure medium and not include personal, confidential or otherwise sensitive information within an email.
2.3 Email Newsletter
If you choose to join our email newsletter, the email address that you submit to us will be forwarded to MailChimp who provide us with email marketing services. We consider MailChimp to be a third party data processor. The email address that you submit will not be stored within this website’s own database or in any of our internal computer systems.
Your email address will remain within MailChimp’s database for as long as we continue to use MailChimp’s services for email marketing or until you specifically request removal from the list. You can do this by unsubscribing using the unsubscribe links contained in any email newsletters that we send you or by requesting removal via email to: firstname.lastname@example.org. When requesting removal via email, please send your email to us using the email account that is subscribed to the mailing list.
If you are under 16 years of age you MUST obtain parental consent before joining our email newsletter.
While your email address remains within the MailChimp database, you will receive periodic newsletter-style emails from us.
2.4 Payment Information
3.0 Third Party Data Processors
We use a number of third parties to process personal data on our behalf. These third parties have been carefully chosen and all of them comply with the legislation set out above.
3.1 Delivery and Fulfilment
4.1 Types of Cookies We Use
4.1.1 Essential cookies
Essential cookies (First-Party Cookies) are sometimes called “strictly necessary,” as without them we cannot provide many services that you need. For example, essential cookies help us to identify your account and remember your preferences as you use our Site.
4.1.2 Analytics cookies
These cookies track information about your visits and usage of the Site, so that we can make improvements and report our performance — for example, to analyse visitor and user behaviour so as to provide more relevant content or suggest certain activities. We might also use analytics cookies to test new products, pages, or features to see how users react to them. Google Analytics is the main technology we currently use in this regard. To learn more about Google Analytics and your privacy, visit the “How Google uses data when you use our partners’ sites or apps” page at www.google.com/policies/privacy/partners/. To opt out of being tracked by Google Analytics when using our website, visit http://tools.google.com/dlpage/gaoptout.
4.1.3 Functionality or preference cookies
During your visit to the Site, cookies are used to remember information you have entered or choices you make (such as your username, language, or your region). They also store your preferences when personalising the Site, to optimise your use of the Site (for example, your preferred currency or language). These preferences are remembered through the use of persistent cookies, and the next time you visit the Site, you will not have to set them again.
4.1.4 Social media cookies
5.0 How We Store Your Personal Information
If you purchase a product on this website some personal information will be stored within this website’s database. This is currently the only occasion where personal data will be stored on this website. This data is currently stored in an identifiable fashion; a limitation of the content management system that this website is build on (WordPress). In the near future we aim to change the storage of this data to a pseudonymous fashion meaning that the data would require additional processing using a separately stored ‘key’ before it could be used to identify an individual.
Pseudonymisation is a recent requirement of the GDPR which many web application developers are currently working to fully implement. We are committed to keeping it as a high priority and will implement it on this website as soon as we are able to.
5.1 How We Use Your Personal Information
We use, process, and store your information as necessary to perform our contract with you and for our legitimate business interests, in operating our Site and business including:
- Process your purchase and arrange delivery
- Deliver your purchases to you
- Confirm your order
- Respond to your customer service requests
- to help us administer our Site, authenticate users for security purposes, provide personalised user features and access, process transactions, develop new products, and improve the features, algorithms, and usability of our Sites;
- As required by applicable law, legal process or regulation.
- to send emails and other communications. We may send you service, technical and other administrative emails, messages and other types of communications. We may also contact you to inform you about changes on our site, such as security and fraud notices. These communications are considered part of the Pullman Editions product and you may not opt out of them. In addition, we sometimes send emails about new product features, promotional communications or other news about Pullman Editions. We will only send you marketing information if you consent to us;
- for billing, account management and other administrative matters. We may need to contact you for invoicing, account management and similar reasons and we use account data to administer accounts and keep track of billing and payments.
- to investigate and help prevent security issues, fraud and abuse.
If information is aggregated or de-identified so it is no longer reasonably associated with an identified or identifiable natural person, we may use it for any business purpose.
6.0 Data Breaches
We will report any unlawful data breach of this website’s database or the database(s) of any of our third party data processors to any and all relevant persons and authorities within 72 hours of the breach if it is apparent that personal data stored in an identifiable manner has been stolen.
7.0 Data Controller
The data controller of this website is:
Motion Limited, a UK Private limited Company with company number: 06021101
Whose registered office is:
Units 16-18, The Boscombe Centre, Mills Way, Amesbury, Wiltshire, SP4 7SD
And whose operating office is:
11A Hannell Road, Fulham, SW6 7RA
8.0 Data Protection Officer
Mr. Benjamin Gibbs
Director, Motion Ltd.