PushON (PushON Limited) understands that your privacy is important to you and that you care about how your information is used and shared online. We respect and value the privacy of everyone who visits Our Site and will only collect and use information in ways that are useful to you and in a manner consistent with your rights and Our obligations under the law.
1. Definitions and Interpretation
In this Policy the following terms shall have the following meanings:
Account: means an account required to access and/or use certain areas and features of Our Site;
Cookie: means a small text file placed on your computer or device by Our Site when you visit certain parts of Our Site and/or when you use certain features of Our Site. Details of the Cookies used by Our Site are set out in section 12, below;
Our Site: means these websites and all its subdomains,
UK and EU Cookie Law: means the relevant parts of the Privacy and Electronic Communications (EC Directive) Regulations 2003 as amended in 2004, 2011 and 2015; and
We/Us/Our: means PushON Ltd, a company registered in England and Wales, company number  Registered office: PushON Ltd, First Floor, Eastgate, Castle Street, Castlefield, Manchester, M3 4LZ. United Kingdom
2. Information About Us
Our Site/s, is owned and operated by PushON Ltd, a company registered in England and Wales, company number  Registered office: PushON Ltd, First Floor, Eastgate, Castle Street, Castlefield, Manchester, M3 4LZ. United Kingdom
3. What Does This Policy Cover?
4. What Data Do We Collect?
4.1 Communication Data that includes any communication that you send voluntarily to us whether that be through the contact forms on our website, completing a survey, through email, social media messaging, social media posting or any other communication that you send us. We process this data for the purposes of communicating with you, to ensure relevant content is provided to you, for record keeping and for the establishment, pursuance or defence of legal claims. Our lawful ground for this processing is our legitimate interests which in this case are to reply to communications sent to us, to keep records and to establish, pursue or defend legal claims.
4.2 User Data that includes data about how you use our website and any online services together with any data that you post for publication on our website or through other online services. We process this data to operate our website and ensure relevant content is provided to you, to ensure the security of our website, to maintain back-ups of our website and/or databases and to enable publication and administration of our website, other online services and business. Our lawful ground for this processing is our legitimate interests which in this case are to enable us to properly administer our website and our business.
4.3 Technical Data that includes data about your use of our website and online services such as your IP address, your login data, details about your browser and device, length of visit to pages on our website, page views and navigation paths, details about the number of times you use our website, time zone settings and other technology on the devices you use to access our website. The source of this data is from our analytics tracking system. We process this data to analyse your use of our website and other online services, to administer and protect our business and website, to deliver relevant website content and advertisements to you and to understand the effectiveness of our advertising. Our lawful ground for this processing is our legitimate interests which in this case are to enable us to properly administer our website and our business and to grow our business and to decide our marketing strategy.
4.4 Marketing Data that includes data about your preferences in receiving marketing from us and our third parties and your communication preferences. We process this data to enable you to partake in our promotions such as competitions, surveys, prize draws and free giveaways, to deliver relevant website content and advertisements to you and measure or understand the effectiveness of this advertising. Our lawful ground for this processing is our legitimate interests which in this case are to study how visitors’ user our website, to develop them, to grow our business and to decide our marketing strategy.
5. How Do We Use Your Data?
5.1 All personal data is stored securely in accordance with the EU General Data Protection Regulation (Regulation (EU) 2016/679) (GDPR). For more details on security see section 6, below.
5.2 We use your data to provide the best possible user experience of our website. This includes:
5.2.1 Providing and managing your Account
5.2.2 Providing and managing your access to Our Site
5.2.3 Personalising and tailoring your experience on Our Site
5.2.4 Supplying content and information to you
5.2.5 Personalising and tailoring content and information for you
5.2.6 Responding to communications from you
5.2.7 Supplying you with email newsletters, service updates etc. that you have subscribed to (you may unsubscribe or opt-out at any time by clicking the ‘To unsubscribe from all of our emails’ link in the email or by contacting us at firstname.lastname@example.org)
5.2.8 Market research
5.2.9 Analysing your use of Our Site and gathering feedback to enable Us to continually improve Our Site and your user experience
5.3 In some cases, the collection of data may be a statutory or contractual requirement, and We will be limited in the services We can provide you without your consent for Us to be able to use such data.
5.4 Once you have submitted your data to us, we use your data for marketing purposes which may include contacting you by email, telephone with information, news and offers on Our products and services. We will not, however, send you any unsolicited marketing or spam and will take all reasonable steps to ensure that We fully protect your rights and comply with Our obligations under the GDPR and the Privacy and Electronic Communications (EC Directive) Regulations 2003, as amended in 2004, 2011 and 2015.
5.5 Under GDPR we will ensure that your personal data is processed lawfully, fairly, and transparently, without adversely affecting your rights. We will only process your personal data if at least one of the following basis applies:
a) you have given consent to the processing of your personal data for one or more specific purposes;
b) processing is necessary for the performance of a contract to which you are a party or in order to take steps at the request of you prior to entering into a contract;
c) processing is necessary for compliance with a legal obligation to which we are subject;
d) processing is necessary to protect the vital interests of you or of another natural person;
e) processing is necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in the controller; and/or
f) processing is necessary for the purposes of the legitimate interests pursued by us or by a third party, except where such interests are overridden by the fundamental rights and freedoms of the data subject which require protection of personal data, in particular where the data subject is a child.
5.6 We may use Customer Data, User Data, Technical Data and Marketing Data to deliver relevant website content and advertisements to you (including Facebook adverts or other display advertisements) and to measure or understand the effectiveness of the advertising we serve you. Our lawful ground for this processing is legitimate interests which is to grow our business. We may also use such data to send other marketing communications to you. Our lawful ground for this processing is either consent or legitimate interests (namely to grow our business).
6. How and Where Do We Store Your Data?
6.1 We only keep your data for as long as We need to in order to use it as described above in section 5, and/or for as long as We have your permission to keep it. In any event, your data will be deleted if you notify us via email, telephone or post.
6.2 Some or all of your data may be stored or transferred outside of the European Economic Area (“the EEA”) (The EEA consists of all EU member states, plus Norway, Iceland and Liechtenstein). You are deemed to accept and agree to this by using Our Site and submitting information to Us. If We do store or transfer data outside the EEA, We will take all reasonable steps to ensure that your data is treated as safely and securely as it would be within the EEA and under the GDPR. Such steps may include, but not be limited to, the use of legally binding contractual terms between Us and any third parties We engage with.
6.3 Data security is of great importance to Us, and to protect your data We have put in place suitable physical, electronic and managerial procedures to safeguard and secure data collected through Our Site.
6.4 The Company shall ensure that the following measures are taken with respect to the collection, holding, and processing of personal data:
- All employees, agents, contractors, or other parties working on behalf of the Company shall be made fully aware of both their individual responsibilities and the Company’s responsibilities under the Regulation and under this Policy, and shall be provided with a copy of this Policy;
- Only employees, agents, sub-contractors, or other parties working on behalf of the Company that need access to, and use of, personal data in order to carry out their assigned duties correctly shall have access to personal data held by the Company;
- All employees, agents, contractors, or other parties working on behalf of the Company handling personal data will be appropriately trained to do so;
- The performance of those employees, agents, contractors, or other parties working on behalf of the Company handling personal data shall be regularly evaluated and reviewed;
- All employees, agents, contractors, or other parties working on behalf of the Company handling personal data will be bound to do so in accordance with the principles of the Regulation and this Policy by contract;
- All agents, contractors, or other parties working on behalf of the Company handling personal data must ensure that any and all of their employees who are involved in the processing of personal data are held to the same conditions as those relevant employees of the Company arising out of this Policy and the Regulation
6.5 Notwithstanding the security measures that We take, it is important to remember that the transmission of data via the internet may not be completely secure and that you are advised to take suitable precautions when transmitting to Us data via the internet
7. Do We Share Your Data?
7.1 We may only share your data with wholly owned subsidiaries of PushON Ltd.
7.2 We may contract with third parties to supply products and services to you on Our behalf. These may include payment processing, delivery of goods, search engine facilities, advertising and marketing. In some cases, the third parties may require access to some or all of your data. Where any of your data is required for such a purpose, We will take all reasonable steps to ensure that your data will be handled safely, securely, and in accordance with your rights, Our obligations, and the obligations of the third party under the law. We currently contract with:
First Name, Surname and Email address
First Name, Surname, Company name, Email address and Telephone number
First Name, Surname, Email address and Telephone number
First Name, Surname, Company name, Email address and Telephone number
First Name, Surname, Company name, Email address and Telephone number
7.3 We may compile statistics about the use of Our Site including data on traffic, usage patterns, user numbers, sales and other information. All such data will be anonymised and will not include any personally identifying information. We may from time to time share such data with third parties such as prospective investors, affiliates, partners and advertisers. Data will only be shared and used within the bounds of the law.
7.4 In certain circumstances We may be legally required to share certain data held by Us, which may include your personal information, for example, where We are involved in legal proceedings, where We are complying with the requirements of legislation, a court order, or a governmental authority. We do not require any further consent from you in order to share your data in such circumstances and will comply as required with any legally binding request that is made of Us.
8. What Happens If Our Business Changes Hands?
8.2 In the event that any of your data is to be transferred in such a manner, you will be contacted in advance and informed of the changes. When contacted you will be given the choice to have your data deleted or withheld from the new owner or controller.
9. How Can You Control Your Data?
9.1 When you submit information via Our Site, you may be given options to restrict Our use of your data. We aim to give you strong controls on Our use of your data (including the ability to opt-out of receiving emails from Us which you may do by unsubscribing using the links provided in Our emails or by emailing us to let us know your preferences).
9.2 You may also wish to sign up to one or more of the preference services operating in your country. Please note, however, that these services will not prevent you from receiving marketing communications that you have consented to receiving.
10. Your Right to Withhold Information and Your Right to Withdraw Information After You Have Given it
10.1 You may access certain areas of Our Site without providing any data at all. However, to use all features and functions available on Our Site you may be required to submit or allow for the collection of certain data.
10.3 You may withdraw your consent for Us to use your personal data as set out in section in 5 at any time by contacting Us using the details set out in section 14, and We will delete Your data from Our systems. However, you acknowledge this may limit Our ability to provide the best possible products and services to you.
11. How Can You Access Your Data?
You have the legal right to ask for a copy of any of your personal data held by Us (where such data is held). Please contact Us for more details at email@example.com, or using the contact details below in section 14.
12. What Cookies Do We Use and What For?
12.2 By using Our Site you may also receive certain third party Cookies on your computer or device. Third party Cookies are those placed by websites, services, and/or parties other than Us. We use third party Cookies on Our Site for advertising services. For more details, please refer to section 5, above, and to section 12.6 below. These Cookies are not integral to the functioning of Our Site.
12.3 All Cookies used by and on Our Site are used in accordance with current UK and EU Cookie Law.
12.5 Certain features of Our Site depend on Cookies to function. UK and EU Cookie Law deems these Cookies to be “strictly necessary”. These Cookies are shown below in section 12.6. Your consent will not be sought to place these Cookies. You may still block these Cookies by changing your internet browser’s settings as detailed below in section 12.10, but please be aware that Our Site may not work as intended if you do so. We have taken great care to ensure that your privacy is not at risk by allowing them.
12.6 We do not place third party Cookies on your computer or device, however the following third party Cookies may be placed on your computer or device:
Facebook – Third Party – For advertising purposes
Google Adwords – Third Party – For advertising purposes
12.7 Our Site uses analytics services provided by Google. Website analytics refers to a set of tools used to collect and analyse usage statistics, enabling Us to better understand how people use Our Site. This, in turn, enables Us to improve Our Site and the products and services offered through it. You do not have to allow Us to use these Cookies, as detailed below, however whilst Our use of them does not pose any risk to your privacy or your safe use of Our Site, it does enable Us to continually improve Our Site, making it a better and more useful experience for you.
12.8 The analytics service(s) used by Our Site use(s) Cookies to gather the required information. These Cookies may be placed immediately when you first visit Our Site and it may not be possible for Us to obtain your prior consent. You may remove these Cookies and prevent future use of them by following the steps set out below in section 12.10.
12.9 The analytics service(s) used by Our Site use(s) the following Cookies:
Google Analytics – Third Party – For the purposes of analysing the use of our site to improve user experience and grow the business, full details of potential Google Analytics cookies used can be found at https://developers.google.com/analytics/devguides/collection/analyticsjs/cookie-usage
Ruler Analytics – Third Party – To improve functionality and to help measure the amount of page visits and traffic sources our site receives, we use a monitoring service provided by Ruler Analytics.
12.10 You can choose to enable or disable Cookies in your internet browser. Most internet browsers also enable you to choose whether you wish to disable all cookies or only third party cookies. By default, most internet browsers accept Cookies but this can be changed. For further details, please consult the help menu in your internet browser or the documentation that came with your device.
12.11 You can choose to delete Cookies at any time however you may lose any information that enables you to access Our Site more quickly and efficiently including, but not limited to, login and personalisation settings.
12.12 It is recommended that you keep your internet browser and operating system up-to-date and that you consult the help and guidance provided by the developer of your internet browser and manufacturer of your computer or device if you are unsure about adjusting your privacy settings.
13. Summary of Your Rights under GDPR
Under the GDPR, you have:
13.1 the right to request access to, deletion of or correction of, your personal data held by Us;
13.2 the right to complain to a supervisory authority;
13.3 be informed of what data processing is taking place;
13.4 the right to restrict processing;
13.5 the right to data portability;
13.6 object to processing of your personal data;
14. Contacting Us