Legal
PRIVACY & COOKIES POLICY
Introduction
Welcome to Pilio Limited's privacy and cookies policy.
Pilio Limited (“Pilio” / “we” / “our” / “us”) respects your privacy and is committed to protecting your personal data. This privacy and cookies policy (together with our terms of website use, any other documents referred to on it and any user agreement) will inform you how we look after your personal data when you interact with us or when you visit our website (regardless of where you visit it from) and tell you about your privacy rights and how the law protects you.
This privacy and cookies policy is provided in a layered format so you can click through to the specific areas set out below. Please also use the Glossary to understand the meaning of some of the terms used in this privacy and cookies policy.
Important information & who we are
Purpose of this privacy and cookies policy
This privacy and cookies policy aims to give you information on how Pilio collects and processes your personal data, when you interact with us, apply for a role with us or through your use of this website, including any data you may provide through this website when you sign up to our newsletter, or have an online account with us.
This website is not intended for children and we do not knowingly collect data relating to children.
It is important that you read this privacy and cookies policy together with any other privacy policy or fair processing policy we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. This privacy and cookies policy supplements other notices and privacy policies and is not intended to override them.
If you apply for a job with us please see below Processing Personal Data of Candidates.
Capacity in which Pilio processes Personal Data
Under data protection laws organisations are “data controllers” if they determine the purposes and means of processing personal data and “data processors” if they process personal data on behalf of a data controller.
Pilio may act as a “data controller” or a “data processor”. Typical instances where Pilio is a data controller include: where Pilio is the employer (or potential employer if you are a candidate), where we capture data through our website and when we conduct marketing for ourselves.
Pilio is typically a data processor, when it processes your personal data (such as information to access our services) on behalf of another data controller which could be the organisation you represent. We could also act as sub processor, for example when our services are provided through an Authorised Licensor.
Pilio as Sub-Processor & Authorised Licensors
Pilio services are sometimes provided through one of our Authorised Licensors. The organisation you represent contracts with the Authorised Licensors to provide services to your company. In such case, Pilio will act as the sub-processor of the Authorised Licensor. We encourage you to read the privacy policy of the Authorised Licensor.
Where Pilio act as a sub-processor in this manner, Pilio shall process your personal data relating to authentication information to allow you to access our services via an online account. It is within Pilio’s legitimate interest to process such personal data in order to comply with Pilio’s obligations to the Authorised Licensor and to provide the services to you.
Pilio as Controller
Pilio is the controller in relation to personal data as described in this privacy and cookies policy where it does not act as a processor.
Data Privacy Manager
We have appointed a data privacy manager who is responsible for overseeing questions in relation to this privacy and cookies policy. If you have any questions about this privacy and cookies policy, including any requests to exercise Your Legal Rights, please contact the data privacy manager using the details set out below.
Contact details
If you have any questions about this privacy and cookies policy or our privacy practices, please contact our data privacy manager in the following ways:
Full name of legal entity: Pilio Limited
Email address: info@piliogroup.com
Postal address: Pilio Limited, Data Privacy Manager, 16 Church Lane, Merton Park, London, SW19 3PD
You have the right to make a complaint at any time to the Information Commissioner's Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO, so please contact us in the first instance.
Changes to the privacy and cookies policy and your duty to inform us of changes
We keep our privacy and cookies policy under regular review. This version was last updated on 15/07/2019.
It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.
Third-party links
This website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy policy of every website you visit.
The data we collect about you
Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).
We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:
Identity Data
Includes first name, last name, username or similar identifier, social media identifier, title, date of birth and gender, company details.
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Contact Data
Includes billing address, delivery address, company email address and telephone numbers.
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Financial Data
Includes bank account and payment card details.
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Transaction Data
Includes details about payments to and from you or the organisation you represent and other details of products and services you or the organisation you represent have purchased from us or are interested in and any opinions that you have in relation to our business.
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Technical Data
Includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, traffic data, location data, weblogs and other technology on the devices you use to access this website.
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Profile Data
Includes your username and password, purchases or services made by you (or an organisation you represent), your interests, preferences, feedback, content you post and survey responses.
Usage Data
Includes information about how you use our website, products and services.
Marketing and Communications Data
Includes your preferences in receiving marketing from us and our third parties and your communication preferences.
We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data could be derived from your personal data but is not considered personal data in law as this data will not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy and cookies policy.
We do not collect any Special Categories of Personal Data about you unless you are a candidate as described below (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health, and genetic and biometric data). Nor do we collect any information about criminal convictions and offences.
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If you fail to provide personal data
Where we need to collect personal data by law, or under the terms of a contract we have with you, the organisation you represent or an Authorised Licensor, and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into (for example, to provide you with our products or services). In this case, we may have to cancel a product or service you have with us but we will notify you if this is the case at the time.
How is your personal data collected?
We use different methods to collect data from and about you including through:
Direct interactions
You may give us your Identity, Contact, Financial, Transaction, Profile and Marketing and Marketing and Communications Data by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:
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apply for, or otherwise discuss with us, our products or services;
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interact with an account on our website;
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subscribe to one of our services or publications;
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request marketing to be sent to you;
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enter a competition, promotion or survey; or
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give us feedback or contact us.
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Automated technologies or interactions
As you interact with our website, we will automatically collect Technical and Usage Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies and other similar technologies. Please see our cookie policy below for further details.
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Third parties or publicly available sources
We will receive personal data about you from various third parties and public sources as set out below:
Technical Data from the analytics providers such as Google based outside the EU.
Contact, Financial and Transaction Data from providers of technical, payment and delivery services such as Stripe based outside the EU.
Identity and Contact Data from publicly available sources such as Companies House and the Electoral Register based inside the EU.
How we use your personal data
We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:
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Where we need to perform the contract we are about to enter into or have entered into with you
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Where it is necessary for our legitimate interests (or those of a third party, which may include the organisation you represent) and your interests and fundamental rights do not override those interests
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Where we need to comply with a legal obligation
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Where it is necessary for compliance with our legal obligations
Click here to find out more about the types of lawful basis that we will rely on to process your personal data.
Generally, we do not rely on consent as a legal basis for processing your personal data although we will get your consent before sending third party direct marketing communications to you via email or text message. You have the right to withdraw consent to marketing at any time by contacting us.
Purposes for which we will use your personal data
We have set out below, in a table format, a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.
Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below.
Purposes for which we will use your personal data
Marketing
We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising. Please contact our data privacy manager using the contact details above to find further information and to let us know your choices.
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Promotional offers from us
We may use your Identity, Contact, Technical, Usage and Profile Data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which products, services and offers may be relevant for you (we call this marketing).
You will receive marketing communications from us if you have requested information from us or purchased products or services from us and you have not opted out of receiving that marketing.
Third-party marketing
We will get your express opt-in consent before we share your personal data with any third party for marketing purposes.
Opting out
You can ask us or third parties to stop sending you marketing messages at any time by contacting us at any time.
Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of a product/service purchase, warranty registration, product/service experience or other transactions.
Cookies
You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of this website may become inaccessible or not function properly. For more information about the cookies we use, please see Cookies Policy, below.
Change of purpose
We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.
If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.
Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.
Disclosures of your personal data
We may share your personal data with the parties set out below for the purposes set out in the table Purposes for which we will use your personal data above.
Your Organisation
Where you are granted an account to access our services by virtue of an organisation you represent, we may share your personal data with that organisation. With Pilio Software peer group account your information is shared with the account administrator if the peer group is for a single-business. If you belong to a peer group of multiple businesses you can indicate if you wish to give the administrator access to your individual information or share your information for anonymised and combined reporting.
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External Third Parties as set out in the Glossary
Third parties to whom we may choose to sell, transfer or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy and cookies policy.
We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.
Processing personal data of candidates
Pilio is the data controller when you apply to work for us (whether as an employee, worker or contractor). Pilio makes you aware of how and why your personal data will be used, namely for the purposes of the recruitment exercise, and how long it will usually be retained for. It provides you with certain information that must be provided under the GDPR.
Information we hold about you as a Candidate
In connection with your application for work with us, we will collect, store, and use the following categories of personal data about you:
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The information you have provided to us in your curriculum vitae and covering letter
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The information you have provided on our application form, including name, title, address, telephone number, personal email address, date of birth, gender, employment history, and qualifications
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Any information you provide to us during an interview
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How we collect personal data for Candidates
We collect personal data about candidates from the following sources:
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You, the candidate
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Your references
How we will use information about you
We will use the personal information we collect about you to:
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Assess your skills, qualifications, and suitability for the role
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Carry out background and reference checks, where applicable
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Communicate with you about the recruitment process
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Keep records related to our hiring processes
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Comply with legal or regulatory requirements
It is in our legitimate interests to decide whether to appoint you to role since it would be beneficial to our business to appoint someone to that role.
We also need to process your personal information to decide whether to enter into a contract of employment with you.
If you fail to provide personal information
If you fail to provide information when requested, which is necessary for us to consider your application (such as evidence of qualifications or work history), we will not be able to process your application successfully. For example, if we require a credit check or references for this role and you fail to provide us with relevant details, we will not be able to take your application further.
How we use particularly sensitive personal information
We will use your particularly sensitive personal information in the following ways:
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We will use information about your disability status to consider whether we need to provide appropriate adjustments during the recruitment process, for example whether adjustments need to be made during a test or interview
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We will use information about your race or national or ethnic origin, religious, philosophical or moral beliefs, or your sexual life or sexual orientation, to ensure meaningful equal opportunity monitoring and reporting
Information about criminal convictions
We do not envisage that we will process information about criminal convictions.
Automated decision-making
You will not be subject to decisions that will have a significant impact on you based solely on automated decision-making.
International transfers
We do not transfer your personal data outside of the European Economic Area.
Data security
We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.
We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.
Data retention
How long will you use my personal data for?
We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.
To determine the appropriate retention period for personal data, we consider the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements.
By law we have to keep basic information about our customers (including Contact, Identity, Financial and Transaction Data) for six years after they cease being customers.
In some circumstances you can ask us to delete your data: see Your Legal Rights below for further information.
In some circumstances we will anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes, in which case we may use this information indefinitely without further notice to you.
Your legal rights
Under certain circumstances, you have rights under data protection laws in relation to your personal data. Please click on the links below to find out more about these rights:
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Request access to your personal data
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Request correction of your personal data
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Request erasure of your personal data
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Object to processing of your personal data
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Request restriction of processing your personal data
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Request transfer of your personal data
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Right to withdraw consent
If you wish to exercise any of the rights set out above, please contact us using the above details.
No fee usually required
You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we could refuse to comply with your request in these circumstances.
What we may need from you
We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.
Time limit to respond
We try to respond to all legitimate requests within one month. Occasionally it could take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.
Cookies policy
We use cookies, which are small files of letters and numbers that we store on your browser or the hard drive of your computer or mobile device if you agree. Cookies contain information that is transferred to your computer's or mobile device’s hard drive.
We use the following cookies:
Strictly necessary cookies
These are cookies that are required for the operation of the website.
Analytical/performance cookies
They allow us to recognise and count the number of visitors and to see how visitors move around the website when they are using it. They also enable us to see how users use the website works, for example, by ensuring that users are finding what they are looking for easily.
Functionality cookies
These are used to recognise you when you return to the website. This enables us to personalise our content for you, greet you by name and remember your preferences (for example, your choice of language or region).
Targeting cookies. These cookies record your visit to our website, the pages you have visited and the links you have followed. We will use this information to make the website and the advertising displayed on it more relevant to your interests.
By clicking “agree” in the cookie consent box when you first access the website and by continuing to access and use the website you accept our use of the cookies.
You can find more information about the individual cookies we use and the purposes for which we use them in the table below:
Cookies on the Pilio website
You can block cookies by activating the setting on your browser that allows you to refuse the setting of all or some cookies. However, if you use your browser settings to block all cookies (including essential cookies) you may not be able to access all or parts of the Website.
For more detailed information about cookies and how they can be managed and deleted, please visit www.allaboutcookies.org.
Glossary
Lawful Basis
Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give you the best service/product and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us.
Performance of Contract means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.
Comply with a legal obligation means processing your personal data where it is necessary for compliance with a legal obligation that we are subject to.
Third Parties
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External Third Parties:
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Third parties that your organisation has a contract with or intends to enter a contract with (e.g. a Authorised Licensor of our services such as Julie’s Bicycle) in relation to our services.
Third parties whom you explicitly ask us to provide your personal data to for the potential or actual delivery of our products and/or services.
Service providers (for example, IT services), business partners, suppliers and sub-contractors for the performance of any contract we enter into with you, but also when providing you with marketing communications.
Analytics and search engine providers that assist us in the improvement and optimisation of the website.
Government or other law enforcement agencies, in connection with the investigation of unlawful activities or for other legal reasons (this may include your location information).
Professional advisers including lawyers, bankers, auditors and insurers who provide consultancy, banking, legal, insurance and accounting services.
HM Revenue & Customs, regulators and other authorities based in the United Kingdom who require reporting of processing activities in certain circumstances.
Your Legal Rights
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You have the right to:
Request access to your personal data (commonly known as a "data subject access request"). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios:
If you want us to establish the data's accuracy.
Where our use of the data is unlawful but you do not want us to erase it.
Where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims.
You have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.