Ping Europe Limited (“PING,” “us” or “we”) is committed to protecting your privacy. PING has prepared this privacy policy to describe to you or, if you represent an entity or other organisation, that entity or organisation (in either case, “You” or “User”) our practices regarding the personal data that PING collects, uses and shares regarding our online informational platform (the “Platform”) accessed through the website located at https://ping.com/ and any other websites operated by PING (each a “Site”) or using mobile applications provided by and on behalf of PING (each an “Application” and each Site and Application treated as a part of the “Platform” for purposes of this privacy policy). This privacy policy will inform you as to how we look after your personal data and tell you about your privacy rights and how the law protects you.
1. Important information and who we are
Purpose of this privacy policy
This privacy policy aims to give you information on how PING collects and processes your personal data.
It is important that you read this privacy policy together with any other privacy notice or fair processing notice 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 policy supplements the other notices and is not intended to override them.
Controller
Ping Europe Limited is made up of different legal entities. It encompasses Thonock Park and Ping Scandinavia AB (which is a wholly owned subsidiary of Ping Europe Limited). This privacy policy is issued on behalf of all such entities, so when we mention PING, "we", "us" or "our" in this privacy policy we are referring to the relevant company or entity in PING responsible for processing your data. Ping Europe Limited is the controller of your data.
Changes to the privacy policy and your duty to inform us of changes
PING reserves the right, at any time, to modify this privacy policy. If we make revisions that change the way we collect, use, or share personal data, we will post those changes in this privacy policy. You should review this privacy policy periodically so that you keep up to date on our most current policies and practices. We will note the effective date of the latest version of our privacy policy at the end of this privacy policy.
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.
2. The data we collect about you
Personal data refers to information that is connected to you, or from which a 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, maiden name, last name, username or similar identifier, marital status, title, date of birth and gender.
• Contact Data includes billing address, delivery address, email address and telephone numbers.
• Financial Data includes bank account and payment card details.
• Transaction Data includes details about payments to and from you and other details of products and services you have purchased from us.
• 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 and other technology on the devices you use to access this website.
• Profile Data includes your username and password, purchases or orders made by you, your interests, preferences, feedback 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 your communication preferences.
We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data may be derived from your personal data but is not considered personal data in law as this data does 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 policy.
We do not collect any Special Categories of Personal Data about you (except information about your health where you provide it to us for any applicable or necessary reason, for example Thonock Park membership suspension). Nor do we collect any information about criminal convictions and offences.
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 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 with you (for example, to provide you with goods 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.
3. 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 and Financial Data by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:
• Automated technologies or interactions. We may automatically collect Technical Data about your equipment, browsing actions and patterns by using the following automated technologies or interactions:
• Third parties or publicly available sources. We may receive personal data about you from various third parties and public sources as set out below:
4. How we use your personal data
PING will only use your personal data when the law allows us to.
PING will use your personal data in the following circumstances:
We do not rely on consent as a legal basis for processing your personal data. You have the right to update your preferences or unsubscribe from receiving marketing communications at any time by updating or unsubscribing on the email you receive, by contacting us at the address listed in section 10 or by emailing at info@pingeurope.co.uk.
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 at the address listed below or email us at info@pingeurope.co.uk 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.
Marketing
We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising.
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 goods or services from us or if you provided us with your details when you entered a competition or registered for a promotion and, in each case, you have not opted out of receiving that marketing.
Third-party marketing
PING may share your personal data with companies that are affiliated with us (i.e. that control, are controlled by or are under common control with PING). We do not share your information with third parties to directly market to you.
Opting out
You can ask us to stop sending you marketing messages at any time by logging into our website and checking or unchecking relevant boxes to adjust your marketing preferences or by following the opt-out links on any marketing message sent to you or by contacting us at the address listed below or email us at info@pingeurope.co.uk 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, 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 have chosen to disable cookies on your browser, some parts of the Platform may become inaccessible or some of the functionality of the Platform may be lost. Certain services provided by PING, require that cookies be enabled in your browser and cannot be used when you have disabled cookies in your browser.
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 at the address listed below or email us at info@pingeurope.co.uk
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.
5. Disclosures of your personal data
We may have to share your personal data with the parties set out below for the purposes set out in the table in paragraph 4 above.
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.
6. International data transfers
Ping Europe Limited shares some of its business processes and technical systems across borders with other Ping Companies and some of our IT systems are hosted and operated from the United States (US). This will involve transferring your data outside the European Economic Area (EEA). We ensure your personal data is protected by requiring all our PING companies to follow the same rules when processing your personal data.
Your personal data may also be processed by personnel working outside of the EEA who work for us or for one of our providers. Such personnel may be engaged in, among other things, the fulfilment of your order, the processing of your payment details and the provision of content, products or services. By submitting your personal data, you agree to this transfer, storing, or processing. We will take all steps reasonably necessary to ensure that personal data is treated securely and in accordance with this privacy policy and applicable law.
Whenever we transfer your personal data out of the EEA, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:
7. Data security, integrity and purpose limitation.
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.
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.
8. Data retention
How long will you use my personal data for?
PING will retain your personal data as needed to fulfil the purposes for which it was collected, or until you withdraw your consent. PING will retain and use your personal data as necessary to comply with PING’s business requirements, legal obligations, resolve disputes, protect our assets, and enforce our agreements.
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 for tax purposes.
In some circumstances we may 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.
9. Your legal rights
You also have the following rights under applicable data protection law in relation to your personal data:
PING has implemented the following procedure that you may use to access, correct or delete your personal data, or choose how your information is used:
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 may 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 will try to respond to all legitimate requests within 30 days. Occasionally it may take us longer than 30 days 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.
10. Communications
If you have any additional questions or concerns about our privacy policy or any other privacy or security issue, please contact us at:
Ping Europe Limited
Corringham Road
Gainsborough
Lincolnshire
United Kingdom
DN21 1XZ
Email: Info@pingeurope.co.uk
If PING needs, or is required, to contact you concerning any event that involves information about you, we may do so by email, telephone, or mail.