Global Privacy Statement

Updated on 23 May 2018

Information covered by this statement

This Privacy Statement applies to the use and processing of personal information collected and used by certain members of PMI

The phrases PMI “us”, “our” or “we” shall, when used herein, mean those members of the PMI on behalf of and in respect of whom this statement is made.

By using our websites and mobile applications or otherwise providing your personal information to us, you agree to the collection, use and sharing of your information in accordance with this statement. Please read this Privacy Statement carefully and contact us via email (info@pallmallinvestments.com) if you have any questions.

Personal information is information, or any combination of separate pieces of information, that could be used to identify you.

Should you have any queries in respect of this statement or our use of personal data, please contact PMI via email (info@pallmallinvestments.com).

Information We collect

We may collect information about you from a variety of sources. This includes information we collect directly from you; information we collect when you visit our sites, view our online content or use our mobile webpages or other services; and information we collect about you from other sources.

Information we collect directly from you

We collect information directly from you when you choose to participate in our offers and programs, create an account on our websites or in our mobile applications, call or email us, or otherwise provide information directly to us. The following are examples of information we may collect directly from you:

  • Name
  • Email address
  • Postal address
  • Username and password
  • Telephone and/or fax number
  • Date of birth
  • Demographic information
  • Payment information (such as a credit card) and bank account details
  • Future communication preferences
  • Telephone number and recordings when you call our customer service line

Information we collect when you visit our sites, view our online ads or promotions, or use our mobile applications or other services

We use cookies and other technologies to collect information when you visit our sites, view our online advertisements or promotions, or use our mobile applications or other services. The following are examples of information we may collect with these technologies:

  • Information about your device browser and operating system.
  • IP address
  • Web pages you view
  • Links you click
  • PMI emails you open

Information collected through Mobile webpages

When you use our mobile webpages to your mobile device, we may also collect information that you provide. We also automatically collect information through our online resources.

The following are examples of the types of information we may automatically collect through our mobile webpages:

  • Marketing ID or similar identifier
  • Information about your devices’ operating system
  • Information about the way you use the webpages

Your Choices about information collection through Mobile Webpages

You can opt out of continued information collection by our mobile webpages by editing the security settings on your mobile device.

Precise Location Data

Our mobile webpages may collect precise location information from your device if you consent to the collection of this information. We may use third-party service providers to provide location services using the location data you provide. You may opt out at any time to the continued collection of this information by adjusting the settings on your device.

Information PMI collects from other sources

We may obtain information about you from other sources, including publicly available sources, such as the Land Registry, social media platforms or referral agents, etc. Examples of information we may collect from other sources are:

  • Name.
  • Postal address.
  • Email address.
  • Date of birth.
  • Income level.
  • Publicly observed activities or information made available by you to the public, such as blogs, videos, internet postings, and user generated content.

How Pall Mall Investments Limited uses this information

We use the information we collect to provide you products, offers and services, to deliver to you advertisements, offers or other content tailored to your interests, and to conduct other PMI business operations. The following are examples of how we may use the information we collect:

  • Answer your questions or respond to your requests.
  • Develop new products and services.
  • Enrol you in contests, programs, or offers that you request.
  • Create and manage your account.
  • Process payment for purchases or other services.
  • Protect against or identify possible fraudulent transactions.
  • Send you email and/or postal messages with information about PMI brands and other content we think may be of interest to you.
  • Telephone you about PMI’s brands and other content we think may be of interest to you.
  • Develop and provide Marketing tailored to your interests, including interest-based marketing.
  • Personalise your experience on our websites by presenting products and information tailored to you.
  • Allow you to participate in social sharing on our websites.
  • Analyse the use of, and develop, our products, services and marketing. Enforce our Terms & Conditions and otherwise manage our business.

PMI will only process your information in pursuance of our legitimate interest if we receive any requests related to, for example, a product or service, a call-back, or specific marketing materials; we will use your personal information to fulfil your request. Where we need to manage your account and protect you against or identify possible fraudulent transactions, we will do so in accordance with our legal obligation placed on us under law. We will seek consent from you if we need to process your data solely identified purposes. To ensure meaningful consent is obtained from you, we will provide you with reasonable notice ensuring that your consent is provided on an informed basis.

Information sharing

The success of our business depends on your trust, and we do not sell your personal information to marketers outside of PMI. We share your personal information within our company and as described in this statement. We do not share personal information with marketers outside of our company unless you consent to such sharing, or as described within this statement.

Co-promotions with Carefully Selected Business Partners

We from time to time may collect personal and other information for a co-promotion or joint program with a business partner and share your information with that business partner. For these programs we will make clear at the point of collection that the information will be shared with PMI and the participating business partner and ask for your consent as required by applicable laws.

Third-party service providers

We engage third-party service providers to perform a variety of business operations on our behalf. In so doing, we may share your personal information with them. We provide our service providers with only the personal information they need in order to perform the services we request, and we contractually require that they protect this information appropriately and not use it for any other purpose.

For example, we may rely on a 3rd party service provider to:

  • Fulfil your service requests and answer your questions.
  • Host our sites and deliver our email or other communications.
  • Contact contest winners, manage payments or take other actions on our behalf.
  • Analyse our data, sometimes combined with data from other sources, to send you communications.
  • Conduct research and analyse data to improve our products, services and sites.
  • Perform other services that we request.

Where permitted by law, we combine personal information about you that we have collected with personal information about you that a business partner has collected so we can jointly send tailored promotional communications to you. In such instances, our business partner will not be permitted to use our data or the combined data for its own, independent marketing purposes. Our service provider will only be allowed to use the combined set of information to send you joint communications that we hope will be of interest to you. If you prefer not to receive these joint communications, you can always opt out by following the instructions provided in any such communication or through this Privacy Statement as indicated above.

Please email us at info@pallmallinvestments.com to receive a list of all third party service providers

Other situations

We may transfer or otherwise process your personal information:

  • As part of the sale of our brand to another company.
  • When we have received your instruction to pass the sale of your property to another agent
  • To protect, defend or exercise the rights and property of PMI (including enforcing our Terms and Conditions).
  • When required by law and/or government authorities.

Personal Information Retention Period

We will retain Personal Information for the period necessary to fulfil the purposes outlined in this Privacy Statement, unless a longer retention period is required or permitted by law.

Aggregated and non-personal information.

We share aggregated and/or anonymous information that does not identify you for our business purposes. For example, we may disclose the number of visitors to our sites or services. We may also share aggregated and/or anonymous information with our business partners for their own business purposes.

Your communication options

We give you choices about how we communicate with you.

Email Communications

You can stop receiving promotional email messages from PMI by following the opt-out instructions provided in any such message you receive.

Postal Mail

You can stop receiving promotional postal mail from us by following the opt-out instructions that may be included within those communications.

You can also stop receiving promotional email or postal communication through this Privacy Statement.

Mobile Text Messages

We only send you promotional mobile text messages if you explicitly ask to receive these (i.e. you opt in). You can stop receiving promotional text messages by following the instructions to opt out provided within that text messaging program.

PLEASE NOTE: We will honour your request to stop receiving promotional email, text and postal messages from PMI as practicable. However, we may continue to send you service-related communications. We may keep information for record keeping to ensure we fulfil your request not to send particular types of messages.

You and your information

To the extent provided for by applicable law, you have certain rights in respect of the management of the personal data we hold about you.

Access

We take steps to keep your personal information accurate. Many of our programs provide access to view or update personal information you provided when you registered online. Check where you registered to learn if you can view or update your information there.

Data Deletion

You can delete your stored data online account at any time. Contact us via email on info@pallmallinvestments.com find out how to delete your online data.

This will erase any personal information in your account that we have about you. And it will mean any data about how you’ve used the online account will be made anonymous.

This data deletion process won’t delete any data you’ve shared with PMI for reasons that aren’t connected with your online activity. If you wish us to erase your data which is unconnected with your online activity, please contact us as described below and we will deal with your request as necessary under applicable law.

Other rights

To the extent provided by applicable law, you have the right to request rectification of your personal data; to obtain restriction of the processing of personal data; to object to the processing of personal data (including direct marketing) and to data portability. To exercise any of these rights, please contact us as described below.

Consent

Where you have provided consent for our processing of your personal data, you may withdraw that consent at any time by contacting us as described below. We will cease processing your personal data as soon as reasonably practicable following our receipt of your withdrawal.

Complaints

If you consider that we have processed personal data in violation of applicable law, please contact us as described below. If you consider that we have processed personal data in violation of applicable law and failed to remedy such violation to your reasonable satisfaction, you may also lodge a complaint with a supervisory authority (e.g. the Information Commissioner’s Office in the UK).

Cookies Policy

Cookies on Pall Mall Investments Limited’s website

Cookies are small text files that are placed on your computer by websites that you visit. They are widely used in order to make websites work, or work more efficiently, as well as to provide information to the owners of the site.

Most web browsers allow some control of most cookies through the browser settings. To find out more about cookies, including how to see what cookies have been set and how to manage and delete them, visit www.allaboutcookies.org

To opt out of being tracked by Google Analytics across all websites visit http://tools.google.com/dlpage/gaoptout.

Cookies on our websites

  • Cookie: user_allowed_save_cookie
    • Usage: user access
    • Expiry: 1 year
  • Cookie: store
    • Usage: user access
    • Expiry: 1 year
  • Cookie: section_data_ids
    • Usage: site functionality
    • Expiry: when the browsing session ends
  • Cookie: searchsuiteautocomplete
    • Usage: site functionality
    • Expiry: when the browsing session ends
  • Cookie: recently_viewed_product_previous
    • Usage: personalisation
    • Expires: when the browsing session ends
  • Cookie: recently_viewed_product
    • Usage: personalisation
    • Expiry: when the browsing session ends
  • Cookie: recently_compared_product_previous
    • Usage: personalisation
    • Expires: when the browsing session ends
  • Cookie: recently_compared_product
    • Usage: personalisation
    • Expiry: when the browsing session ends
  • Cookie: product_data_storage
    • Usage: site functionalisty
    • Expiry: when the browsing session ends
  • Cookie: private_content_version
    • Usage: personalisation
    • Expiry: 10 years
  • Cookie: mage-translation-storage
    • Usage: site functionality
    • Expiry: when the browsing session ends
  • Cookie: mage-translation-file-version
    • Usage: site functionality
    • Expiry: when the browsing session ends
  • Cookie: mage-messages
    • Usage: site functionality
    • Expiry: when the browsing session ends
  • Cookie: mage-cache-storage-section-invalidation
    • Usage: site functionality
    • Expiry: when the browsing session ends
  • Cookie: mage-cache-storage
    • Usage: site functionality
    • Expiry: when the browsing session ends
  • Cookie: mage-cache-sessid
    • Usage: site functionality
    • Expiry: when the browsing session ends
  • Cookie: guestwishlist
    • Usage: personalisation
    • Expiry: 1 month
  • Cookie: __sharethis_cookie_test__
    • Usage: site functionality
    • Expiry: when the browsing session ends