Terms & Conditions

Introduction

Welcome to the PP Tech Limited 's privacy policy.

PP Tech Limited respects your privacy and is committed to protecting your personal data. This privacy policy
will inform you as to how we look after your personal data 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 policy is provided in a layered format so you can click through to the specific areas set out below.
Alternatively, you can download a pdf version of the policy here: https://atalis.io/atalis-privacy-policy. Please
also use the Glossary to understand the meaning of some of the terms used in this privacy policy.

1. IMPORTANT INFORMATION AND WHO WE ARE
2. THE DATA WE COLLECT ABOUT YOU
3. HOW IS YOUR PERSONAL DATA COLLECTED?
4. HOW WE USE YOUR PERSONAL DATA
5. DISCLOSURES OF YOUR PERSONAL DATA
6. INTERNATIONAL TRANSFERS
7. DATA SECURITY
8. DATA RETENTION
9. YOUR LEGAL RIGHTS
10. GLOSSARY

1. Important information and who we are

Purpose of this privacy policy

This privacy policy aims to give you information on how PP Tech Limited collects and processes your personal
data through your use of this website, including any data you may provide through this website when you
access our website, open an account with us or purchase any product or service through our website or sign
up to our newsletter
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 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 policy supplements other notices
and privacy policies and is not intended to override them.

Controller

PP Tech Limited is the controller and responsible for your personal data (collectively referred to as "PP Tech",
"we", "us" or "our" in this privacy policy).
We have appointed a data protection officer (DPO) who is responsible for overseeing questions in relation to
this privacy policy. If you have any questions about this privacy policy, including any requests to exercise
your legal rights, please contact the DPO using the details set out below.

Contact details

If you have any questions about this privacy policy or our privacy practices, please contact our DPO in the
following ways:
Full name of legal entity: PP Tech Limited
Email address: [email protected]
Postal address: 20-22 Wenlock Road, London, N1 7GU, United Kingdom
Telephone number: +44 (0)20 3036 2820


You have the right to make a complaint at any time to the Information Commissioner's Office (ICO), the UK
regulator 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 policy and your duty to inform us of changes

We keep our privacy policy under regular review. This version was last updated on 31st October 2022. Historic
versions can be obtained by contacting us.
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, 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, 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 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 policy.

We do not collect any Special Categories of Personal Data about you (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.

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 or the
organisation you represent, 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 or the organisation you represent (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 either for yourself or on behalf of the organisation you represent :
    - Order or request any products or services;
    - create or update an account on our website;
    - subscribe to any publication or newsletter;
    - request marketing to be sent to you;
    - enter a competition, promotion or survey; or
    - give us feedback or contact us.
  • Automated technologies or interactions. As you interact with our website, we will automatically
    collect Technical Data about your equipment, browsing actions and patterns. We collect this
    personal data by using cookies, server logs and other similar technologies. We may also receive
    Technical Data about you if you visit other websites employing our cookies. Please see our cookie
    policy https://atalis.io/atalis-cookie-policy or further details.
  • 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 following parties;
  • analytics providers [such as Google based outside the UK];
  • advertising networks such as Google, Affiliate Windows based inside OR outside the UK; and
  • search information providers such as Google based inside OR outside the UK.
  • Identity and Contact Data from publicly available sources such as Companies House and the
    Electoral Register based inside the UK.

4. 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:

  • Where we need to perform the contract we are about to enter into or have entered into with you
    or the organisation you represent.
  • Where it is necessary for our legitimate interests (or those of a third party) and your interests and
    fundamental rights do not override those interests.
  • Where we need to comply with a legal obligation
     

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.

 

Purpose/Activity Type of data

Lawful basis for processing including

basis of legitimate interest

To register you as a new

customer

(a) Identity

(b) Contact

Performance of a contract with you

To process and deliver an order

including:

(a) Manage payments, fees and

charges

(b) Collect and recover money

owed to us

(a) Identity

(b) Contact

(c) Financial

(d) Transaction

(e) Marketing and

Communications

(a) Performance of a contract with you

(b) Necessary for our legitimate interests

(to recover debts due to us)

To manage our relationship with

you or the organisation that you

represent which will include:

(a) Notifying you about changes

to our terms or privacy policy

(b) Asking you to leave a review

or take a survey

(a) Identity

(b) Contact

(c) Profile

(d) Marketing and

Communications

(a) Performance of a contract with you

(b) Necessary to comply with a legal

obligation

(c) Necessary for our legitimate interests

(to keep our records updated and to study

how customers use our

products/services)

To enable you to take part in a

prize draw, competition or

complete a survey

(a) Identity

(b) Contact

(c) Profile

(d) Usage

(e) Marketing and

Communications

(a) Performance of a contract with you

(b) Necessary for our legitimate interests

(to study how customers use our

products/services, to develop them and

grow our business)

To administer and protect our

business and this website

(including troubleshooting, data

analysis, testing, system

maintenance, support, reporting

and hosting of data)

(a) Identity

(b) Contact

(c) Technical

(a) Necessary for our legitimate interests

(for running our business, provision of

administration and IT services, network

security, to prevent fraud and in the

context of a business reorganisation or

group restructuring exercise)

(b) Necessary to comply with a legal

obligation

To deliver relevant website

content and advertisements to

you and measure or understand

the effectiveness of the

advertising we serve to you

 

(a) Identity

(b) Contact

(c) Profile

(d) Usage

(e) Marketing and

Communications

(f) Technical

Necessary for our legitimate interests (to

study how customers use our

products/services, to develop them, to

grow our business and to inform our

marketing strategy)

To use data analytics to improve

our website, products/services,

marketing, customer relationships

and experiences

(a) Technical

(b) Usage

Necessary for our legitimate interests (to

define types of customers for our products

and services, to keep our website updated

and relevant, to develop our business and

to inform our marketing strategy)

To make suggestions and

recommendations to you about

goods or services that may be of

interest to you or the organisation

you represent.

(a) Identity

(b) Contact

(c) Technical

(d) Usage

(e) Profile

(f) Marketing and

Communications

Necessary for our legitimate interests (to

develop our products/services and grow

our business)

 

Marketing


We strive to provide you with choices regarding certain personal data uses, particularly around marketing
and advertising. We have established the following personal data control mechanisms:

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 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 logging into the
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 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

https://atalis.io/atalis-cookie-policy.

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.

5. 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 above.

  • Ambra SRL for purchases of laboratory testing services for the purpose of Ambra communicating
    test results and Certificates of Analysis.
  • 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 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.

6. International transfers

We do not transfer your personal data outside the UK.

7. 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.

8. 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 for tax purposes.

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.

9. 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:

  • Request access to your personal data.
  • Request correction of your personal data.
  • Request erasure of your personal data.
  • Object to processing of your personal data.
  • Request restriction of processing your personal data.
  • Request transfer of your personal data.
  • Right to withdraw consent.

If you wish to exercise any of the rights set out above, please contact us at [email protected].

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.

10. 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

External Third Parties

  • Service providers acting as processors based The EU or the UK who provide IT and system
    administration services.
  • HM Revenue & Customs, regulators and other authorities acting as processors or joint controllers
    based in the United Kingdom who require reporting of processing activities in certain
    circumstances.
  • Ambra SRL who perform laboratory testing services sold through PP Tech Limited.

YOUR LEGAL RIGHTS


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.

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