Privacy notice

1. Purpose and background

Placing Platform Limited is committed to protecting the personal information we hold about you. This privacy notice describes how, when and why we, Placing Platform Limited (‘PPL’), may use your personal information that you provide to us (‘Privacy Notice’).

In this Privacy Notice, ‘we’, ‘us’ and ‘our’ refers to PPL and ‘you’ refers to any individual about whom we collect personal information via our website. By ‘personal information’ we mean any information about you that you or third parties provide to us and includes ‘personal data’ for the purposes of data protection legislation.

This Privacy Notice also sets out information regarding your rights in relation to your personal information and how you can contact us in the event that you have a complaint.

2. Information we collect and hold about you

Personal information that we hold about you will often come from you directly (for example, when you contact us to arrange a demonstration or in relation to onboarding) and depends on the particular activities carried out through our website. This personal information will include the following:

First and last name
Corporate email address
Corporate contact number
Employer
Job title

Where you have signed up to PPL and have executed your Market User Agreement you will be required to complete and submit an onboarding form so that we can set you up on the PPL platform (‘PPL Platform’). The personal information that we collect from you during the onboarding process will include the following:

First and last name
Corporate email address
Corporate contact number
Employer
Job title
Stamp, initials or scratch
Broker code

We do not process your sensitive personal information which is known as ‘special category data’ under data protection law.

3. What we use your personal information for and our legal basis for doing so

Data protection legislation requires us to have a legal basis (lawful reason) to process your personal information. In most cases, the legal basis will be one of the following:

To protect our legitimate interests (for example, to allow us to liaise with you regarding queries you have relating to the PPL Platform or arranging training for you) on the basis that your own interests do not override our own legitimate interests; or
To allow us to take actions that are necessary for us to provide you with our services (for example, to be set up on and gain access to the PPL Platform).

The table below sets out what we use your personal information for and our legal basis for doing so. Where our legal basis is a legitimate interest (that is, where our interests do not outweigh your interests), those interests are also set out in the table.

What we use your personal information for	Our legal basis for doing so
To provide, manage and personalise our services to you	Where necessary to carry out our agreement, such as where you have entered into a Market User Agreement with us, or to take steps to enter into an agreement with you. It is in our legitimate interests to make sure that our customer accounts are well-managed, so that our customers are provided with a high standard of service, and to protect our business interests and the interests of our customers.
To communicate with you about your use of our services	Where necessary to carry out our agreement where you have entered into a Market User Agreement with us, or to take steps to enter into an agreement with you. It is in our legitimate interests to make sure that our customer accounts are well-managed, so that our customers are provided with a high standard of service.
To communicate with you generally in relation to any queries you have regarding our services	Where necessary to carry out our agreement where you have entered into a Market User Agreement with us, or to take steps to enter into an agreement with you. It is in our legitimate interests to make sure that our customer accounts are well-managed, so that our customers are provided with a high standard of service, and to protect our business interests and the interests of our customers.
To onboard you onto the PPL Platform	Where necessary to carry out our agreement for you to use the PPL Platform where you have entered into a Market User Agreement with us. It is in our legitimate interests to facilitate your access to the PPL Platform so that you can make use of our services.
To arrange training on the PPL Platform for you	Where necessary to carry out our agreement, such as where you have entered into a Market User Agreement with us, or to take steps to enter into an agreement with you. It is in our legitimate interests to provide you with training on the PPL Platform so that you can utilise all of the relevant features that the PPL Platform provides and to make sure that we provide our customers with a high standard of service.
To arrange a demonstration of the PPL Platform for you	Where necessary to take steps to enter into an agreement for the use of the PPL Platform with you. It is in our legitimate interests to provide demonstrations of our services to you in order to allow you to make an informed decision as to whether you would like to use our services.
To manage change requests and feedback that you have submitted	Where necessary to carry out our agreement, such as where you have entered into a Market User Agreement with us. It is in our legitimate interests to develop and improve our systems so that we can continue to provide services that our customers want to use, to make sure we continue to be competitive and to provide our customers with a high standard of service.
To manage complaints, take action to put matters right and to answer questions	Where necessary to carry out our agreement, such as where you have entered into a Market User Agreement with us. It is in our legitimate interests to make sure that complaints are investigated (for example, so that our customers receive a high standard of service and we can prevent complaints from arising in the future).
To send you marketing materials and news updates in relation to the PPL Platform	Where necessary to carry out our agreement, such as where you have entered into a Market User Agreement with us. It is in our legitimate interests to provide information to you that is relevant to your use of our services, such as maintenance of or updates to the PPL Platform, and to keep you informed about the features and benefits of the services that we provide to you.

4. Who we will share your personal information with

We will keep your personal information confidential, but we may disclose it to:

Our professional advisors (including without limitation tax, legal or other corporate advisors who provide professional services to us);
Other third-party suppliers, business partners and sub-contractors for business administration, support, processing, services or IT purposes; and
Analytics or search engines, that enable us to optimise and improve your website experience.

Where we disclose your personal information to these third parties they must also keep your personal information secure and confidential.

5. Transfers of your personal information outside of the UK

We may transfer personal information to countries outside of the UK in order to provide our services to you. These countries may not have the same data protection laws as the country in which you initially provided the information and may not provide the same level of protection.

If we transfer personal information to countries outside of the UK/European Economic Area (“EEA”), we may rely on a decision from the European Commission/ UK Government determining that the country provides an adequate level of protection to the data protection laws. Alternatively, we may rely on appropriate safeguards in respect of transfers of personal information to a country outside of the UK/EEA, for example, by agreeing standard contractual clauses adopted by the European Commission/ UK Government.

Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal information, we cannot guarantee the security of your data transmitted to our websites and any transmission is at your own risk. Once we have received your information, we will use procedures and security features to try to prevent unauthorised access.

6. Storing your personal information

We will keep your personal information for as long as is necessary for the purposes set out in section 3 (What we use your Personal Information for and the Legal Basis for doing so).

Where your relationship with us has ended, for example where your query has been resolved, we will only keep your personal information for a period of time that is appropriate for the type of personal information and what we hold it for.

We will only keep personal information that allows us to:

Maintain business records for analysis or audit purposes;
Comply with relevant laws (for example, laws relating to preventing, detecting and investigating money laundering)
Defend or take legal action;
Keep records of anyone who does not want to receive marketing from us;
Deal with any future complaints about the services we have provided;
Assess the eﬀectiveness of marketing we may have sent you.

The period that we keep personal information for is often linked to the amount of time available to bring a legal claim, which in many cases is six or seven years after your agreement with us ends. We will keep your personal information after this time if we have to do so to comply with the law, if there are existing claims or complaints that will reasonably require us to keep your personal information or technical reasons. If we do need to keep your personal information for a longer period, we will continue to protect that personal information.

7. Cookies and other tracking technologies

Our site uses cookies to collect data from your device that allow us to distinguish you from other users of our site. This helps us to provide you with a better experience when you browse our site, understand how you use our site and also allows us to improve our site.

For more information about cookies and how we use them on our site, please refer to our Cookie Policy.

8. Your rights

You have certain rights relating to your personal information. These include the right to:

Right	Description
Information	A right to be informed about the personal information we hold about you.
Access	A right to access the personal information we hold about you.
Rectification	A right to require us to rectify any inaccurate personal information we hold about you.
Erasure	A right to ask us to delete the personal information we hold about you. This right will only apply where (for example): we no longer need to use the personal information to achieve the purpose we collected it for; where you withdraw your consent if we are using your personal information based on your consent; or where you object to the way we process your data.
Restriction of processing	In certain circumstances, a right to restrict our processing of the personal information we hold about you. This right will only apply where (for example): you dispute the accuracy of the personal information held by us; where you would have the right to ask us to delete the personal information but would prefer that our processing is restricted instead; or where we no longer need to use the personal information to achieve the purpose we collected it for, but you need the data for the purposes of establishing, exercising or defending legal claims.
Data portability	In certain circumstances, a right to receive the personal information you have given us, in a structured, commonly used and machine-readable format. You also have the right to require us to transfer this personal information to another organisation, at your request.
Objection	A right to object to our processing of the personal information we hold about you where our lawful basis is for the purpose of our legitimate interests, unless we are able to demonstrate, on balance, legitimate grounds for continuing to process the personal information which override your rights or which are for the establishment, exercise or defence of legal claims.
Automated decision making and profiling	A right for you not to be subject to a decision based solely on an automated process, including profiling, which produces legal eﬀects concerning you or similarly significantly aﬀect you. We do not carry out any automated processing or profiling.
Withdrawal	A right to withdraw your consent, where we are relying on it to use your personal information (for example, to provide you with brochures and newsletters).

Your ability to exercise these rights will depend on a number of factors, and in some instances we will not be able to agree to your request (for example, if we have a legitimate reason for not doing so or the right doesn’t apply to the particular information we hold about you).

9. Keeping your personal information secure

We will always hold your personal information securely. To prevent unauthorised disclosure or access to your personal information, we have implemented strong physical and electronic security safeguards.

We have appropriate security measures in place to prevent personal information from being accidentally lost, used or accessed in an unauthorised way. We limit access to your personal information to those who have a genuine business need to know it. Those processing your personal information will do so only in an authorised manner and are subject to a duty of confidentiality.

We also have procedures in place to deal with any suspected data security breach. We will notify you and any applicable regulator of a suspected data security breach where we are legally required to do so.

10. Changes to this privacy notice

We may change, update, modify, add or remove portions of this Privacy Notice at any time as the need arises in order to accurately reflect how we gather and manage your personal information. All changes to this Privacy Notice will become eﬀective immediately. Please visit this page regularly to keep up to date.

11. How to contact us

Please contact us at datprotection@placingplatformlimited.com if you have any questions about this Privacy Notice or the personal information we hold about you.

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