We ask that you read this privacy notice carefully as it contains important information on who we are, how and why we collect, store, use and share personal information, your rights in relation to your personal information and on how to contact us and supervisory authorities in the event you have a complaint. This policy only applies to our site. If you leave our site via a link or otherwise, you will be subject to the policy of that website provider. We have no control over that policy or the terms of that website and you should check their policy before continuing to access the site.
Who we are
Pen Test Partners LLP, (a limited liability partnership, registered number, OC353362) whose registered office is at Sandhill House, Middle Claydon, Buckingham, Bucks, MK18 2LD collects, uses and is responsible for certain personal information about you. When we do so we are regulated under the Data Protection Act 2018 and we are responsible as ‘controller’ of that personal information for the purposes of those laws.
The personal information we collect and use
Information collected by us and how it is collected
We may collect the following personal information about you:
- Your name, address, phone number, email address, job title, employer and other contact information (“Contact Information”) when you register on our website, respond to a survey or promotion or contact us in some other way, or provide us with your contact details;
- Your Contact Information when you or your employer purchase products or services from us;
- Your Contact Information, educational background, financial details where you or your employer provide products and services to us;
- Credit references, background checks and background information where we enter into transactions or are contemplating entering into a transaction with you or your employer. You should note that as we usually contract with companies and other legal entities, rather than individuals, credit checks are usually carried out against those companies or legal entities but we may receive personal data of directors, executives and other employees as part of these checks; and
How and why we use your personal data
Under data protection law, we can only use your personal data if we have a proper reason for doing so, e.g:
- to comply with our legal and regulatory obligations;
- for the performance of our contract with you or to take steps at your request before entering into a contract;
- for our legitimate interests or those of a third party; or
- you have given consent.
A legitimate interest is when we have a business or commercial reason to use your information, so long as this is not overridden by your own rights and interests.
The table below explains what we use (process) your personal data for and our reasons for doing so:
|What we use your personal data for||Our reasons|
|To respond to queries and contact made by you||For our legitimate interests or those of a third party|
|To provide details of products and services to you or your employer||For our legitimate interests or those of a third party|
|To provide products and services to you or your employer||For the performance of our contract with you or your employer|
|To receive products and services from you or your employer||For the performance of our contract with you or your employer|
|Conducting credit checks and other processing necessary to comply with professional, legal and regulatory obligations that apply to our business||To comply with our legal and regulatory obligations|
|Ensuring business policies are adhered to, e.g. policies covering security and internet use||For our legitimate interests or those of a third party|
|Operational reasons, such as improving efficiency, training and quality control and administering our website||For our legitimate interests or those of a third party|
|Ensuring the confidentiality of commercially sensitive information||To comply with our legal and regulatory obligations|
|Audits, investigations, management reporting and quality checks||To comply with our legal and regulatory obligations|
|Statistical analysis to help us manage our business||For our legitimate interests or those of a third party, i.e. to be as efficient as we can so we can deliver the best service|
|Preventing unauthorised access and modifications to systems||For our legitimate interests or those of a third party, i.e. to prevent and detect criminal activity that could be damaging for us and for you
To comply with our legal and regulatory obligations
|Ensuring safe working practices, staff administration and assessments||To comply with our legal and regulatory obligations
For our legitimate interests or those of a third party, e.g. to make sure we are following our own internal procedures and working efficiently so we can deliver the best service to you
|Marketing our services to existing and former customers and third parties who have previously expressed an interest in our services||For our legitimate interests or those of a third party, i.e. to promote our business to existing and former customers|
We may use your personal information to send you updates about our services, including, promotions or new services.
We have a legitimate interest in processing your personal information for promotional purposes (see above ‘How and why we use your personal information’). This means we do not usually need your consent to send you promotional communications. However, where consent is needed, we will ask for this consent separately and clearly.
We will always treat your personal information with the utmost respect and never share it with other organisations for marketing purposes.
You have the right to opt out of receiving promotional communications at any time by contacting us at [email protected]
We may ask you to confirm or update your marketing preferences if you instruct us to provide further services in the future, or if there are changes in the law, regulation, or the structure of our business.
Who we share your personal information with
We may share Contact Details with our employees, officers and consultants and with subcontractors, business partners and other suppliers who are engaged in relation to any contract which we have entered into with you or your employer. We may also share your information with our professional advisors and service providers.
We will share personal information with law enforcement or other authorities if required by applicable law.
We will not share your personal information with any other third party.
How long your personal information will be kept
We will hold personal data for the period we are required to retain this information by applicable UK law. Note that different periods may apply to different types of data.
Transfer of your information out of the EEA
We may transfer your personal information to countries or organisations that are located outside the European Economic Area (EEA) such as our service providers and subcontractors. We will only transfer personal data to a country which has been assessed as providing an adequate level of protection for personal data or to other countries where we are satisfied that the transfer complies with data protection laws and personal data will be secure. Our standard practice is to use standard data protection contract clauses which have been approved by the European Commission.
If you would like further information please contact us (see how to contact us below)
Under the Data Protection Act 2018 you have a number of important rights which you can exercise free of charge. In summary, those include rights to:
- fair processing of information and transparency over how we use your use personal information
- access to your personal information and to certain other supplementary information that this Privacy Notice is already designed to address
- require us to correct any mistakes in your information which we hold
- require the erasure of personal information concerning you in certain situations
- receive the personal information concerning you which you have provided to us, in a structured, commonly used and machine-readable format and have the right to transmit those data to a third party in certain situations
- object at any time to processing of personal information concerning you for direct marketing
- object to decisions being taken by automated means which produce legal effects concerning you or similarly significantly affect you
- object in certain other situations to our continued processing of your personal information
- otherwise restrict our processing of your personal information in certain circumstances
If you would like to exercise any of those rights, please:
- Use the online subject request form, email, call or write to [email protected]
- let us know the information to which your request relates
We have appropriate security measures in place to prevent personal information from being accidentally lost, or 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 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.
We hope that we can resolve any query or concern you raise about our use of your information.
The Data Protection Act 2018 also gives you right to lodge a complaint with a supervisory authority. The supervisory authority in the UK is the Information Commissioner who may be contacted at https://ico.org.uk/concerns/ or telephone: 0303 123 1113.
Changes to this privacy notice
This privacy notice was published in April, 2018 an updated in September 2018.
We may change this privacy notice from time to time.
How to contact us
Please contact [email protected] if you have any questions about this privacy notice or the information we hold about you.