Terms of Business

We are committed to protecting your privacy. This Privacy Notice applies between you, the user of the
website  www.pinksindemnity.co.uk and Markets Direct Ltd.

Markets Direct Ltd is the owner and provider of this website, and this Privacy Notice
sets out our privacy practices and explains how we collect, process, hold and store (collectively
referred to as handle) personal data and with whom we share it. The personal data we handle is only
that which is required by us so that we may deliver the services you require. Except as provided in
this Privacy Notice, we do not supply personal data to any company for marketing purposes.

We are registered (Registration Number CSN1891503) as a data controller with the Information
Commissioner Office (ICO), which is the UK’s independent body set up to uphold information rights.
As a data controller, we determine the purpose for which, and the manner in which, personal data is
processed, and we make sure we comply with UK data protection law when we process such data.
You may browse our website without telling us who you are or revealing any personal data about
yourself. The information we collect from you is only that which is required by us so that we may
deliver the site functionality, information you have requested or searched for and to provide you with
our services.

Our Privacy Notice will be reviewed on a regular basis and may be updated from time to time. We will
notify you via email when this happens and provide you with a copy of the most recent and up-to-date

Privacy Notice.

What is Personal Data

When we refer to personal data, we mean any information relating to an identifiable person who can
be directly or indirectly identified in particular by reference to an identifier. Under data protection
legislation it is known as personal data. Some personal data will identify you directly – for example, by
giving your name and email address. It may also be possible to identify you indirectly, from
information in which your name is not given, for example by naming your job title and employer, or by
using another form of identifier such as an online identifier.

What Personal Data Do We Collect – We may collect the various categories of personal data as
outlined below:

 Personal Details – Full name, Title, Gender, Date of Birth, Profession/Job Title.

 Contact Details – Telephone number, mobile phone number, correspondence address, email
address.

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 Financial Details – Bank details, Credit or Debit card details.
 Technological Details (automatically collected) – IP address, web browser type and version, operating system, URLs, etc.

When Do We Collect Personal Data

Personal data may be collected at various points throughout your interaction with us. Basic personal
and contact details may be collected upon your initial contact with us or upon submission of an email
or website contact form, whilst more detailed personal data, including documentation and financial
details, may be collected during the process of our service provision. This will usually be when we are
collating the personal data required, to submit or manage, an application on your behalf.

How Do We Collect Personal Data – the following outlines the processes we employ to collect
personal data:

 Contacting Us – we may record, use and store any telephone, postal, e-mail or other
electronic communications provided by you. This is to ensure that we can refer back to any
instruction you may have given to us as well as to ensure that the information we provide you
with is accurate.

 General Statistics – we collect statistics relating to pages visited, paths through the website,
search terms used to find us. This is done to improve the visitor experience, understand our
customer’s needs and help us improve site design and layout.

 Online Forms – we collect data that you have entered into our online/contact forms. We have
appropriate measures in place to ensure that users' personal details are not misused,
accidentally destroyed, lost or altered within the server environment. No data transmission
over the internet can be guaranteed to be totally secure, we cannot ensure, guarantee or
warrant the security of any information which you send to us, and you do so at your own risk.

Our website may contain links to enable you to visit other websites. Once you have left our
site, you should note that we do not have any control over the other linked website. We
cannot be held responsible therefore for the protection and privacy of any information which
you provide whilst visiting such sites and such sites are not governed by this Privacy Notice.
You should exercise caution and look at the privacy notice applicable to the website in
question.

 Third Parties – we may be provided with your personal data by any third parties whom you
have instructed to do so.

 Publicly Available Sources – we may collect your personal data from any publicly available
records such as internet searches.

Why Do We Collect Personal Data – the personal data we collect is used to:
 Enable us to provide you with information about our products and services;

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 Enable us to provide you with our products and services;
 Enable us to contact you regarding general product and service level matters;
 Keep you informed of new features, products and services available from us;
 Maintain internal records;
 Ensure that we comply with the necessary laws and regulations; and
 Ensure that our website is compatible with the browsers and operating systems used by most
of our visitors.

It is important that the information we hold about you is accurate and current. Please keep us
informed if any such information were to change during the period for which we hold it.
We may use your personal data for the above purposes if we deem it necessary to do so for our
legitimate interests. If you are not satisfied with this, you have the right to object in certain
circumstances (see below).

In handling your personal data, we may use automated individual decision-making, which means we
are making a decision solely by automated means without any human involvement and we may also
do profiling, which means automated processing of personal data to evaluate certain aspects about
an individual.

For the delivery of direct marketing to you via email, we need your consent whether via an opt-in or
soft-opt-in arrangement:

 Soft-opt-in consent applies when you have previously engaged with us by enquiring about or
receiving our products or services and we are marketing similar products or services. Under
soft-opt-in consent we will take your consent as given unless you opt-out.
 For other types of email marketing we will require your explicit consent, for example asking
you to tick a box to confirm you are happy to receive these communications.
When you enter into a contract to receive our products or services, the legal basis for processing your
personal data is the contract between us or the taking of steps at your request and consent, to enter
into such a contract.

Disclosing Personal Data to Third Parties:

 We will not sell, share or rent your name, email address, or any other personal data to any
third party for marketing purposes;
 We will disclose your Personal Data to the relevant Provider(s) from whom we will be
providing products or services to you;
 We may disclose personal data to third parties (this may include but is not limited to, our
employees, agents, accountants, contractors and other professional advisors) who may

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require access to personal data in the course of them providing us with their services. We will
at all stages ensure that these third parties have appropriate security measures in place when
handling any personal data;

 Your data may be shared with third-party payment providers who process payments made
over the website if applicable;
 We may at our discretion disclose personal data that is required by the police (or other
organisations with a law enforcement role) for the prevention and detection of crime or the
apprehension or prosecution of offenders;
 We may disclose specific personal data where we are required to by law;
 We may share aggregated demographic information with our partners, advertisers or other
third parties. This will not contain information that can identify any individual person.

Data Retention

Unless a longer retention period is required or permitted by law, we will only hold your personal data
on our systems only for the period necessary to fulfil the purposes outlined in this Privacy Notice or
until you request that your personal data be deleted.
Even if we delete your personal data, it may remain on backup or archival media for legal, tax or
regulatory purposes.

Viewing, Changing or Removing Client Data:

You have the following rights in relation to your personal data:
 Right to access – the right to request (i) copies of the personal data we hold about you at any
time, or (ii) that we modify, update or delete such personal data. If we provide you with access
to the information we hold about you, we will not charge you for this, unless your request is
"manifestly unfounded or excessive." Where we are legally permitted to do so, we may refuse
your request. If we refuse your request, we will tell you the reasons why.

 Right to correct – the right to have your personal data rectified if it is inaccurate or
incomplete.
 Right to erase – the right to request that we delete or remove your personal data from our
systems in certain circumstances.
 Right to restrict our use of your personal data – the right to ask us to restrict the
processing of your personal data or limit the way in which we can use it, in certain
circumstances.
 Right to personal data portability – the right to request that we move, copy or transfer your
personal data, in certain circumstances.
 Right to object – the right to object to our use of your personal data including where we use it
for our legitimate interests, in certain circumstances.

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To make enquiries or complaints, exercise any of your rights set out above, or withdraw your consent
to the processing of your personal data (where consent is our legal basis for processing your personal
data), please contact us via the details below. Except as above in the “Right to access” section, you
are not required to pay any charge for exercising your rights. If you make a request, we have one
month to respond to you.

If you are not satisfied with the way a complaint you make in relation to your personal data is handled
by us, you may be able to refer your complaint to the ICO. The ICOs contact details can be found on
their website at https://ico.org.uk/, call the ICO Helpline number at 0303 123 1113, or you can write to
them at:
Information Commissioner’s Office
Wycliffe House
Water Lane
Wilmslow
Cheshire
SK9 5AF

How We Store Client Data:

Your data will be stored securely in line with industry best practices at all times. The security
measures in place are reviewed annually and include:
 Requiring a username and password to access your personal data;
 Your personal data being stored on secure servers; and
 The encryption of payment details (where applicable).
Personal data which we collect from you may be stored and processed in and transferred to countries
outside of the European Economic Area (EEA). For example, this could occur if our servers are in a
country outside the EEA or one of our service providers is situated in a country outside the EEA. We
may also share information with other group companies, some of which may be located outside the
EEA.

We will only transfer personal data outside the EEA where it is compliant with data protection
legislation and the means of transfer provides adequate safeguards in relation to your personal data,
e.g. by way of personal data transfer agreement, incorporating the current standard contractual
clauses adopted by the European Commission.
To ensure that your personal data receives an adequate level of protection, we have put in place
appropriate safeguards and procedures with the third parties we share your personal data with. This
ensures your personal data is treated by those third parties in a way that is consistent with the Data
Protection Laws.

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If you suspect any data breach or misuse, loss or unauthorised access to your personal data, please
let us know immediately via the contact details below.
If you want detailed information from Get Safe Online on how to protect your information and your
computers and devices against fraud, identity theft, viruses and many other online problems, please
visit https://www.getsafeonline.org/. Get Safe Online is supported by HM Government and leading
businesses.

Change of Business Ownership and Control

We may, from time to time, expand or reduce our business and this may involve the sale and/or the
transfer of control. Personal data as well as any other form of data provided by you will, where it is
relevant to any part of our business so transferred, be transferred along with that part and the new
owner or newly controlling party will, under the terms of this Privacy Notice, be permitted to use such
data for the purposes for which it was originally supplied to us.
We may also disclose such data to a prospective purchaser of our business or any part of it. In the
above instances, we will take steps with the aim of ensuring your privacy is protected.

General

You may not transfer any of your rights under this Privacy Notice to any other person. We may
transfer our rights under this Privacy Notice where we reasonably believe your rights will not be
affected.
If any court or competent authority finds that any provision of this Privacy Notice (or part of any
provision) is invalid, illegal or unenforceable, that provision or part-provision will, to the extent
required, be deemed to be deleted, and the validity and enforceability of the other provisions of this
Privacy Notice will not be affected.
Unless otherwise agreed, no delay, act or omission by a party in exercising any right or remedy will be
deemed a waiver of that, or any other, right or remedy.
This Privacy Notice will be governed by and interpreted according to the law of England and Wales.
All disputes arising under this Privacy Notice will be subject to the exclusive jurisdiction of the English
and Welsh courts.
Changes to this Privacy Notice
We reserve the right to change this Privacy Notice as we may deem necessary from time to time or as
may be required by law. Any changes will be immediately posted on the website and you are deemed
to have accepted the terms of the Privacy Notice on your first use of the website following the

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alterations or any changes will be notified to you and you are deemed to have accepted the terms of
the Privacy Notice on your receipt. 
For further information please contact us as below:
Contact
 Name: Pinks Indemnity
 Address:228 Park View, Whitley Bay, Tyne & Wear, NE26 3QR
 Telephone: TBC
 Email:Info@pinksindemnity.co.uk
Last updated 06 August 2023