This is the Privacy Notice for the website retailwithoutborders.co.uk. The personal data of all data subjects is collected in line with the requirements of the GDPR.
2.1 The Data Protection Officers are responsible for ensuring that this notice is made available to data subjects prior to We Are Pentagon Limited (Pentagon) collecting/processing their personal data.
2.2 All Employees of Pentagon who interact with data subjects are responsible for ensuring that this notice is drawn to the data subject’s attention and their consent to the processing of their data is secured.
3. Privacy notice
3.1 Who are we?
This website is operated by We Are Pentagon Limited.
We Are Pentagon Limited is a subsidiary of We Are Pentagon Group Limited, the parent company of a group of subsidiaries. The business of the Group is to provide a complete solution to the ecommerce industry sector.
We Are Pentagon Limited is a company, incorporated in England, that provides ecommerce managed services to businesses that sell their products on online marketplaces.
We Are Pentagon Limited also runs Retail Without Borders, an industry event, that provides information to retailers and brands in relation to selling on online marketplaces domestically and globally.
We collect your personal contact data when:
- you submit a form requesting a resource
- you subscribe to our blog or newsletter
The personal data we would like to collect from you is:
|Personal data type:||Source (where Pentagon obtained the personal data from if it has not been collected directly from you, the data subject. Note if the personal data has been accessed from publicly accessible sources):|
3.4 Where do we store your data?
The personal data we collect will be stored:
- on our database on our servers in the EU
- on the database of Hubspot (which is the client record management platform we use). Hubspot’s database is based outside the EU but your personal data will be transferred to it in accordance with the requirements of the GDPR
- on the database of Mailchimp (which is the email platform we use from time to time)
- on Google Drive
3.5 What do we use your personal data for?
The personal data we collect will be used for the following purposes:
- to contact you to pursue your inquiry
- to send you our newsletters
- to send you blog notifications and updates
- to update you about our events
3.6 What’s our legal basis for collecting your personal data?
Our legal basis for processing for the personal data is:
- your specific consent to each purpose either confirmed by email or indicated on the form you submit from the website
- your submission of the form
- agreement to this Privacy Notice
By consenting to this privacy notice you are giving us permission to process your personal data specifically for the purposes identified.
Consent is required for Pentagon to process personal data, but it must be explicitly given.
You may withdraw consent at any time by clicking on the “Unsubscribe” link on any email.
Your data is shared with, and stored by,
(a) Hubspot for the following purposes as part of the processing activities:
- to manage our database
- to manage our marketing activities
- to send emails
- to send emails
3.9 Retention period
Your personal data will be stored and used for the purposes identified until you withdraw your consent by unsubscribing. We will also check from time to time that you still consent to us retaining your records.
The retention period has been established in accordance with our Retention of Records Policy.
3.10 Your rights as a data subject
At any point while we are in possession of or processing your personal data, you, the data subject, have the following rights:
- Right of access – you have the right to request a copy of the information that we hold about you.
- Right of rectification – you have a right to correct data that we hold about you that is inaccurate or incomplete.
- Right to be forgotten – in certain circumstances you can ask for the data we hold about you to be erased from our records.
- Right to restriction of processing – where certain conditions apply to have a right to restrict the processing.
- Right of portability – you have the right to have the data we hold about you transferred to another organisation.
- Right to object – you have the right to object to certain types of processing such as direct marketing.
- Right to object to automated processing, including profiling – you also have the right to be subject to the legal effects of automated processing or profiling.
- Right to judicial review: in the event that Pentagon refuses your request under rights of access, we will provide you with a reason as to why. You have the right to complain as outlined in clause 3.6 below.
You may access a Subject Access Request Form from this link.
All of the above requests will be forwarded on should there be a third party involved (as stated in 3.4 above) in the processing of your personal data.
In the event that you wish to make a complaint about how your personal data is being processed by Pentagon, or how your complaint has been handled, you have the right to lodge a complaint directly with the supervisory authority and We Are Pentagon Group’s Data Protection Officers.
The details for each of these contacts are:
|Supervisory authority contact details||Data Protection Officer (DPO)contact details|
|Contact Name:||Information Commissioner’s Officefirstname.lastname@example.org
|Address line 1:||Wycliffe House|
|Address line 2:||Water Lane|
|Address line 3:||Wilmslow|
|Address line 4:||Cheshire|
|Address line 5:||SK9 5AF|
|Telephone:||0303 123 1113|
Read more about how and why we use your data from this link to our Privacy Statement
4. Online privacy statement
Under the EU’s General Data Protection Regulation (GDPR) personal data is defined as:
“any information relating to an identified or identifiable natural person (‘data subject’); an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person”.
How we use your information
The Privacy Notice tells you how we, Pentagon, will collect and use your personal data.
Why does Pentagon need to collect and store personal data?
In order for us to contact you or provide you with the information you have requested we need to collect personal data for correspondence purposes and/or detailed service provision. In any event, we are committed to ensuring that the information we collect and use is appropriate for this purpose, and does not constitute an invasion of your privacy.
In terms of being contacted for any purposes, other than those you have consented to, or for which we have a legitimate reason, Pentagon would contact you for additional consent.
Will Pentagon share my personal data with anyone else?
We may pass your personal data on to the third-party service providers we have specified contracted to Pentagon who provide client record management and email services. Any third parties that we may share your data with are obliged to keep your details securely, and to use them only to fulfil the purposes for which we collect your data, as described in the Privacy Notice. When they no longer need your data to fulfil this service, they will dispose of the details in line with Pentagon’s procedures.
How will Pentagon use the personal data it collects about me?
Pentagon will process (collect, store and use) the information you provide in a manner compatible with the EU’s General Data Protection Regulation (GDPR). We will endeavour to keep your information accurate and up to date, and not keep it for longer than is necessary. Pentagon is required to retain information in accordance with the law, such as information needed for income tax and audit purposes. How long certain kinds of personal data should be kept may also be governed by specific business-sector requirements and agreed practices. Personal data may be held in addition to these periods depending on individual business needs.
Under what circumstances will Pentagon contact me?
Our aim is not to be intrusive, and we undertake not to ask irrelevant or unnecessary questions. Moreover, the information you provide will be subject to rigorous measures and procedures to minimise the risk of unauthorised access or disclosure.
Can I find out the personal data that the organisation holds about me?
Pentagon at your request, can confirm what information we hold about you and how it is processed. If Pentagon does hold personal data about you, you can request the following information:
- Identity and the contact details of the person or organisation that has determined how and why to process your data. In some cases, this will be a representative in the EU.
- Contact details of the data protection officer, where applicable.
- The purpose of the processing as well as the legal basis for processing.
- If the processing is based on the legitimate interests of Pentagon or a third party, information about those interests.
- The categories of personal data collected, stored and processed.
- Recipient(s) or categories of recipients that the data is/will be disclosed to.
- If we intend to transfer the personal data to a third country or international organisation, information about how we ensure this is done securely. The EU has approved sending personal data to some countries because they meet a minimum standard of data protection. In other cases, we will ensure there are specific measures in place to secure your information.
- How long the data will be stored.
- Details of your rights to correct, erase, restrict or object to such processing.
- Information about your right to withdraw consent at any time.
- How to lodge a complaint with the supervisory authority.
- Whether the provision of personal data is a statutory or contractual requirement, or a requirement necessary to enter into a contract, as well as whether you are obliged to provide the personal data and the possible consequences of failing to provide such data.
- The source of personal data if it wasn’t collected directly from you.
- Any details and information of automated decision making, such as profiling, and any meaningful information about the logic involved, as well as the significance and expected consequences of such processing.
What forms of ID will I need to provide in order to access this?
Pentagon accepts the following forms of ID when information on your personal data is requested:
Passport, driving licence, birth certificate, utility bill (from last 3 months)
Contact details of the Data Protection Officer / GDPR Owner:
|Data Protection Officer / GDPR Owner contact details|
|Contact Name:||Aleksandrina Bozhilova|
|Address line 1:||11 The Green|
|Address line 2:||Richmond|
|Address line 3:||Surrey|
|Address line 4:||TW9 1PX|
|Address line 5:||United Kingdom|