1. WHO ARE WE AND OUR COMMITMENT TO YOU
PAAW House Limited (”We” or “PAAW House”) are committed to protecting and respecting your privacy.
Please read the following carefully to understand our views and practices regarding your personal data and how we will treat it.
By visiting https://paaw.house/ (“our site”) you are accepting and consenting to the practices described in this policy.
For the purpose of the Data Protection Act 2018 (the Act), the data controller is PAAW House Limited with its registered office at 130 Shaftesbury Avenue, 2nd Floor, London W1D 5EU.
2. INFORMATION WE COLLECT
We will collect and process the following data about you:
Information you give us. This is information about you that you give us by filling in forms on our site, participating in voluntary surveys or by corresponding with us by phone, e-mail or otherwise. It includes information you provide when you register to use our site, subscribe to our service, participate in discussion boards or other social media functions on our site, complete a voluntary survey and when you report a problem with our site. The information you give us may include:
first and surname
IP address and system info you already have
your full biography (if you opt to provide this information)
photo if you provide one
Where you are a pet owner we ask you to provide information on the number of pets, type of pets you have and the pets name and breed.
Information we collect about you. We collect demographic information such as your area postcode when you agree to participate in campaigns, age, gender, preferences, interests and generic favourites. In addition, with regard to each of your visits to our site we will automatically collect the following information:
technical information, including the Internet protocol (IP) address used to connect your computer to the Internet, your login information, browser type and version, time zone setting, browser plug-in types and versions, operating system and platform, log-in time and referring website addresses
information about your visit, including the full Uniform Resource Locators (URL), clickstream to, through and from our site (including date and time), products you viewed or searched for, page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs), methods used to browse away from the page, and any phone number used to call us.
Information we receive from other sources. This is information we receive about you if you use any of the other websites we operate or the other services we provide. We are working closely with third parties (including, for example, business partners, sub-contractors in technical, payment and delivery services, advertising networks, analytics providers, search information providers, credit reference agencies).
Special Category Data. We do not collect special category data such as biometric data for unique identification, health information and medical records, criminal records, racial or ethnic origin, political orientation or beliefs, religious or philosophical beliefs, trade union membership, data concerning sex life or sexual orientation, genetic data, nor do we require you to give us this data.
Information about other individuals. If you give us information on behalf of someone else, you confirm that the other person has appointed you to act on his/her behalf and has agreed that you can:
give consent on his/her behalf to the processing of his/her personal data;
receive on his/her behalf any data protection notices; and
You should inform them how we collect, use, disclose, and retain their personal data according to our privacy notice.
To request removal of your personal data from a Forum, contact us at firstname.lastname@example.org. In some cases, we may not be able to remove personal data that you submitted on a Forum, in which case we will let you know if we are unable to do so and why.
5. USES MADE OF THE INFORMATION
We use information held about you in the following ways:
to provide you with information about what we do and our mission;
to provide you with the information, products and services available via our site;
to send you information about special offers, petitions, campaigns, case studies, blogs, tips and other information that we think will be of interest to you;
to notify you about changes to our service;
to contact you to invite you to participate in voluntary surveys for the purpose of conducting research into your opinion of current services and/or of potential new services that may be offered;
to ensure that content from our site is presented in the most effective manner for you and for your computer;
to administer our site and for internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes and as part of our efforts to keep our site safe and secure;
to allow you to participate in interactive features of our service (when you choose to do so);
to measure or understand the effectiveness of advertising we serve to you and others, and to deliver relevant advertising to you;
to make suggestions and recommendations to you and other users of our site about goods or services that may interest you or them.
Information we receive from other sources. We will combine this information with information you give to us and information we collect about you. We will use this information and the combined information for the purposes set out above (depending on the types of information we receive).
6. MARKETING AND OPTING OUT
Where you have opted in to receive our newsletter we will share your personal data with our mail management service provider (see ‘Data Storage and Transfers’ section below for more information) and you will be sent our newsletter by email. If you have given permission, we may share your personal data with organisations who are our business partners and we or they may contact you (unless you have asked us or them not to do so) by email or mail about petitions, campaigns, blogs, recommendations, voluntary surveys, services, promotions and special offers, and other things that we think may be of interest to you. If you prefer not to receive any further direct marketing communications from us or our business partners, you can opt out at any time using the unsubscribe or opt out mechanism in the relevant communication or by contacting us. See further ‘Your rights’, below.
7. LEGITIMATE INTERESTS
We process personal data for certain legitimate business purposes, which include some or all of the following:
where the processing enables us to enhance, modify, personalise or otherwise improve our services’ communications for the benefit of our members;
to identify and prevent fraud;
to enhance the security of our network and information systems;
to better understand how people interact with our site;
to provide postal communications which we think will be of interest to you e.g. petitions, newsletters, case studies including useful tips; special offers
to determine the effectiveness of petitions, promotional campaigns and advertising.
“Legitimate Interests” means the interests of our company in conducting and managing our business to enable us to give you the best service/products and the best and most secure experience.
When we process your personal data for our legitimate interests, we make sure to consider and balance any potential impact on you (both positive and negative), and your rights under data protection laws. Our legitimate business interests do not automatically override your interests – we will 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).
Our site is aimed at building a community of like minded people and providing a forum where information of interest to this community can be shared. To achieve the purposes of this forum we believe it is in the interests of users of our site for us to invite you to sign petitions that we think promote the purpose of the forum, to campaign for legalisation to recognise the importance of emotional support and companion animals and to make responsible pet ownership a human right, to provide useful information, tips and support for pets and their owners including recommendations of pet services.
You have the right to object to this processing if you wish, and if you wish to do so please see the ‘Your Rights’ section below. Please bear in mind that if you object this may affect our ability to carry out tasks above for your benefit and may defeat the object of your participation in the forum offered through our site.
8. DISCLOSURE OF YOUR INFORMATION
You agree that we have the right to share your personal data with:
Any member of our group. (For more information on our group members please check our site or contact us. See ‘Contact’ below.)
Selected third parties including:
our mail management service provider (see Data Storage and Transfers below for more information);
carefully selected charities;
pet service providers that we partner with;
analytics and search engine providers that assist us in the improvement and optimisation of our site.
We will disclose your personal data to third parties:
In the event that we sell or buy any business or assets, in which case we will disclose your personal data to the prospective seller or buyer of such business or assets.
If PAAW House Limited or substantially all of its assets are acquired by a third party, in which case personal data held by it about its customers will be one of the transferred assets.
9. DATA STORAGE AND TRANSFERS
Expect as stated below, all information you provide to us is stored on our secure servers located in the UK and/or the European Economic Area (EEA). It will also be processed by staff operating inside the UK or the EEA who work for us or for one of our suppliers. This includes staff engaged in, among other things, the provision of our site and the forum including support services and the processing of your payment details.
You can obtain more information about the locations where your data is stored and transferred to, including the identity of third party suppliers and their locations and processing activities please by contacting us. See “Contact” below.
We use Mailchimp to manage our mailing lists and to send our newsletters. Mailchimp is based in the USA and is Privacy Shield Certified under the EU-U.S. Privacy Shield Framework as set forth by the U.S. Department of Commerce regarding the collection, use, and retention of personal information transferred from the European Union to the United States. To learn more about the Privacy Shield program, and to view our Mailchimp’s certification, please visit https://mailchimp.com/help/about-mailchimp-the-eu-swiss-privacy-shield-and-the-gdpr/
We will use technical and organisational measures to safeguard your personal data, for example:
access to your account is controlled by a password and username that are unique to you;
we store your personal data on secure servers;
we use industry standard encryption of data at rest and in transit; and
we deploy technology such as DDOS Mitigation, Content Delivery Networks and MFA.
While we will use all reasonable efforts to safeguard your personal data, you acknowledge that the use of the internet is not entirely secure and for this reason we cannot guarantee the security or integrity of any personal data that are transferred from you or to you via the internet.
Where we have given you (or where you have chosen) a password which enables you to access certain parts of our site, you are responsible for keeping this password confidential. We ask you not to share a password with anyone.
Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted to our site; any transmission is at your own risk. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorised access.
11. FOR HOW LONG DO WE KEEP YOUR DATA
We only keep your information for so long as it is necessary to fulfil the purpose for which it was collected. We use the following criteria to determine how long we should keep your data for:
Whether or not you are actively using your account;
Whether or not you are opening emails that we send to you with communications we think you are interested in;
If we are required by law to keep your information for a certain period of time;
If we will need to keep copies of correspondence with you to resolve complaints.
If you have not logged-into your account or you have not opened emails from us for a period of 6 or more months we may close your account and delete your information. We contact you before we do this to ask you if you want us to do this or if you want us to keep your account open and if you want us to continue to communicate with you.
12. YOUR RIGHTS
Right to ask us to stop contacting you with direct marketing. Even if you have accepted the processing of your personal data for marketing purposes (by ticking the relevant box), you have the right to ask us to stop processing your personal data for such purposes. Let us know what method of contact you are not happy with if you are unhappy with certain ways of contacting you only (for example, you may be happy for us to contact you by email but not by telephone).
Right to request a copy of your information. You can request a copy of your information which we hold (this is known as a subject access request). If you would like a copy of some or all of it, please contact us and let us know the information you want a copy of, including any account or reference numbers, if you have them. Any subject access request may be subject to a reasonable fee to cover the cost of providing you with details of the information we hold about you.
Right to correct any mistakes in your information. Where you are a registered user on our site and have a log-in, you can log-in and update your own information. It is your responsibility to do this as soon as any of your information changes. However, you can require us to correct any mistakes in your information which we hold free of charge. If you would like to do this, please contact us and let us know the information that is incorrect and the information you want it replaced with.
Right to request we cease processing your information. You may request that we cease processing your personal data. If you make such a request, we shall retain only the amount of personal data pertaining you that is necessary to ensure that no further processing of your personal data takes place.
Data Portability Request. You have rights to obtain a copy of some of the personal data that we hold on you and reuse or share it for your own purposes (“right to data portability”). The right to data portability only applies:
to personal data you’ve provided to us (i.e. not any other information),
where we are processing your Personal data because you have provided your consent for us to do so, or under a contract with you; and
when processing is carried out by automated means.
We can refuse your data portability request if the processing does not satisfy the above criteria. Also, if the personal data concerns more than one individual, we may not be able to transfer the information to you if doing so would prejudice the other person’s rights.
Right to request deletion of your information. You can ask us to erase all your personal data (also known as the “right to be forgotten”) in the following circumstances:
it is no longer necessary for us to hold that personal data with respect to the purpose for which it was originally collected or processed;
you wish to withdraw your consent to us holding and processing your personal data;
you object to us holding and processing your personal data (and there is no overriding legitimate interest to allow us to continue doing so);
the personal data has been processed unlawfully; or
the personal data needs to be erased in order for us to comply with a particular legal obligation.
Unless we have reasonable grounds to refuse to erase your personal data, all requests for erasure shall be complied with.
If you have any complaints about the way in which we collect, store and use your information, and these have not been addressed by contacting us first, you can contact the supervisory authority in the United Kingdom, the Information Commissioner’s Office: https://ico.org.uk/concerns/
17. LINKS TO OTHER WEBSITES
Our website may contain links to other websites of interest. However, once you have used these links to leave our site, you should note that we do not have any control over other websites and their content. Therefore, we cannot be responsible for the protection and privacy of any information which you provide whilst visiting such sites and such sites are not governed by this privacy statement. You should exercise caution and look at the privacy statement applicable to the website in question.
Last Updated: 13 November 2019