Pembridge respects your privacy and is committed to protecting your Personal Data.We want to be transparent with you about how we collect and use your Personal Data in making available our website located at: www.pembridgeresources.com and tell you about your privacy rights and how the law protects you.
Who we are.
Our address is: 180 Piccadilly, London W1J 9HF, UK.
How to contact us.
You can contact us by emailing: firstname.lastname@example.org.
By law you have the right to:
- Request access to your Personal Data. This enables you to receive a copy of the Personal Data we hold about you and to check that we are lawfully processing it.
- Request correction of the Personal Data that we hold about you. This enables you to have any incomplete or inaccurate information we hold about you corrected.
- Request erasure of your Personal Data. This enables you to ask us to delete or remove Personal Data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your Personal Data where you have exercised your right to object to processing (see below).
- Object to processing of your Personal Data. This right exists where we are relying on a Legitimate Interest as the legal basis for our processing and there is something about your particular situation, which makes you want to object to processing on this ground. You also have the right to object where we are processing your Personal Data for direct marketing purposes.
- Request the restriction of processing of your Personal Data. This enables you to ask us to suspend the processing of Personal Data about you, for example if you want us to establish its accuracy or the reason for processing it.
- Request the transfer of your Personal Data. We will provide to you, or a third party you have chosen, your Personal Data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
- Withdraw consent. This right only exists where we are relying on consent to process your Personal Data (“Consent Withdrawal”). If you withdraw your consent, we may not be able to provide you with access to the certain specific functionalities of our Site. We will advise you if this is the case at the time you withdraw your consent.
How to exercise your rights
If you want to exercise any of the rights described above, please contact us by emailing: email@example.com.
Typically, you will not have to pay a fee to access your Personal Data (or to exercise any of the other rights). However, except in relation to Consent Withdrawal, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive, or, we may refuse to comply with your request in these circumstances.
We may need to request specific information from you to help us confirm your identity and ensure your right to access your Personal Data (or to exercise any of your other rights). This is a security measure to ensure that Personal Data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.
We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.
We will reply to your complaint as soon as we can.
If you feel that your complaint has not been adequately resolved, please note that the GDPR gives you the right to contact your local data protection supervisory authority, which for the UK, is the Information Commissioner’s Office.
Where you opt out of receiving these marketing messages, this will not apply to service correspondence.
All the Personal Data we collect, both from you and from third parties about you, is outlined in the table below.
Category of Personal Data collected
What this means
|Identity Data||First name and last name.|
|Contact Data||Your email address.|
|Marketing and Communications Data||Your preferences in receiving marketing and investor relations updates from us and our third parties and your communication preferences.|
No Special Categories of Personal Data
We do not collect any “Special Categoriesof Personal Data” about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data). Nor do we collect any information about criminal convictions and offences.
We will only use your Personal Data for the purposes for which we collected it as listed below, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose.
What is our “legal basis” for processing your Personal Data?
In respect of each of the purposes for which we use your Personal Data, the GDPR requires us to ensure that we have a “legal basis” for that use. Most commonly, we will rely on one of the following legal bases:
- Where we need to perform a contract we are about to enter into or have entered into with you (“Contractual Necessity”).
- Where it is necessary for our legitimate interests and your interests and fundamental rights do not override those interests (“Legitimate Interests”). More detail about the specific legitimate interests pursued in respect of each Purpose we use your Personal Data for is set out in the table below.
- Where we need to comply with a legal or regulatory obligation (“Compliance with Law”).
- Where we have your specific consent to carry out the processing for the Purpose in question (“Consent”).
Generally, we do not rely on your Consent as a legal basis for using your Personal Data other than in the context of direct marketing communications.
We have set out below, in a table format, the legal bases we rely on in respect of the relevant Purposes for which we use your Personal Data.
|Purpose||Category(ies) of Personal Data involved||Why do we do this||Our legal basis for this use of data|
|Troubleshooting and/or Support||Identity Data, Contact Data||To respond to your enquiries when you contact and track and resolve issues that might be occurring on our systems.||Legitimate Interests. It is in our legitimate interests that we are able to ensure the proper operation of our Sites and associated systems and services, and respond to your enquiries on our Site and services.|
|Marketing||Identity Data, Contact Data, Marketing and Communications Data||To provide you with investor relationship information, and form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which services and offers may be relevant for you.||Consent.|
Where we need to process your Personal Data either to comply with law, or to perform the terms of a contract we have with you and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with the functionalities of the Site).
In this case, we may have to stop you using our Site but we will notify you if this is the case at the time.
The table below describes who we share your Personal Data with, what we share and why we share it.
Some of our external third parties are based outside the European Economic Area (“Europe”) so their processing of your Personal Data will involve a transfer of data to countries based outside of Europe.
We endeavour to ensure that people to whom we provide Personal Data hold it subject to appropriate safeguards and controls. Whenever we transfer your Personal Data out of Europe, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented
- We may transfer your Personal Data to countries that have been deemed to provide an adequate level of protection for Personal Data by the European Commission. For further details, see European Commission: Adequacy of the protection of Personal Data in non-EU countries.
- Where we use service providers outside Europe, we may use specific contracts approved by the European Commission, which give Personal Data the same protection it has in Europe. For further details, see European Commission: Model contracts for the transfer of Personal Data to third countries.
- Where we use service providers based in the U.S., we may transfer data to them if they are part of the Privacy Shield, which requires them to provide similar protection to Personal Data shared between Europe and the U.S. For further details, see European Commission: EU-U.S. Privacy Shield.
|Recipients||Category(ies) of Personal Data we share||Why we share it||Location(s)|
|Service Providers||Identity Data, Contact Data||Our service providers provide us with IT and system administration services.||Within Europe|
|Emailing Marketing Providers||Identity Data, Contact Data||We use third party providers to provide email services enabling us to update you about investor news (provided you have elected to receive such information).||Within Europe, United States|
|Professional advisers||Identity Data, Contact Data||Our lawyers, bankers, auditors and insurers and other advisers who provide consultancy, banking, legal, insurance and accounting services.||Within Europe|
|HM Revenue & Customs, regulators and other authorities||Identity Data, Contact Data||Authorities may require reporting of processing activities in certain circumstances.||Within Europe|
We have put in place appropriate security measures to prevent your Personal Data from being accidentally lost, used or accessed in an unauthorized way, altered or disclosed.
We limit access to your Personal Data to those employees and other staff who have a business need to have such access. All such people are subject to a contractual duty of confidentiality.
We have put in place procedures to deal with any actual or suspected Personal Data breach. In the event of any such breach, we have systems in place to work with applicable regulators. In addition, in certain circumstances (e.g., where we are legally required to do so) we may notify you of breaches affecting your Personal Data.
We will only retain your Personal Data for so long as we reasonably need to use it for the purposes set out above [“How we use your Personal Data and why.”], unless a longer retention period is required by law (for example for regulatory purposes).
The table below shows our standard retention practices:
Category of Personal Data
|• Marketing and Communications Data • Contact Data • Identity Data||For so long as you do not opt-out of receiving our investor news and alerts.|
This Site is not intended for children below 16 and we do not knowingly collect data relating to such children.
Pembridge Resources plc, 2018