Last Updated: 14 January 2021
Paso Holdings Limited (11646064) (“Company,” “we,” “us” or “our”) wholly owns and operates the www.getpaso.co.uk website (the "Service").
This page informs you of our policies regarding the collection, use and disclosure of personal data when you use our Service and the choices you have associated with that data.
For the purpose of the Data Protection Act 1998, the data controller is Paso Holdings Limited whose registered office is at 12 Norland Square, London W11 4PX.
To provide you with the products and services that Company has to offer, we request specific personal information (personal data) as detailed below. We value and respect your privacy.
Service is the www.getpaso.co.uk website solely owned and operated by Paso Holdings Limited.
Personal Data means data about a living individual who can be identified from those data (or from those and other information either in our possession or likely to come into our possession).
Usage Data is data collected automatically either generated by the use of the Service or from the Service infrastructure itself (for example, the duration of a page visit).
Cookies are small pieces of data stored on your device (such as but not limited to computer or mobile device).
Data Controller means the natural or legal person who (either alone or jointly or in common with other persons) determines the purposes for which and the manner in which any personal information are, or are to be, processed.
Data Processors (or Service Providers)
Data Processor (or Service Provider) means any natural or legal person who processes the data on behalf of the Data Controller.
We may use the services of various Service Providers in order to process your data more effectively.
Data Subject (or User)
Data Subject is any living individual who is using our Service and is the subject of Personal Data.
Information Collection and Use.
We collect several different types of information for various purposes to provide and improve our Service to you.
Types of Data Collected:
While using our Service, we may ask you to provide us with certain personally identifiable information that can be used to contact or identify you ("Personal Data"). Personally identifiable information may include, but is not limited to:
- Email address
- First name and last name
- Phone number
- Address, ZIP/Postal code, City
- Cookies and Usage Data
We may use your Personal Data to contact you with newsletters, marketing or promotional materials and other information that may be of interest to you. You may opt out of receiving any, or all of these communications from us by following the unsubscribe link or instructions provided in any email we send.
We may also collect information on how the Service is accessed and used ("Usage Data"). This Usage Data may include information such as your computer's Internet Protocol address (e.g. IP address), browser type, browser version, the pages of our Service that you visit, the time and date of your visit, the time spent on those pages, unique device identifiers and other diagnostic data.
Tracking Cookies Data
Cookies are files with small amounts of data which may include an anonymous unique identifier. Cookies are sent to your browser from a website and stored on your device. Tracking technologies also used are beacons, tags, and scripts to collect and track information and to improve and analyse our Service.
You can instruct your browser to refuse all cookies or to indicate when a cookie is being sent. However, if you do not accept cookies, you may not be able to use some portions of our Service.
Examples of Cookies we use:
- Session Cookies. We use Session Cookies to operate our Service.
- Preference Cookies. We use Preference Cookies to remember your preferences and various settings.
- Security Cookies. We use Security Cookies for security purposes.
Age Requirements for General Use of Site & Children's Privacy.
Participation and registration on the Site is restricted to those individuals at least 18 years of age. By registering or participating in services or functions on the Site, you hereby represent that you are at least 18 years of age.
We understand and are committed to respecting the sensitive nature of children’s privacy online. If we learn or have reason to suspect that a Site user is not at least 18 years of age, we will promptly delete any personal information in that user’s account. If you are under 18 years of age, do not use the Site.
Our Service does not address anyone under the age of 18 ("Children").
We do not knowingly collect personally identifiable information from anyone under the age of 18. If you are a parent or guardian and you are aware that your Children have provided us with Personal Data, please contact us. If we become aware that we have collected Personal Data from children without verification of parental consent, we will take steps to remove that information from our servers.
What Information We Collect:
We collect personally identifiable information as a condition of registration at the Site, purchasing our products (“Products”), or subscribing to our mailing list. If you engage in any of these activities on the Site, you may be asked to provide information such as your full name, company name, email address, mailing address, and telephone number. If you decide to place an order, we will also need to know your shipping and billing address, credit card number, security code, and expiration date. To protect your personal information, customers of Products on the Site must also register with an email address. We do not store credit card details nor do we share financial details with any 3rd parties.
Aggregate Demographic Information
Company gathers aggregated demographic information through its tracking of IP addresses and other types of traffic data. This information is not linked to any personal information that can identify any individual person. Aggregated demographic information may be used by us and shared with third parties in order to provide tailored advertisements on the Site about goods and services that may be of interest to you.
How We Use Your Personal Information and Personal Data.
We will process and use personally identifiable information about you for the following reasons or in the following ways:
- For our market research purposes.
- To provide and maintain our Service.
- To notify you about changes to our Service.
- To allow you to participate in interactive features of our Service when you choose to do so.
- To provide customer support.
- To gather analysis or valuable information so that we can improve our service.
- To monitor the usage of our Service.
- To detect, prevent and address technical issues.
- To provide you with news, special offers and general information about other goods, services and events which we offer that are similar to those that you have already purchased or enquired about unless you have opted not to receive such information.
- To register you as a user or customer on the Site, and manage and maintain your account.
- Provide Products and services that you request.
- Process, validate, confirm, verify, deliver and track your purchases (including but not limited to processing payment card transactions, arranging shipping and handling returns and refunds, and contacting you about your orders, including by telephone).
- Maintain a record of the purchases you make.
- Respond to your questions and comments and provide customer support.
- Tailor our Products and services to suit your personal interests and manner in which you use the Site.
- Analyse and enhance our marketing communications and strategies.
- Analyse trends and statistics regarding the user experience when visiting the Site, mobile applications or social media assets, and the purchases you make.
- We need to send the information to third party partners, vendors, agents, or service providers who work on behalf of Company to provide a Product or service for you on our behalf and to provide other related services, including, but not limited to, payment processing, shipping, order tracking, promotional fulfilment, and customer service.
- We need to respond to valid legal process. This includes a search warrant, subpoena, or court order, and any other instance when we believe we are required to do so by law.
- We deem it necessary to disclose personally identifiable information, in our sole discretion, to comply with any applicable law, regulation, legal process or governmental request, or to protect Company’s rights or interests.
- We may also exchange information, including personally identifiable information, with other companies and organisations for credit fraud protection and risk reduction.
- For any other purpose or use, provided we have your consent.
If you do not want us to use your personal information for our marketing purposes, send us an email at firstname.lastname@example.org stating that you withdraw your consent to such use.
Legal Basis for Processing Personal Data Under General Data Protection Regulation (GDPR)
Paso Holdings Limited may process your Personal Data because:
- We need to perform a contract with you
- You have given us permission to do so
- The processing is in our legitimate interests and it's not overridden by your rights
- For payment processing purposes
- To comply with the law
Retention of Data.
Paso Holdings Limited will also retain Usage Data for internal analysis purposes. Usage Data is generally retained for a shorter period of time, except when this data is used to strengthen the security or to improve the functionality of our Service, or we are legally obligated to retain this data for longer time periods.
Transfer of Data.
Your information, including Personal Data, may be transferred to — and maintained on — computers located outside of your state, province, country or other governmental jurisdiction where the data protection laws may differ than those from your jurisdiction.
If you are located outside United Kingdom and choose to provide information to us, please note that we transfer the data, including Personal Data, to United Kingdom and process it there.
Disclosure of Data.
Paso Holdings Limited may disclose your Personal Data in the good faith belief that such action is necessary to:
- To comply with a legal obligation
- To protect and defend the rights or property of Paso Holdings Limited
- To prevent or investigate possible wrongdoing in connection with the Service
- To protect the personal safety of users of the Service or the public
- To protect against legal liability
Security of Data.
The security of your data is important to us, but remember that no method of transmission over the Internet, or method of electronic storage is 100% secure. While we strive to use commercially acceptable means to protect your Personal Data, we cannot guarantee its absolute security.
Security of Data: Your Data Protection Rights Under General Data Protection Regulation (GDPR)
If you are a resident of the European Economic Area (EEA), you have certain data protection rights. Paso Holdings Limited aims to take reasonable steps to allow you to correct, amend, delete, or limit the use of your Personal Data.
If you wish to be informed what Personal Data we hold about you and if you want it to be removed from our systems, please contact us on email@example.com.
In certain circumstances, you have the following data protection rights:
The right to access, update or to delete the information we have on you. Whenever made possible, you can access, update or request deletion of your Personal Data by contacting us and we will assist you to do so.
The right of rectification. You have the right to have your information rectified if that information is inaccurate or incomplete.
The right to object. You have the right to object to our processing of your Personal Data.
The right of restriction. You have the right to request that we restrict the processing of your personal information.
The right to data portability. You have the right to be provided with a copy of the information we have on you in a structured, machine-readable and commonly used format.
The right to withdraw consent. You also have the right to withdraw your consent at any time where Paso Holdings Limited relied on your consent to process your personal information.
Please note that we may ask you to verify your identity before responding to such requests.
You have the right to complain to a Data Protection Authority about our collection and use of your Personal Data. For more information, please contact your local data protection authority in the European Economic Area (EEA).
We may employ third party companies and individuals to facilitate our Service ("Service Providers"), to provide the Service on our behalf, to perform Service-related services or to assist us in analysing how our Service is used.
These third parties have access to your Personal Data only to perform these tasks on our behalf and are obligated not to disclose or use it for any other purpose.
We may use third-party Service Providers to monitor and analyse the use of our Service.
Google Analytics is a web analytics service offered by Google that tracks and reports website traffic. Google uses the data collected to track and monitor the use of our Service. This data is shared with other Google services. Google may use the collected data to contextualise and personalise the ads of its own advertising network.
For more information on the privacy practices of Google, please visit the Google Privacy Terms web page: http://www.google.com/intl/en/policies/privacy/
Google AdWords remarketing service is provided by Google Inc.
You can opt-out of Google Analytics for Display Advertising and customise the Google Display Network ads by visiting the Google Ads Settings page: http://www.google.com/settings/ads
Google also recommends installing the Google Analytics Opt-out Browser Add-on - https://tools.google.com/dlpage/gaoptout - for your web browser. Google Analytics Optout Browser Add-on provides visitors with the ability to prevent their data from being collected and used by Google Analytics.
For more information on the privacy practices of Google, please visit the Google Privacy Terms web page: http://www.google.com/intl/en/policies/privacy/
Twitter remarketing service is provided by Twitter Inc.
You can opt-out from Twitter's interest-based ads by following their instructions: https://support.twitter.com/articles/20170405
Facebook remarketing service is provided by Facebook Inc.
You can learn more about interest-based advertising from Facebook by visiting this page: https://www.facebook.com/help/164968693837950
To opt-out from Facebook's interest-based ads follow these instructions from Facebook: https://www.facebook.com/help/568137493302217
Facebook adheres to the Self-Regulatory Principles for Online Behavioural Advertising established by the Digital Advertising Alliance. You can also opt-out from Facebook and other participating companies through the Digital Advertising Alliance in the USA http://www.aboutads.info/choices/, the Digital Advertising Alliance of Canada in Canada http://youradchoices.ca/ or the European Interactive Digital Advertising Alliance in Europe http://www.youronlinechoices.eu/, or opt-out using your mobile device settings.
For more information on the privacy practices of Facebook, please visit Facebook's Data Policy: https://www.facebook.com/privacy/explanation
Pinterest remarketing service is provided by Pinterest Inc.
You can opt-out from Pinterest's interest-based ads by enabling the "Do Not Track" functionality of your web browser or by following Pinterest instructions: http://help.pinterest.com/en/articles/personalization-and-data
We may provide paid products and/or services within the Service. In that case, we use third-party services for payment processing (e.g. payment processors).
The payment processors we work with are:
Sale or Acquisition of Assets.
We automatically track and collect the following categories of information when you visit our Site: (1) IP addresses; (2) types of operating systems used to access the Site; and (3) types of web browsers used to access the Site (collectively “Traffic Data”). Traffic Data is anonymous information that does not personally identify you but is helpful for marketing purposes or for improving your experience on the Site. We also use Google Analytics to track Site traffic (page hits) and view aggregate or anonymous user data.
IP Addresses: We use IP addresses to analyse trends, administer the Site, track traffic patterns, and gather demographic information for aggregate use, as well as in combination with your personally identifiable information for credit fraud protection and risk reduction.
Company may also keep track of Internet Protocol (IP) addresses to troubleshoot technical concerns and to maintain website safety and security. An IP address is a number that is used by computers on the network to identify your computer every time you log on to the Internet.
The personal information that we collect from you will be transferred to, and stored in, secured databases. By submitting your personal information to us, you agree to this transfer and storing.
Various security measures, such as encryption and passwords, are implemented by us in accordance with industry standards to protect the security of your personal information as well as sensitive information (such as credit card number) both online and offline.
Unfortunately, despite our security efforts, there is always a risk that third parties may unlawfully intercept transmissions. As a result, we cannot ensure the security of any information you transmit, and you transmit all information at your own risk.
Links to Other Sites.
For avoidance of doubt, if we provide links to social media platforms, such as Facebook or Twitter, and you choose to visit those websites through our links, please note that the personal information you post, transmit or otherwise make available on those websites may be viewed by the general public. Company does not control the user-posted content on its social media homepages and is not responsible for any third party use of your personal information that you have posted, transmitted or otherwise made available there.
Updating Personal Information; Termination of Account.
If a registered account holder’s information changes or a registered account holder wishes to terminate his or her account, Company will correct, update, or remove that user’s personal information from its database, upon receipt of notification from the registered account holder. Account holders may update information or terminate their account under their account settings or by emailing us at firstname.lastname@example.org.
A user who has submitted his or her information in order to join our mailing list may choose to unsubscribe from any future communications by clicking on the “unsubscribe” feature within the email communication.
Company reserves the right to cancel a customer or user’s account at any time, in its sole discretion.
For any reason and at any time, you may contact us at the following address: email@example.com.