Welcome to Phonesmart Limited’s (“plunc™”, "we", "us", "our") privacy notice. plunc™ has always had a straight forward approach to processing and storing customer data. We are commited to ensuring that your privacy is protected and we endeavour to try to collect the minimum we need to complete your recycling transaction, whilst providing you best in class customer service. This notice will inform you as to how we do this and what rights you have.
We may change this policy from time to time by updating this page. You should check this page from time to time to ensure that you are happy with any changes. This policy is effective from 25th February 2020 and is subject to be changed.
The information that we collect and use about you is regulated by the General Data Protection Regulation which applies across the European Union, including in the United Kingdom.
If you have any questions about this privacy notice, including any requests to exercise your legal rights, please contact us here: firstname.lastname@example.org.
When you are using our plunc™ website and services, the data controller is Phonesmart Limited, a company registered in Scotland under company registration number 351010 and whose registered office address is at 505 Stobcross St, Glasgow G3 8GJ.
What personal information we collect
When you recycle with us we collect your name, contact details, business details (if applicable) and your payment details. These details are used to fulfil the recycling request. We do not use your data further for marketing purposes. We do keep this data for accounting and fraud prevention purposes in a secure manner.
We also store communications we have had with you and your recycling history so that we can provide a more tailored service using automated and computerised technologies (e.g. saved checkout, recommended product).
How we process your data
When we use your personal information we are required to have a legal basis for doing so. Here are the different categories these bases fall under:
• Consent – where you have given us clear consent for us to process your personal information for a specific purpose
• Performance of a Contract – processing your data in order to fulfil a contract i.e. completion of a recycling submission
• Legal Obligation – where our use of your personal information is necessary for us to comply with legal or regulatory obligations
• Legitimate Interest – where our use of your personal information is necessary for our legitimate interests or the legitimate interests of a third party
• The right to be informed - Anyone processing your data must make it clear what data they are processing, why they are processing it and who else the data might be passed on to.
• The right to access - You can ask us to provide the data that we have relating to you and your transactions with us.
• The right to be forgotten - You can ask us to delete any information that we hold on you that we are no longer required to keep it legitimately or where we needed your consent to use it and you have withdrawn that consent (opt-out).
• The right to rectification - You can ask us to update our records. Please contact us via email to update any of your information
• The right to data portability - You have the right to ask for any data supplied to be in a commonly used format.
• The right to restrict our processing -You can ask us to halt processing of your data if there is an ongoing legal dispute, for example.
• The right to object - You can object to any further processing of your data if the reason for processing doesn’t fall in line with the original purpose it was collected.
• Rights in relation to automated decision making and profiling - You have the right to not be subject to decision making based on automated processing
You can exercise any of these rights by contacting us below
The Pentagon Centre
Glasgow, G3 8AZ
How the law protects you
Your privacy is protected by law. Data protection law says that we are allowed to use personal information only if we have a proper reason to do so. This includes sharing it outside of plunc™. The law says we must have one or more of these reasons:
- To fulfil a contract we have with you, or
- When it is our legal duty, or
- When it is in our legitimate interest
A legitimate interest is when we have a business or commercial reason to use your information. But even then, it must not unfairly go against what is right and best for you. If we rely on our legitimate interest, we will tell you what that is.
Below is a list of all the ways that we may use your personal information, and which reasons we rely on to do so. This is also where we tell you what our legitimate interests are:
|What we use your personal information for||Our Reasons||Our legitimate interests|
Groups of personal information
We may use many different kinds of personal information, and then group them together like this:
|Type of personal information||Description|
|Banking||Your bank account details for payment|
|Communications||What we learn about you from letters, emails and verbal conversations between us|
|Contact||Your address, email and phone number to fulfil orders|
|Contractual||Details about the products or services we provide you|
|Open Data and Public Records||Details about you that are in public records, such as information held in Companies House, and information about you that is openly available on the internet|
|Technical||Details on the devices and technology you use|
|Transactional||Details about payments to and from your accounts with us|
|Usage Data||Other data about how your use our services|
Where we collect personal information from
We may collect personal information about you from these sources:
|Data you give us:||Data from third parties:|
Who we share your personal information with
plunc™ will not pass on your personal data to third parties unless: it is a requirement of the service or product you have with us, where this will be detailed within the contract. Or if it is a prerequisite to the service or product you intend to have with us, you will be notified beforehand.
How long we hold your personal information for
The length of time we retain your information is dependent on what we are holding and why we are holding it. We will not keep your information for longer that is necessary for our business or legal requirements.
plunc™ may process personal data for up to 7 years if you are a prospective customer and for the length of your contract if you become an active customer. This is in keeping with our legitimate interests and contractual obligations.
We may also store personal data for up to 7 years for any of the following reasons:
- Respond to any questions or complaints
- To show that we treated you fairly
- To maintain records to comply with legal and regulatory rules that apply to us
- In keeping with our legitimate interests and contractual obligations
What are cookies? They're small files that websites use to remember information about their customers. At plunc™, we use them to remember what you are recycling (like a shopping basket), to remember your language selection and to remember your decision to opt-in or opt-out of non-essential cookies.You can disable cookies on your browser settings but some functionality on plunc™ will not work.
We use analytics providers such as Google Analytics to find out more about where our customers came from and how they use our website. It helps us get better and better at what we do.
If things go wrong and you wish to make a complaint or if you are not happy with the service you have received you can raise a complaint through any of the following channels:
By Phone: 0141 249 0668
By Email: email@example.com
The Pentagon Centre
Glasgow, G3 8AZ
In the event that you wish to make a complaint about how your personal data is being processed by plunc™ (or third parties as described above), or how your complaint has been handled, you have the right to lodge a complaint directly with the supervisory authority and plunc™ data protection representatives.