Privacy Policy

1. Who we are

Palmer-Hunter Ltd is a company registered in England and Wales.

• Company name: Palmer-Hunter Ltd
• Company number: 16983601
• ICO registration reference: ZC177043
• Registered office: Team Entrepreneurship Hub, Room 2X102, Bristol Business School, Frenchay Campus, Bristol, BS16 1QY, United Kingdom

Palmer-Hunter is the data controller for personal information where we determine why and how that information is processed. In some customer, education, research or organisational deployments, Palmer-Hunter may process personal information on behalf of another organisation acting as the data controller.

2. Information we may collect

The information we process depends on how you interact with Palmer-Hunter and which services you use. It may include:

• Identity and contact information, such as your name, email address, organisation and role.
• Account information, including user identifiers, account roles, permissions and organisation membership.
• Authentication and security information, including session, login, two-factor authentication, trusted-device and security activity records.
• Commercial and procurement information, including quotations, deployment configurations, subscriptions, invoices, purchase orders, payment status and transaction references.
• Support and correspondence information when you contact Palmer-Hunter or communicate with us about our products, services or platform.
• Questionnaire, research or project information where you participate in a Palmer-Hunter-enabled questionnaire, study or deployment.
• Operational information associated with devices, deployments, sites, classrooms, users or organisations where that information is linked or reasonably capable of being linked to an identifiable individual.

3. Environmental and sensor data

Palmer-Hunter systems collect environmental and operational data, including measurements produced by sensing devices and information associated with environmental monitoring deployments.

Environmental measurements are not necessarily personal data. UK data protection law applies where information identifies, or can reasonably be linked to, an identifiable individual. Where deployment information is associated with a user, customer, researcher, learner, site contact or other identifiable person, we handle the relevant personal information in accordance with this Privacy Policy.

4. How we use personal information

We may use personal information to:

• create and administer user and organisation accounts;
• authenticate users and protect accounts and systems;
• provide and operate the PML Platform and related services;
• configure, support and manage sensing devices, deployments and environmental intelligence services;
• manage quotations, procurement, subscriptions, billing, payment status and customer relationships;
• provide technical and customer support;
• administer education, research or questionnaire functionality where applicable;
• maintain security, investigate incidents and prevent misuse, fraud or unauthorised access;
• maintain appropriate operational, compliance and audit records;
• meet legal and regulatory obligations; and
• improve and develop Palmer-Hunter products and services where this can be done lawfully and appropriately.

5. Lawful bases for processing

Depending on the circumstances, Palmer-Hunter may rely on one or more lawful bases for processing personal information.

Contract

We may process information where this is necessary to provide services, administer an account, fulfil an order or perform a contract with you or your organisation.

Legitimate interests

We may process information where necessary for legitimate business purposes, including operating and securing our systems, supporting customers, maintaining records, improving services and protecting Palmer-Hunter, its customers and users, provided those interests are not overridden by your rights and interests.

Legal obligations

We may process information where necessary to comply with legal, regulatory, accounting, taxation or other applicable obligations.

Consent

Where processing relies on your consent, you may withdraw that consent at any time. Withdrawal does not affect the lawfulness of processing carried out before consent was withdrawn.

6. Education and research use

Palmer-Hunter technologies may be used by universities, schools, research organisations and other institutions. In these situations, the relevant institution may determine the purpose and means of processing and may therefore act as the data controller, with Palmer-Hunter acting as a processor or service provider for relevant information.

Customer and research organisations are responsible for ensuring that they have an appropriate lawful basis, authority, consent or other permission where required for information they collect or submit through Palmer-Hunter services.

7. Payments and commercial information

Palmer-Hunter may process commercial information such as quotation numbers, invoice information, purchase-order details, payment provider, payment status and transaction references in order to manage customer procurement and billing.

Where payment is processed through an external payment provider such as Worldpay, that provider may process payment information in accordance with its own privacy and security obligations. Palmer-Hunter systems may receive and retain information about the status and reference of a payment where required to manage the customer relationship, entitlement or transaction.

8. Sharing personal information

Palmer-Hunter does not sell personal information. We may share information where necessary with:

• technology, hosting, communications and infrastructure providers that support our services;
• payment, banking, accounting or commercial service providers involved in processing or administering transactions;
• customer organisations where information relates to their authorised users, projects or deployments;
• professional advisers, auditors or insurers where reasonably necessary; and
• regulators, law-enforcement bodies, courts or other authorities where disclosure is required or permitted by law.

Service providers that process personal information on our behalf are expected to protect that information and use it only for the relevant authorised purpose.

9. International transfers

Where personal information is transferred outside the United Kingdom, Palmer-Hunter will take appropriate steps required by applicable data protection law to protect that information. This may include relying on adequacy regulations or appropriate contractual safeguards where required.

10. Data retention

Palmer-Hunter retains personal information only for as long as is reasonably necessary for the purpose for which it was collected, including providing services, maintaining appropriate security and operational records, fulfilling contractual obligations, resolving disputes and meeting legal, regulatory, accounting or compliance requirements.

Different categories of information may therefore be retained for different periods. Information may also be securely deleted, anonymised or aggregated when it is no longer required in identifiable form.

11. Security

Palmer-Hunter uses technical and organisational measures intended to protect information against unauthorised access, alteration, disclosure, loss or misuse. These measures include access controls, authenticated platform sessions, security monitoring and protected communications appropriate to the systems and information involved.

No system can guarantee absolute security. Users are responsible for protecting their own account credentials and for notifying Palmer-Hunter if they believe an account or device has been compromised.

12. Your data protection rights

Subject to applicable law and any relevant exemptions, you may have rights including:

• the right to access your personal information;
• the right to correct inaccurate information;
• the right to request deletion of information;
• the right to restrict certain processing;
• the right to object to certain processing;
• the right to receive or transfer certain information in a portable format where applicable; and
• the right to withdraw consent where processing is based on consent.

Some rights depend on the circumstances and legal basis for processing. Where Palmer-Hunter processes information solely on behalf of another organisation, we may refer your request to that organisation as the relevant data controller.

13. Contacting us about privacy

To ask a privacy question or exercise a data protection right, contact Palmer-Hunter Ltd at support@palmer-hunter.co.uk.

Please provide enough information for us to understand your request. We may need to verify your identity before acting on certain requests.

14. Complaints

If you have concerns about the way Palmer-Hunter handles your personal information, please contact us so that we can investigate the matter.

You also have the right to raise a complaint with the UK Information Commissioner's Office. Palmer-Hunter Ltd is registered with the Information Commissioner's Office under registration reference ZC177043.

15. Changes to this Privacy Policy

Palmer-Hunter may update this Privacy Policy as our services, technology, business operations or legal requirements change. The current version will be published on this website with its latest revision date.