PAM Limited Privacy Policy
PAM Limited (“PAM”) is committed to protecting and respecting your privacy. We want to tell you how we use and protect your personal information. This includes informing you of your rights regarding your personal information that we hold.
This Privacy Policy sets out how PAM may use, process and store your personal information. PAM may get that information from you or our partners, through contracts or other legal arrangements you have with us or our partners to deliver contractual/ legal obligations. In other cases, we will get that information from you with your permission and consent, or we may receive your personal information from third parties who you have given consent to pass this information on to us.
The Laws and Regulations
The laws that govern personal data in the IOM are:
The Data Protection Act 2002
REGULATION (EU) 2016/679 OF THE EUROPEAN PARLIAMENT AND OF THE COUNCIL of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data and repealing Directive 95/46/EC (General Data Protection Regulation) (“GDPR”).
The independent authority that upholds information rights in the public interest in the Isle of Man is the Isle of Man Information Commissioner. Further information can be found at https://www.inforights.im
Who is PAM Limited?
PAM’s registered address, company number and contact information:
PAM Limited
Cronkbane House
Oak Hill
Port Soderick
Braddan
Isle of Man
IM4 1AR
Company Registration Number: 135010C
Email: john@pamadmin.co.uk
Phone: +44 (0) 7624 470550
PAM’s website: www.pamadmin.co.uk
Information we may collect from you
PAM collects personal information about you whenever you use its services. Some of it is information you give us directly when, for example, you email. Other information is collected as you interact with us.
Information you give us
You may give us information about yourself with your consent, for example by filling in a form or sending us an e-mail. This information may be personal, financial, educational, or related to your employment history.
Cookies
PAM’s website uses cookies to analyse website traffic and optimize a visitor’s website experience. By accepting our use of cookies, your data will be aggregated with all other user data.
Why does PAM collect personal information?
PAM collects information for some or all of the following reasons:
- To provide services to you after you have engaged our services
- For legal or regulatory reasons, for example, if you have entered into a contract with us
- Things we do with your consent for example marketing purposes
What legal basis does PAM have for processing your information?
PAM may process your information because:
- We have a contract with you
- You have given us permission to do so
- We are required to provide services to you after you have engaged with us for our services
- To comply with the law
All of these reasons are reasons PAM may legally process the information we have about you.
Who might PAM share your information with?
PAM may need to share your personal information with external organisations that carry out a range of services on behalf of PAM. Should we do so, we carry out checks to ensure that the companies we work with will give your information the same level of care and protection as we do. Both we and they are obliged to handle your information in accordance with data protection law, and we are also required to put in place contractual measures reinforcing those obligations.
The main functions that are or may be carried out, fully or in part, by third parties are listed below:
- Management and execution of marketing campaigns
- Anti-fraud and -money laundering checks and ID verification
- Web hosting, online content services and data storage
- Data analytics and data cleansing
- Market research and collecting or analysing customer feedback
- IT services and support
- Audit-, Legal- & Compliance- related services
Where we store your personal data:
PAM stores and process your personal data in the Isle of Man. If we do transfer your personal data outside the EEA it will be because you have consented or because we have a legal reason to do so.
Some examples of reasons your data may be processed outside of the EEA include:
- Services fulfilment
- Verification processing
- Payment processing
- Technical support services
If your personal data cannot be processed within the EEA, we will:
- Comply with all other data protection principles
- Where possible, use a country that is on the EU Commissions’ list of countries that provide adequate protections for the rights and freedoms of data subjects
- Make sure we have assessed the adequacy of protections in all other cases.
Transmission and storage of your personal data
Unfortunately, the transmission of information via the internet is not completely secure. Although we use best practice to ensure your data is encrypted to the standard required by the GDPR to protect your personal data, we cannot guarantee the security of your data as it is transmitted and stored.
How long will we keep your personal information?
PAM will not retain your personal information for longer than required. We will keep your personal information:
- For as long as required by law
- Until we no longer have a valid reason for keeping it
- Until you request us to stop using it
- We may keep just enough of your personal information to ensure that we comply with your requests not to use your personal information or comply with your right to erasure. For example, we must keep your request to be erased even if it includes your personal data until such time as you are no longer our customer.
If you have questions about our Data Retention Policy, we can provide you with a copy. Please contact: john@pamadmin.co.uk
What if you chose not to give your personal information to PAM?
If the personal information is necessary to supply services to you under a contract between you and PAM and you do not give us your personal information, we will not enter into that contract or provide the services.
Your Rights
PAM will respect your legal rights to your data. Below are the rights that you have under law, and what PAM does to protect those rights:
Legal right – What PAM does to protect your rights
The right to be informed. PAM is publishing this Privacy Policy to keep you informed as regards what we do with your personal information. We strive to be transparent about how we use your data.
The right to access – You have the right to access your information.
Please email PAM’s Data Protection Officer john@pamadmin.co.uk if you wish to request a Subject Access Request which shows all information PAM holds about you. This information will be provided to you within 30 days of your request.
The right to rectification
If the information PAM holds about you is inaccurate or not complete, you have the right to ask PAM to rectify it. If that data has been passed to a third party with your consent or for legal reasons, then we will also ask them to rectify the data. Please contact our Data Protection Officer john@pamadmin.co.uk if you need us to rectify your information.
The right to erasure
This is sometimes called ‘the right to be forgotten’. If you want PAM to erase all your personal data and we do not have a legal reason to continue to process and hold it, please contact our Data Protection Officer on john@pamadmin.co.uk
The right to restrict processing
You have the right to ask PAM to restrict how we process your data. This means we are permitted to store the data but not process it further. If you want us to restrict processing of your data, please contact our Data Protection Officer on john@pamadmin.co.uk
The right to data portability
PAM must allow you to obtain and reuse your personal data for your own purposes across our services in a safe and secure way without this affecting the usability of your data. Please contact our Data Protection Officer on john@pamadmin.co.uk if you want information how to port your data elsewhere.
This right only applies to personal data that you have provided to us. The data must be held by us by consent or for the performance of a contract.
The right to object
You have the right to object to PAM processing your data even if it is based on PAM’s legitimate interests, the exercise of official authority, direct marketing (including data aggregation), and processing for the purposes of statistics. If you wish to object, please contact our Data Protection Officer on john@pamadmin.co.uk
The right to withdraw consent
If you have given us your consent to process your data but change your mind later, you have the right to withdraw your consent at any time and PAM must stop processing your data. If you want to withdraw your consent, please contact our Data Protection Officer on john@pamadmin.co.uk
The right to complain to a Supervisory Authority
You have the right to complain to the ICO. You can find their contact details here: https://www.inforights.im/
Links to Other Websites
From time to time, PAM’s website may contain links to and from other websites. If you follow a link to any of these websites, please note that these websites may have their own privacy policies and that PAM does not accept any responsibility or liability for any such policies. Please check these policies, where available, before you submit any personal data to these websites.
Changes to Our Privacy Policy
PAM may change this policy from time to time in the future. Any such changes will be posted here and, where appropriate, notified to you in writing. We advise you to check back frequently for any updates or changes.
This policy was last updated in January 2022.