Privacy Policy

Background

This Privacy Policy (‘policy’) applies to Walker Myrie Ltd T/A WM Promus hereinafter referred to as WM Promus (‘WM Promus’, ‘we’, ‘us’, ‘our’) and provides information on the collection, use and sharing (‘processing’ or ‘process’) of your personal data (‘personal information’). This includes personal information collected via our websites (‘Website’), our products or personal information collected from you directly, such as in person, via telephone or email, or indirectly through third parties in the course of our business.

WM Promus supports the right to privacy and understands the importance of protecting personal information and complying with applicable data protection laws. We have appointed a Data Protection Officer for assisting with questions regarding this policy and the processing of your personal information. For details on how to contact us, see the Contact Information section.

This policy outlines:

• What Data We Collect
• How We Process Your Data
• How We Collect Your Data
• How We Share Your Data
• How Long We Store Your Data
• Your Privacy Rights
• Children’s Privacy
• Contact Information

What Data We Collect

 

Personal Data

The personal information we process about you and how we collect it can vary depending on (a) the product(s) or service(s) you use; (b) how you use the product or service; (c) how you have interacted with WM Promus, and (d) the information that we have obtained from a customer or from a third party with permission to share such information with us.

WM Promus may collect personal information about you such as, for example: full name, email address, telephone number, company name, company location, position in company, department, billing information including credit card details where applicable, IP address and how you use our services. Refer to Cookie Technology section for details on what we collect using cookies and other technologies.

Usage Data

We may also collect information on how our Website is accessed and used (“Usage Data”). This Usage Data may include information such as your computer’s Internet Protocol address, browser type, browser version, the pages of our Website 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

We use cookies and similar tracking technologies to track the activity on our Website and hold certain information.

Cookies are files with small amount 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 Website.

 

Specific services that use Cookies:

Google Analytics:

We use Google Analytics to track the use of our Website, this data allows us understand (for example) the most popular pages of our website, which general geographic location our Website is users come from and how long users spend on our Website. We cannot use this data to personally identify you and we would not seek to do so.

Heatmaps:

We use “Heatmaps” to track where users click on our Website pages, this allows us to understand the most popular features of a given web page. We are unable to identify which users clicked where, only that a click was registered.

Remarketing:

We use cookies to track website users so that we are able to offer them online behavioural advertising via our advertising partners (Facebook and Google are two examples). We are unable to identify you personally from this information and we rely on our partners to serve the advertisements to you.

If you reside within the European Union, you may use this tool to help you opt out of these advertising services – http://www.youronlinechoices.com/

Please be aware that we share data with our partners as part of our cookie use. Be assured that we carefully select our service providers and would never knowingly use any service that would put your data at risk.

WM Promus may combine the personal information you provide with information that is not collected directly from you. Data not provided directly by you may be supplied by WM Promus vendors and/or partners. Refer to section below Personal Information Collected from Third Parties.

 

How We Process Your Data

WM Promus processes personal information to respond to your requests, to provide you WM Promus products and services, including information, support and delivery and access to online resources. Some of the specific processing activities include, for example:

• Account set up and administration;
• Internal research and development to customized content and enhance the user experience;
• Legal obligations;
• Regulatory requirements such as internal audits;
• Fulfilment of obligations outlined in any agreements;
• Gathering feedback and opinions about our provided services (i.e., surveys);
• Notification to users of changes to our services;
• Responding to your requests and comments;
• Event registration;
• Downloading of white papers; and
• Marketing communications.

All processing activities are based upon a relevant legal basis which may include fulfilment of a contract, to meet our legal obligations, for our legitimate interests or consent received directly from you.

 

How We Collect Your Data

We collect personal information through various means including for example via our Website, order forms and provision of products or services, third party service providers, customer support activities and exhibitions and events. Your employer, as a customer or partner of WM Promus, may provide your contact information as required to provide WM Promus products or services. The Website may also collect information about your visits to the Website as outlined above (See Usage Data section) without you actively submitting such information through cookie technology.

Cookie Technology: WM Promus will collect information about the use of our Website, either directly or through third party tracking providers. This may include information collected using cookies (small text files placed on your computer while visiting certain sites on the Internet used to identify your computer), IP addresses, your browser type, operating system version, language settings, the web page you were visiting immediately prior to visiting our Website, pages of our Website that you visited, the time spent on those pages, information you searched for on our Website, access times and dates and other statistics. Usage information may be linked to your account with WM Promus in order to assist WM Promus to provide services to you, including relevant marketing material. Your browser may allow you to set a “Do not track” preference. Unless otherwise stated, our sites do not honour “Do not track” requests. However, you may elect not to accept cookies by changing the designated settings on your web browser or opting out of the WM Promus cookies. Please note that if you do not accept certain cookies, you may not be able to use all functions and features of our Website.

Personal Information Collected from Third Parties: WM Promus may collect and receive personal information about you from companies that provide WM Promus products & services by way of co-branded or private labelled websites. Companies with which WM Promus partners to market and distribute its products and services also may supply us with personal information, such as your name, email address and mailing address information in order to help us fulfil orders and provide services. We may also collect your personal information from public sources or from data brokers. We may add this information to the information we have already collected from you via our Website or other sources.

How We Share Your Data

WM Promus may share personal information with its affiliates, business partners, vendors and agents working on our behalf. We do this, for example:

• to complete your requests, to provide you WM Promus products and services;
• to target advertising on our Website or to manage our advertising on other sites. This may include providing identified information to third party operated social networks or other web offerings (such as Twitter or LinkedIn). If you don’t want to receive this advertising, you can go to the relevant platform’s ad settings to opt out; and
• where you have purchased products and services using a third party or partner organization, we often need to exchange information with them as part of managing that relationship and your account. You should also review the partner company’s privacy policy because it may describe uses of your information that are different from ours.

We may be required to share personal information with a third party or body where such disclosure is required to satisfy applicable law, or other legal or regulatory requirement or to protect the rights or property of WM Promus or others. This can include in response to lawful requests from a competent authority or body and to meet national security or law enforcement requirements.

If all or any part of our business is re-organized or sold to another organization, we may need to provide your information to that organization. We may also be the recipient of personal information, where we are acquiring another organization or a part of their business. Where third parties are performing processing on our behalf, WM Promus will require these organizations to adopt adequate technical and organizational security measures to protect personal information and to ensure the processing of personal information is only performed as instructed by WM Promus and for no other purposes.

Personal information may be processed outside the country of your residence by our affiliates, partners or services providers. The transfer to other countries shall be in accordance with applicable data protection legislation which may include an adequacy decision or appropriate safeguards. Appropriate safeguards may include: WM Promus and third parties entering into the EU Model Clauses approved by the European Commission.

How We Protect Your Data

Securing your data, both online and offline, is a priority for us. We have implemented appropriate technical and organizational measures to protect your personal information and ensure a level of security appropriate to the risk.

All our employees are subject to confidentiality agreements and undergo annual training on the proper handling of personal information.

Links to other websites or locations may be provided for your convenience but does not signify our endorsement of such other websites or locations or their contents. When you click on such links, you will leave the WM Promus Website and go to another site. When this happens, a third party may collect personal information from you. Please be aware that the terms of this policy do not apply to such outside websites or content or to any collection of data after you click on a link to a third-party website or location. If you submit personal information to any of those sites, your information is governed by their privacy statements. We encourage you to carefully read the privacy notice of any website you visit.

How Long We Store Your Data

WM Promus will retain personal information for as long as needed to provide the relevant product or services or to fulfil the purposes for which the information was collected. WM Promus may also retain and use this information for a longer period as permitted or required by law, to comply with our legal, tax or regulatory obligations (e.g. audit and accounting requirements), handle disputes, to exercise or defend claims, and enforce our agreements. We ensure that personal information we dispose of, is de-identified or destroyed in a secure manner.

Your Privacy Rights

Your local applicable law may provide certain rights regarding the use of your personal information. You may request from WM Promus access to, correction of, updating of and/or deletion of your personal information, or object to our use of your personal information in certain circumstances, in line with applicable data protection law. Your rights may differ according to your place of residence.

Choice/Opting out of Marketing: WM Promus offers you the choice of receiving different types of communication and information related to our products and services. You may subscribe to e-newsletters or other publications; you may also elect to receive marketing communications and other special offers from us via email. If at any time you would like to change your communication preferences, we provide unsubscribe links and an opt-out mechanism in all our communications or contact us information.

Under GDPR and UK data protection law (and other applicable data protection regulations), you have rights we need to make you aware of. The rights available to you depend on your jurisdiction and our reason for processing your information:

• Your right of access
  You have the right to ask us for copies of your personal information. This right always applies. There are some exemptions, which means you may not always receive all the information we process.
• Your right to rectification
  You have the right to ask us to rectify information you think is inaccurate. You also have the right to ask us to complete information you think is incomplete. This right always applies.
• Your right to erasure
  You have the right to ask us to erase your personal information in certain circumstances.
• Your right to restriction of processing
  You have the right to ask us to restrict the processing of your information in certain circumstances.
• Your right to object to processing
  You have the right to object to processing if we are able to process your information because the process forms part of our public tasks or is in our legitimate interests.
• Your right to data portability
  This only applies to information you have given us. You have the right to ask that we transfer the information you gave us from one organization to another or give it to you. The right only applies if we are processing information based on your consent or are under, or in talks about entering into a contract and the processing is automated.

If we are processing your information for criminal law enforcement purposes, your rights are slightly different. Please see the relevant section of this notice.

Exercise Your Privacy Rights: To exercise your privacy rights, please contact the WM Promus Data Protection Officer (Refer to Contact Information below for further details).

Please direct any complaints or questions you may have with regard to our privacy practices to WM Promus Data Protection Officer (Refer to Contact Information below for further details).

You may also have the right to complain to the competent supervisory authority. Contact details of Data Protection Authorities in the European Economic Area can be found here, and in the UK here.

GDPR and UK Data Protection Act: Where the GDPR or UK Data Protection Act applies to EU and UK residents and their personal information, these individuals are afforded additional rights including:

• right to object/restrict processing in certain circumstances;
• right to request data portability which includes providing personal information to them in a “structured, commonly-used and machine-readable format” in certain circumstances;
• right to lodge a complaint with the applicable authority responsible for privacy protection.

Please direct any complaints or questions you may have with regard to our privacy practices to WM Promus Data Protection Office. (Refer to Contact Information below for further details).

Cookies: to understand how to manage these, refer to our Cookie Technology.

CCPA. The California Consumer Privacy Act (“CCPA”) requires businesses to disclose if they sell personal information. WM Promus does not sell personal information. WM Promus may share personal information with third parties or allow them to collect personal information from our Website, products or services in certain situations, such as where they are our authorized service providers or business partners and have a contract with us, where you consent to or direct us to disclose the personal data to those parties, if you use our Websites or services to interact with those third parties or we are otherwise permitted or required to do so by law. We may also share personal information with or allow third parties to collect personal information from our Websites and apps (for example, through the use of cookies or similar technologies) to help us deliver advertising to you and to make it more relevant to you. This activity may be considered a sale under the CCPA. See our Cookie Policy for information on how to manage these. For details on how to manage advertising, visit Digital Advertising Alliance Consumer Choice. For your mobile device, you can review your device settings: Android devices allow you to opt out using “Opt-out of Ads Personalization” and Apple devices allow apps to include interest-based advertising only if you opt in using the app’s pop-up notice.

WM Promus shall not sell, rent, disclose, disseminate, make available, transfer or otherwise communicate orally, in writing or by electronic or other means, any personal information to a third party for monetary or other valuable consideration as part of our business.

California residents may request and obtain from us once a year, free of charge, certain information about the personal information (if any) we disclosed to third parties for direct marketing purposes in the preceding calendar year. If applicable, this information would include a list of the categories of personal information that were shared and the names and addresses of all third parties with which we shared information in the preceding calendar year. For details on how to contact us with a request in relation to your privacy rights, Refer to Contact Information section of this policy.

 

Children’s Privacy

 

WM Promus encourages parents and guardians to take an active role in their children’s online activities. Our Services are not aimed at people under 18 and WM Promus does not knowingly collect personal information from children without appropriate parental or guardian consent. If you believe that we may have collected personal information from someone under the age of 18 (or the applicable age of consent) without proper consent, please submit your complaint in writing to the address found in the Contact Information section.

 

Contact Information

WM Promus Data Protection Office can be reached at DPO@wmpromus.com or by mail at:

WMP Data Protection Officer

WM Promus

Bromley Old Town Hall

Clockwise Offices

30 Tweedy Rd

Bromley

BR1 3FE

 

Changes to this Privacy Policy

WM Promus may update this policy from time to time. If we modify this policy, we will post the revised version on our website. You should review this page periodically for updates.

This policy was last updated in Feb, 2024.