PRIVACY POLICY

PS Holdings Ltd (trading as “Communisis Brand Deployment”) takes the privacy of information very seriously both as a Data Controller and a Data Processor.

When providing services to our clients such as sending marketing communications on their behalf, Communisis Brand Deployment processes personal information in the role of a data processor in accordance with the UK Data Protection Act 2018 and the GDPR (2016/679) and therefore does not own, control, or direct its use. If your personal data has been submitted to us by or on behalf of a Communisis Brand Deployment client and you wish to exercise any rights you may have under applicable data protection laws, please inquire with the applicable client directly.

The remainder of this notice will cover Communisis Brand Deployment’s role as a data controller, and is designed to ensure that you are fully informed about:
• Communisis Brand Deployment business details
• How and why, we collect and process your information,
• Who we share your information with and
• Your rights.

Throughout the notice, the words ‘we’ and ‘us’ refers to Communisis Brand Deployment, unless otherwise indicated. We may vary this notice from time to time. The current version will be published on our website.

PS Holdings Ltd Business Details

PS Holdings Ltd is a Paragon Company and is registered in England and Wales under company number 13606790

A Data Protection Officer has been appointed who can be contacted by email or postal address as stated below: [email protected]

Data Protection Officer
Paragon Customer Communications Ltd., Lower Ground Floor, Park House
16-18 Finsbury Circus , London, EC2M 7EB

Users aged 16 and under

If you are 16 or under you must have permission from a parent or guardian before you give us personal information. If we find that we have received information from you without the appropriate consent, we reserve the right to remove all personal data that you have supplied. You will be able to re-submit the information when you have the required permission.

Employment

When processing the personal data of our employees, workers and other third parties, Paragon are committed to adhering to the principles relating to processing as set out in the GDPR and other relevant regulations in the jurisdictions that we operate. For further information, please refer to our ‘Employee Data Protection Agreement’.

Legal basis for processing of your information

Your data will be processed under various legal bases based on the specific activity interests for the following purposes:

  • Sales of product and services to customers – contractual obligation
  • Maintaining our accounts and records – contractual obligation
  • To send out service messages – legitimate interests
  • Customer analytics and suppression – legitimate interests
  • Legal or Enforcement – legal obligation
  • For the purposes of security and prevention and detection of crime
  • Outward Marketing communications – legitimate interests
  • Requests for information, brochures etc. – your consent to allow us to fulfil your request
  • Research activity we might undertake is covered by our legitimate interests

 

Where legitimate interests are relied upon for processing, we will always balance the benefits to you against those of our business to make sure we are compliant with data protection legislation.

Retention

We keep the data you give us for differing lengths of time depending on what data it is and the reason for its collection.

  • Specific enquiry data – to fulfil the enquiry and for one year afterwards
  • Business/contact data – for the length of the contract plus two years

Who do we share your information with?

Your personal information will be stored on secure systems and data centres hosted in the UK and EEA either locally managed by Paragon or by approved managed service providers.

International Transfer

Your personal information will not be stored outside the UK or EEA but could be accessed or viewed by approved suppliers globally, as part of contracted service delivery obligations. Paragon will ensure there are correct safeguards in place, such as (as applicable):

  • Data Processing Agreements, including technical and organisational controls.
  • International Data Transfer Agreements (IDTAs)
  • Binding Corporate Rules for Processors
  • Standard Contractual Clauses (SCCs)

Your rights

Under current legislation and where Paragon is the Data Controller, you have many rights in respect of how we hold and use your data:

Right to be informed

This means that we must inform you how we are going to use your personal data. We do this through this privacy notice and by informing you how your data will be used each time we collect it.

Right to access
You may gain access to a copy of the PII (Personally Identifiable Information) data we hold about you by contacting the Data Protection Officer via post or email as specified.

Right to rectification
If you believe any of the information that we hold about you is incorrect, being misused, or want further information you may contact the Data Protection Officer via post or email as specified.

Restriction of processing
You can contact us and ask us to limit the processing we perform with your data. Please address requests of this nature formally to your contact at the respective Paragon business.

Right to be forgotten
You have the right to ask us to remove your data from all of our systems. If this is the case, where there is no reason not to (such as an outstanding contractual obligation) we will implement your request. In all cases, please address your formal requests to your contact at the respective Paragon business.

Automated decisions and profiling
Automated decision-making will not be used on any data supplied to us. Profiling we undertake on business contacts is based on the size of the company and the industry sector and the job titles of individuals. This may then be used within the marketing communication to make sure anything we send is relevant to you.

Right to data portability
As a data subject, you have the right to have the data that Paragon hold about you transmitted to another Data Controller where technically feasible. Please address requests of this nature formally with your contact at the respective Paragon business.

Right to object
If you wish for Paragon not to process your personal information, please address requests of this nature formally to your contact at the respective Paragon business.

Opting out of marketing communications

As a business contact, we will be holding, processing your data and contacting you under the Legitimate Interests provision of the General Data Protection Regulation (GDPR) and in line with Privacy and Electronic Communications Regulations (PECR), having undertaken an appropriate balancing assessment. However, if you no longer wish to hear from us, you can always easily opt out in the following ways:

  • Unsubscribe from specific communications, for example via email or SMS unsubscribe links,
  • Inform your contact at Communisis Brand Deployment who will pass your wishes on,
  • Contact us using [email protected] to opt out of any channel,
  • Write to us at Data Protection Office, Paragon Customer Communications Ltd, Park House, 16-18 Finsbury Circus, London, EC2M 7EB.

If you want to complain

You have the right to complain about the way we have used your data. If this is the case, please contact our Data Protection Officer using the address below. If you are not satisfied with our response, you can also contact the Information Commissioner’s Office on their website – www.ico.org.uk.

COOKIE POLICY

When you visit the Communisis Brand Deployment Website via the internet, in order to assist you with your web browsing experience, especially when revisiting our website, the site will sometimes place a small amount of information on your device such as your computer, laptop, tablet or mobile phone.

These include small files that are known as ‘Cookies’. They cannot be used to identify you personally. These pieces of information are used to improve your web browsing experience by, for example:

  • enabling a service to recognise your device, so that you do not have to give the same information several times during one task or browsing sessions.
  • recognising that you may already have given a username and password, so that you do not need to do it for every web page that you visit.
  • analysing anonymous data to help us understand how people interact with the website, so that we can make improvements and to assist us in developing the website in an informed way for our online users.

Our Cookies Banner Provider is One Trust.

Disabling/Enabling Cookies

You can Accept All or Manage Preferences for the use of Cookies from the Cookies Notice that appears, when you view the website. However, we would like you to have the best experience of our website and it is likely that disabling cookies will limit the functionality of the website.

In the Manage Preferences section, there is an explanation of each of the Cookies’ functions and you can choose to opt in or remain opted out of each Cookie Type listed, except for the Strictly Necessary Cookies. The other Cookies are Performance Cookies, Functional Cookies, Targeting Cookies and Social Media Cookies. Please see the Cookies Banner Notice for further information.

If you are concerned about the use of Cookies, in relation to “Spyware” you can use Anti-Spyware software to delete Cookies that may be considered invasive, rather than disabling the Cookies altogether.

Consent

By accepting Cookies with your browser settings and using the Communisis Brand Deployment website, you consent to the processing of data about you by Communisis Brand Deployment and Google in the manner and for the purposes set out in this Cookies Policy.

If Communisis Brand Deployment does obtain consent the first time that Cookies are set, Communisis does not have to repeat it every time the same person visits the website. However, it is good to keep in mind that devices may be used by different people. You can therefore, clear Cookies from your web browser settings prompting all websites to initiate their Cookie Notice consent with a view to actioning your Cookies Preferences and this can be done at any time.

How to Control and Delete Cookies

We will not use Cookies to collect personally identifiable information about you. However, if you wish to restrict or block the Cookies, which are set by our websites or indeed any other website, you can do this through your web browser settings. The ‘Help’ function within your browser, should tell you how to do this. Alternatively, you may wish to visit the following website: www.aboutcookies.org 

This website contains comprehensive information on how to manage Cookies across a wide variety of browsers. You will also find details on how to delete Cookies from your device, as well as more general information about Cookies.

A comprehensive set of guidelines for the use of Cookies can be accessed from the UK’s Information Commissioner’s Office (www.ico.org.uk).

Information on  how to clear Cookies are provided by the ICO here as well as further information about cookies can be found here too.

If you wish to view your Cookie Code, just click on a Cookie to open it. You will see a short string of text and numbers. The numbers are your identification card, which can only be seen by the server that provided the Cookie.

For information on how to do this within the web browser of your mobile phone, you will need to refer to your mobile handset manual or visit the help section of your mobile provider’s website.

To opt-out of third parties collecting any data regarding your interaction on our website, please refer to their websites for further information.

Withdrawing Consent for Cookies

Once consent has been obtained by Communisis Brand Deployment, users or subscribers may choose to withdraw that consent at any time. They can withdraw the consent by clearing the Cookies via the Internet Browser settings (Please see the above ICO link for the instructions on how to clear the Cookies).

However, if a user decides to disable the Cookies, this may detrimentally affect the general functionality of the Communisis Brand Deployment website experience.

COOKIES WE USE ON THIS WEBSITE

FIRST-PARTY COOKIES

JavaScript Detection

These Cookies are used to “remember” whether users’ terminals support the use of JavaScript. This facilitates an enhanced user experience, as JavaScript-enhanced features can be made available to users:

Name: panel_cookie
Purpose: This Cookie is used to show if you have allowed our site to use Cookies. It does not send any data about you to anyone.
Typical Content: Sequence of Numbers
Expires: 7 Days

THIRD-PARTY COOKIES

We use Third-Party Suppliers and their services on this website, which may also use Cookies as detailed below.

Web Analytics/Metrics

This category comprises of Cookies used to evaluate site performance, in terms of number of visits, unique visitors, drop-off rate for transactions and so on:

Cookie NameDefault expiration timeDescription
_ga2 yearsUsed to distinguish users.
_gid24 hoursUsed to distinguish users.
_gat1 minuteUsed to throttle request rate. If Google Analytics is deployed via Google Tag Manager, this cookie will be named _dc_gtm_<property- id>.

Considerations about Third-Party Cookies

Whilst Communisis Brand Deployment takes all reasonable precautions to make sure that other organisations, who it deals with have good security practices, Communisis Brand Deployment is not responsible for the privacy practices of other organisations, whose websites may be linked to its services or whose contact details it may provide on the website. Communisis Brand Deployment is not responsible for the Privacy Policies of social media or other Third-Party providers with whom it has pages or accounts.

Social Media Plugin

We use services, such as social sharing and these are offered by different companies. These companies may drop Cookies onto your computer, when you use them on our website or if you are already logged in to them.

These Social Media Cookies are set by a range of social media services that we have added to the site to enable you to share our content with your friends and networks. They can track your browser across other sites and building up a profile of your interests. This may impact the content and messages you see on the other websites that you visit. If you do not allow these Cookies, you may not be able to use or see these sharing tools.

Here is a list of places where you can find out more about specific services that we may use and their use of Cookies:

Facebook – Privacy policy
Google +1 – Privacy policy – Privacy & Terms – Google
Twitter – Privacy policy

If you would like to disable “Third-Party” Cookies generated by these providers, you can turn them off by going to the Third-Party’s website and getting them to generate a one-time “Decline All/No Thanks” Cookie that will stop any further Cookies being written to your machine.

If you would like to disable “Third-Party” Cookies generated by these providers, you can turn them off by going to the Third-Party’s website and getting them to generate a one-time “Decline All/No Thanks” Cookie that will stop any further Cookies being written to your machine.

Social Media Cookies:

www.communisis.comstatic.addtoany.com3rd Party

Cookies for Improving Service

We use Google Analytics to collect information about how people access and use this website using an Analytics Tool. We do this to make sure it is meeting its users’ needs and to understand how we could make the user experience of this website better. This is an analytics service provided by Google Inc.

Google Analytics stores information about what pages you visit, how long you are on the site, how you got here and what you click on. We do not collect or store your personal information (for example, your name or address), so this information cannot be used to identify who you are.

Read more about how Google uses cookies here. 

For detailed information about Cookies used by Google Analytics on this website, please view the above ‘Web Analytics/Metrics’ section.

Cookie List

A Cookie is a small piece of data (text file) that a website, when visited by a user and it asks your browser to store on your device, in order to remember information about you, such as your language preference or login information. Those Cookies are set by us and called First-Party Cookies. We also use Third-Party Cookies, which are from a domain different than the domain of the website that you are visiting, such as for our advertising and marketing efforts. More specifically, we use Cookies and other tracking technologies for the following purposes:

Strictly Necessary Cookies

These Cookies are necessary for the website to function and cannot be switched off in our systems. They are usually only set in response to actions made by you, which amount to a request for services, such as log-in, saving language preferences, privacy preferences, filling in forms, performance measurement and improvement, routing traffic between web servers, detection of the size of the screen, measuring page load times, improving user experience including relevance, audience measurement, detecting fraud and abuse, securing our product, personalisation essential to the user experience, first party measurement and analytics of site usage. You can set your browser to block or alert you to these Cookies, but some parts of the site will not function, if these are blocked. These Cookies do not store any personally identifiable information.

Strictly Necessary Cookies
Cookie Sub-GroupCookiesCookies Used
www.communisis.com

OptanonConsent

This Cookie is set by the Cookie Compliance Solution from One Trust. It stores information about the categories of Cookies the site uses and whether visitors have given or withdrawn consent for the use of each category. This enables site owners to prevent Cookies in each category from being set in the users’ browser, when consent is not given. The Cookie has a normal lifespan of one year, so that returning visitors to the site will have their preferences remembered. It contains no information that can identify the site visitor.

1st Party
www.communisis.com

OptanonAlertBoxClosed

This Cookie is set by websites using certain versions of the Cookie Law Compliance Solution from One Trust.  It is set after visitors have seen a Cookie information notice and in some cases, only when they actively close the notice down.  It enables the website not to show the message more than once to a user.  The Cookie has a one-year lifespan and contains no personal information.

1st Party
www.communisis.com

Eupubconsent

This Cookie is used by the IAB Europe Transparency & Consent Framework to store the user’s consent to the data collection purposes. The Cookie holds an encrypted consent string that vendors participating in the framework can read and determine the user’s consent.

1st Party
www.communisis.com

www.bugherd.com

Bugherd is a visual feedback tool. With the help of the Bugherd browser extension, you can collect website feedback and track bugs directly on the page.

3rd Party

 

Performance Cookies

These Cookies allow us to count visits and traffic sources, so that we can measure and improve the performance of our site. They help us to know which pages are the most and least popular and see how visitors move around the site. All information these Cookies collect is aggregated and therefore anonymous. If you do not allow these Cookies we will not know, when you have visited our site and will not be able to monitor its performance.

Performance Cookies
Cookie Sub-GroupCookiesCookies Used
www.communisis.com_hjIncludedInPageviewSample1st Party
communisis.com_hjAbsoluteSessionInProgress_ga_hjid_gid_hjFirstSeen_gat_UA-_hjTLDTest1st Party

 

Functional Cookies

These Cookies enable the website to provide enhanced functionality and personalisation. They may be set by us or by third-party providers, whose services we have added to our pages. If you do not allow these cookies, then some or all of these services may not function properly.

Functional Cookies
Cookie Sub-GroupCookiesCookies Used
vimeo.comvuid 
cdn.cookielaw.orgcdn.cookielaw.org 

Targeting Cookies

These Cookies may be set through our site by our advertising partners. They may be used by those companies to build a profile of your interests and show you relevant adverts on other sites. They do not store directly personal information, but are based on uniquely identifying your browser and internet device. If you do not allow these Cookies, you will experience less targeted advertising.

Targeting Cookies
Cookie Sub-GroupCookiesCookies Used
linkedin.comlidc, lang, bcookie, UserMatchHistory3rd Party
ads.linkedin.comlang3rd Party
syndication.twitter.comlang3rd Party
twitter.compersonalization_id3rd Party
pi.pardot.compardot3rd Party
www.linkedin.combscookie3rd Party
google.com_GRECAPTCHA3rd Party

Legal Obligations

The statutory and/or regulatory directives and legislation on which this Policy is based upon is the current UK Data Protection legislation.

This is all applicable UK Data Protection and Privacy legislation in force from time-to-time, including the General Data Protection Regulation (EU) 2016/679, the UK Data Protection Act 2018 and the Privacy and Electronic Communications (EU Directive) Regulations 2003 (as amended) (PECR) and any superseding legislation and all other applicable laws, regulations, statutory instruments and/or any codes, practice or guidelines issued by the relevant Data Protection or Supervisory Authority in force from time to time and applicable to a Party, relating to the processing of personal data and/or governing individual’s rights to privacy.

From 28th June 2021, the UK has been granted an adequacy decision by the EU, which covers data transfers between the UK and the EU and this adequacy decision is due to be reviewed in four years’ time on 28th June 2025 with a view to this safeguard remaining in place for UK/EU Data Transfers.

Communisis Brand Deployment complies with its obligations set up in Privacy and Electronic Communications Regulations (PECR) related to the use of Cookies by:

  • Informing people that its Cookies are there;
  • Explaining what the Cookies are doing and why; and
  • Obtaining the person’s consent to store a Cookie on their device.

Our Cookies Policy is regularly reviewed.

Last Update: January 2024.