Privacy Policy - Pimlico Trading

1. INTRODUCTION

Pimlico Trading ("we," "our," or "us") respects your privacy and is committed to protecting your personal data. This privacy policy will inform you about how we look after your personal data when you visit our website (https://pimlicotrading.com) and tell you about your privacy rights and how the law protects you.

This privacy policy applies to all information collected through our website, related services, sales, marketing, or events (collectively, the "Services").

We encourage you to read this privacy policy carefully to understand our policies and practices regarding your personal information. By accessing or using our Services, you agree to this privacy policy.

2. IMPORTANT INFORMATION AND WHO WE ARE

2.1 Data Controller

Pimlico Trading, a US-based company, is responsible for your personal data. If you have any questions about this privacy policy, including any requests to exercise your legal rights, please contact us using the details set out in the "Contact Us" section below.

2.2 Changes to the Privacy Policy

We may update this privacy policy from time to time. If we make material changes, we will notify you by posting the new privacy policy on this page and updating the "Last Updated" date at the top.

2.3 Third-Party Links

Our website may include links to third-party websites, plug-ins, and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. We encourage you to read the privacy policy of every website you visit.

3. THE DATA WE COLLECT ABOUT YOU

We collect several types of information from and about users of our Services, including:

3.1 Personal Data

Personal data, or personal information, means any information about an individual from which that person can be identified. This includes:

Identity Data: Name, username or similar identifier, title, date of birth.
Contact Data: Billing address, delivery address, email address, telephone numbers.
Financial Data: Payment card details (we do not store complete payment card information).
Transaction Data: Details about payments to and from you and other details of products and services you have purchased from us.
Technical Data: Internet protocol (IP) address, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, and other technology on the devices you use to access our Services.
Profile Data: Your username and password, purchases or orders made by you, your interests, preferences, feedback, and survey responses.
Usage Data: Information about how you use our website and Services.
Marketing Data: Your preferences in receiving marketing from us and our third parties.

3.2 Aggregated Data

We also collect, use, and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data could be derived from your personal data but is not considered personal data in law as this data will not directly or indirectly reveal your identity.

3.3 Special Categories of Personal Data

We do not collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health, and genetic and biometric data). Nor do we collect any information about criminal convictions and offenses.

4. HOW IS YOUR PERSONAL DATA COLLECTED?

We use different methods to collect data from and about you including through:

4.1 Direct Interactions

You may give us your Identity, Contact, and Financial Data by filling in forms or by corresponding with us by post, phone, email, or otherwise. This includes personal data you provide when you:

Apply for a wholesale account;
Create an account on our website;
Subscribe to our publications;
Request marketing to be sent to you;
Enter a competition, promotion, or survey; or
Give us feedback or contact us.

4.2 Automated Technologies or Interactions

As you interact with our website, we may automatically collect Technical Data about your equipment, browsing actions, and patterns. We collect this personal data by using cookies, server logs, and other similar technologies. See our Cookie Policy section for further details.

4.3 Third Parties or Publicly Available Sources

We may receive personal data about you from various third parties and public sources such as analytics providers, advertising networks, search information providers, as well as identity and contact data from publicly available sources.

5. HOW WE USE YOUR PERSONAL DATA

5.1 Purposes for Which We Will Use Your Personal Data

We have set out below, in a table format, a description of all the ways we plan to use your personal data:

Purpose/Activity	Type of Data
To register you as a new customer	Identity, Contact
To process and deliver your order	Identity, Contact, Financial, Transaction
To manage our relationship with you	Identity, Contact, Profile
To administer and protect our business and website	Identity, Contact, Technical
To deliver relevant website content and advertisements	Identity, Contact, Profile, Usage, Marketing, Technical
To use data analytics to improve our website	Technical, Usage
To make suggestions and recommendations to you	Identity, Contact, Technical, Usage, Profile

5.2 Marketing

We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising. You will receive marketing communications from us if you have requested information from us or purchased goods or services from us and you have not opted out of receiving that marketing.

5.3 Opting Out

You can ask us to stop sending you marketing messages at any time by following the opt-out links on any marketing message sent to you or by contacting us at any time. Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of a product/service purchase, product/service experience, or other transactions.

5.4 Cookies

You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of this website may become inaccessible or not function properly. For more information about the cookies we use, please see our Cookie Policy section.

5.5 Change of Purpose

We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.

6. COOKIE POLICY

6.1 What Are Cookies

Cookies are small text files that are placed on your computer or mobile device when you browse websites. Our website uses cookies to distinguish you from other users of our website. This helps us to provide you with a good experience when you browse our website and also allows us to improve our site.

6.2 Cookies We Use

We use the following types of cookies:

Strictly Necessary Cookies: Required for the operation of our website. They include, for example, cookies that enable you to log into secure areas of our website or use a shopping cart.
Analytical/Performance Cookies: Allow us to recognize and count the number of visitors and to see how visitors move around our website when they are using it. This helps us to improve the way our website works.
Functionality Cookies: Used to recognize you when you return to our website. This enables us to personalize our content for you, greet you by name, and remember your preferences.
Targeting Cookies: Record your visit to our website, the pages you have visited, and the links you have followed. We will use this information to make our website and the advertising displayed on it more relevant to your interests.

6.3 Managing Cookies

You can block cookies by activating the setting on your browser that allows you to refuse the setting of all or some cookies. However, if you use your browser settings to block all cookies (including essential cookies), you may not be able to access all or parts of our site.

7. DISCLOSURES OF YOUR PERSONAL DATA

We may share your personal data with the parties set out below for the purposes outlined in the table above:

Service providers acting as processors who provide IT and system administration services;
Professional advisers including lawyers, bankers, auditors, and insurers;
Regulators and other authorities who require reporting of processing activities in certain circumstances;
Third parties to whom we may choose to sell, transfer, or merge parts of our business or our assets; and
Third-party marketing companies (only with your consent).

We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.

8. INTERNATIONAL TRANSFERS

As a US-based company, we may transfer your personal data to countries outside the United States to our service providers or business partners. When we transfer personal data internationally, we take reasonable steps to ensure your data is protected, which may include:

Using data hosting services in the United States;
Entering into data processing agreements and standard contractual clauses with service providers; and
Working with service providers who adhere to relevant data protection frameworks.

Please contact us if you want further information on how we protect your personal data when it is transferred internationally.

9. DATA SECURITY

We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used, or accessed in an unauthorized way, altered, or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors, and other third parties who have a business need to know. They will only process your personal data on our instructions, and they are subject to a duty of confidentiality.

We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

10. DATA RETENTION

We will only retain your personal data for as long as reasonably necessary to fulfill the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting, or reporting requirements.

In some circumstances, we will anonymize your personal data (so that it can no longer be associated with you) for research or statistical purposes, in which case we may use this information indefinitely without further notice to you.

Specific retention periods:

For transaction data: 7 years from the date of the transaction
For marketing data: 2 years from your last interaction with us
For customer account data: As long as your account is active plus 2 years
For technical and usage data: 13 months

11. YOUR LEGAL RIGHTS

Depending on your location, you may have rights under applicable data protection laws in relation to your personal data. For US residents, these rights vary by state, but may include the right to:

Request access to your personal data.
Request correction of your personal data.
Request deletion of your personal data.
Opt-out of certain data sharing practices.
Withdraw consent, where applicable.

11.1 No Fee Usually Required

You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive, or excessive. Alternatively, we could refuse to comply with your request in these circumstances.

11.2 What We May Need From You

We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it.

11.3 Time Limit to Respond

We try to respond to all legitimate requests within one month. Occasionally it could take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.

12. STATE-SPECIFIC PRIVACY RIGHTS

12.1 California Privacy Rights

If you are a California resident, you have specific rights regarding your personal information under the California Consumer Privacy Act (CCPA) and the California Privacy Rights Act (CPRA):

12.1.1 Right to Know

You have the right to request that we disclose certain information to you about our collection and use of your personal information over the past 12 months.

12.1.2 Right to Delete

You have the right to request that we delete any of your personal information that we collected from you and retained, subject to certain exceptions.

12.1.3 Right to Opt-Out of Sales

You have the right to opt-out of the sale of your personal information to third parties. Note that we do not sell personal information in the traditional sense. However, under the CCPA's broad definitions, some data sharing for advertising purposes may be considered a "sale."

12.1.4 Right to Non-Discrimination

We will not discriminate against you for exercising any of your CCPA rights.

To exercise your rights under the CCPA, please submit a verifiable consumer request by contacting us using the information in the "Contact Us" section.

12.2 Virginia, Colorado, Connecticut, Utah, and Other States

Residents of states with comprehensive privacy laws (such as Virginia's CDPA, Colorado's CPA, Connecticut's CTDPA, and Utah's UCPA) may have similar rights to access, delete, correct, and opt out of the sale of personal information. We honor these rights for all US residents regardless of state of residence.

To exercise any of these rights, please contact us using the information provided in the "Contact Us" section.

13. CHILDREN'S PRIVACY

Our Services are not intended for children under 16 years of age. No one under age 16 may provide any personal data through the Services. We do not knowingly collect personal data from children under 16. If you are under 16, do not use or provide any information on our Services. If we learn we have collected or received personal data from a child under 16 without verification of parental consent, we will delete that information. If you believe we might have any information from or about a child under 16, please contact us.

14. DATA BREACH PROCEDURES

In the case of a personal data breach, we will notify you and any applicable regulator when we are legally required to do so. The notification will be made without undue delay and, where feasible, not later than 72 hours after having become aware of it. The notification will include the likely consequences of the breach and the measures taken or proposed to be taken to address the breach.

15. CONTACT US

If you have any questions about this privacy policy or our privacy practices, please contact us at:

info@pimlicotrading.com

While we are committed to resolving any concerns you may have, you also have the right to file a complaint with the appropriate regulatory authority for data protection issues in your jurisdiction, such as your state Attorney General's office or the Federal Trade Commission (www.ftc.gov) in the United States.