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PRIVACY POLICY
Last updated March 01, 2023

 

 

This privacy notice for Punchhole solutions limited (doing business as Punchhole
Solutions) ('Punchhole Solutions', 'we', 'us', or 'our'), describes how and why we
might collect, store, use, and/or share ('process') your information when you use our
services ('Services'), such as when you:

to this privacy notice

  • Engage with us in other related ways, including any sales, marketing, or

events

 

Questions or concerns? Reading this privacy notice will help you understand your
privacy rights and choices. If you do not agree with our policies and practices, please
do not use our Services. If you still have any questions or concerns, please contact
us at info@punchhole.co.

 

SUMMARY OF KEY POINTS


This summary provides key points from our privacy notice, but you can find
out more details about any of these topics by clicking the link following each
key point or by using our table of contents below to find the section you are
looking for. You can also click here to go directly to our table of contents.


What personal information do we process? When you visit, use, or navigate our
Services, we may process personal information depending on how you interact with
Punchhole Solutions and the Services, the choices you make, and the products and
features you use. Click here to learn more.

 

Do we process any sensitive personal information? We do not process sensitive
personal information.

 

Do we receive any information from third parties? We do not receive any
information from third parties.

 

How do we process your information? We process your information to provide,
improve, and administer our Services, communicate with you, for security and fraud
prevention, and to comply with law. We may also process your information for other
purposes with your consent. We process your information only when we have a valid
legal reason to do so. Click here to learn more.

 

In what situations and with which types of parties do we share personal
information?
We may share information in specific situations and with specific
categories of third parties. Click here to learn more.


How do we keep your information safe? We have organisational and technical
processes and procedures in place to protect your personal information. However, no
electronic transmission over the internet or information storage technology can be
guaranteed to be 100% secure, so we cannot promise or guarantee that hackers,
cybercriminals, or other unauthorised third parties will not be able to defeat our
security and improperly collect, access, steal, or modify your information.
Click here to learn more.



What are your rights? Depending on where you are located geographically, the
applicable privacy law may mean you have certain rights regarding your personal
information. Click here to learn more.


How do you exercise your rights? The easiest way to exercise your rights is by
filling out our data subject request form available here:
http://www.punchhole.co/datarequest, or by contacting us. We will consider and act
upon any request in accordance with applicable data protection laws.

 

Want to learn more about what Punchhole Solutions does with any information we
collect? Click here to review the notice in full.

 

TABLE OF CONTENTS
1. WHAT INFORMATION DO WE COLLECT?
2. HOW DO WE PROCESS YOUR INFORMATION?
3. WHAT LEGAL BASES DO WE RELY ON TO PROCESS YOUR PERSONAL
INFORMATION?
4. WHEN AND WITH WHOM DO WE SHARE YOUR PERSONAL INFORMATION?
5. IS YOUR INFORMATION TRANSFERRED INTERNATIONALLY?
6. HOW LONG DO WE KEEP YOUR INFORMATION?
7. HOW DO WE KEEP YOUR INFORMATION SAFE?
8. DO WE COLLECT INFORMATION FROM MINORS?
9. WHAT ARE YOUR PRIVACY RIGHTS?
10. CONTROLS FOR DO-NOT-TRACK FEATURES
11. DO CALIFORNIA RESIDENTS HAVE SPECIFIC PRIVACY RIGHTS?
12. DO WE MAKE UPDATES TO THIS NOTICE?
13. HOW CAN YOU CONTACT US ABOUT THIS NOTICE?
14. HOW CAN YOU REVIEW, UPDATE, OR DELETE THE DATA WE COLLECT
FROM YOU?

 

 

1. WHAT INFORMATION DO WE COLLECT?


Personal information you disclose to us

 

In Short: We collect personal information that you provide to us.

 

We collect personal information that you voluntarily provide to us when you express
an interest in obtaining information about us or our products and Services, when you
participate in activities on the Services, or otherwise when you contact us.
 

Personal Information Provided by You. The personal information that we collect
depends on the context of your interactions with us and the Services, the choices you
make, and the products and features you use. The personal information we collect
may include the following:

  • names

  • phone numbers

  • email addresses

  • contact preferences

  • contact or authentication data

 

Sensitive Information. We do not process sensitive information.

 

All personal information that you provide to us must be true, complete, and accurate,
and you must notify us of any changes to such personal information.

 

Information automatically collected


In Short: Some information — such as your Internet Protocol (IP) address and/or
browser and device characteristics — is collected automatically when you visit our
Services.

 

We automatically collect certain information when you visit, use, or navigate the
Services. This information does not reveal your specific identity (like your name or
contact information) but may include device and usage information, such as your IP
address, browser and device characteristics, operating system, language
preferences, referring URLs, device name, country, location, information about how
and when you use our Services, and other technical information. This information is
primarily needed to maintain the security and operation of our Services, and for our
internal analytics and reporting purposes.


The information we collect includes:

 

  • Log and Usage Data. Log and usage data is service-related, diagnostic,

usage, and performance information our servers automatically collect when
you access or use our Services and which we record in log files. Depending on
how you interact with us, this log data may include your IP address, device
information, browser type, and settings and information about your activity in
the Services (such as the date/time stamps associated with your usage, pages
and files viewed, searches, and other actions you take such as which features
you use), device event information (such as system activity, error reports
(sometimes called 'crash dumps'), and hardware settings).

 

  • Location Data. We collect location data such as information about your

device's location, which can be either precise or imprecise. How much
information we collect depends on the type and settings of the device you use
to access the Services. For example, we may use GPS and other technologies
to collect geolocation data that tells us your current location (based on your IP
address). You can opt out of allowing us to collect this information either by
refusing access to the information or by disabling your Location setting on your
device. However, if you choose to opt out, you may not be able to use certain
aspects of the Services.

 

2. HOW DO WE PROCESS YOUR INFORMATION?
 

In Short: We process your information to provide, improve, and administer our
Services, communicate with you, for security and fraud prevention, and to comply
with law. We may also process your information for other purposes with your consent.

 

We process your personal information for a variety of reasons, depending on
how you interact with our Services, including:

 

  • To deliver and facilitate delivery of services to the user. We may process your information to provide you with the requested service.

  •  To respond to user inquiries/offer support to users. We may process your information to respond to your inquiries and solve any potential issues you might have with the requested service.

  • To send administrative information to you. We may process your information to send you details about our products and services, changes to our terms and policies, and other similar information.

  • To enable user-to-user communications. We may process your information if you choose to use any of our offerings that allow for communication with another user.

  • To request feedback. We may process your information when necessary to request feedback and to contact you about your use of our Services.

  • To send you marketing and promotional communications. We may process the personal information you send to us for our marketing purposes, if this is in accordance with your marketing preferences. You can opt out of our marketing emails at any time. For more information, see 'WHAT ARE YOUR PRIVACY RIGHTS?' below).

  • To deliver targeted advertising to you. We may process your information to develop and display personalised content and advertising tailored to your interests, location, and more.

  • To identify usage trends. We may process information about how you use our Services to better understand how they are being used so we can improve them.

  • To determine the effectiveness of our marketing and promotional campaigns. We may process your information to better understand how to provide marketing and promotional campaigns that are most relevant to you.

  • To save or protect an individual's vital interest. We may process your

         information when necessary to save or protect an individual’s vital interest,
        such as to prevent harm.

 

 

3. WHAT LEGAL BASES DO WE RELY ON TO PROCESS
YOUR INFORMATION?


In Short: We only process your personal information when we believe it is necessary
and we have a valid legal reason (i.e. legal basis) to do so under applicable law, like
with your consent, to comply with laws, to provide you with services to enter into or
fulfil our contractual obligations, to protect your rights, or to fulfil our legitimate
business interests.


The General Data Protection Regulation (GDPR) and UK GDPR require us to explain
the valid legal bases we rely on in order to process your personal information. As
such, we may rely on the following legal bases to process your personal information:
Consent. We may process your information if you have given us permission
(i.e. consent) to use your personal information for a specific purpose. You can
withdraw your consent at any time. Click here to learn more.
Performance of a Contract. We may process your personal information when
we believe it is necessary to fulfil our contractual obligations to you, including
providing our Services or at your request prior to entering into a contract with
you.
Legitimate Interests. We may process your information when we believe it is
reasonably necessary to achieve our legitimate business interests and those
interests do not outweigh your interests and fundamental rights and freedoms.
For example, we may process your personal information for some of the
purposes described in order to:
Send users information about special offers and discounts on our
products and services
Develop and display personalised and relevant advertising content for
our users
Analyse how our Services are used so we can improve them to engage
and retain users
Support our marketing activities
Understand how our users use our products and services so we can
improve user experience
Legal Obligations. We may process your information where we believe it is
necessary for compliance with our legal obligations, such as to cooperate with
a law enforcement body or regulatory agency, exercise or defend our legal
rights, or disclose your information as evidence in litigation in which we are
involved.
Vital Interests. We may process your information where we believe it is
necessary to protect your vital interests or the vital interests of a third party,
such as situations involving potential threats to the safety of any person.
4. WHEN AND WITH WHOM DO WE SHARE YOUR
PERSONAL INFORMATION?
In Short: We may share information in specific situations described in this section
and/or with the following categories of third parties.
Vendors, Consultants, and Other Third-Party Service Providers. We may share
your data with third-party vendors, service providers, contractors, or agents ('third
parties') who perform services for us or on our behalf and require access to such
information to do that work. The categories of third parties we may share personal
information with are as follows:
Data Analytics Services
We also may need to share your personal information in the following situations:
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Business Transfers. We may share or transfer your information in connection
with, or during negotiations of, any merger, sale of company assets, financing,
or acquisition of all or a portion of our business to another company.
Affiliates. We may share your information with our affiliates, in which case we
will require those affiliates to honour this privacy notice. Affiliates include our
parent company and any subsidiaries, joint venture partners, or other
companies that we control or that are under common control with us.
Business Partners. We may share your information with our business
partners to offer you certain products, services, or promotions.
5. IS YOUR INFORMATION TRANSFERRED
INTERNATIONALLY?
In Short: We may transfer, store, and process your information in countries other
than your own.
Our servers are located in India. If you are accessing our Services from outside India,
please be aware that your information may be transferred to, stored, and processed
by us in our facilities and by those third parties with whom we may share your
personal information (see 'WHEN AND WITH WHOM DO WE SHARE YOUR
PERSONAL INFORMATION?' above), in India, and other countries.
If you are a resident in the European Economic Area (EEA) or United Kingdom (UK),
then these countries may not necessarily have data protection laws or other similar
laws as comprehensive as those in your country. However, we will take all necessary
measures to protect your personal information in accordance with this privacy notice
and applicable law.
6. HOW LONG DO WE KEEP YOUR INFORMATION?
In Short: We keep your information for as long as necessary to fulfil the purposes
outlined in this privacy notice unless otherwise required by law.
We will only keep your personal information for as long as it is necessary for the
purposes set out in this privacy notice, unless a longer retention period is required or
permitted by law (such as tax, accounting, or other legal requirements).
When we have no ongoing legitimate business need to process your personal
information, we will either delete or anonymise such information, or, if this is not
possible (for example, because your personal information has been stored in backup
archives), then we will securely store your personal information and isolate it from
any further processing until deletion is possible.
7. HOW DO WE KEEP YOUR INFORMATION SAFE?
In Short: We aim to protect your personal information through a system of
organisational and technical security measures.
We have implemented appropriate and reasonable technical and organisational
security measures designed to protect the security of any personal information we
process. However, despite our safeguards and efforts to secure your information, no
electronic transmission over the Internet or information storage technology can be
guaranteed to be 100% secure, so we cannot promise or guarantee that hackers,
cybercriminals, or other unauthorised third parties will not be able to defeat our
security and improperly collect, access, steal, or modify your information. Although
we will do our best to protect your personal information, transmission of personal
information to and from our Services is at your own risk. You should only access the
Services within a secure environment.
8. DO WE COLLECT INFORMATION FROM MINORS?
In Short: We do not knowingly collect data from or market to children under 18 years
of age.
We do not knowingly solicit data from or market to children under 18 years of age. By
using the Services, you represent that you are at least 18 or that you are the parent
or guardian of such a minor and consent to such minor dependent’s use of the
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Services. If we learn that personal information from users less than 18 years of age
has been collected, we will deactivate the account and take reasonable measures to
promptly delete such data from our records. If you become aware of any data we
may have collected from children under age 18, please contact us at
sales@punchhole.co.
9. WHAT ARE YOUR PRIVACY RIGHTS?
In Short: In some regions, such as the European Economic Area (EEA) and United
Kingdom (UK), you have rights that allow you greater access to and control over your
personal information. You may review, change, or terminate your account at any time.
In some regions (like the EEA and UK), you have certain rights under applicable data
protection laws. These may include the right (i) to request access and obtain a copy
of your personal information, (ii) to request rectification or erasure; (iii) to restrict the
processing of your personal information; and (iv) if applicable, to data portability. In
certain circumstances, you may also have the right to object to the processing of your
personal information. You can make such a request by contacting us by using the
contact details provided in the section 'HOW CAN YOU CONTACT US ABOUT THIS
NOTICE?' below.
We will consider and act upon any request in accordance with applicable data
protection laws.
If you are located in the EEA or UK and you believe we are unlawfully processing
your personal information, you also have the right to complain to your local data
protection supervisory authority. You can find their contact details here:
https://ec.europa.eu/justice/data-protection/bodies/authorities/index_en.htm.
If you are located in Switzerland, the contact details for the data protection authorities
are available here: https://www.edoeb.admin.ch/edoeb/en/home.html.
Withdrawing your consent: If we are relying on your consent to process your
personal information, you have the right to withdraw your consent at any time. You
can withdraw your consent at any time by contacting us by using the contact details
provided in the section 'HOW CAN YOU CONTACT US ABOUT THIS NOTICE?'
below.
However, please note that this will not affect the lawfulness of the processing before
its withdrawal nor, will it affect the processing of your personal information conducted
in reliance on lawful processing grounds other than consent.
Opting out of marketing and promotional communications: You can unsubscribe
from our marketing and promotional communications at any time by replying 'STOP'
or 'UNSUBSCRIBE' to the SMS messages that we send, or by contacting us using
the details provided in the section 'HOW CAN YOU CONTACT US ABOUT THIS
NOTICE?' below. You will then be removed from the marketing lists. However, we
may still communicate with you — for example, to send you service-related
messages that are necessary for the administration and use of your account, to
respond to service requests, or for other non-marketing purposes.
If you have questions or comments about your privacy rights, you may email us at
info@punchhole.co.
10. CONTROLS FOR DO-NOT-TRACK FEATURES
Most web browsers and some mobile operating systems and mobile applications
include a Do-Not-Track ('DNT') feature or setting you can activate to signal your
privacy preference not to have data about your online browsing activities monitored
and collected. At this stage no uniform technology standard for recognising and
implementing DNT signals has been finalised. As such, we do not currently respond
to DNT browser signals or any other mechanism that automatically communicates
your choice not to be tracked online. If a standard for online tracking is adopted that
we must follow in the future, we will inform you about that practice in a revised
version of this privacy notice.
11. DO CALIFORNIA RESIDENTS HAVE SPECIFIC
PRIVACY RIGHTS?
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In Short: Yes, if you are a resident of California, you are granted specific rights
regarding access to your personal information.
California Civil Code Section 1798.83, also known as the 'Shine The Light' law,
permits our users who are California residents to request and obtain from us, once a
year and free of charge, information about categories of personal information (if any)
we disclosed to third parties for direct marketing purposes and the names and
addresses of all third parties with which we shared personal information in the
immediately preceding calendar year. If you are a California resident and would like
to make such a request, please submit your request in writing to us using the contact
information provided below.
If you are under 18 years of age, reside in California, and have a registered account
with Services, you have the right to request removal of unwanted data that you
publicly post on the Services. To request removal of such data, please contact us
using the contact information provided below and include the email address
associated with your account and a statement that you reside in California. We will
make sure the data is not publicly displayed on the Services, but please be aware
that the data may not be completely or comprehensively removed from all our
systems (e.g. backups, etc.).
12. DO WE MAKE UPDATES TO THIS NOTICE?
In Short: Yes, we will update this notice as necessary to stay compliant with relevant
laws.
We may update this privacy notice from time to time. The updated version will be
indicated by an updated 'Revised' date and the updated version will be effective as
soon as it is accessible. If we make material changes to this privacy notice, we may
notify you either by prominently posting a notice of such changes or by directly
sending you a notification. We encourage you to review this privacy notice frequently
to be informed of how we are protecting your information.
13. HOW CAN YOU CONTACT US ABOUT THIS NOTICE?
If you have questions or comments about this notice, you may email us at
sales@punchhole.co or by post to:
Punchhole solutions limited
152-160
CITY ROAD
London, London EC1V2NX
England
14. HOW CAN YOU REVIEW, UPDATE, OR DELETE THE
DATA WE COLLECT FROM YOU?
Based on the applicable laws of your country, you may have the right to request
access to the personal information we collect from you, change that information, or
delete it. To request to review, update, or delete your personal information, please
visit: http://www.punchhole.co/datarequest.
This privacy policy was created using Termly's Privacy Policy Generato

. WHAT LEGAL BASES DO WE RELY ON TO PROCESS YOUR INFORMATION?

In Short: We only process your personal information when we believe it is necessary and we have a valid legal reason (i.e. legal basis) to do so under applicable law, like with your consent, to comply with laws, to provide you with services to enter into or fulfil our contractual obligations, to protect your rights, or to fulfil our legitimate business interests.

The General Data Protection Regulation (GDPR) and UK GDPR require us to explain the valid legal bases we rely on in order to process your personal information. As such, we may rely on the following legal bases to process your personal information:

Consent. We may process your information if you have given us permission (i.e. consent) to use your personal information for a specific purpose. You can withdraw your consent at any time. Click here to learn more.

Performance of a Contract. We may process your personal information when we believe it is necessary to fulfil our contractual obligations to you, including providing our Services or at your request prior to entering into a contract with you.

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