Privacy Policy

How to use this notice

Please note:

  1. We have drafted the below so that it can easily be slotted onto a website
  2. ► indicates that by clicking on this text, the next level of text will be revealed
  3. The numbers indicate the list level e.g. when you click on one of the above, all Level 1s will be revealed. Clicking on a Level 1 will reveal the Level 2s under that Level 1 and clicking on a Level 2 will reveal the Level 3s under that Level 2 and so on.
  4. The wording in this notice will need to be updated (i) in the event of any further guidance on the requirements for fair processing notices from the ICO; and (ii) shortly before Brexit.

Before using this notice

  1. Check the content. You should assume that if a particular use of personal data is not correctly identified and explained in this Privacy Policy, it is unlikely that PURE will be able to continue such use of personal data. Therefore, you must review this in detail to ensure that your uses of personal data are appropriately reflected.
  2. Check whether you may be required to include specific information by a third party.
  3. Please note that the new UK Data Protection Act 2018 (the "Act") received Royal Assent on 23 May. However, only some of the sections of the Act have come into force. As other sections of the Act come into force, the wording in this notice will need to be reviewed and may need to be updated to reflect new processing grounds that could be relied on.

Where to include this notice

This Notice should be hosted on the PURE website, replacing the existing privacy policy. The link to the notice titled "Privacy Policy" should be maintained on the homepage.

General notes:

  1. WP29 transparency guidance states that the wording used in a privacy notice should not be phrased in ambivalent/ abstract terms or leave room for different interpretations; language qualifiers such as “may”, “might”, “some”, “often” and “possible” should also be avoided. This is particularly difficult to do where there are so many varying categories of personal data collected and uses of personal data depending on the client and the exact circumstances. Therefore market approach has been that where possible, be as clear and specific as possible, however the use of language qualifiers cannot be entirely avoided.

 

  1. WP29 transparency guidance on transparency emphasised the importance of making it clear which purposes and lawful basis would apply to each type of data subject. We have therefore largely grouped the contents by data subject, which means an individual would only click on the entry from section 2 that applies to them and could see at a glance, how their personal information is used, where it has come from, the legal ground PURE relies on to process it and who it is shared with.

 

  1. This notice has been constructed for use on a website to incorporate click throughs. Where data subjects are provided with a paper copy or ask for a paper copy, you will only need to provide them with the relevant entry from section 2 (and then a copy of all other sections).

 

PURE PRIVACY POLICY

 

PURE is committed to protecting the privacy of all individuals it interacts with and we therefore ask that you please read this fair processing notice carefully. This fair processing notice explains how PURE collects and uses your personal information.

 

1.     About PURE ►

2.     PURE's processing of your personal information ►

Where you register a warranty with us for a Pure product, or make a claim under a warranty►

Where you raise a support ticket or register to create an account on support.pure.com or ask us to fix a product that is not under warranty ►

Where you use the PURE Go and Connect Apps ►

Where you use the PURE website ►

3.     What marketing activities do we carry out? ►

4.     How long do we keep your personal information for? ►

5.     What is our approach to sending information overseas? ►

6.     Automated decision making and profiling ►

7.     Your rights ►

8.     Contacting us ►

9.     Keeping your information safe ►

10.  Updates to this Notice ►

 

  1. About PURE

1

This is the privacy policy of PURE International Limited, trading as PURE. PURE is registered in England and Wales with company number 10392690 and registered office at Concept House, Home Park Road, Kings Langley, Hertfordshire, WD4 8UD.

 

PURE is the world’s leading digital radio manufacturer, with over 5 million digital radios sold worldwide to date. Passionate not just about radio, but quality audio, Pure designs and engineers its radios in its state-of-the art engineering facilities just outside of London.

 

  1. Our processing of your personal information ►

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We will collect and use different personal information about you for different reasons, depending on our relationship with you.

 

As a digital radio manufacturer, we collect and process personal data so that we can register your PURE product warranties, respond to any support ticket that you raise on the support.pure.com website, repair your product and process any payment for repair (where it is not under warranty), and send this out to you, provide you with services via our apps, improve your use of our website and answer any queries that you have. We will also use your personal data where we need to do so to comply with a legal or regulatory obligation. This makes us a controller of your personal data.

 

In order to make this notice as user friendly as possible, we have split it into different sections. Please click on the section below that best describes your relationship with us and the service you receive from us.

 

 

 

1

Where you register a warranty with us for a Pure product, or make a claim under a warranty►

2

This section will apply if you create an account with us in order to register a PURE product warranty, or if you make a claim on a PURE warranty.

 

What personal information may we collect?          

3

·         Your name, email address and date of birth;

·         Information collected from any communications with you in respect of your account, such as your password

·         Information collected from any communications with you in respect of your warranty, such as your product's serial number and your date of purchase.

2

How will we collect your personal information? ►

3

We will collect information directly from you when:

·         you sign up to create an account;

·         you contact us, including by email, by telephone, or via the contact form on the support.pure.com website.

We will also collect information from the following third parties:

·         Facebook, where we collect your name and email address when you use your Facebook account to create a PURE account

2

What will we use your personal information for? ►

3

There are a number of reasons we use your personal information and, for each use, we need to have a "lawful basis" to do so. We will rely on the following “lawful bases” when we process your personal information for the purposes mentioned:

·         we need to use your personal information to verify that you are entitled to the warranty, to verify the relevant warranty period (by reference to the receipt for the relevant product that you upload to the PURE website), and to provide the services identified in the warranty for the PURE product in question. For example, we may need to use your personal information when carrying out any servicing or repairs to your PURE product, or to return your PURE product to you after we have repaired the product;

·         we have a valid business reason to use your personal information so that we can undertake our everyday business operations and activities, including:

o    communicating with you in relation to any upgrade, safety or recall messages, any queries or complaints relating to our warranty service or your account;

o    managing your PURE account;

o    recording warranty registrations and claims in order to run our business efficiently and effectively and to aid further development of our products.

In each case where we consider we have a valid business reason, we assess our need to use this personal information for these purposes against your rights to privacy to ensure we are protecting your rights.

 

2

Who will we share your personal information with? ►

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We will not sell or transfer your personal information to anyone unless we have a valid purpose as set out above and we will only disclose it to the following parties:

·         other PURE group companies;

·         selected third parties in connection with any sale, transfer or disposal of our business;

·         our insurers;

·         anyone who we have to report to in relation to any legal or regulatory obligations;

·         third parties who provide services to us or on our behalf so that we can carry out our everyday business operations and activities, such as third parties carrying out servicing or repairs on our behalf, couriers, PURE product manufacturers, storage warehouses, secure login and email providers,IT suppliers.

 

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Where you raise a support ticket , register to create an account on support.pure.com or ask us to fix a PURE product that is not under warranty►

2

This section will apply if you visit support.pure.com and raise a support ticket, or call us and speak to a member of our support team, register to create an account on support.pure.com or ask us to fix a PURE product that is not under warranty.

 

What personal information may we collect?          

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·         Your name email address and the timezone that is applicable to you;

·         Details of your PURE product, including its serial number and the date of purchase;

·         Information collected from any communications with you in respect of your support ticket, your account or any other queries or requests we receive from you. This may include your account password, your email address and your contact number;

·         Your payment details and your address where you ask us to repair a PURE product that does not have a valid warranty in place.

2

How will we collect your personal information? ►

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We will collect information directly from you when:

·         you contact us using the Contact Us form on support.pure.com, or call us and speak to a member of our support team and we use the information you give us to generate a support ticket or respond to your request or query;

·         you sign up to create an account;

·         you provide us with your address and payment details where you have asked us to repair a PURE product that does not have a warranty in place.

 

2

What will we use your personal information for? ►

3

There are a number of reasons we use your personal information and, for each use, we need to have a "lawful basis" to do so. We will rely on the following “lawful bases” when we process your personal information for the purposes mentioned:

·         we need to use your personal information to provide the services that you have requested for the PURE product in question. For example, we may need to use your personal information when carrying out any servicing or repairs to your PURE product, to request payment for the service or to return your PURE product to you after we have repaired the product.

·         we have a valid business reason to use your personal information so that we can undertake our everyday business operations and activities, including:

o    communicating with you in relation to any queries or complaints relating to your support ticket or your account;

o    managing your account;

o    recording receipt and resolution of support tickets in order to run our business efficiently and effectively.

In each case where we consider we have a valid business reason, we assess our need to use this personal information for these purposes against your rights to privacy to ensure we are protecting your rights.

 

2

Who will we share your personal information with? ►

3

We will not sell or transfer your personal information to anyone unless we have a valid purpose as set out above and we will only disclose it to the following parties:

·         other PURE group companies;

·         selected third parties in connection with any sale, transfer or disposal of our business;

·         our insurers;

·         anyone who we have to report to in relation to any legal or regulatory obligations;

·         third parties who provide services to us or on our behalf so that we can carry out our everyday business operations and activities, such as third parties carrying out servicing or repairs on our behalf, couriers, PURE product manufacturers, storage warehouses, secure login and email providers,IT suppliers.

 

 

 



 

1

Where you use the PURE Go and Connect Apps ►

2

This section applies where you use the PURE Go and Connect Apps.

 

What personal information may we collect?          

3

Where you have an account within the relevant app:

·         your name and email address;

·         analytics data associated with your account – this will include your unique client ID and information on your use of the app.

·         information obtained through our use of cookies, such as IP address and browsing history. You can find more information about this in our cookies policy which can be found here https://www.pure.com/about-pure/cookie-policy.

2

How will we collect your personal information? ►

3

Where you have an account within the relevant app:

·         we will collect information directly from you, if you signed up to an account previously;

·         we will collect information from third party service providers, including Google Analytics, Fabric Analytics and Firebase.

2

What will we use your personal information for? ►

 

There are a number of reasons we use your personal information and, for each use, we need to have a "lawful basis" to do so. We will rely on the following “lawful basis” when we process your personal information for the purposes mentioned, namely, we have a valid business reason to use your personal information so that we can undertake our everyday business operations and activities, including:

·         supporting you with your connected PURE products or devices;

·         supporting you with use of any account associated with a PURE app;

·         reviewing usage of our apps in order to aid further development of our apps or services.

In each case where we consider we have a valid business reason, we assess our need to use this personal information for these purposes against your rights to privacy to ensure we are protecting your rights.

 

2

Who will we share your personal information with? ►

3

We will not sell or transfer your personal information to anyone unless we have a valid purpose as set out above and we will only disclose it to the following parties:

·         other PURE group companies;

·         selected third parties in connection with any sale, transfer or disposal of our business;

·         anyone who we have to report to in relation to any legal or regulatory obligations;

·         third parties who provide services to us or on our behalf so that we can carry out our everyday business operations and activities, such as our app hosting companies.

 

 

 

1

Where you use the PURE website►

2

This section will apply if you use our website. If you use our website to create an account to register a PURE product warranty, the section "Where you register a warranty with us for a Pure product, or make a claim under a warranty" will also apply.

 

What personal information may we collect?                      

3

·         Information submitted via the website, for example, details provided when you contact the PURE support team using the contact form, including your name and email address.

·         Information obtained through our use of cookies, such as IP address and browsing history. You can find more information about this in our cookies policy which can be found here https://www.pure.com/about-pure/cookie-policy.

·         Information obtained from Google Analytics, Facebook Analytics and Hotjar. This includes information such as how you use our website and the demographics of visitors to our website.

2

How will we collect your personal information? ►

3

We will collect your information from you directly when you submit information via our website.

 

We will also collect your information through our use of cookies and from third party service providers, including Google Analytics, Facebook Analytics and Hotjar.

2

What will we use your personal information for? ►

3

There are a number of reasons we use your personal information and, for each use, we need to have a "lawful basis" to do so. We will rely on the following “lawful basis” when we process your personal information for the purposes mentioned, namely, that we have a valid business reason to use your personal information so that we can undertake our everyday business operations and activities, including:

·         monitoring usage of our website and identifying ways in which we can improve the experience of our website users;

·         responding to any enquiries you have submitted using the contact form.

In each case where we consider we have a valid business reason, we assess our need to use this personal information for these purposes against your rights to privacy to ensure we are protecting your rights.

 

2

Who will we share your personal information with? ►

3

We will not sell or transfer your personal information to anyone unless we have a valid purpose as set out above and we will only disclose it to the following parties:

·         other PURE group companies;

·         selected third parties in connection with any sale, transfer or disposal of our business;

·         third parties who provide services to us or on our behalf so that we can carry out our everyday business operations and activities, such as IT suppliers and website providers.

 

  1. What marketing activities do we carry out? ►

1

Newsletters

We will send you our PURE newsletters where you’ve agreed to receive them. You can unsubscribe from this type of communication at any time by clicking the link in the footer of the email, or contacting us on team@pure.com.

 

Promotions and prizes

We may also email you in relation to redemption-based promotions where you can claim a free item in return for providing evidence of your proof of purchase of a PURE product.

 

  1. How long do we keep personal information for? ►

1

We will only keep your personal information for as long as reasonably necessary to fulfil the purposes set out in sections 2 - 3 above, or for as long as necessary to respond to any concerns you raise. For example:

a.         when you create a PURE account and register a warranty for a PURE product with us, we will retain your personal information for the duration of the warranty period and thereafter in order to use your warranty information to help us respond more effectively and efficiently to a support ticket that you may raise and/or notify you of any security updates for your PURE product;

b.         where you have an account for either a PURE Go or a PURE Connect app, we will retain your personal information until the account is no longer required by you.

If you would like further information about how long we will keep your personal information for, please contact us using the details set out in section 8. 

 

  1. What is our approach to sending your personal information overseas ►

1

·         There are a small number of instances where your personal information may be transferred to countries outside of the European Economic Area ("EEA").  For example, if you send your PURE product to us to repair it, where you are located outside of the EEA we will need to provide your name, delivery address and contact number to our couriers to allow them to return your PURE product after we have repaired the product.

 

 

Where such a transfer takes place, we will take the appropriate safeguarding measures to ensure that your personal information is adequately protected. This may include one of the following measures:

·         entering into data transfer contracts and using specific contractual provisions that have been approved by European data protection authorities (often referred to as the "standard contractual clauses"). You can find out more about standard contractual clauses at https://ec.europa.eu/info/law/law-topic/data-protection/data-transfers-outside-eu/model-contracts-transfer-personal-data-third-countries_en;

·         where transferring personal data to a company in the United States, checking that the company is certified under the "Privacy Shield" framework. The Privacy Shield is a scheme whereby companies certify that they provide an adequate level of data protection. You can find out more about the Privacy Shield https://www.privacyshield.gov/welcome or

·         checking that the company in question is based in a country outside the EEA which has been deemed by European data protection authorities to have adequate levels of protection for personal information. You can find out more about this at https://ec.europa.eu/info/law/law-topic/data-protection/data-transfers-outside-eu/adequacy-protection-personal-data-non-eu-countries_en

We are also entitled under European data protection laws to transfer your personal information to countries outside the EEA where it is necessary for the performance of the contract we have with you.

If you would like further information regarding our data transfers and the steps we take to safeguard your personal information, please contact us using the details set out in section 8. 

 

  1. Automated decision making and profiling ►

1

What is automated decision making?

Automated decision making refers to a situation where a decision is taken using personal information that is processed solely by automatic means (i.e. using an algorithm or other computer software) rather than a decision that is made with some form of human involvement.

 

PURE does not currently undertake automated decision making.

 

What is profiling?

Profiling is any form of automated processing of personal information which uses that personal information to evaluate certain personal aspects in relation to an individual.

 

Pure does not currently undertake profiling.

 

  1. Your rights ►

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You have several rights which you can exercise at any time relating to the personal information that we hold about you and use in the ways set out in this notice. Please contact us at any time using the details set out in section 8 (Contacting us) if you wish to exercise these rights; we will not usually charge you.

 

We respect your rights and will always consider and assess them. However, please be aware that we may not always be able to comply with a request that you make as the consequence might be that:

·         in doing so, we could not comply with our own legal or regulatory requirements; or

·         in doing so, we could not provide services to you and would have to cancel your contract. For example, we could not provide warranty services for a PURE product that you had purchased if we had deleted your personal information.

We will of course inform you if any of the above situations arise or if we are unable to comply with your request.

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·         The right to access your personal information

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You are entitled to a copy of the personal information we hold about you and certain details of how we use it. Please contact us using the details in section 8 to request a copy of the information we hold.

 

We are happy to provide you with those details but, in the interests of confidentiality, we follow strict disclosure procedures and may require proof of identity from you prior to disclosing such information.

 

We will usually provide your personal information to you in writing unless you request otherwise. Where your request has been made electronically (e.g. by email), a copy of your personal information will be provided to you by electronic means where possible.

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·         The right to rectification

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Please help us to keep your personal information accurate and up to date. If you believe that there are any inaccuracies, discrepancies or gaps in the personal information we hold about you, please contact us and ask us to update or amend it.

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·         The right to restriction of processing

2

In certain circumstances, you have the right to ask us to stop using your personal information, for example, where you think that the personal information we hold about you may be inaccurate or where you think that we no longer need to use your personal information. 

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·         The right to withdraw your consent

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Where we rely on your consent to process your personal information, you have the right to withdraw your consent to further use of your personal information.

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·         The right to erasure

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You can request that your personal information is deleted in certain circumstances such as where we no longer need your personal information for the purpose we originally collected it. When you exercise this right, we will need to consider other factors to assess whether we can comply with your request.

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·         The right to object to direct marketing

2

You have a choice about whether or not you wish to receive marketing information from us and you have the right to request at any time that we stop sending you marketing messages.  You can do this either by clicking the link in the footer of any email that we send to you or by contacting us on data@pure.com.

 

Please note that, even if you opt out of receiving marketing messages, we may still send you communications which are relevant to the nature of services we offer you. If you have asked us to stop using your personal information for marketing purposes, your name, date of birth and email address will be added to and kept on a "suppression list" to make sure that we do not send you marketing communications via the relevant channel(s) in the future.

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·         The right to object to processing

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In certain circumstances, where we only process your personal data because we consider we have a legitimate business need to do so, you have the right to object to our processing of your personal data.

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·         The right to data portability

2

In certain circumstances, you can request that we transfer any personal information that you have provided to us to a third party.

When you exercise this right, we will need to consider other factors to assess whether we can comply with your request.

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·         Rights relating to automated decision-making

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We do not carry out automated decision-making.

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·         The right to make a complaint with the ICO ►

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If you believe that we have breached data protection laws when using your personal information, you have a right to complain to a data protection supervisory authority which, in the UK, is the Information Commissioner's Office (ICO). You can visit the ICO's website at https://ico.org.uk/ for more information.  Please note that lodging a complaint will not affect any other legal rights or remedies that you have.

 

  1. Contacting us ►

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If you would like any further information about any of the matters in this notice or if you have any other questions about how we collect, store or use your personal information, please contact Alex Lainé, our PURE data protection contact, at data@pure.com or FAO Alex Lainé, Pure International Limited, Concept House, Home Park Road, Kings Langley, Herts, WD4 8UD.

 

  1. Keeping your information safe►

1

We have in place appropriate technical and security measures to prevent unauthorised access and accidental loss of your personal information.

 

We store your personal details on secure servers. We use industry standard security and firewalls on our servers. When we collect payment card details electronically, we use encryption by using Secure Website Certificate technology, which makes it hard for a hacker to decrypt your details.

 

We maintain physical, electronic and procedural safeguards in connection with the collection, storage and disclosure of your personal information. Our security procedures mean that we may occasionally request proof of identity, for example, your password, before we disclose personal information to you. You are responsible for protecting against unauthorised access to your password and to your computer.

 

  1. Updates to this notice ►

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From time to time we may need to make changes to this notice, for example, as the result of changes to law, technologies, or other developments. We will provide you with the most up-to-date notice by email and you can also check our website periodically to view it.

 

This notice was last updated on 21 June 2018.