Last updated [16th October 2019]
Thank you for choosing to be part of our community at Penguin Wealth Planners Ltd (“company”, “we”, “us”, or
“our”). We are committed to protecting your personal information and your right to privacy. If you have any
questions or concerns about our policy, or our practices with regards to your personal information, please contact
us at email@example.com.
When you visit our website [www.penguinwealth.com] (“Site”) and use our services, you trust us with your
We seek to explain to you in the clearest way possible what information we collect, how we use it and what rights
you have in relation to it. We hope you take some time to read through it carefully, as it is important. If there are
[our mobile] [or] [our Facebook & Twitter applications] (“Apps”), and/or any related services, sales, marketing or
information with us.
V0.1 16/10/19 – LTD
In Short: We collect personal information that you provide to us such as name, address, contact information, and
social media login data.
We collect personal information that you voluntarily provide to us when [registering at the Sites or Apps,]
expressing an interest in obtaining information about us or our products and services, when participating in
activities on the Sites (such as posting messages in our online forums or entering competitions, contests or
giveaways) or otherwise contacting us.
The personal information that we collect depends on the context of your interactions with us and the Sites, the
choices you make and the products and features you use. The personal information we COLLECT can include the
We collect your first and last name, email address, postal address, phone number, and
other similar contact data.
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.
V0.1 16/10/19 – LTD
In Short: Some information – such as IP address and/or browser and device characteristics – is collected
automatically when you visit our websites.
We automatically collect certain information when you visit, use or navigate the Sites. 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 Site and other technical
information. This information is primarily needed to maintain the security and operation of our Sites, and for our
internal analytics and reporting purposes.
In Short: We may collect limited data from public databases, marketing partners, social media platforms, and other
We may obtain information about you from other sources, such as public databases, joint marketing partners,
social media platforms (such as Facebook), as well as from other third parties. Examples of the information we
receive from other sources include: social media profile information (your name, gender, birthday, email, current
city, state and country, user identification numbers for your contacts, profile picture URL and any other information
that you choose to make public); marketing leads and search results and links, including paid listings (such as
In Short: We process your information for purposes based on legitimate business interests, the fulfillment of our
contract with you, compliance with our legal obligations, and/or your consent.
We use personal information collected via our Sites for a variety of business purposes described below. We process
your personal information for these purposes in reliance on our legitimate business interests (“Business Purposes”),
in order to enter into or perform a contract with you (“Contractual”), with your consent (“Consent”), and/or for
compliance with our legal obligations (“Legal Reasons”). We indicate the specific processing grounds we rely on
next to each purpose listed below.
V0.1 16/10/19 – LTD
We use the information we collect or receive:
To send you marketing and promotional communications [for Business Purposes and/or with your Consent]. We
and/or our third party marketing partners may use 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 (see the “Your Privacy Rights” below).
• To send administrative information to you [for Business Purposes, Legal Reasons and/or possibly Contractual].
We may use your personal information to send you product, service and new feature information and/or
information about changes to our terms, conditions, and policies.
• Administer prize draws and competitions [for our Business Purposes and/or with your Consent]. We may use
your information to administer prize draws and competitions when you elect to participate in competitions.
• Request Feedback [for our Business Purposes and/or with your Consent]. We may use your information to
request feedback and to contact you about your use of our Sites.
• To protect our Sites [for Business Purposes and/or Legal Reasons]. We may use your information as part of
our efforts to keep our Sites safe and secure (for example, for fraud monitoring and prevention).
• To enable user-to-user communications [with your consent]. We may use your information in order to enable
user-to-user communications with each user’s consent.
• To enforce our terms, conditions and policies [for Business Purposes, Legal Reasons and/or possibly
• To respond to legal requests and prevent harm [for Legal Reasons]. If we receive a subpoena or other legal
request, we may need to inspect the data we hold to determine how to respond.
• For other Business Purposes. We may use your information for other Business Purposes, such as data analysis,
identifying usage trends, determining the effectiveness of our promotional campaigns and to evaluate and
improve our Sites, products, services, marketing and your experience.
V0.1 16/10/19 – LTD
In Short: We only share information with your consent, to comply with laws, to protect your rights, or to fulfill
We only share and disclose your information in the following situations:
• Compliance with Laws. We may disclose your information where we are legally required to do so in order
to comply with applicable law, governmental requests, a judicial proceeding, court order, or legal process,
such as in response to a court order or a subpoena (including in response to public authorities to meet
national security or law enforcement requirements).
• Vital Interests and Legal Rights. We may disclose your information where we believe it is necessary to
investigate, prevent, or take action regarding potential violations of our policies, suspected fraud,
situations involving potential threats to the safety of any person and illegal activities, or as evidence in
litigation in which we are involved.
• Vendors, Consultants and Other Third-Party Service Providers. We may share your data with third party
vendors, service providers, contractors or agents who perform services for us or on our behalf and require
access to such information to do that work. Examples include: data analysis, email delivery, hosting services,
customer service and marketing efforts. We may allow selected third parties to use tracking technology on
the Sites, which will enable them to collect data about how you interact with the Sites over time. This
information may be used to, among other things, analyze and track data, determine the popularity of
certain content and better understand online activity. Unless described in this Policy, we do not share, sell,
rent or trade any of your information with third parties for their promotional purposes.
• 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
• Affiliates. We may share your information with our affiliates, in which case we will require those affiliates
partners or other companies that we control or that are under common control with us.
V0.1 16/10/19 – LTD
• Business Partners. We may share your information with our business partners to offer you certain products,
services or promotions.
• With your Consent. We may disclose your personal information for any other purpose with your consent.
• Other Users. When you share personal information (for example, by posting comments, contributions or
other content to the Sites) or otherwise interact with public areas of the Site, such personal information
may be viewed by all users and may be publicly distributed outside the Site in perpetuity. If you interact
with other users of our Sites and register through a social network (such as Facebook), your contacts on
the social network will see your name, profile photo, and descriptions of your activity. Similarly, other
users will be able to view descriptions of your activity, communicate with you within our Sites, and view
In Short: We may transfer, store, and process your information in countries other than your own.
Our servers are located in the United Kingdom. If you are accessing our Sites from outside the United Kingdom,
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 “Disclosure of Your Information”
above), in USA and other countries .
If you are a resident in the European Economic Area, then these countries may not have data protection or other
laws as comprehensive as those in your country. We will however take all necessary measures to protect your
European Commission’s Standard Contractual Clauses. Such measures implementing the European Commission’s
Standard Contractual Clauses for transfers of personal information between our group companies and between us
and our third-party providers, which require all such recipients to protect personal information that they process
from the EEA in accordance with European data protection laws. We have implemented similar appropriate
safeguards with our third party service providers and partners and further details can be provided upon request.
V0.1 16/10/19 – LTD
In Short: We are not responsible for the safety of any information that you share with third-party providers who
advertise, but are not affiliated with, our websites.
The Sites may contain advertisements from third parties that are not affiliated with us and which may link to other
websites, online services or mobile applications. We cannot guarantee the safety and privacy of data you provide
for the content or privacy and security practices and policies of any third parties, including other websites, services
or applications that may be linked to or from the Sites. You should review the policies of such third parties and
contact them directly to respond to your questions.
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
policy, unless a longer retention period is required or permitted by law (such as tax, accounting or other legal
requirements). No purpose in this policy will require us keeping your personal information for longer the period of
time in which you have an account with us.
When we have no ongoing legitimate business need to process your personal information, we will either delete or
anonymise it, 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.
In Short: We aim to protect your personal information through a system of organisational and technical security
We have implemented appropriate technical and organisationalsecurity measures designed to protect the security
of any personal information we process. However, please also remember that we cannot guarantee that the
internet itself is 100% secure. Although we will do our best to protect your personal information, transmission of
V0.1 16/10/19 – LTD
personal information to and from our Sites is at your own risk. You should only access the services within a secure
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 Sites, 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 Site. If we learn that personal information from users less than 18 years of age has been
collected, we will take reasonable measures to promptly delete such data from our records. If you become aware
of any data we have collected from children under age 18, please contact us at www.penguinwealth.com.
In Short: In some regions, such as the European Economic Area, you have rights that allow you greater access to
and control over your personal information. You may review, change, or request to delete your information at any
In some regions (like the European Economic Area), 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. To make such a request, please use the contact us on firstname.lastname@example.org. We will
consider and act upon any request in accordance with applicable data protection laws.
If we are relying on your consent to process your personal information, you have the right to withdraw your consent
at any time. Please note however that this will not affect the lawfulness of the processing before its withdrawal.
If you are resident in the European Economic Area 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: http://ec.europa.eu/justice/data-protection/bodies/authorities/index_en.htm] ]
V0.1 16/10/19 – LTD
You can unsubscribe from our marketing email list at any time by clicking on the unsubscribe link in the emails that
we send or by contacting us using the details provided below. You will then be removed from the marketing email
list – however, we will still need to send you service-related emails that are necessary for the administration and
use of your account. You can also opt-out by:
• Contacting us using the contact information provided below
In Short: Yes, we will update this policy as necessary to stay compliant with relevant laws.
date and the updated version will be effective as soon as it is accessible. If we make material changes to this privacy
policy, we may notify you either by prominently posting a notice of such changes or by directly sending you a
If you have questions or comments about this policy, email us [Our Privacy Officer] at email@example.com or
by post to:
Penguin Wealth Planners Ltd
2 Raleigh Walk
If you have any further questions or comments about us or our policies, email us at using the above details