Portolio Ltd understands that your privacy is important to you and that you care about how your personal data is used and shared online. We respect and value the privacy of everyone who visits this website, www.portolio.co.uk (“Our Site”) and will only collect and use personal data in ways that are described here, and in a manner that is consistent with Our obligations and your rights under the law.
Please read this Privacy Policy carefully and ensure that you understand it. Your acceptance of Our Privacy Policy is deemed to occur upon your first use of Our Site. If you do not accept and agree with this Privacy Policy, you must stop using Our Site immediately.
Our Privacy Promise
We promise:
- To keep your data safe and private
- Not to sell your data
- To give you ways to manage and review your marketing choices at any time.
- Definitions and Interpretation
In this Policy, the following terms shall have the following meanings:
“Account” means an account required to access and/or use certain areas and features of Our Site
“Cookie” means a small text file placed on your computer or device by Our Site when you visit certain parts of Our Site and/or when you use certain features of Our Site. Details of the Cookies used by Our Site are set out in section 14 (below)
“Cookie Law” means the relevant parts of the Privacy and Electronic Communications (EC Directive) Regulations 2003
“Personal data” means any and all data that relates to an identifiable person who can be directly or indirectly identified from that data. In this case, it means personal data that you give to Us via Our Site. This definition shall, where applicable, incorporate the definitions provided in the EU Regulation 2016/679 – the General Data Protection Regulation (“GDPR”); and
“We/Us/Our” means Portolio Ltd, a limited company registered in Scotland under company number 575618, whose registered address is 101 Rose Street South Lane, Edinburgh, EH2 3JG.
- About Us
Our Site is owned and operated by Portolio Ltd, a limited company registered in Scotland under company number 575618, whose registered address is 101 Rose Street South Lane, Edinburgh, EH2 3JG. Our VAT number is 280 0968 94.
- What Does This Policy Cover?
This Privacy Policy applies only to your use of Our Site. Our Site may contain links to other websites. Please note that We have no control over how your data is collected, stored, or used by other websites and We advise you to check the privacy policies of any such websites before providing any data to them.
- Your Rights
You have the following rights under the GDPR, which this Policy and Our use of personal data have been designed to uphold:
- The right to be informed about Our collection and use of personal data
- The right of access to the personal data We hold about you
- The right to rectification if any personal data We hold about you is inaccurate or incomplete
- The right to be forgotten – i.e. the right to ask Us to delete any personal data We hold about you
- The right to restrict (i.e. prevent) the processing of your personal data
- The right to data portability (obtaining a copy of your personal data to re-use with another service or organisation)
- The right to object to Us using your personal data for particular purposes
- Rights with respect to automated decision making and profiling.
If you have any cause for complaint about Our use of your personal data, please contact Us using the details provided under section 16 and We will do Our best to solve the problem for you. If We are unable to help, you also have the right to lodge a complaint with the UK’s supervisory authority, the Information Commissioner’s Office.
For further information about your rights, please contact the Information Commissioner’s Office or your local Citizens Advice Bureau.
- What Data Do We Collect?
Depending upon your use of Our Site, We may collect some or all of the following personal and non-personal data.
- Name
- Date of birth
- Gender
- Business/company name
- Job title
- Profession
- Contact information such as email addresses and telephone numbers
- Demographic information such as post code, preferences, and interests
- Financial information such as credit/debit card numbers
- IP address
- Web browser type and version
- Operating system
- A list of URLs starting with a referring site, your activity on Our Site, and the site you exit to
- How Do We Use Your Data?
All personal data is processed and stored securely, for no longer than is necessary in light of the reason(s) for which it was first collected. We will comply with Our obligations and safeguard your rights under the GDPR at all times.
Our use of your personal data will always have a lawful basis, either because it is necessary for Our performance of a contract with you, because you have consented to Our use of your personal data (e.g. by subscribing to emails), or because it is in Our legitimate interests. Specifically, We may use your data for the following purposes:
- Providing and managing your Account
- Providing and managing your access to Our Site
- Personalising and tailoring your experience on Our Site
- Supplying Our products and/or services to you (please note that We require your personal data in order to enter into a contract with you)
- Personalising and tailoring Our products and/or services for you
- Replying to emails from you
- Supplying you with emails that you have opted into (you may unsubscribe or opt-out at any time by clicking on the unsubscribe link at the base of emails or by emailing us directly requesting your email address to be removed from our mailing list
- Market research
- Analysing your use of Our Site and gathering feedback to enable Us to continually improve Our Site and your user experience
With your permission and/or where permitted by law, We may also use your data for marketing purposes which may include contacting you by email, telephone, text message or post with information, news and offers on Our products and/or services. We will not, however, send you any unsolicited marketing or spam and will take all reasonable steps to ensure that We fully protect your rights and comply with Our obligations under the GDPR and the Privacy and Electronic Communications (EC Directive) Regulations 2003.
- Storing your data
We do not keep your personal data for any longer than is necessary in light of the reason(s) for which it was first collected. Some or all of your data may be stored outside of the UK or European Economic Area (“the EEA”) (The EEA consists of all EU member states, plus Norway, Iceland, and Liechtenstein). You are deemed to accept and agree to this by using Our Site and submitting information to Us. If We do store data outside the EEA, We will take all reasonable steps to ensure that your data is treated as safely and securely as it would be within the UK and under the GDPR.
- Do We Share Your Data?
In certain circumstances, We may be legally required to share certain data held by Us, which may include your personal data, for example, where We are involved in legal proceedings, where We are complying with legal obligations, a court order, or a governmental authority.
We may sometimes contract with third parties to supply products and services to you on Our behalf. These may include payment processing, delivery of goods, search engine facilities, advertising, and marketing. In some cases, the third parties may require access to some or all of your data. Where any of your data is required for such a purpose, We will take all reasonable steps to ensure that your data will be handled safely, securely, and in accordance with your rights, Our obligations, and the obligations of the third party under the law.
We may compile statistics about the use of Our Site including data on traffic, usage patterns, user numbers, sales, and other information. All such data will be anonymised and will not include any personally identifying data, or any anonymised data that can be combined with other data and used to identify you.
We may sometimes use third party data processors that are located outside of the UK or European Economic Area (“the EEA”) (The EEA consists of all EU member states, plus Norway, Iceland, and Liechtenstein). Where We transfer any personal data outside the EEA, We will take all reasonable steps to ensure that your data is treated as safely and securely as it would be within the UK and under the GDPR.
- What Happens If Our Business Changes Hands?
We may, from time to time, expand or reduce Our business and this may involve the sale and/or the transfer of control of all or part of Our business. Any personal data that you have provided will, where it is relevant to any part of Our business that is being transferred, be transferred along with that part and the new owner or newly controlling party will, under the terms of this Privacy Policy, be permitted to use that data only for the same purposes for which it was originally collected by Us.
- How Can You Control Your Data?
When you submit personal data via Our Site, you may be given options to restrict Our use of your data. In particular, We aim to give you strong controls on Our use of your data for direct marketing purposes (including the ability to opt-out of receiving emails from Us).
You may also wish to sign up to one or more of the preference services operating in the UK: The Telephone Preference Service (“the TPS”), the Corporate Telephone Preference Service (“the CTPS”), and the Mailing Preference Service (“the MPS”). These may help to prevent you receiving unsolicited marketing. Please note, however, that these services will not prevent you from receiving marketing communications that you have consented to receiving.
- How Can You Access Your Data?
You have the right to ask for a copy of any of your personal data held by Us (where such data is held). Under the GDPR, no fee is payable and We will provide any and all information in response to your request free of charge. Please contact Us for more details at [email protected], or telephoning 0131 500 0495.
- What are Cookies?
Cookies and other online tracking technologies are small bits of data or code that are used to identify your devices when you use and interact with our websites and other services. They are often used for remembering your preferences, and generally improving your online experience.
- Our Use of Cookies
- Certain features of Our Site depend on Cookies to function. Cookie Law deems these Cookies to be “strictly necessary”. These Cookies are described below. Your consent will not be sought to place these Cookies, but it is still important that you are aware of them. You may still block these Cookies by changing your internet browser’s settings, but please be aware that Our Site may not work properly if you do so. We have taken great care to ensure that your privacy is not at risk by allowing them.
- Our Site may place and access certain first party Cookies on your computer or device. First party Cookies are those placed directly by Us and are used only by Us. We use Cookies to facilitate and improve your experience of Our Site and to provide and improve Our products and/or services. We have carefully chosen these Cookies and have taken steps to ensure that your privacy and personal data is protected and respected at all times.
- By using Our Site you may also receive certain third party Cookies on your computer or device. Third party Cookies are those placed by websites, services, and/or parties other than Us. These Cookies are not integral to the functioning of Our Site and your use and experience of Our Site will not be impaired by refusing consent to them.
- Before Cookies are placed on your computer or device, you will receive a pop-up prompt requesting your consent to set those Cookies. By giving your consent to the placing of Cookies you are enabling Us to provide the best possible experience and service to you. You may, if you wish, deny consent to the placing of Cookies; however certain features of Our Site may not function fully or as intended. [You will be given the opportunity to allow only first party Cookies and block third party Cookies.]
- All Cookies used by and on Our Site are used in accordance with current Cookie Law.
- Types of Cookies
There are several types of Cookies, some of which may be used by and on Our Site.
Strictly Necessary Cookies
These cookies are essential for the running of a website and its features. They allow proper website functionality and access to services such as your account, secure shopping and posting comments on a blog. Without them, a website cannot perform properly.
Performance Cookies
These cookies collect information about how visitors use a website. For example, which pages are visited most often, how people navigate around the site and if there are any error messages that appear. They don’t collect any information that identifies a user, only anonymised, aggregated information that is used to improve the way the website works and the customer journey.
Functionality Cookies
These cookies allow a website to remember your preferences and choices you make, such as your preferred language, region and username. They gather information on things you customise and select and retain it for your next visit. They are not essential but enhance the user experience of a site.
Third Party Cookies
Some website pages may use third party services or software, such as maps, online videos or social networking features. Many of these services may set cookies in your browser. This website has no control over third party cookies but visitors can opt out of these cookies via their browser.
Flash cookies
Flash cookies are commonly used in website advertisements, video clips and animation. They enable a website to recognise the user’s browser when it returns and store information such as when a video stopped playing. They also provide functions such as remembering your settings and preferences.
Advertising Cookies
These cookies are used by advertisers to deliver adverts that are more relevant to you and your interests. They keep track of which ads a person has viewed, control how many times they are exposed to the same advert and track the effectiveness of marketing campaigns. This information can then be used in remarketing, by customising adverts the user sees on other websites.
Web Beacons
Web beacons are bits of data that count the number of users who access a website or webpage. They allow an organisation to see if a cookie has been activated, if a user has clicked through to links to adverts contained in emails. This is used to identify which emails are of most interest to a customer and to track the success of advertisements.
- Enabling/Disabling Cookies
In addition to the controls that We provide, you can choose to enable or disable Cookies in your internet browser. Most internet browsers also enable you to choose whether you wish to disable all cookies or only third party Cookies. By default, most internet browsers accept Cookies but this can be changed. For further details, please consult the help menu in your internet browser or the documentation that came with your device.
You can choose to delete Cookies on your computer or device at any time, however you may lose any information that enables you to access Our Site more quickly and efficiently including, but not limited to, login and personalisation settings.
It is recommended that you keep your internet browser and operating system up-to-date and that you consult the help and guidance provided by the developer of your internet browser and manufacturer of your computer or device if you are unsure about adjusting your privacy settings.
- Contacting Us
If you have any questions about Our Site or this Privacy Policy, please contact Us by email at [email protected], by telephone on 0131 500 0495. Please ensure that your query is clear, particularly if it is a request for information about the data We hold about you.
- Changes to Our Privacy Policy
We may change this Privacy Policy from time to time (for example, if the law changes). Any changes will be immediately posted on Our Site and you will be deemed to have accepted the terms of the Privacy Policy on your first use of Our Site following the alterations. We recommend that you check this page regularly to keep up-to-date.