Overview
Paplis Group Holding (“Paplis”, “we”, “us” or “our”) is a holding group that brings together a portfolio of independently operated businesses. This Privacy Policy applies to the corporate website at paplisgroup.com (the “Site”) and to enquiries you send us directly.
It does not cover the websites, products or services of the individual companies in the group, each of which operates independently and publishes its own privacy notice. See section 13.
By using the Site you acknowledge the practices described here. If you do not agree with this policy, please do not use the Site.
Who we are
The data controller responsible for personal information collected through the Site is [registered company name], a company registered in [country / jurisdiction] under number [company registration number], with its registered office at [registered office address].
For any privacy question, or to exercise your rights, contact us at info@paplisgroup.com or by post at the address above, marked for the attention of the Privacy Team.
Information we collect
Information you provide to us
When you contact us, for example by email or through a contact or enquiry form, we collect the information you choose to give us. This typically includes your name, email address, organisation, and the content of your message.
Information collected automatically
When you visit the Site, certain information is collected automatically by us or our service providers, including:
- device and browser type, operating system, and screen settings;
- your approximate location, derived from your IP address;
- pages viewed, links clicked, referring pages, and the dates and times of your visits;
- diagnostic and performance data used to keep the Site secure and working correctly.
We do not ask for special categories of data (such as health, political or biometric data) and ask that you do not send them to us.
How we use information
We use personal information to:
- respond to your enquiries and correspond with you;
- operate, maintain, secure and improve the Site;
- understand how the Site is used, in aggregate, so we can make it better;
- evaluate potential partnerships, investments and business opportunities;
- comply with legal obligations and enforce our Terms of Use;
- establish, exercise or defend legal claims.
We do not sell personal information, and we do not use it for automated decision-making that produces legal or similarly significant effects.
Legal bases for processing
Where data protection law such as the GDPR or UK GDPR applies, we rely on the following legal bases:
- Legitimate interests: to respond to enquiries, run and secure the Site, and pursue business opportunities, where those interests are not overridden by your rights;
- Consent: for non-essential cookies and analytics, where required (you can withdraw consent at any time);
- Legal obligation: where we must retain or disclose information to comply with the law;
- Performance of a contract: where we are taking steps at your request prior to entering into a contract.
Cookies & similar technologies
The Site uses a small number of cookies and similar technologies. Strictly necessary cookies keep the Site secure and remember your display preferences; these cannot be switched off. Analytics cookies help us understand usage in aggregate and are only set where permitted.
You can control cookies through your browser settings and, where offered, through the cookie banner on the Site. Blocking some cookies may affect how the Site works. This section will be updated with a full cookie table once the Site's analytics configuration is finalised: [list cookie names, providers, purposes and retention].
Sharing & disclosure
We share personal information only as described below:
- Group companies: with entities within the Paplis group where relevant to your enquiry, under appropriate safeguards;
- Service providers: with vendors that host the Site, deliver email, or provide analytics and security, acting on our instructions;
- Professional advisers: lawyers, auditors and insurers, where necessary;
- Legal and safety: where required by law, regulation or legal process, or to protect the rights, property or safety of Paplis, our users or others;
- Corporate transactions: in connection with a merger, acquisition, financing or sale of assets, subject to confidentiality.
International transfers
Paplis and its service providers may process personal information in countries other than the one in which you are located. Where information is transferred out of the UK, EEA or another region with data-transfer restrictions, we rely on an adequacy decision or on appropriate safeguards such as Standard Contractual Clauses. Details of the safeguards used are available on request from info@paplisgroup.com.
Data retention
We keep personal information only for as long as needed for the purposes set out in this policy. Enquiry correspondence is generally retained for up to [retention period, e.g. 24 months] after our last contact, unless a longer period is required for legal, tax or dispute-resolution reasons. Aggregated analytics data that no longer identifies you may be kept indefinitely.
Your rights
Subject to applicable law, you may have the right to:
- access the personal information we hold about you;
- have inaccurate information corrected;
- have information erased in certain circumstances;
- restrict or object to certain processing;
- receive certain information in a portable format;
- withdraw consent where processing is based on consent;
- lodge a complaint with your local supervisory authority (in the UK, the Information Commissioner's Office; elsewhere, [relevant data protection authority]).
To make a request, email info@paplisgroup.com. We will respond within the timeframe required by law and may need to verify your identity first.
Security
We use technical and organisational measures designed to protect personal information against loss, misuse and unauthorised access, disclosure or alteration. No method of transmission or storage is completely secure, so we cannot guarantee absolute security. If we become aware of a personal data breach that affects you, we will notify you and the relevant regulator where required by law.
Children's privacy
The Site is intended for a business audience and is not directed at children. We do not knowingly collect personal information from children under the age of 16. If you believe a child has provided us with personal information, contact us and we will delete it.
Third-party & portfolio company sites
The Site links to the websites of companies within the group and to other third-party sites. Those sites are controlled by others and have their own privacy notices and terms. Paplis is not responsible for the content or privacy practices of any site it links to. Review each site's own policy before providing personal information.
Changes to this policy
We may update this policy from time to time. When we do, we will change the “last updated” date above and, where changes are significant, provide a more prominent notice. Continued use of the Site after an update means you accept the revised policy.
Contact us
Questions, requests or complaints about this policy or your personal information can be sent to:
Paplis Group Holding
Privacy Team
info@paplisgroup.com
[registered office address]