Last Updated: 3rd April 2020
PPEWay is a trading style of CH Halsbury Limited and respects the privacy of its users and are fully committed to protecting their personal information and to use it appropriately. This policy describes how we may collect and use personal information, and the rights and choices available to our visitors and users regarding such information.
- Your Consent (please read carefully!)
Please note: you are not obligated by law to provide us with any information. You hereby acknowledge, warrant and agree that any information you do provide us is provided of your own free will and consent, for the purposes and uses described herein.
- What Information Do We Collect?
Visitor and User Information
We collect two types of information regarding our Visitors and Users:
- Un-identified and non-identifiable information pertaining to a Visitor or un-identified User, which may be made available to us, or collected automatically via his/her use of the Services (“Non-personal Information”). Such Non-personal Information does not enable us to identify the Visitor or User from whom it was collected. The Non-personal Information collected by us mainly consists of technical and aggregated usage information, such as Visitors’ and Users’ browsing and ‘click-stream’ activity on the Services, session heatmaps and scrolls, non-identifying information regarding the Visitor’s or User’s device, operating system, internet browser, screen resolution, language and keyboard settings, internet service provider, referring/exit pages, date/time stamps, etc.
- Individually identifiable information, namely information that identifies an individual or may with reasonable efforts cause the identification of an individual or may be of private or sensitive nature (“Personal Information”). The Personal Information collected by us mainly consists of contact details (e.g., e-mail address or phone number), details regarding a browsing or usage session (IP address, Geo-location and/or device unique identifier), correspondences (including those made through or uploaded to our Services), and any other Personal Information provided to us by Visitors and/or Users through their access to and/or use of the Services. For the avoidance of doubt, any Non-personal Information that is connected or linked to Personal Information (for example, in order to improve the Services we offer) is deemed and treated by us as Personal Information, as long as such connection or linkage exists.
- How Do We Collect Such Information?
There are two main methods we use:
- We collect information through your use of the Services. In other words, when you are visiting or using our Services, including when you browse the Website, we are aware of it any may gather, collect and record such uses, sessions and related information, either independently or with the help of third-party services as detailed in Section 8 below, including through the use of “cookies” and other tracking technologies, as further detailed in Section 9 below.
- We collect information which you provide us voluntarily. For example, we collect the Personal Information you provide us when you register to our Services; when you submit or upload such Personal Information as you use any of our Services; and/or when you contact us directly.
- Why Do We Collect Such Information?
We collect such Non-personal and Personal Information for the following purposes:
- To provide and operate the Services;
- To further develop, customise and improve our Services, based on Visitors’ and Users’ common or personal preferences, experiences and difficulties;
- To provide our Users with ongoing customer assistance and support;
- To create aggregated statistical data and other aggregated and/or inferred Non-personal Information, which we or our business partners may use to provide and improve our respective services;
- To enhance our data security and fraud prevention capabilities;
- To comply with any applicable laws and regulations.
- Where Do We Store Your Information?
CH Halsbury Limited Visitors’, CH Halsbury Limited Users’ Personal Information may be maintained, processed and stored by CH Halsbury Limited and our authorised service providers as necessary for the proper delivery of our Services and/or as may be required by law (as further explained below).
CH Halsbury Limited is based in the UK, which is considered by the European Commission to be offering an adequate level of protection for the personal information of EU Member State residents.
CH Halsbury Limited service providers that store or process your Personal Information on CH Halsbury Limited’s behalf are each committed to keep it protected and secured, in accordance with industry standards and regardless of any lesser legal requirements which may apply in their jurisdiction.
Upon request CH Halsbury Limited will provide you with information about whether we hold any of your personal information. You may access, correct, or request deletion of your personal information by contacting us at email@example.com We will respond to your request within a reasonable timeframe and assist you in making a valid subject access request where appropriate.
- Sharing Personal Information with Third Parties
CH Halsbury Limited may share your Personal Information with third parties (or otherwise allow them access to it) only in the following manners and instances:
Third Party Services:
CH Halsbury Limited has partnered with a number of selected service providers, whose services and solutions complement, facilitate and enhance our own. These include hosting and server co-location services, communications and content delivery networks (CDNs), data and cyber security services, billing and payment processing services, domain name registrars, fraud detection and prevention services, web analytics, e-mail distribution and monitoring services, session recording and remote access services, performance measurement data optimisation and marketing services, content providers, and our legal and financial advisors (collectively, “Third Party Service(s)”).
Such Third-Party Services may receive or otherwise have access to our Visitors’ Personal Information, in its entirety or in part – depending on each of their particular roles and purposes in facilitating and enhancing our Services and business and may only use it for such purposes.
Legal Requests and Duties:
CH Halsbury Limited may disclose or otherwise allow others access to your Personal Information pursuant to a legal request, such as legal proceedings or court order, or in compliance with applicable laws, if we have a good faith that the law requires us to do so, with or without notice to you.
Protecting Rights and Safety:
CH Halsbury Limited may share your Personal Information with others if we believe in good faith that this will help protect the rights, property or personal safety of CH Halsbury Limited, any of our Users, or any member of the general public, with or without notice to you.
Social Media Features and Framed Pages:
Our Services include certain Social Media features and widgets, such as the “Facebook Connect” or “Google Sign-in” features, “Facebook Like” button, the “Share this” button or other interactive mini-programs (“Social Media Features”). These Social Media Features may collect information such as your IP address or which page you are visiting on our Website and may set a cookie to enable them to function properly. Social Media Features are either hosted by a third party or hosted directly on our Services. Your interactions with these third parties are governed by their policies and not ours.
CH Halsbury Limited Subsidiaries and Affiliated Companies:
For the avoidance of doubt, CH Halsbury Limited may share your Personal Information in manners other than as described above, pursuant to your explicit approval, or if we are legally obligated to do so. Moreover, CH Halsbury Limited may transfer, share, disclose or otherwise use Non-personal Information in its sole discretion and without the need for further approval.
The CH Halsbury Limited, together with its marketing, analytics and technology partners, uses certain monitoring and tracking technologies (such as cookies, beacons, pixels, tags and scripts). These technologies are used in order to maintain, provide and improve our Services on an ongoing basis, and in order to provide our Visitors with a better experience. For example, thanks to these technologies, we are able to maintain and keep track of our Visitor’s and Users’ preferences and authenticated sessions, to better secure our Services, to identify technical issues, user trends and effectiveness of campaigns, and to monitor and improve the overall performance of our Services.
Cookies: In order for some of these technologies to work properly, a small data file (“cookie”) must be downloaded and stored on your device. By default, we use several persistent cookies for purposes of session and user authentication, security, keeping the User’s preferences (e.g., regarding default language and settings), connection stability (e.g., for uploading media, using e-Commerce features, etc.), monitoring performance of our services and marketing campaigns, and generally providing and improving our Services.
If you want to delete or block any cookies, please refer to the help and support area on your internet browser for instructions on how to locate the file or directory that stores cookies. Information on deleting or controlling cookies is also available at www.aboutcookie.org (note that this website is not provided by CH Halsbury Limited, and we therefore cannot ensure its accuracy, completeness or availability). Please note that deleting our cookies or disabling future cookies or tracking technologies may prevent you from accessing certain areas or features of our Services or may otherwise adversely affect your user experience.
Most browsers allow you to refuse to accept cookies and to delete cookies. The methods for doing so vary from browser to browser, and from version to version. You can however obtain up-to-date information about blocking and deleting cookies via these links:
Safari – https://support.apple.com/kb/PH21411 ; and
Clear Gifs: We and certain Third-Party Services may employ a software technology called clear gifs (a.k.a. Web Beacons/Web Bugs), which enables them and us to improve our Services by measuring their effectiveness and performance. Clear gifs are tiny graphics with a unique identifier, similar in function to cookies, however unlike cookies these are not stored on your device, but are instead embedded within our Services.
“Do Not Track” Signals: Please note that we do not change our practices in response to a “Do Not Track” signal in the HTTP header from a browser or mobile application.
- Communications from CH Halsbury Limited
By subscribing to any Services (including to any of our newsletters, blogs, social media accounts or public events) and providing CH Halsbury Limited with your e-mail address or any other contact information (such as your phone number), you expressly agree to receive promotional content, messages or calls from CH Halsbury Limited or our partners (acting on CH Halsbury Limited’s behalf) through such means.
Accordingly, CH Halsbury Limited and its partners shall be entitled to call you or send you promotional content or messages by e-mail, SMS, direct text messages, marketing calls and similar forms of communication. If you wish not to receive such promotional messages or calls, you may notify CH Halsbury Limited at any time or follow the “unsubscribe” or STOP instructions contained in the promotional communications you receive.
Service and Billing Messages:
CH Halsbury Limited may also contact you with important information regarding our Services, or your use thereof.
For example, we may send you a notice (through any of the means available to us) if a certain Service is temporarily suspended; or we may send you reminders or warnings regarding upcoming or overdue payments; or notify you of material changes in our Services.
You will not be able to opt-out of receiving such Service and Billing Messages.
- Accessing Your Personal Information
If you wish to access and/or request us to make corrections to the Personal Information that you have stored with us; or wish to request a list of what Personal Information (if any) pertaining to you we disclosed to third parties for direct marketing purposes, feel free to send us an e-mail to or by postal mail to our registered address, and we will respond within a reasonable timeframe and in accordance with any applicable law.
Your principal rights under data protection law are:
(a) the right to access;
(b) the right to rectification;
(c) the right to erasure;
(d) the right to restrict processing;
(e) the right to object to processing;
(f) the right to data portability;
(g) the right to complain to a supervisory authority; and
(h) the right to withdraw consent.
You have the right to confirmation as to whether or not we process your personal data and, where we do, access to the personal data, together with certain additional information. That additional information includes details of the purposes of the processing, the categories of personal data concerned and the recipients of the personal data. Providing the rights and freedoms of others are not affected, we will supply to you a copy of your personal data. The first copy will be provided free of charge, but additional copies may be subject to a reasonable fee.
You have the right to have any inaccurate personal data about you rectified and, taking into account the purposes of the processing, to have any incomplete personal data about you completed.
In some circumstances you have the right to the erasure of your personal data without undue delay. Those circumstances include: where holding your personal data is no longer necessary in relation to the purposes for which they were collected or otherwise processed; you withdraw consent to consent-based processing; you object to the processing under certain rules of applicable data protection law; the processing is for direct marketing purposes; and the personal data have been unlawfully processed. However, there are exclusions of the right to erasure. The general exclusions include where processing is necessary: for exercising the right of freedom of expression and information; for compliance with a legal obligation; or for the establishment, exercise or defence of legal claims.
In some circumstances you have the right to restrict the processing of your personal data. Those circumstances are: you contest the accuracy of the personal data; processing is unlawful but you oppose erasure; we no longer need the personal data for the purposes of our processing, but you require personal data for the establishment, exercise or defence of legal claims; and you have objected to processing, pending the verification of that objection. Where processing has been restricted on this basis, we may continue to store your personal data. However, we will only otherwise process it: with your consent; for the establishment, exercise or defence of legal claims; for the protection of the rights of another natural or legal person; or for reasons of important public interest.
You have the right to object to our processing of your personal data on grounds relating to your particular situation, but only to the extent that the legal basis for the processing is that the processing is necessary for: the performance of a task carried out in the public interest or in the exercise of any official authority; or the purposes of the legitimate interests pursued by us or by a third party. If you make such an objection, we will cease to process the personal information unless we can demonstrate compelling legitimate grounds for the processing which override your interests, rights and freedoms, or the processing is for the establishment, exercise or defence of legal claims.
You have the right to object to our processing of your personal data for direct marketing purposes (including profiling for direct marketing purposes). If you make such an objection, we will cease to process your personal data for this purpose.
You have the right to object to our processing of your personal data for scientific or historical research purposes or statistical purposes on grounds relating to your particular situation, unless the processing is necessary for the performance of a task carried out for reasons of public interest.
To the extent that the legal basis for our processing of your personal data is:
(a) consent; or
(b) that the processing is necessary for the performance of a contract to which you are party or in order to take steps at your request prior to entering into a contract,
and such processing is carried out by automated means, you have the right to receive your personal data from us in a structured, commonly used and machine-readable format. However, this right does not apply where it would adversely affect the rights and freedoms of others.
If you consider that our processing of your personal information infringes data protection laws, you have a legal right to lodge a complaint with a supervisory authority responsible for data protection. The supervisory authority in the UK is the Information Commissioner’s Office (ICO) and any concerns can be raised at https://ico.org.uk/concerns
To the extent that the legal basis for our processing of your personal information is consent, you have the right to withdraw that consent at any time. Withdrawal will not affect the lawfulness of processing before the withdrawal.
You may exercise any of your rights in relation to your personal data by written notice to us OR email to firstname.lastname@example.org
- Data Retention
We may retain your Personal Information for as long as your Account is active or as otherwise needed to provide you with our Services.
We may continue to retain such Personal Information even after you close your Account and/or cease to use any particular Services, as reasonably necessary to comply with our legal obligations, to resolve disputes, prevent fraud and abuse, enforce our agreements and/or protect our legitimate interests.
We are required under UK tax law to keep your basic personal data relating to the Services we provide (name, address, contact details) for a minimum of 6 years after which time it will be destroyed. If you have asked us to prepare testamentary documentation the information may be retained for a minimum of 6 years from the date your documentation is actioned (your date of death). The retention time may be longer where partners or spouses have drafted Wills together, as the details of the individual who passed away first (first death) may be held for a minimum of 6 years following the death of the surviving spouse or partner (second death). The information we use for marketing purposes and to advise you of any changes in legislation or recommended best practise guidance will be kept with us until you notify us that you no longer wish to receive this information.
CH Halsbury Limited has implemented security measures designed to protect the Personal Information you share with us, including physical, electronic and procedural measures. Among other things, we offer HTTPS secure access to most areas on our Services. We also regularly monitor our systems for possible vulnerabilities and attacks, and regularly seek new ways and Third-Party Services for further enhancing the security of our Services and protection of our Visitors’ and Users’ privacy.
However, regardless of the measures and efforts taken by CH Halsbury Limited, we cannot and do not guarantee the absolute protection and security of your Personal Information or any other Information that you share with CH Halsbury Limited or anyone else.
If you have any questions regarding the security of our Services, you are more than welcome to contact us at email@example.com.
- Public Forums and User Content
Our Services offer publicly accessible blogs, communities and support forums. Be aware that any information you provide in any such areas may be read, collected, and used by others who access them. To request removal of your Personal Information from our blogs, communities or forums, feel free to contact us at: firstname.lastname@example.org. In some cases, we may not be able to remove your Personal Information from such areas. For example, if you use a third-party application to post a comment (e.g., the Facebook social plugin application) while logged in to your related profile with such third party, you will need to login into such application or contact its provider if you want to have the Personal Information you posted through it removed.
In any event, we recommend that you do not post any information (or use any posting means to post information) you would not want to be made public on these areas.
Any heading, caption or section title contained herein, and any explanation, is provided only for convenience, and in no way defines or explains any section or provision hereof, or legally binds any of us in any way.
- Contacting Us