Hi, and welcome to our privacy policy.

The PA Way is a membership platform provided by The PA Way Limited (we’ll refer to ourselves as ‘we’, ‘us’, and ‘our’). We are the controller of personal data obtained through The PA Way, which means we are the organisation legally responsible for deciding how and for what purpose that data is used.

We take your privacy seriously, so please read this policy carefully as it contains important information about who we are, and how and why we collect, store, and use any information that could be used to identify you (your ‘personal data’) when you use The PA Way. We’ll also explain your rights in respect of your personal data and how you can contact us or the regulator if you want to make a complaint.

We collect and use certain personal data about you on The PA Way. When we do that, we are subject to the UK General Data Protection Regulation (better known as the ‘UK GDPR’).

This policy is split out into headed sections to hopefully make it easier for you to navigate and read. If you need this policy in another format (such as audio, large print, or braille), please just let us know by using the contact details in the How to contact us section of this policy.

What this policy applies to

This policy relates to your membership and use of The PA Way only. You might find links to other websites owned and operated by third parties, and they might gather information about you under their own separate privacy policy.

Personal data we collect about you

We collect the following personal data about you. If you choose not to share any of the following personal data, you might not be able to use The PA Way (we’ll tell you when this is the case):

• your name, address, and contact information, including email address, telephone number, and company details;
• your billing information, transaction, and payment card or other payment method information;
• bank account and payment details;
• your activities on, and use of, The PA Way; and
• information about the services we provide to you.

We may also collect personal data that you voluntarily share on The PA Way, such as:

• your gender;
• location data;
• details of any information, feedback, or other matters you share with us;
• your personal and professional interests; or
• your professional online presence, such as your LinkedIn profile.

How your personal data is collected

We collect personal data from you directly when you enter or send us information, such as when you register with The PA Way, contact us, send us feedback, sign up for services, etc. We might also collect data from you when you volunteer information via The PA Way.

How and why we use your personal data

Under data protection laws, we can only use your personal data if we have a proper reason to do so, such as:

• where you have given consent;
• to comply with our legal and regulatory obligations;
• to perform a contract or services with/for you; or
• for our legitimate interests or those of a third party.

A ‘legitimate interest’ is when we have a business or commercial reason to use your personal data, so long as this isn’t overridden by your own rights and interests. We assess our interests against your own if we ever rely on legitimate interests to use your personal data.

We use your personal data for the following reasons (this is quite technical legally, so we’ve tried to make this as clear as possible for you):

• to create and manage your account with us. We do so to perform a contract or services with/for you;
• communications with you not related to marketing, such as changes to our terms or policies or changes to the services we offer. We do so to comply with our legal and regulatory obligations, and in other cases for our legitimate interests (such as to be as efficient as we can to deliver the best services to you);
• updating and enhancing our member records. We do so to perform a contract or services with/for you, to comply with our legal and regulatory obligations, or for our legitimate interests (such as making sure we can keep in touch with our members for new services and updates; and
• marketing our services to existing and former members. We do so for our legitimate interests (such as promoting The PA Way and its services to existing and former members). There’s more detail on this below.

Marketing

We will use your personal data to send you updates by email about The PA Way, our services, and our features, including exclusive offers or promotions. We have a legitimate interest in using your personal data for marketing purposes (see above).

You do have the right to opt out of receiving marketing communications at any time by using the unsubscribe link in emails.

We will always treat your personal data with the utmost respect and never sell or share it with other organisations for marketing purposes.

Who we share your personal data with

We routinely share personal data with third parties we use to help deliver services and features to you under The PA Way. We also share personal data with other third parties that we use to help us run The PA Way, such as marketing agencies, website hosts, and our banks.

We may also share personal data with our professional advisers (such as or lawyers or accountants) and law enforcement agencies, courts, and regulatory bodies if we need to in order to comply with our legal and regulatory obligations.

We do not share your personal data with any other third party.

How long your personal data will be kept

We will not keep your personal data for longer than we need it for the purposes for which we use it. If you cancel your membership to The PA Way, we will delete or anonymise your account data within a reasonable amount of time.

Transferring your personal data out of the UK

We do not transfer your personal data out of the UK.

Your rights

You generally have the following rights, which you can usually exercise free of charge (we’ve tried to make these as clear as possible, but please contact us if you have any questions):

• the right to be provided with a copy of your personal data;
• the right to require us to correct any mistakes in your personal data;
• the right to require us to delete your personal data (in certain situations);
• the right to require us to restrict us of your personal data (in certain situations);
• the right to receive the personal data you provided to us in a structured, commonly used, and machine-readable format and/or transmit that data to a third party (in certain situations);
• the right to object at any time to your personal data being used for direct marketing and (in certain situations) to our continued use of your personal data;
• the right not to be subject to a decision based solely on automated processing – we do not make any such decisions based on data collected by your membership of The PA Way; and
• if you have given us your consent to use your personal data, you have the right to withdraw that consent easily at any time.

For more information of each of these rights, you might find it helpful to look at the guidance from the Information Commissioner on your rights under the UK GDPR.

Keeping your personal data secure

We have appropriate security measures to prevent personal data from being accidentally lost, or used or accessed unlawfully. We also limit access to your personal data to those who have a genuine need to access it.

We will notify you and the regulator of a suspected data security breach where we are legally required to do so.

How to contact us

You can contact us by post or email if you have any questions about this policy or the information we hold about you, to exercise a right under the UK GDPR or to make a complaint.

Our contact details are:

• by email: info@thepaway.co.uk; and
• by post: Suite 15 Highfield House, 185 Chorley New Road, Bolton, BL1 4QZ.

How to complain

We hope we can resolve any issues you might have. If we haven’t addressed your questions or concerns in a manner you’re happy with, you have the right to lodge a complaint with the Information Commissioner. The Information Commissioner may be contacted using the details are ico.org.uk/make-a-complaint.

Changes to this privacy policy

We may change this privacy policy from time to time. If we make significant changes, we will inform you by email.