Pemberton:Privacy policy

Pemberton Digital - Privacy Policy

17/10/2024

Our Commitment to Privacy

At Pemberton Digital, we believe that understanding how spaces are used shouldn't come at the cost of personal privacy. That's why we've built our entire technology stack around a simple principle: collecting valuable insights without collecting personal information.

Our sensors use advanced radar technology to understand space utilisation and occupancy patterns. Unlike camera-based systems that require privacy masking or face-blurring, our sensors cannot and do not capture any images, videos, or identifying information about individuals. When someone walks past one of our sensors, all we know is that a person is present – not who they are, what they look like, or where they've been before.

This privacy-by-design approach means that the people moving through spaces monitored by our sensors maintain complete anonymity. There are no images to hack, no faces to blur, and no personal data to protect because we simply don't collect it in the first place.

For our customers who use our dashboard to view analytics and insights, we are equally committed to protecting your privacy. This Privacy Policy explains how we handle the information we do collect to provide our services, and the measures we take to keep that information secure.

Introduction

This Privacy Policy applies between you, the User of our Website and Application, and Pemberton Digital Ltd, the owner and provider of these services. We take the privacy of your information very seriously, and this Privacy Policy explains our practices regarding any data collected through our website at https://pemberton.digital and our application at https://app.pemberton.digital.

Please read this Privacy Policy carefully as it affects your rights and liabilities under law. If you do not agree with the terms of this Privacy Policy, please do not use our Website or Application.

Understanding Our Service and Data Collection

Pemberton Digital provides occupancy and space analytics through a network of radar sensors that count people and measure occupancy levels. It's important to understand that our service involves different types of data:

Sensor Data consists entirely of anonymous counting and movement patterns. Our radar technology detects the presence and movement of people but cannot identify individuals. This is fundamentally different from camera-based systems – we don't capture images that need to be masked or blurred because we don't capture images at all.

Customer Data relates to the organisations and individuals who purchase our services and use our dashboard to view analytics. This includes account information and usage data necessary to provide our services.

Website Data covers information collected when people visit our website, primarily through cookies and analytics tools.

Who We Are

Pemberton Digital Ltd is a company incorporated in England and Wales with registered number 14422623. Our registered office is at Lytchett House, 13 Freeland Park, Wareham Road, Poole, BH16 6FA. For the purposes of data protection law, we are the "data controller" responsible for the personal data we collect through our Website and Application.

Information We Collect

When You Visit Our Website

When you browse our website, we automatically collect certain technical information to help us understand how visitors use our site and to improve their experience. This includes your IP address, the type of browser and device you're using, which pages you visit, and how you arrived at our site. We use Google Analytics to help us analyse this information in aggregate form.

We also collect information you provide directly when you contact us through our website, such as your name, email address, company name, and the content of your enquiry.

When You Use Our Application

For customers who register to use our dashboard application, we collect the information needed to create and manage your account. This includes your name, email address, job title, company name, and contact details. We also collect information about how you use the application, such as when you log in, which features you access, and what reports you generate.

Your account credentials are stored securely with passwords encrypted using industry-standard methods. We maintain logs of system access for security and troubleshooting purposes.

From Our Sensors

Our radar sensors detect and count people in spaces, measuring occupancy levels, movement patterns, and dwell times. This data is completely anonymous – the sensors cannot determine any identifying characteristics of individuals. They simply detect that a person is present, not who that person is.

This is a fundamental aspect of our technology choice. While some competitors use cameras that capture images requiring privacy masking, our radar-based approach means there are no images to protect and no risk of identifying individuals.

How We Use Information

The information we collect serves different purposes depending on its type:

Website visitor information helps us improve our website's content and navigation, understand which pages are most useful, and respond to enquiries effectively. We analyse this data in aggregate to identify trends and improve user experience.

Application user information enables us to provide access to our dashboard, manage accounts, deliver customer support, send important service updates, and ensure the security of our systems. We may also use this information to inform you about new features or services that might benefit your organisation.

The anonymous sensor data we collect is used to generate the analytics and insights our customers rely on. This might include occupancy reports, usage patterns, space efficiency metrics, and other analytical outputs. We may also use aggregated sensor data to develop industry benchmarks and insights, but this is always done in a way that maintains the anonymity of both the individuals counted and our customers.

Sharing Information

We work with carefully selected service providers who help us deliver our services. These include European cloud hosting providers who store our data, analytics services like Google Analytics that help us understand website usage, email service providers for customer communications, and customer support platforms.

These providers are contractually required to protect your information and can only use it to provide services to us. We ensure they maintain appropriate security standards and comply with applicable data protection laws.

We may also share information with our professional advisers, such as lawyers and accountants, who are bound by professional confidentiality obligations. If legally required, we may disclose information to law enforcement or regulatory authorities. In the event of a potential sale or restructuring of our business, relevant information may be shared with prospective purchasers under strict confidentiality agreements.

We never sell, rent, or trade personal information to third parties for their marketing purposes.

Protecting Your Information

Security is fundamental to our service. We implement comprehensive technical and organisational measures to protect all information in our care.

All data transmitted between your browser and our systems is encrypted using current TLS protocols. Data stored in our systems is encrypted at rest. We use secure cloud infrastructure with regular security updates and monitoring. Access to systems is strictly controlled through authentication requirements and role-based permissions.

Our cloud infrastructure is based in the European Union and the United Kingdom.

For our Application, we offer additional security features including multi-factor authentication. We conduct regular security assessments and maintain incident response procedures.

How Long We Keep Information

We retain information only as long as necessary for the purposes described in this policy or as required by law. Website visitor data collected through Google Analytics is retained for 26 months according to Google's standard retention policy. Application user accounts are maintained for the duration of your service agreement plus 12 months to handle any post-contract matters. Communications related to customer support are retained for three years to help us provide consistent service.

When information is no longer needed, we ensure it is securely deleted or anonymised.

Your Rights

Data protection law gives you several rights regarding your personal information. You can request access to the personal information we hold about you, ask us to correct any inaccuracies, request deletion of your information (subject to our legal obligations), restrict how we process your information, receive your data in a portable format, and object to certain types of processing.

To exercise any of these rights, please contact us at support@pemberton.digital. We will respond to your request within one month, though complex requests may take longer. We may need to verify your identity before processing your request.

Cookies and Analytics

Our website uses cookies, which are small text files stored on your device, to improve your experience and help us understand how our site is used. Essential cookies are necessary for features like maintaining your session when logged into the Application. Analytics cookies, primarily from Google Analytics, help us understand website usage patterns.

You can control cookie settings through your browser, though disabling certain cookies may affect website functionality. For detailed information about cookies and how to manage them, visit http://www.aboutcookies.org .

Google Analytics collects aggregated information about website visits, including pages viewed, visit duration, and general geographic location (at country or city level). If you prefer not to be tracked by Google Analytics, you can install the Google Analytics Opt-out Browser Add-on.

International Transfers

To provide our services, we may transfer information to service providers located outside the UK or European Economic Area. When we do this, we ensure appropriate safeguards are in place, such as standard contractual clauses approved by relevant authorities or relying on adequacy decisions. Our primary infrastructure providers maintain high security standards and appropriate certifications for international data transfers.

Children's Privacy

Our services are designed for business use and are not intended for children under 16. We do not knowingly collect personal information from children. If we become aware that we have inadvertently collected such information, we will promptly delete it.

Changes to This Policy

We may update this Privacy Policy as our services evolve or legal requirements change. Any updates will be posted on this page with a new "Last Updated" date. If we make significant changes that affect how we handle your personal information, we will notify active customers by email. Your continued use of our services after changes are posted constitutes acceptance of the updated policy.

Contact Us

We welcome questions and feedback about our privacy practices. You can reach our data protection team at:

• Email: support@pemberton.digital
• Post: Data Protection Officer, Pemberton Digital Ltd, Lytchett House, 13 Freeland Park, Wareham Road, Poole, BH16 6FA

If you have concerns about how we handle your information that we haven't been able to resolve, you have the right to lodge a complaint with the Information Commissioner's Office (ICO). You can contact the ICO at Home or by calling 0303 123 1113.

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