Website privacy policy (GDPR and DPA 2018) (UK)
July 2024
INTRODUCTION
Welcome to the Pioneer Business Development Solutions (PBDS) privacy policy.
PBDS respects your privacy and is committed to protecting your personal data. This privacy policy will inform you as to how
we look after your personal data when you visit our website (regardless of where you visit it from) and tell you about your
privacy rights and how the law protects you.
This privacy policy is provided in a layered format so you can click through to the specific areas set out below. Alternatively,
you can access a pdf version of the policy here by contacting a member of the admin team. Please also use the Glossary to
understand the meaning of some of the terms used in this privacy policy.

1. IMPORTANT INFORMATION AND WHO WE ARE
PURPOSE OF THIS PRIVACY POLICY
This privacy policy aims to give you information on how PBDS collects and processes your personal data through your use of
our website and the website/ social media platforms of partner organisations we support, including any data you may provide
through such aforementioned portals when you [sign up to our newsletter OR purchase a product or service OR take part in a
competition OR join a fundraising lottery via a partner’s online direct debit platform.
This website is not intended for children and we do not knowingly collect data relating to children.
It is important that you read this privacy policy together with any other privacy policy or fair processing policy we may provide
on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why
we are using your data. This privacy policy supplements other notices and privacy policies and is not intended to override
them.

CONTROLLER
PBDS is the controller and responsible for your personal data (collectively referred to as [” COMPANY”], “we”, “us” or “our”
in this privacy policy).
We have appointed a Data Protection Officer (DPO) who is responsible for overseeing questions in relation to this privacy
policy. If you have any questions about this privacy policy, including any requests to exercise [your legal rights], please contact
the DPO using the details set out below.
CONTACT DETAILS
If you have any questions about this privacy policy or our privacy practices, please contact our DPO in the following ways:
Full name of legal entity: Pioneer Business Development Solutions
Email address: markg@pioneerbds.com or info@pioneerbds.com
Postal address: 1-2 Frecheville Court, Bury, Lancashire BL9 0UF
Telephone number: 01204 357 010
You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK supervisory
authority for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns
before you approach the ICO so please contact us in the first instance.

CHANGES TO THE PRIVACY POLICY AND YOUR DUTY TO INFORM US OF CHANGES
We keep our privacy policy under regular review. This version was last updated in August 2023.
It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data
changes during your relationship with us.
THIRD-PARTY LINKS
This website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those
connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not
responsible for their privacy statements. When you leave our website, we encourage you to read the privacy policy of every
website you visit.
2. THE DATA WE COLLECT ABOUT YOU
Personal data, or personal information, means any information about an individual from which that person can be identified. It
does not include data where the identity has been removed (anonymous data).
We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:
• Identity Data includes [first name, maiden name, last name, username or similar identifier, marital status, title, date of
birth and gender].
• Contact Data includes [billing address, delivery address, email address and telephone numbers].
• Financial Data includes [bank account and payment card details].
• Transaction Data includes [details about payments to and from you and other details of products and services you have
purchased from us].
• Technical Data includes [internet protocol (IP) address, your login data, browser type and version, time zone setting and
location, browser plug-in types and versions, operating system and platform, and other technology on the devices you use
to access this website].
• Profile Data includes [your username and password, purchases or orders made by you, your interests, preferences,
feedback and survey responses].
• Usage Data includes [information about how you use our website, products and services].
• Marketing and Communications Data includes [your preferences in receiving marketing from us and our third parties
and your communication preferences].
We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data
could be derived from your personal data but is not considered personal data in law as this data will not directly or indirectly
reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific
website feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or
indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy policy.
We do not collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity,
religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about
your health, and genetic and biometric data). Nor do we collect any information about criminal convictions and offences.
IF YOU FAIL TO PROVIDE PERSONAL DATA
Where we need to collect personal data by law, or under the terms of a contract we have with you, and you fail to provide that
data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to
provide you with goods or services). In this case, we may have to cancel a product or service you have with us, but we will
notify you if this is the case at the time.
3. HOW IS YOUR PERSONAL DATA COLLECTED?
We use different methods to collect data from and about you including through:

• Direct interactions. You may give us your [Identity, Contact and Financial Data] by filling in forms or by corresponding
with us by post, phone, email or otherwise. This includes personal data you provide when you:
• apply for our products or services;
• subscribe to our service or publications;
• request marketing to be sent to you;
• enter a competition, promotion or survey; or
• give us feedback or contact us.
• Automated technologies or interactions. As you interact with our website, or partner website and/ or social media
platforms, we will automatically collect Technical Data about your equipment, browsing actions and patterns. We collect
this personal data by using cookies [server logs] and other similar technologies. [We may also receive Technical Data
about you if you visit other websites employing our cookies.]
• Third parties or publicly available sources. We will never source information from 3

rd party sources, but may contact

individuals who are already involved in a partner organisation
Technical Data from the following parties:
(a) CRM system of partner organisation and
(b) advertising networks and social media platforms of partner organisations e.g. Facebook and Twitter feeds of sports clubs
we provide services for; and

4. HOW WE USE YOUR PERSONAL DATA
We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the
following circumstances:
• Where we need to perform the contract, we are about to enter into or have entered into with you.
• Where it is necessary for our legitimate interests (or those of the partner organisation you are associated with) and your
interests and fundamental rights do not override those interests.
• Where we need to comply with a legal obligation.
We will not be sending third party direct marketing communications to you via email or text message. The only
communications you will ever receive are from PBDS or the partner organisation you have associated with e.g. parent football
club of the Pioneer Competition Prize Draw you have purchased tickets for
You have the right to withdraw consent to marketing at any time by contacting us.

PURPOSES FOR WHICH WE WILL USE YOUR PERSONAL DATA
We have set out below, in a table format, a description of all the ways we plan to use your personal data, and which of the legal
bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.
Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we
are using your data. Please contact us if you need details about the specific legal ground, we are relying on to process your
personal data where more than one ground has been set out in the table below.

Purpose/Activity Type of data Lawful basis for processing including basis of

legitimate interest

To register you as a new customer (a) Identity
(b) Contact

Performance of a contract with you

To process and deliver your order
including:
(a) Manage payments, fees and charges
(b) Collect and recover money owed to
us

(a) Identity
(b) Contact
(c) Financial
(d) Transaction
(e) Marketing and
Communications

(a) Performance of a contract with you
(b) Necessary for our legitimate interests (to
recover debts due to us)

To manage our relationship with you
which will include:
(a) Notifying you about changes to our
terms or privacy policy
(b) Asking you to leave a review or take
a survey

(a) Identity
(b) Contact
(c) Profile
(d) Marketing and
Communications

(a) Performance of a contract with you
(b) Necessary to comply with a legal obligation
(c) Necessary for our legitimate interests (to keep
our records updated and to study how customers
use our products/services)

To enable you to partake in a prize draw,
competition or complete a survey

(a) Identity
(b) Contact
(c) Profile
(d) Usage
(e) Marketing and
Communications

(a) Performance of a contract with you
(b) Necessary for our legitimate interests (to
study how customers use our products/services,
to develop them and grow our business)

To administer and protect our business
and this website (including
troubleshooting, data analysis, testing,
system maintenance, support, reporting
and hosting of data)

(a) Identity
(b) Contact
(c) Technical

(a) Necessary for our legitimate interests (for
running our business, provision of administration
and IT services, network security, to prevent
fraud and in the context of a business
reorganisation or group restructuring exercise)
(b) Necessary to comply with a legal obligation

To deliver relevant website content and
advertisements to you and measure or
understand the effectiveness of the
advertising we serve to you

(a) Identity
(b) Contact
(c) Profile
(d) Usage
(e) Marketing and
Communications

Necessary for our legitimate interests (to study
how customers use our products/services, to
develop them, to grow our business and to
inform our marketing strategy)

(f) Technical

To use data analytics to improve our
website, products/services, marketing,
customer relationships and experiences

(a) Technical
(b) Usage

Necessary for our legitimate interests (to define
types of customers for our products and services,
to keep our website updated and relevant, to
develop our business and to inform our
marketing strategy)

To make suggestions and
recommendations to you about goods or
services that may be of interest to you

(a) Identity
(b) Contact
(c) Technical
(d) Usage
(e) Profile
(f) Marketing and
Communications

Necessary for our legitimate interests (to develop
our products/services and grow our business)

MARKETING
We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising.
PROMOTIONAL OFFERS FROM US
We may use your Identity, Contact, Technical, Usage and Profile Data to form a view on what we think you may want or need,
or what may be of interest to you. This is how we decide which products, services and offers may be relevant for you (we call
this marketing).
You will receive marketing communications from us if you have requested information from us or purchased [goods or
services] from us and you have not opted out of receiving that marketing.
THIRD-PARTY MARKETING
We will get your express opt-in consent before we share your personal data with any third party for marketing purposes.
OPTING OUT
You can ask us or third parties to stop sending you marketing messages at any time by following the opt-out links on any
marketing message sent to you OR by contacting us at any time].
Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of [a
product/service purchase, warranty registration, product/service experience or other transactions].
COOKIES
You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you
disable or refuse cookies, please note that some parts of this website may become inaccessible or not function properly.
CHANGE OF PURPOSE
We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to
use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the

processing for the new purpose is compatible with the original purpose, please contact us.
If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which
allows us to do so.
Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules,
where this is required or permitted by law.
5. DISCLOSURES OF YOUR PERSONAL DATA
We may share your personal data with the parties set out below for the purposes set out in the table [Purposes for which we will
use your personal data] above.
• Internal Third Parties as set out in the [Glossary].
• External Third Parties as set out in the [Glossary].

We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not
allow our third-party service providers to use your personal data for their own purposes and only permit them to process your
personal data for specified purposes and in accordance with our instructions.

6. INTERNATIONAL TRANSFERS
We do not transfer your personal data outside the European Economic Area (EEA).
In the unlikely event that we are legally required, or partner organisations stipulate we transfer your personal data out of the
EEA, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is
implemented:
• We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for
personal data by the European Commission.
• Where we use certain service providers, we may use specific contracts approved by the European Commission which
give personal data the same protection it has in Europe.
• Where we use providers based in the US, we may transfer data to them if they are part of the Privacy Shield which
requires them to provide similar protection to personal data shared between Europe and the US. Please contact us if you
want further information on the specific mechanism used by us when transferring your personal data out of the EEA.

7. DATA SECURITY
We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed
in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents,
contractors and other third parties who have a business need to know. They will only process your personal data on our
instructions, and they are subject to a duty of confidentiality.
We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable
regulator of a breach where we are legally required to do so.

8. DATA RETENTION
HOW LONG WILL YOU USE MY PERSONAL DATA FOR?
We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including
for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal data

for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our
relationship with you.
To determine the appropriate retention period for personal data, we consider the amount, nature and sensitivity of the personal
data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process
your personal data and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax,
accounting or other requirements.
Details of retention periods for different aspects of your personal data are set out in the table [Purposes for which we will use
your personal data] above.
OR
By law we have to keep basic information about our customers (including Contact, Identity, Financial and Transaction Data)
for [six] years after they cease being customers for [tax] purposes.]
In some circumstances you can ask us to delete your data: see [your legal rights] below for further information.
In some circumstances we will anonymise your personal data (so that it can no longer be associated with you) for research or
statistical purposes, in which case we may use this information indefinitely without further notice to you.
9. YOUR LEGAL RIGHTS
Under certain circumstances, you have rights under data protection laws in relation to your personal data. Please click on the
links below to find out more about these rights:
https://ico.org.uk/
If you wish to exercise any of the rights set out above, please contact us via the contact details of the DPO.
NO FEE USUALLY REQUIRED
You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a
reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we could refuse to comply with your
request in these circumstances.
WHAT WE MAY NEED FROM YOU
We may need to request specific information from you to help us confirm your identity and ensure your right to access your
personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to
any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request
to speed up our response.
TIME LIMIT TO RESPOND
We try to respond to all legitimate requests within one month. Occasionally it could take us longer than a month if your request
is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.

10. GLOSSARY
LAWFUL BASIS
Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give you the
best service/product and the best and most secure experience. We make sure we consider and balance any potential impact on
you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not
use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or
are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests
against any potential impact on you in respect of specific activities by contacting us.

Performance of Contract means processing your data where it is necessary for the performance of a contract to which you are
a party or to take steps at your request before entering into such a contract.
Comply with a legal obligation means processing your personal data where it is necessary for compliance with a legal
obligation that we are subject to.
THIRD PARTIES
INTERNAL THIRD PARTIES
Other companies in the Pioneer Group [acting as joint controllers or processors] and who are based [SPECIFIC COUNTRIES]
and provide [IT and system administration services and undertake leadership reporting].
EXTERNAL THIRD PARTIES
• Service providers [acting as processors] based who provide [IT and system administration services].
• Professional advisers [acting as processors or joint controllers] including lawyers, bankers, auditors and insurers who
provide [consultancy, banking, legal, insurance and accounting services].
• HM Revenue & Customs, regulators and other authorities [acting as processors or joint controllers] based [in the United
Kingdom] [who require reporting of processing activities in certain circumstances].

YOUR LEGAL RIGHTS
You have the right to:
Request access to your personal data (commonly known as a “data subject access request”). This enables you to receive a
copy of the personal data we hold about you and to check that we are lawfully processing it.
Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data
we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good
reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have
successfully exercised your right to object to processing (see below), where we may have processed your information
unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not
always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at
the time of your request.
Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there
is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts
on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for
direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your
information which override your rights and freedoms.
Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your
personal data in the following scenarios:
• If you want us to establish the data’s accuracy.
• Where our use of the data is unlawful, but you do not want us to erase it.
• Where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal
claims.
• You have objected to our use of your data, but we need to verify whether we have overriding legitimate grounds to use it.
Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have
chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to
automated information which you initially provided consent for us to use or where we used the information to perform a
contract with you.

Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect
the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be
able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.