This Privacy Policy applies to operated by THE PT CARTEL (“we”, “us”, “our”). If you have any questions about our Privacy Policy or wish to exercise your rights under applicable laws, please contact us using or call +44 (0)7751 212811 or write to THE PT CARTEL LTD, 23 2/1 Argyle Street, Paisley, PA1 2ET.



jargon to a minimum, to make sure you understand the information provided. However, to achieve this objective we would like to explain you the following two concepts.

a) What is Personal Data?

Personal Data is any information that relates to an identified or identifiable living individual. Different pieces of information, which collected together can lead to the identification of a particular person, also constitute Personal Data.

b) What is Processing?

“Processing” means and covers virtually any handling of data.

c) What law applies?

We act as the data controller in accordance with the UK`s Data Protection Act 2018 (“DPA”) and the EU`s General Data Protection Regulation (“GDPR”).


General Principles

a) Purpose and legal basis of processing

In accordance with the DPA and GDPR we need to have both a purpose and a legal basis to process Personal Data. The purposes are:

  • providing the website and shop and their functions and contents,
  • responding to contact requests and communicating with our customers,
  • providing our services, and
  • security measures.

Of course, we can only do that if we have at least one of the following legal bases or in other words lawful reasons to do so. Unless specifically described below, we typically link the above purposes to one of the following:

  • consent,
  • to fulfil our services and carry out contractual obligations,
  • to fulfil our legal obligations, and
  • to protect our legitimate interests.

a) Security

Our website uses SSL or TLS encryption to ensure the security of data processing and to protect the transmission of confidential content, login data or contact requests that you send to us. We have also implemented numerous security measures (“technical and organisational measures”) for example encryption or need to know access, to ensure the most complete protection of Personal Data processed through this website.

Nevertheless, internet-based data transmissions can always have security gaps, so that absolute protection cannot be guaranteed. And databases or data sets that include Personal Data may be breached inadvertently or through wrongful intrusion.

Upon becoming aware of a data breach, we will notify all affected individuals whose Personal Data may have been compromised as expeditiously as possible after which the breach was discovered.


b) Retention and Storage

We retain your Personal Data as necessary in connection with the purposes described in this Privacy Policy, and in accordance with the UK’s Statutory Retention Periods and other applicable laws for up to 6 years.

c) Minors

We do not request Personal Data from minors and children and do not knowingly collect such data or pass it on to third parties.

d) Automated decision-making

Automated decision-making including profiling does not take place.

e) Do Not Sell

We do not sell your Personal Data.

f) Special Category Data

Unless specifically required and consent is obtained, for a particular service, we do not process special category data.

g) Social Media

We are present on social media on the basis of our legitimate interest. If you contact us via social media, we and the relevant social media platform are jointly responsible for the processing of your data and enter into a so-called joint controller agreement. The legal basis is our legitimate interest, your consent or, in some cases, the initiation of a contractual service, if any.

h) International Transfer

In the course of our website operation, we process data. We usually do not transfer Personal Data to countries outside the UK or the EEA. However, if we do, we ensure that processing of your Personal Data is governed by Processing Agreements that include Standard Contractual Clauses to ensure a high level of data protection.

i) Sharing and Disclosure

We will not disclose or otherwise distribute your Personal Data to third parties unless this is a) necessary for the performance of our services for example with our web host (see below), b) you have consented to the disclosure, c) or if we are legally obliged to do so e.g., by court order or if this is necessary to support criminal or legal investigations or other legal investigations or other legal proceedings; as required by law or regulation; if THE PT CARTEL (or a part of THE PT CARTEL) is sold to or merged with another company; or proceedings at home or abroad or to fulfil our legitimate interests.


Data collection and processing


a) Data we collect directly

We may ask you for Personal Data when you:

  • use our website,
  • request services, support, or information,
  • participate online or otherwise in marketing activities,
  • subscribe to THE PT CARTEL marketing and promotional emails or other materials,
  • interact with us on third-party social networking sites (subject to the terms of use and privacy policies of said third parties), or
  • contact us.

Categories of Personal Data we collect may include your name, email address, and IP addresses. We may also collect demographic data such your interests, and preferences. In the context of the Book A Free Consultation function on our website, in addition to your enquiry you may also disclose your name, e-mail and Services required.

In order to provide you with a more consistent and personalised user experience in your interactions with THE PT CARTEL, data collected through one source may also be linked to other data collected by THE PT CARTEL through other sources. This may include data that helps us identify you when you access our website through several different devices.

We process the data of our service users in order to be able to provide our contractual services as well as to ensure the security of our services and to be able to develop it further. This includes in particular our support, correspondence with you, invoicing, fulfilment of our accounting and tax obligations. Accordingly, the data is processed on the basis of fulfiling our contractual obligations as well as to fulfil our legal obligations.

Some of the data you choose to provide may be considered non-Personal Data and/or “special” or “sensitive” in certain jurisdictions, for example your racial or ethnic origins, sexual orientation, and religious beliefs. By choosing to provide this data, you consent to our processing of that data.

Where any Personal Data relates to a third party, you represent and warrant that the Personal Data is up-to-date, complete, and accurate and that you have obtained the third party’s prior consent for our collection, use and disclosure of their Personal Data for the Purposes. You agree that you shall promptly provide us with written evidence of such consent upon demand by us.

Unless otherwise specified the purposes of processing are contractual performance and service, contact requests and communication, office and organisational procedures, administration, and response to requests, visit action evaluation. The legal basis for the data processing is the fulfilment of our contractual obligations and, in individual cases, the fulfilment of our legal obligations as well as your Consent. You may withdraw your consent and request us to stop using and/or disclosing your personal and special category data by submitting your request to us in writing using or per mail to the above address.

b) Data we collect automatically

We may automatically collect information about user behaviour and usage regarding your visits to our websites, such as the pages you view, the links you click, and other actions you take in connection with our website.

We may also collect certain information about the browser you use to access our website, such as your IP address, device identifier, location data, browser type and language, and your access times, the URL (“Uniform Resource Locator”) of the website from which you arrived at our website, and the URL to which you are directed after leaving our website if you clicked on a link on our website.

c) Data we collect automatically

We may obtain data about you from third-party sources, such as our marketing partners, social networks, and other third parties. We may use this data to better analyse your user behaviour to improve our ability to provide you with relevant marketing information and services, and to prevent and combat fraud.

d) Cookies

We use so-called cookies on our web site. Cookies are small text files that are stored on your respective device (PC, smartphone, tablet, etc.) and saved by your browser. For further information please refer to our Cookie Policy. The legal basis for the use of cookies is your consent as well as our legitimate interest.

e) Hosting

To provide our website, we use the services of, LLC,. Doing so, GoDaddy processes the data to be processed in connection with the operation of this website on our behalf. The legal basis is our legitimate interest.

Our use of Personal Data

THE PT CARTEL may use your Personal Data for the following purposes:

  • providing you with services and support, and conducting transactions you request,
  • enabling you to use our website,
  • providing support to respond to your online inquiries,
  • customise, analyse, and optimise our website and services (including content to gauge usage trends and determine the effectiveness of our marketing campaigns,
  • better understanding our readers and website users,
  • personalising content and implementing your preferences,
  • prevention of fraud and other prohibited or unlawful activities,
  • protecting the security and integrity of our websites, businesses, and services; and
  • other functions and purposes disclosed to you at the time of collection or as required or permitted by law.

Cooperation with processors

We use content or service offers of third-party providers on the basis of our legitimate interests in order to integrate their content and services on our website. This usually requires that the third-party provider becomes aware of your IP address so that the content and services can be displayed on your device.

Below you can find a list of the relevant content and services we use along with the relevant third-party provider. We would like to ask you to review their privacy policies, which contain further information on the processing of Personal Data and so-called opt-out measures, if any.

If you do not wish to participate in our advertising personalisation or retargeting/tracking you can object to behavioural advertising at the Following websites: Your Online Choices, Digital Advertising Alliance of Canada, Network Advertising Initiative  or AdChoices.


Insofar as you have also given us your consent to process your Personal Data for marketing and advertising purposes, we are entitled to contact you for these purposes via the communication channels you have given your consent to.

Your Rights and Privileges

a) Privacy rights

Under the DPA and GDPR, you can exercise the following rights:

  • The right to access – You have the right to request copies of your Personal Data. We may charge you a small fee for this service.
  • The right to rectification – You have the right to request that we correct any information you believe is inaccurate. You also have the right to request us to complete the information you believe is incomplete.
  • The right to erasure – You have the right to request that we erase your Personal Data, under certain conditions.
  • The right to restrict processing – You have the right to request that we restrict the processing of your Personal Data, under certain conditions.
  • The right to object to processing – You have the right to object to our processing of your Personal Data, under certain conditions.
  • The right to data portability – You have the right to request that we transfer the data that we have collected to another organisation, or directly to you, under certain conditions.

If you have any questions, please contact us.

b) Updating your information

If you believe that the information, we hold about you is inaccurate or request its rectification, deletion, or object to its processing, please do so by contacting us.

c) Withdrawing your consent

You can withdraw consents you have given at any time by contacting us.

d) Access Request

In the event you want to make a Data Subject Access Request, please contact us. We will respond to requests regarding access and correction as soon as reasonably possible. Should we not be able to respond to your request within thirty (30) days, we will tell you why and when we will be able to respond to your request. If we are unable to provide you with any Personal Data or to make a correction requested by you, we will tell you why.

e) Complaint to a supervisory authority

You have the right to complain about our processing of Personal Data to a supervisory authority responsible for data protection. The supervisory authority in the UK is: The Information Commissioner’s Office (ICO) is located at Wycliffe House, Water Ln, Wilmslow SK9 5AF, UK


We may update this Privacy Policy from time to time. If we make changes to this Privacy Policy or materially change our use of your Personal Data, we will revise the Privacy Policy accordingly. This Privacy Policy was last updated on Tuesday, 14 February 2023.


If you have any questions about the processing of your Personal Data, please contact us using or call +44 (0)7751 212811 or write to the above address.