Last updated: 25 August 2022
In this policy you can find more about:
We use different methods to collect data from and about you including through:
Direct interactions: You may provide us your data by filling in forms in our Website or by corresponding with us by email, phone, post, live chat or otherwise. This includes personal data you provide when you:
Automated technologies or interactions: As you interact with our Website, we may automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies and other similar technologies. Please see our Cookies Policy for further details.
Third parties or publicly available sources: We may receive personal data about you from various third parties and public sources as set out below:
Indirectly: We may have access to your personal data because someone who has it engaged us to provide a service that requires us to access and use that data. In this case, we will be processing your personal data as data processors, on behalf of the data controller, who determines in exclusivity the types and purposes for which we will process your data and is solely liable to you for any data breaches not caused exclusively by us. If you contact us in relation to personal data that we process as data processors on behalf of a data controller, we will direct you to the contact person of the data controller.
We may collect, use, store and transfer different kinds of personal data about you which we have grouped together:
We also collect, use and share aggregated data such as statistical or demographic data for any purpose. Aggregated Data may be derived from your personal data but is not considered personal data under the Data Protection Legislation as this data does not directly or indirectly reveal your identity.
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). We also do not willingly collect any information about criminal convictions and offences, except data collected on commercial databases and media searches for Anti-Money Laundering and Counter-Terrorist Financing due diligence purposes as legally required. If we happen to unwillingly receive data of such kind, we will immediately delete it.
Where we need to collect personal data by law, or under the terms of an agreement we have with you, and you fail to provide that data when requested, we may not be able to perform the agreement we have or are trying to enter into with you. 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.
It is important that the personal data we hold about you is accurate, complete and up to date. Please keep us informed if your personal data changes during your relationship with us.
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:
Specifically, we may use your personal data for the following purposes:
PURPOSE / ACTIVITY
TYPE OF DATA
LAWFUL BASIS FOR PROCESSING
To provide the service, which may include sharing your data internally as well as disclosing it to third parties.
Performance of a contract with you or a data controller who has your data.
To manage our relationship with you which will include:
To administer and protect our business and this Website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data).
To deliver relevant website content and advertisements to you and measure and understand the effectiveness of the advertising we serve to you.
Necessary for our legitimate interests (to study how users use our services and Website, to develop them, to grow our business and to inform our marketing strategy).
To use data analytics to improve our Website, products/services, marketing, customer relationships and experiences.
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 our products or services that may be of interest to you.
Necessary for our legitimate interests (to develop our products/services and grow our business).
To deliver relevant social media content and advertisements and to give back to our community of users.
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 have to process your personal data without your knowledge or consent, in compliance with the above rules, where this is required by law.If you are in any doubt, please contact us about the specific legal ground we are relying on to process your personal data.As you have to give an opt-in consent for marketing purposes, you can also ask us or third parties to stop sending you marketing messages at any time either through the relevant message, the Website or by another means indicated to you by us.
The security of your personal data is highly important to us. All information and personal data provided to us is stored securely.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 may require access to it in order to perform the services requested by you. They will only process your personal data on our instructions, and they are subject to a duty of confidentiality.We maintain physical, electronic and procedural safeguards to protect the information against loss, misuse, damage or modification and unauthorized access or disclosure. More specifically, we have implemented the following security measures:
It is important to bear in mind that no method of electronic transmission or storage is 100% secure, so we may not guarantee the infallibility of the abovementioned security measures.
Under certain circumstances, you have the following rights under the Data Protection Legislation in relation to your personal data:
If you wish to exercise any of the rights set out above, please contact us in writing to [email protected].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 unreasonable, repetitive or excessive. Alternatively, we could refuse to comply with your request in these circumstances.We try to respond to all legitimate requests as soon as practicable. Occasionally it could take us longer 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.
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.In some circumstances you can ask us to delete your personal data as indicated above.We may also collect and retain aggregated, anonymised or pseudonymised information indefinitely, in order to protect the safety and security of our website, improve our services or comply with any mandatory obligations. Aggregated, anonymised or pseudonymised information will not directly identify you.
This policy was last updated on the date shown at the top. We may change this policy at any time by posting an updated version on the Website and will make reasonable efforts to bring any material changes to your attention. You may wish to check it before using the Website as any changes will be effective from the date that they are made.
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