- This Policy details our commitment to protecting the privacy of the End Users who use the Network and our associated services.
- Our websites may contain links to other third party websites. If you follow a link to any of those third party websites, please note that they have their own privacy policies and that we do not accept any responsibility or liability for their policies or processing of your personal data. Please check these policies before you submit any personal data to such third party websites.
- Personal data we may collect
- We may collect and process all or some of the following personal data about you which you may provide directly, or which may be provided from Users and other third parties.
- Contact and biographical information ► including your name, email address, and other contact details and related information such as details relating to your job role;
- Log-in credentials ► including your user-name and passwords that enable you to access and use the Network;
- KYC and anti-fraud information ► information relating to your financial situation, your creditworthiness or any criminal or fraudulent activities provided to us by you or third parties including information which establishes your identity, such as driving licences, passports and utility bills; information about transactions, credit ratings from credit reference agencies; fraud offences, suspicious transactions, politically exposed person and sanctions lists where your details are included;
- Our correspondence ► if you contact us, we will typically keep a record of that correspondence;
- Survey information ► we may also ask you to complete surveys that we use for research purposes. In such circumstances we shall collect the information provided in the completed survey;
- Your usage of the Network ► details of your usage of the Network (including, where applicable, financial metrics), and our associated services; and
- Website and communication usage ► details of your visits to the websites and information collected through cookies and other tracking technologies including, but not limited to, your IP address and domain name, your browser version and operating system, traffic data, location data, web logs and other communication data, and the resources that you access.
- Uses of your personal data
- Transmission, storage and security of your personal data
Security over the internet
Export outside the EEA
- No data transmission over the Internet or website can be guaranteed to be secure from intrusion. However, we maintain commercially reasonable physical, electronic and procedural safeguards to protect your personal data in accordance with data protection legislative requirements.
- All information you provide to us is stored on our or our subcontractors’ secure servers and accessed and used subject to our security policies and standards. Where we have given you (or where you have chosen) a password which enables you to access certain parts of our websites, you are responsible for keeping this password confidential and for complying with any other security procedures that we notify you of. We ask you not to share a password with anyone.
- Where we transfer personal data from inside the European Economic Area (the EEA) and UK to outside the EEA and UK, we may be required to take specific additional measures to safeguard the relevant personal data. Certain countries outside the EEA and UK have been approved by the European Commission (and, in the case of the UK, the Information Commissioner’s Office) as providing essentially equivalent protections to EEA and UK data protection laws and therefore no additional safeguards are required to export personal data to these jurisdictions. In countries which have not had these approvals (see the full list here http://ec.europa.eu/justice/data-protection/international-transfers/adequacy/index_en.htm), we will establish legal grounds justifying such transfer, such as EU Commission-approved model contractual clauses, or other legal grounds permitted by applicable legal requirements.
- Please contact us using the contact details set out in the “Contacting Us” section below if you would like to see a copy of the specific safeguards applied to the export of your personal data.
- Our retention periods for personal data are based on business needs and legal requirements. We retain personal data for as long as is necessary for the processing purpose(s) for which the information was collected, and any other permissible, related purpose. For example, we may retain certain transaction details and correspondence until the time limit for claims arising from the transaction has expired, or to comply with regulatory requirements regarding the retention of such data. When personal data is no longer needed, we either irreversibly anonymise the data (
- Your rights & contacting us
Information Commissioner's Office
Telephone: 0303 123 1113
- You have the right to ask us not to process your personal data for marketing purposes. We will inform you if we intend to use your information for such purposes or if we intend to disclose your information to any third party for such purposes. You can exercise your right to prevent such processing by not checking certain boxes on the forms we use to collect your personal data. You can also exercise the right at any time by contacting us using the contact details set out in the “Contacting Us” section below.
- We will use reasonable endeavours to ensure that your personal data is accurate. In order to assist us with this, you should notify us of any changes to the personal data that you have provided to us by contacting us using the contact details set out in the “Contacting Us” section below.
- If you have any questions in relation to our use of your personal data, you should first contact us using the contact details set out in the “Contacting Us” section below. Under certain conditions, you may have the right to require us to:
- provide you with further details on the use we make of your information;
- provide you with a copy of information that you have provided to us;
- update any inaccuracies in the personal data we hold (please see paragraph 3.2);
- delete any personal data that we no longer have a lawful basis to use;
- transfer your personal data in a structured, commonly used, machine-readable format to an applicable third party in certain circumstances. You may also have the right to:
- where processing is based on consent, to withdraw your consent so that we stop that particular processing (see paragraph 5.1 for marketing);
- object to any processing based on the legitimate interests ground unless our reasons for undertaking that processing outweigh any prejudice to your data protection rights;
- object to receiving marketing communications from us by contacting us using the contact details set out in the “Contacting Us” section below; and
- restrict how we use your information whilst a complaint is being investigated.
- Your exercise of these rights is subject to certain exemptions to safeguard the public interest (e.g. the prevention or detection of crime) and our interests (e.g. the maintenance of legal privilege). If you exercise any of these rights we will check your entitlement and respond in most cases within a month.
- If you are not satisfied with our use of your personal data or our response to any exercise of these rights you have the right to complain to the Information Commissioner’s Office. The contact details are below:
- If you have any questions in relation to this policy, please contact us at the address indicated above or using the contact details set out on our website or in the Network.
- Cookies policy
Annex 1 : Details of lawful bases
The main lawful bases for our use of your Special Categories of Personal Data are as follows:
- Legal obligation: where we need to use your personal data to comply with our legal obligations.
- Legitimate interests: where we have a legitimate interest in using your personal data. We will only rely on this lawful basis if we consider that our interest in using your personal data for the relevant purpose is not outweighed by any interests that you may have, or any prejudice that you may suffer, from the relevant use of your personal data.
- Consent: where you have consented to our use of your personal data. You may withdraw your consent to the use of your personal data by contacting us using the contact details set out in the “Contacting Us” section above. If you do, we may be unable to provide a service that requires the use of such personal data.
- Legal claims: where your personal data is necessary for us to establish, exercise or defend any legal claims.
- Substantial public interest: where we need to process your personal data for reasons of substantial public interest set out in UK law.
- Explicit consent: where you have given your explicit consent to the processing of those personal data for one or more specified purposes. You may withdraw your consent to the use of your personal data by contacting us using the contact details set out in the “Contacting Us” section above. If you do, we may be unable to provide a service that requires the use of such personal data.