Privacy

PRIVACY POLICY

We are committed to protecting your personal data. This privacy policy will inform you as to how we look after your personal data when you use our platform located at [WEBSITE PAGE] (“Platform”) (regardless of where you visit it from) and tell you about your privacy rights and how the law protects you.

PURPOSE OF THIS PRIVACY POLICY  

This privacy policy aims to give you information on how we collect and process your personal data through your use of our Platform.

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.

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, last name, title.
• Contact Data includes billing address, email address and telephone numbers.
• Transaction Data includes details about payments to and from you and other details of products and services you have purchased from us.
• Financial Data includes any payment data you use
• 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.

 We do not collect 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 the services on our Platform). In this case, we may have to cancel your account on our Platform, but we will notify you if this is the case at the time.

 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 data by filling in forms when you sign up to our Platform or use our services on our Platform. This includes personal data you provide when you:

• apply for our services.
• request marketing to be sent to you; or
• give feedback or contact us.

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 a third party) and your interests and fundamental rights do not override those interests.
• Where we need to comply with a legal obligation. 

Generally, we do not rely on consent as a legal basis for processing your personal data although we will get your consent before sending third party direct marketing communications to you via email or text message. You have the right to withdraw consent to marketing at any time by contacting us.

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.

OPTING OUT

You can ask us to stop sending you marketing messages at any time by adjusting your marketing preferences or 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, product/service experience or other transactions.

SECURITY OF YOUR PERSONAL INFORMATION

We are committed to keeping the personal information you provide us secure and we will take reasonable precautions to protect your personal information from loss, misuse or alteration. We have implemented information security policies, rules and technical measures to protect the personal information that we have under our control from:

• Unauthorised Access.
• Improper Use Or Disclosure.
• Unauthorised Modification; And
• Unlawful Destruction Or Accidental Loss.

All our employees and data processors (i.e. those who process your personal information on our behalf, for the purposes listed above), who have access to, and are associated with the processing of personal information, are obliged to respect the confidentiality of the personal information.

CHANGE TO THIS PRIVACY POLICY

We may make changes to this privacy policy from time to time.

We may notify you by e-mail of any significant changes. However, we encourage you to review the privacy policy on our website periodically to be informed of how we use your personal information.

Last updated Feb 2022