Privacy Policy
Introduction
We respect your privacy and are committed to protecting your personal data. This policy will inform you as to how we collect, process and look after your personal data (including when you use our website at https://www.tinycfo.com/ and provide you with our products and services). We will only collect and use personal data in ways that are described here, and in a manner that is consistent with our obligations and your rights under the law. We do not knowingly collect data relating to children.
It is important that you read this policy together with any other privacy notice 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 notice supplements the other notices and is not intended to override them. If you are using our website, your acceptance of this policy is deemed to occur upon your first use of the site.
1. Who We Are
1.1 We are Tiny CFO Ltd, a company registered in England and Wales under number 13035563, whose registered office is at 7 Bell Yard, London, England, WC2A 2JR (“we/us/our”).
1.2 This policy applies where we are acting as a data controller with respect to your personal data; in other words, where we determine the purposes and means of the processing of that personal data.
2. What This Policy Covers
2.1 Personal data, or personal information, means any information about a living individual from which that person can be identified (directly or indirectly). This definition shall, where applicable, incorporate the definitions provided in EU Regulation 2016/679 – the General Data Protection Regulation (“EU GDPR”), the retained EU law version of the GDPR (“UK GDPR”) and the Data Protection Act 2018. Personal data covers obvious information such as your name and contact details, but it also covers less obvious information such as identification numbers, electronic location data, and other online identifiers. It does not include data where the identity has been removed (anonymous data).
2.2 Our 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. We encourage you to read the privacy policy of every website you visit before submitting any personal data to third parties.
2.3 If you give us information on behalf of someone else, you confirm that the other person has appointed you to act on their behalf and has agreed that you can give consent on his/her behalf to the processing of their data and receive on their behalf any data protection notice.
3. What Personal Data Do We Collect?
3.1 Depending upon your use of our website, products and services, we may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:
- Identity Data includes name, username, password or similar identifier, business/company name, gender, title, profession and date of birth.
- Contact Data includes billing address, delivery address, country, email address and telephone number.
- Financial Data includes bank account and payment card details.
- Transaction Data includes details about payments to and from you and other details of products/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 our website.
- Profile Data includes your username and password, purchases or orders made by you, your interests, preferences, feedback, survey and interview responses.
- Enquiry and Correspondence Data includes information contained in any enquiry you submit to us or contained in or relating to any communication that you send to us regarding our website or our products/services.
- Usage Data includes information about how you use our website and our products/services.
- Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.
3.2 We also collect, use and share aggregated data such as statistical or demographic data. 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 policy.
3.3 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.
3.4 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 products/services). In this case, we may have to cancel a subscription/service you have with us but we will notify you if this is the case at the time.
4. How Is Your Personal Data Collected?
4.1 We use different methods to collect data from and about you including through:
4.1.1 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, create an account on our website, subscribe to our service, newsletter or publications, request marketing to be sent to you, enter a competition, promotion or survey, give us feedback or contact us.
4.1.2 Automated technologies or interactions. As you interact with our website, we will automatically collect technical data about your equipment, browsing actions and patterns. We collect this personal data by using cookies and other similar technologies. We may also receive technical data about you if you visit other websites employing our cookies.
4.1.3 Third parties or publicly available sources. We will receive personal data about you from various third parties, namely:
4.1.3.1 Technical data from analytics providers, such as Google based outside the UK;
4.1.3.2 Technical and contact data from technical infrastructure providers, such as Kajabi, Cloudflare, Squarespace, based outside the UK;
4.1.3.3 Contact, financial and transaction data from providers of technical, payment and delivery services, such as Stripe and Transferwise based outside the UK;
4.1.3.4 Identity and Contact Data from publicly available sources such as Companies House based inside the UK.
5. How Do We Use Your Data?
5.1 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:
5.1.1 Where we need to perform the contract we are about to enter into or have entered into with you;
5.1.2 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;
5.1.3 Where we need to comply with a legal obligation.
5.2 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. You have the right to withdraw consent to marketing at any time by contacting us or by opting out of links on any marketing message sent to you via [email protected].
5.3 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 this policy.
5.4 Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give you the best service 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 (see section 9 below).
5.5 Specifically, we may use your data for the following purposes:
5.5.1 To register you as a new customer (on the basis of performance of a contract with you);
5.5.2 To process and deliver your orders, including managing payments and collecting money owed to us (on the basis of performance of a contract with you and it being necessary for our legitimate interests);
5.5.3 To supply our products/services to you and manage our relationship with you, including notifying you about changes to our terms or policies and asking you to leave a review, participate in a prize draw or competition, or take a survey (on the basis of performance of a contract with you, complying with our legal obligations, and it being necessary for our legitimate interests to keep our records updated and to study how customers use our products/services);
5.5.4 To administer and protect our business and website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data), including enforcing our contracts and policies, investigating complaints and preventing illegal activity (being necessary to comply with a legal obligation and for our legitimate interests (for example for running our business, providing administration and IT services and network security));
5.5.5 To deliver relevant website content and marketing to you and measure or understand the effectiveness of the advertising we serve to you (being necessary to comply with a legal obligation and 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));
5.5.6 To use data analytics to improve our website, products, services, marketing, customer relationships and experiences (being necessary for our legitimate interests (to define types of customers for our products/services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy)); and
5.5.7 To make suggestions and recommendations to you about products or services that may be of interest to you (being necessary for our legitimate interests (to develop our services and grow our business)).
5.6 We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising. We may use your personal 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 products/services from us and you have not opted out of receiving that marketing. We will get your express opt-in consent before we share your personal data with any third party for marketing purposes.
5.7 We will always work to fully protect your rights and comply with our obligations under the EU GDPR, UK GDPR, Data Protection Act 2018 and the Privacy and Electronic Communications (EC Directive) Regulations 2003. You can ask us or third parties to stop sending you marketing messages at any time by emailing [email protected] or by following the opt-out links on any marketing message sent to you. Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of a purchase, service experience or other transactions (i.e. service emails).
5.8 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 (see section 9 below.). 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.
1.1 We are Tiny CFO Ltd, a company registered in England and Wales under number 13035563, whose registered office is at 7 Bell Yard, London, England, WC2A 2JR (“we/us/our”).
1.2 This policy applies where we are acting as a data controller with respect to your personal data; in other words, where we determine the purposes and means of the processing of that personal data.
2. What This Policy Covers
2.1 Personal data, or personal information, means any information about a living individual from which that person can be identified (directly or indirectly). This definition shall, where applicable, incorporate the definitions provided in EU Regulation 2016/679 – the General Data Protection Regulation (“EU GDPR”), the retained EU law version of the GDPR (“UK GDPR”) and the Data Protection Act 2018. Personal data covers obvious information such as your name and contact details, but it also covers less obvious information such as identification numbers, electronic location data, and other online identifiers. It does not include data where the identity has been removed (anonymous data).
2.2 Our 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. We encourage you to read the privacy policy of every website you visit before submitting any personal data to third parties.
2.3 If you give us information on behalf of someone else, you confirm that the other person has appointed you to act on their behalf and has agreed that you can give consent on his/her behalf to the processing of their data and receive on their behalf any data protection notice.
3. What Personal Data Do We Collect?
3.1 Depending upon your use of our website, products and services, we may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:
- Identity Data includes name, username, password or similar identifier, business/company name, gender, title, profession and date of birth.
- Contact Data includes billing address, delivery address, country, email address and telephone number.
- Financial Data includes bank account and payment card details.
- Transaction Data includes details about payments to and from you and other details of products/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 our website.
- Profile Data includes your username and password, purchases or orders made by you, your interests, preferences, feedback, survey and interview responses.
- Enquiry and Correspondence Data includes information contained in any enquiry you submit to us or contained in or relating to any communication that you send to us regarding our website or our products/services.
- Usage Data includes information about how you use our website and our products/services.
- Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.
3.2 We also collect, use and share aggregated data such as statistical or demographic data. 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 policy.
3.3 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.
3.4 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 products/services). In this case, we may have to cancel a subscription/service you have with us but we will notify you if this is the case at the time.
4. How Is Your Personal Data Collected?
4.1 We use different methods to collect data from and about you including through:
4.1.1 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, create an account on our website, subscribe to our service, newsletter or publications, request marketing to be sent to you, enter a competition, promotion or survey, give us feedback or contact us.
4.1.2 Automated technologies or interactions. As you interact with our website, we will automatically collect technical data about your equipment, browsing actions and patterns. We collect this personal data by using cookies and other similar technologies. We may also receive technical data about you if you visit other websites employing our cookies.
4.1.3 Third parties or publicly available sources. We will receive personal data about you from various third parties, namely:
4.1.3.1 Technical data from analytics providers, such as Google based outside the UK;
4.1.3.2 Technical and contact data from technical infrastructure providers, such as Kajabi, Cloudflare, Squarespace, based outside the UK;
4.1.3.3 Contact, financial and transaction data from providers of technical, payment and delivery services, such as Stripe and Transferwise based outside the UK;
4.1.3.4 Identity and Contact Data from publicly available sources such as Companies House based inside the UK.
5. How Do We Use Your Data?
5.1 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:
5.1.1 Where we need to perform the contract we are about to enter into or have entered into with you;
5.1.2 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;
5.1.3 Where we need to comply with a legal obligation.
5.2 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. You have the right to withdraw consent to marketing at any time by contacting us or by opting out of links on any marketing message sent to you via [email protected].
5.3 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 this policy.
5.4 Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give you the best service 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 (see section 9 below).
5.5 Specifically, we may use your data for the following purposes:
5.5.1 To register you as a new customer (on the basis of performance of a contract with you);
5.5.2 To process and deliver your orders, including managing payments and collecting money owed to us (on the basis of performance of a contract with you and it being necessary for our legitimate interests);
5.5.3 To supply our products/services to you and manage our relationship with you, including notifying you about changes to our terms or policies and asking you to leave a review, participate in a prize draw or competition, or take a survey (on the basis of performance of a contract with you, complying with our legal obligations, and it being necessary for our legitimate interests to keep our records updated and to study how customers use our products/services);
5.5.4 To administer and protect our business and website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data), including enforcing our contracts and policies, investigating complaints and preventing illegal activity (being necessary to comply with a legal obligation and for our legitimate interests (for example for running our business, providing administration and IT services and network security));
5.5.5 To deliver relevant website content and marketing to you and measure or understand the effectiveness of the advertising we serve to you (being necessary to comply with a legal obligation and 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));
5.5.6 To use data analytics to improve our website, products, services, marketing, customer relationships and experiences (being necessary for our legitimate interests (to define types of customers for our products/services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy)); and
5.5.7 To make suggestions and recommendations to you about products or services that may be of interest to you (being necessary for our legitimate interests (to develop our services and grow our business)).
5.6 We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising. We may use your personal 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 products/services from us and you have not opted out of receiving that marketing. We will get your express opt-in consent before we share your personal data with any third party for marketing purposes.
5.7 We will always work to fully protect your rights and comply with our obligations under the EU GDPR, UK GDPR, Data Protection Act 2018 and the Privacy and Electronic Communications (EC Directive) Regulations 2003. You can ask us or third parties to stop sending you marketing messages at any time by emailing [email protected] or by following the opt-out links on any marketing message sent to you. Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of a purchase, service experience or other transactions (i.e. service emails).
5.8 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 (see section 9 below.). 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.
6. Disclosure of Your Personal Data
6.1 We may share your personal data with the parties set out below for the purposes set out above:
6.1.1 External Third Parties, namely:
6.1.1.1 Service providers, such as Kajabi, who provide IT, cloud hosting, system administration and back-up services;
6.1.1.2 Payment providers, such as Stripe and Transferwise, who provide payment processing and banking services on our behalf;
6.1.1.3 Analytics providers, such as Google Analytics, who collect and evaluate information relating to your website usage stats;
6.1.1.4 Professional advisers including lawyers, bankers, auditors and insurers who provide consultancy, banking, legal, insurance and accounting services; and
6.1.1.5 HM Revenue & Customs, regulators and other authorities based in the United Kingdom who require reporting of processing activities in certain circumstances.
6.1.2 Third parties to whom we may choose to sell, transfer or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this policy.
6.2 In some limited circumstances, we may be legally required to share certain personal data, which might include yours, if we are involved in legal proceedings or complying with legal obligations, a court order, or the instructions of a government authority.
6.3 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 and the law.
7. How, Where and For How Long Do We Store Your Data?
7.1 Some of the external third parties to whom we transfer your personal data are based outside the UK and European Economic Area (“EEA”) so their processing of your personal data will involve a transfer of data outside the UK/EEA. (The EEA consists of all EU member states, plus Norway, Iceland and Liechtenstein.) These are known as “third countries” and may not have data protection laws that are as strong as those in the UK and/or the EEA. This means that we will take additional steps in order to ensure that your personal data is treated just as safely and securely as it would be within the UK and will be fully protected under the UK GDPR, EU GDPR, Data Protection Act 2018 and/or to equivalent standards by law. Transfers of personal data to the EEA from the UK are permitted without additional safeguards. Whenever 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:
7.1.1 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. For further details, see https://ec.europa.eu/info/law/law-topic/data-protection/international-dimension-data-protection/adequacy-decisions_en.
7.1.2 Where we use certain service providers, we may use standard contractual clauses (‘SCCs’), approved by the European Commission which give personal data the same protection it has in Europe. For further details, see https://ec.europa.eu/info/law/law-topic/data-protection/international-dimension-data-protection/standard-contractual-clauses-scc_en.
7.1.3 Where we use providers based in the US, we will make an assessment to determine whether we can transfer your personal data on the basis of SCCs taking into account the circumstances of the transfer, and put supplementary measures in place if required. The supplementary measures along with SCCs follow a case-by-case analysis of the circumstances surrounding the transfer and this would ensure that U.S. law does not encroach on the satisfactory level of protection guarantee. If we come to the decision, taking into account the circumstances of the transfer and possible supplementary measures, that appropriate safeguards would not be ensured, then we will either suspend the transfer of your personal data until we ensure an adequate level of protection can be provided or we might end the transfer of your personal data.
By giving us your personal data, you agree to the arrangements. Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the EEA.
7.2 Data security is very important to us, and to protect your data we have put in place suitable security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. By way of example, these include two-step verification and encrypting emails. 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.
7.3 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.
7.4 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. Notwithstanding this, we may retain your personal data where such retention is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person.
7.5 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.
7.6 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.
6.1 We may share your personal data with the parties set out below for the purposes set out above:
6.1.1 External Third Parties, namely:
6.1.1.1 Service providers, such as Kajabi, who provide IT, cloud hosting, system administration and back-up services;
6.1.1.2 Payment providers, such as Stripe and Transferwise, who provide payment processing and banking services on our behalf;
6.1.1.3 Analytics providers, such as Google Analytics, who collect and evaluate information relating to your website usage stats;
6.1.1.4 Professional advisers including lawyers, bankers, auditors and insurers who provide consultancy, banking, legal, insurance and accounting services; and
6.1.1.5 HM Revenue & Customs, regulators and other authorities based in the United Kingdom who require reporting of processing activities in certain circumstances.
6.1.2 Third parties to whom we may choose to sell, transfer or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this policy.
6.2 In some limited circumstances, we may be legally required to share certain personal data, which might include yours, if we are involved in legal proceedings or complying with legal obligations, a court order, or the instructions of a government authority.
6.3 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 and the law.
7. How, Where and For How Long Do We Store Your Data?
7.1 Some of the external third parties to whom we transfer your personal data are based outside the UK and European Economic Area (“EEA”) so their processing of your personal data will involve a transfer of data outside the UK/EEA. (The EEA consists of all EU member states, plus Norway, Iceland and Liechtenstein.) These are known as “third countries” and may not have data protection laws that are as strong as those in the UK and/or the EEA. This means that we will take additional steps in order to ensure that your personal data is treated just as safely and securely as it would be within the UK and will be fully protected under the UK GDPR, EU GDPR, Data Protection Act 2018 and/or to equivalent standards by law. Transfers of personal data to the EEA from the UK are permitted without additional safeguards. Whenever 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:
7.1.1 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. For further details, see https://ec.europa.eu/info/law/law-topic/data-protection/international-dimension-data-protection/adequacy-decisions_en.
7.1.2 Where we use certain service providers, we may use standard contractual clauses (‘SCCs’), approved by the European Commission which give personal data the same protection it has in Europe. For further details, see https://ec.europa.eu/info/law/law-topic/data-protection/international-dimension-data-protection/standard-contractual-clauses-scc_en.
7.1.3 Where we use providers based in the US, we will make an assessment to determine whether we can transfer your personal data on the basis of SCCs taking into account the circumstances of the transfer, and put supplementary measures in place if required. The supplementary measures along with SCCs follow a case-by-case analysis of the circumstances surrounding the transfer and this would ensure that U.S. law does not encroach on the satisfactory level of protection guarantee. If we come to the decision, taking into account the circumstances of the transfer and possible supplementary measures, that appropriate safeguards would not be ensured, then we will either suspend the transfer of your personal data until we ensure an adequate level of protection can be provided or we might end the transfer of your personal data.
By giving us your personal data, you agree to the arrangements. Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the EEA.
7.2 Data security is very important to us, and to protect your data we have put in place suitable security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. By way of example, these include two-step verification and encrypting emails. 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.
7.3 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.
7.4 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. Notwithstanding this, we may retain your personal data where such retention is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person.
7.5 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.
7.6 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.
8. Your Legal Rights
8.1 Under certain circumstances, you have rights under data protection laws in relation to your personal data. You have the right to:
8.1.1 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.
8.1.2 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.
8.1.3 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.
8.1.4 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.
8.1.5 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:
8.1.5.1 If you want us to establish the data's accuracy;
8.1.5.2 Where our use of the data is unlawful but you do not want us to erase it;
8.1.5.3 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;
8.1.5.4 You have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
8.1.6 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.
8.1.7 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 services to you. We will advise you if this is the case at the time you withdraw your consent.
8.1.8 Rights with respect to automated decision making and profiling. We do not use your personal data in this way.
8.2 If you wish to exercise any of the rights set out above, please contact us. 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.
8.3 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.
8.4 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. In the case of subject access requests, normally, we aim to provide a complete response, including a copy of your personal data within one month. In some cases, however, particularly if your request is more complex, more time may be required up to a maximum of three months from the date we receive your request. You will be kept fully informed of our progress.
8.5 If you require any information about our use of your personal data or exercising your rights as outlined above, please contact us using the details provided in section 9. Further information about your rights can also be obtained from the Information Commissioner’s Office or your local Citizens Advice Bureau. If you have any cause for complaint about our use of your personal data, please contact us using the details provided in section 9 and we will do our best to solve the problem for you. If we are unable to help, you also have the right to lodge a complaint with the UK’s supervisory authority, the Information Commissioner’s Office (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.
9. Contacting Us
To contact us about anything to do with your personal data and data protection, including to make a subject access request, please contact us at [email protected]. Please ensure that your query is clear, particularly if it is a request for information about the data we hold about you (as under section 8 above).
10. Changes to Our Privacy Policy
We keep our privacy policy under regular review. It was last updated in January 2021. We may change this policy from time to time (for example, if the law changes or if we change our business in a way that affects personal data protection). Any changes will be made available on our website. 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.
8.1 Under certain circumstances, you have rights under data protection laws in relation to your personal data. You have the right to:
8.1.1 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.
8.1.2 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.
8.1.3 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.
8.1.4 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.
8.1.5 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:
8.1.5.1 If you want us to establish the data's accuracy;
8.1.5.2 Where our use of the data is unlawful but you do not want us to erase it;
8.1.5.3 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;
8.1.5.4 You have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
8.1.6 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.
8.1.7 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 services to you. We will advise you if this is the case at the time you withdraw your consent.
8.1.8 Rights with respect to automated decision making and profiling. We do not use your personal data in this way.
8.2 If you wish to exercise any of the rights set out above, please contact us. 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.
8.3 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.
8.4 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. In the case of subject access requests, normally, we aim to provide a complete response, including a copy of your personal data within one month. In some cases, however, particularly if your request is more complex, more time may be required up to a maximum of three months from the date we receive your request. You will be kept fully informed of our progress.
8.5 If you require any information about our use of your personal data or exercising your rights as outlined above, please contact us using the details provided in section 9. Further information about your rights can also be obtained from the Information Commissioner’s Office or your local Citizens Advice Bureau. If you have any cause for complaint about our use of your personal data, please contact us using the details provided in section 9 and we will do our best to solve the problem for you. If we are unable to help, you also have the right to lodge a complaint with the UK’s supervisory authority, the Information Commissioner’s Office (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.
9. Contacting Us
To contact us about anything to do with your personal data and data protection, including to make a subject access request, please contact us at [email protected]. Please ensure that your query is clear, particularly if it is a request for information about the data we hold about you (as under section 8 above).
10. Changes to Our Privacy Policy
We keep our privacy policy under regular review. It was last updated in January 2021. We may change this policy from time to time (for example, if the law changes or if we change our business in a way that affects personal data protection). Any changes will be made available on our website. 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.
