We collect, use and are responsible for certain Personal Information about you. When we do so we are subject to data protection laws applicable in the United Kingdom and we are responsible as ‘controller’ of that Personal Information for the purposes of those laws.
1. Key terms
It would be helpful to start by explaining some key terms used in this policy:
|We, us, our||Fibonatix (UK) Limited, a company registered in England and Wales with registered address XYZ Building, 2 Hardman Boulevard, M3 3AQ, Manchester (registered company number 09738892) and our group of companies|
|Our data protection officer||May be reached at firstname.lastname@example.org|
|Personal Information||Any information relating to an identified or identifiable individual|
2. Personal information we collect about you
We may collect and use the following Personal Information about you:
- your name and contact information, including email address and telephone number; and
- information related to your business, including website URL(s), company name and number; and
- information about how you use our website.
This Personal Information is required for us to contact you to inform you about the products and/or services we can provide you or to address any other queries you might have. Where you fail to provide that Personal Information when requested, we may not be able to get in touch with you to assist in performing the contract we have or are trying to enter into with you (for example, to provide you with products and/or services).
3. How your personal information is collected
We collect most of this Personal Information directly from you, by telephone, IM, email and/or via our website and apps. However, we may also collect information:
- from publicly accessible sources, e.g. Companies House or social media websites;
- directly from a third party, e.g.: sanctions screening providers, credit reference agencies, customer due diligence providers;
- from a third party with your consent, e.g. your bank or building society;
- via our IT systems, e.g.: automated monitoring of our websites and other technical systems, such as our computer networks and connections, CCTV and access control systems, communications systems, email and instant messaging systems.
4. How and why we use your personal information
Under data protection law, we can only use your Personal Information if we have a proper reason for doing so. In order to use your personal information, we rely on the following legal bases:
- processing your Personal Information is necessary for us to be able to provide you with our products and/or services;
- processing is necessary for the purposes of the legitimate business interests pursued by us, chiefly to be able to ascertain which of our products/services would be relevant for you; and
- processing is necessary for compliance with a legal obligation to which we are subject (including undertaking screening for financial and other sanctions and conduct checks to identify you and verify your identity).
Generally, we do not rely on consent as a legal basis for processing your Personal Information other than in relation to 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 (see ‘How to contact us’ below).
We collect and process your personal information in order to:
- provide products and/or services to you;
- update customer records;
- prevent unauthorised access and modification to our systems; and
- undertake statistical analysis to help us manage our business e.g. in relation to financial performance, client base and work type.
5. Who we share your personal information with
We routinely share Personal Information with:
- other companies within the Fibonatix group;
- third parties we use to help deliver our products and/or services to you (e.g. financial institutions, credit card schemes, and other payment scheme operators);
- other third parties we use to help us run our business, e.g. marketing agencies or website hosts;
- third parties approved by you.
We only allow our service providers to handle your Personal Information if we are satisfied they take appropriate measures to protect your Personal Information. We also impose contractual obligations on service providers relating to ensure they can only use your Personal Information to provide services to us and to you.
We may disclose and exchange information with law enforcement agencies and regulatory bodies to comply with our legal and regulatory obligations.
We may also need to share some Personal Information with other parties, such as potential buyers of some or all of our business or during a re-structuring. Usually, information will be anonymised, but this may not always be possible. The recipient of the information will be bound by confidentiality obligations.
We will not share your Personal Information with any other third party.
6. How long your personal information will be kept
We will only retain your Personal Information for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, accounting, or reporting requirements.
To determine the appropriate retention period for your Personal Information, we consider the amount, nature, and sensitivity of the Personal Information, the potential risk of harm from unauthorised use or disclosure of your Personal Information, the purposes for which we process your Personal Information and whether we can achieve those purposes through other means, and the applicable legal and regulatory requirements.
When it is no longer necessary to retain your Personal Information, we will anonymise it.
7. Transferring your personal information out of the EEA
We may transfer Personal Information that we collect from you to third party data processors, vendors or hosting partners acting on our behalf located in countries outside of the European Economic Area (“EEA“) or to other entities in our group of companies in connection with the purposes set out above. We will only transfer your personal information outside the EEA where either the transfer is to a country which the EU Commission has decided ensures an adequate level of protection for your personal information, or we have put in place adequate safeguards as required by applicable data protection law.
If you would like further information, please contact us (see ‘How to contact us’ below).
8. Your rights
You have the following rights, which you can exercise free of charge:
|Access||The right to be provided with a copy of your Personal Information (the right of access).|
|Rectification||The right to require us to correct any mistakes in your Personal Information.|
|Erasure||The right to require us to delete your Personal Information – in certain situations.|
|Restriction of processing||The right to require us to restrict processing of your Personal Information – in certain circumstances, e.g. if you contest the accuracy of the data.|
|Data portability||The right to receive the Personal Information you provided to us, in a structured, commonly used and machine-readable format and/or transmit that data to a third party – in certain situations.|
|To object||The right to object:
– at any time to your Personal Information being processed for direct marketing (including profiling); or
– in certain other situations to our continued processing of your Personal Information, e.g. processing carried out for the purpose of our legitimate interests.
|Not to be subject to automated individual decision-making||The right not to be subject to a decision based solely on automated processing (including profiling) that produces legal effects concerning you or similarly significantly affects you.|
|Withdraw consent||The right to withdraw your consent to us processing your Personal Information at any time if our processing is based on your consent.|
For further information on each of those rights, including the circumstances in which they apply, please contact us or see the Guidance from the UK Information Commissioner’s Office (ICO) on individuals’ rights under the General Data Protection Regulation.
If you would like to exercise any of those rights, please:
- email, call or write to us – see below: ‘How to contact us’; and
- let us have enough information to identify you (e.g. your full name, address and customer or matter reference number);
- let us have proof of your identity and address (a copy of your driving licence or passport and a recent utility or credit card bill); and
- let us know what right you want to exercise and the information to which your request relates.
9. Keeping your personal information secure
We have appropriate security measures to prevent Personal Information from being accidentally lost or used or accessed unlawfully. We also have procedures in place to deal with any suspected data security breach. We will notify you and any applicable regulator of a suspected data security breach where we are legally required to do so.
10. How to complain
We hope that we can resolve any query or concern you may raise about our use of your information.
The General Data Protection Regulation also gives you right to lodge a complaint with a supervisory authority, in particular in the European Union (or European Economic Area) state where you work, normally live or where any alleged infringement of data protection laws occurred. The supervisory authority in the UK is the Information Commissioner who may be contacted at https://ico.org.uk/concerns or telephone: 0303 123 1113.
This privacy notice was published on 11th June 2018
We may change this privacy notice from time to time – when we do we will inform you via a notice on our website or via other means of contact such as email.