1.1 Welcome to Complyport Limited’s privacy notice.
1.2 We respect your privacy and are committed to protecting your personal data. This privacy notice will inform you as to how we look after your personal data we collect from you both when you visit our website (regardless of where you visit it from) and where we carry out services for you. This privacy notice tells you about your privacy rights and how the law protects you.
1.3 Please use the Glossary to understand the meaning of some of the terms used in this privacy notice.
2. Purpose of this Privacy Notice
2.1 This privacy notice aims to give you information on how Complyport Limited collects and processes personal data:
2.1.1 through your use of our website, including any data you may provide through our website;
2.1.2 when you purchase our services or contact us in respect of our services through the website or in person;
2.1.3 when we gather data provided by third parties with whom we deal in order to provide our services; when you sign up to our newsletter
2.1.4 when you agree to attend any of our events.
2.2 We do not knowingly collect data relating to children and this privacy notice does therefore not apply to any person under the age of 13.
2.3 It is important that you read this privacy notice together with any other privacy notice or fair processing 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.
Complyport Limited, a company incorporated and registered in England and Wales under company number 04333584 and whose registered office is situated at 1 Kings Avenue, London, United Kingdom, N21 3NA is the controller and responsible for our personal data (collectively we will be referred to as “Company”, “we“, “us” or “our” in this privacy notice).
4. Contact Details
4.1 Our full details are:
Email address: firstname.lastname@example.org
34 Lime Street, London EC3M 7AT
T: +44 (0)20 7399 4980
4.2 You have the right to make a complaint at any time to the Information Commissioner’s Office (“ICO”), the UK supervisory authority for data protection issues (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.
5. Changes to the Privacy Notice
5.1 We keep our privacy notice under regular review to make sure it is up to date and accurate.
5.2 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.
6. Website Third-Party Links
6.1 Our website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections through our website 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.
7. The Data We Collect About You
7.1 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).
7.2 We may collect, use, store and transfer different kinds of personal data about you which we have grouped together follows:
Identity Data includes first name, maiden name, last name, username or similar identifier, marital status, title, date of birth and gender.
Contact Data includes your email address, home address and telephone numbers.
Financial Data includes bank account and payment card details.
Transaction Data includes details of services you have received from the Company.
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 this website.
Profile Data includes preferences, feedback and survey responses.
Usage Data includes information about how you use our website.
Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.
7.3 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 in law as this data does 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 privacy notice.
7.4 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.
8. If you Fail to Provide Personal Data
8.1 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 services). In this case, we may have to cancel the service you require but we will notify you if this is the case at the time.
9. How is Your Personal Data Collected?
9.1 We use different methods to collect data from and about you including through:
9.2 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:
9.2.1 request information about our services including proposals and quotations;
9.2.2 subscribe to our service or publications;
9.2.3 request marketing to be sent to you;
9.2.4 complete a survey; or
9.2.5 give us some feedback.
9.3 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, server logs and other similar technologies.
9.4 Third parties or publicly available sources. We may receive personal data about you from various third parties and public sources as set out in paragraphs 9.5 – 9.6.
9.5 Technical Data from the following parties:
i) analytics providers such as Google based inside the EU; and
ii) search information providers and credit providers based inside the EU.
9.6 Identity and Contact Data from publicly available sources such as Companies House and the Electoral Register.
10. How We Use Your Personal Data
10.1 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:
10.1.1 where we need to perform the contract we are about to enter into or have entered into with you.
10.1.2 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. Our legitimate interests are in performing services to you or promoting or furthering our services.
10.1.3 where we need to comply with a legal or regulatory obligation.
11. Purposes for Which We Will Use Your Personal Data
11.1 We have set out below, in a table format, a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.
11.2 Note that we may process your personal data for more than one lawful basis depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal basis we are relying on to process your personal data where more than one basis has been set out in the table below.
|Purpose/Activity||Type of data||Lawful basis for processing including basis of legitimate interest|
|To register you as a new client||Identity Contact||Performance of a contract with you|
|To manage our relationship with you which will include:
Marketing and Communications
|Performance of a contract with you
|To enable you to complete a survey||Identity
Marketing and Communications
|To administer and protect our business and our website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)||Identity
|To use data analytics to improve our website, products/services, marketing, customer relationships and experiences||Technical
|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)|
We strive to provide you with choices regarding certain personal data uses, particularly around marketing.
You will receive marketing communications from us if prior to 25 May 2018 you requested information from us or after 25 May signed up for such communications and, in each case, you have not opted out of receiving that marketing.
13. Opting Out
You can ask us or third parties to stop sending you marketing messages at any time by following the opt-out links on any marketing message sent to you or by contacting us at any time.
15. Change of Purpose
15.1 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.
15.2 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.
15.3 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.
16. Disclosures of Your Personal Data
16.1 We may have to share your personal data with the parties set out below for the purposes set out in the table in paragraph 11 above.
16.1.1 Internal Third Parties as set out in the Glossary.
16.1.2 External Third Parties as set out in the Glossary.
16.1.3 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 privacy notice.
16.2 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.
17. International Transfers
17.1 Many of our external third parties are based outside the European Economic Area (EEA) so their processing of your personal data will involve a transfer of data outside the EEA.
17.2 In performing our services we may transfer personal data outside of the EEA. We may for example use IT service providers in the Netherlands or third party providers based in the US as part of our normal business procedures.
17.3 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:
17.3.1 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 or where we are satisfied of the adequacy of the level and protection for personal data.
17.3.2 We may use specific contracts approved by the European Commission which give personal data the same protection it has in Europe.
17.3.3 Where we use providers based in the US, we may transfer data to them if they are part of the Privacy Shield which requires them to provide similar protection to personal data shared between Europe and the US.
17.4 Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the EEA.
18. Data Security
18.1 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 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.
18.2 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.
19. Data Retention
19.1 We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.
19.2 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 requirements.
19.3 Details of retention periods for different aspects of your personal data are available in our retention policy which you can request from us by contacting us.
19.4 In some circumstances you can ask us to delete your data: see [Request erasure] below for further information.
19.5 In some circumstances we may 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.
20. Your Legal Rights
20.1 Under certain circumstances, you have rights under data protection laws in relation to your personal data. If you wish to exercise any of the rights set out below after the Glossary please contact us.
20.2 No fee usually required
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 may refuse to comply with your request in these circumstances.
20.3 What we may need from you
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.
20.4 Time limit to respond
We try to respond to all legitimate requests within one month. Occasionally it may 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.
21. Lawful Basis
Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give you the best service/product 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.
Performance of Contract means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.
Comply with a legal or regulatory obligation means processing your personal data where it is necessary for compliance with a legal or regulatory obligation that we are subject to.
22. Third Parties
Internal Third Parties
22.1 Other companies in the Complyport Group acting as joint controllers or processors and who are based outside the EEA.
External Third Parties
22.2 Service providers acting as processors based inside and outside the EEA who provide IT and system administration services.
22.3 Professional advisers acting as processors or joint controllers including lawyers, bankers, auditors and insurers based in the United Kingdom who provide consultancy, banking, legal, insurance and accounting services.
22.4 HM Revenue & Customs, regulators and other authorities acting as processors or joint controllers based in the United Kingdom.
22.5 Financial Conduct Authority acting as processors or joint controllers based in the United Kingdom who require reporting of processing activities in certain circumstances or to whom it is necessary to provide information as part of our services.
YOUR LEGAL RIGHTS
22.6 You have the right to:
22.6.1 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.
22.6.2 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.
22.6.3 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.
22.6.4 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.
22.6.5 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: (a) if you want us to establish the data’s accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) 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; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
22.6.6 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.
22.6.7 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 products or services to you. We will advise you if this is the case at the time you withdraw your consent.