How do we use your information?
Right to be Informed
We may use your information for the following purposes:
To verify your identity and manage your account.
When you apply for an account with us we need to verify your identity using the information that you give us, and we also use that information so that we can effectively manage your account. We may use third parties to help us verify your identity. Not only do we have a legal obligation to use the information that you provide to comply with ‘Know Your Client’ regulations, but it is also in our legitimate interest to do so.
To provide products and services and review your ongoing needs.
Once you register for an app or open a demo or real account with us, we need to use your personal information to provide you with the service you have requested and comply with our obligations to you. We do this to comply with our contractual obligations to you, and also as it is also in our legitimate interest to review your needs from time to time to ensure that you are getting the benefits of the best products and services from us.
To assist us in the development and marketing of our products and services.
We may use personal information about you through your use of our service to help us improve our service. It is in our legitimate interest to use your data in this way to further develop our service and ensure that we continually meet your expectations.
To assist in the investigation of any dispute between you and us or, where relevant, for the purpose of investigating a dispute with a third party.
We may need to use your personal information to investigate disputes between you and us or between a third party and us. We do this to comply with our contractual obligations and also as it is in our legitimate interest to ensure that any disputes are resolved in a quick and efficient manner.
To comply with any applicable law, court order, or judicial process, or to fulfil our legal obligations toward any regulatory authority with jurisdiction over us.
We may need to use your personal information to comply with any applicable law, court order or judicial process, or to fulfil our legal obligations toward any regulatory authority with jurisdiction over us. We do this to comply with our legal obligations and also because it may be in our legitimate interest to do so.
To form a profile about you.
We may use your personal data to form a profile about you so that we can better understand you and provide you with the best service that we can because it may be in our legitimate interest to do so.
For Data analysis purposes.
Our Web pages and e-mails may contain web beacons or pixel tags or any other similar type of data analysis tools which allow us to track receipt of correspondence and to count the number of users that have visited our webpage or opened our correspondence. Where your personal information is completely anonymised, we do not require a lawful basis as the information will no longer constitute personal information. However, where your personal information is not in an anonymised form, it is in our legitimate interest to continually evaluate that personal information to ensure that the products and services we provide are relevant to you.
To provide references about you.
From time to time third parties such as credit agencies may approach us and request information about you to perform credit and identity checks. We may have a legal obligation to comply or it may be in our legitimate interest to do so. However if we are unsure in regards to providing this information we will speak to you first.
To assist in our marketing to you.
We may use your personal information to send you marketing communications by phone, email, or other agreed forms (including social media campaigns) to ensure you are kept up to date with our services. We will send you marketing communications as it is in our legitimate interest to do so or with your consent.
Internal business purposes and record keeping.
We may use your personal information for internal business purposes and record keeping purposes. Such processing is necessary to comply with our legal obligations and is in our legitimate interest to do so.
If we undergo a corporate restructure or part of our business is acquired by a third party, we may need to use your personal information in association with that restructure or acquisition. Such use may include using your details as part of a due diligence exercise. It is in our legitimate interest to use your information in this way provided we comply with any legal obligation we have to you.
Should you visit our premises we may take an image of you via CCTV. We do this as it is in our legitimate interest to ensure a safe working environment.
How long we retain personal information for
Your personal data will not be kept for longer than is necessary for the purposes for which it was collected and processed and for the purposes of satisfying any legal, accounting or reporting requirements.
The criteria we use for retaining your personal data, includes the following:
- General queries and correspondence – when you make an enquiry or contact us by email or telephone, we will retain your information for as long as necessary to respond to your queries. After this period, we will not hold your personal data for longer than 7 years if we have not had any active subsequent contact with you;
- Direct marketing – where we hold your personal data on our database for direct marketing purposes, we will retain your data for no longer than 7 years if we have not had any active subsequent contact with you.
- Legal and regulatory requirements – we may need to retain personal data for up to 7 years where necessary to comply with our legal obligations, resolve disputes or enforce our terms and conditions.
Your Rights in relation to your personal data.
Information about any rights that are available to you in relation to the personal information that we hold about you is set out below:
Right of Access
Upon request we will confirm whether we are processing your personal information, and supply you with an electronic copy of the personal information held by us. This is called a Subject Access Request (SAR).
Right of Rectification
If the personal information we hold about you is inaccurate or incomplete, you are entitled to have it corrected. If we have shared your information with a third party we will let them know about the rectification where possible. If you ask us, where possible and lawful to do so, we will also tell you who we have shared your information with so that you can contact them directly.
Right to be Forgotten (Erasure)
You can ask us to delete or remove your personal information in certain circumstances such as where we no longer need it or you withdraw your consent (where applicable) provided that we have no legal obligation to retain that data. Such request will be subject to any retention limits we are required to comply with in accordance with applicable laws and regulations. If we have shared your personal information with others, we will let them know about the erasure where possible. If you ask us, where possible and lawful to do so, we will also tell you who we have shared your personal information with so that you can contact them directly.
Right to Restrict Processing
You can ask us to stop processing your personal information in certain circumstances and we will do so within the boundaries permitted by our legal and regulatory obligations. We will continue to store your personal information though. We will tell you before we lift any restriction. If we have shared your personal information with others, we will let them know about the restriction where possible. If you ask us, where possible and lawful to do so, we will also tell you who we have shared your personal information with so that you can contact them directly.
The Right to Data Portability
The General Data Protection Regulations (GDPR 679/2016) give you the right to obtain the personal information you have provided us with in a structured, commonly used, machine readable format, and to reuse it elsewhere or ask us to transfer it to a third party of your choice.
Right to Object
You may ask us to stop processing your personal information when we are:
- Relying on a legitimate interest to process the data unless we can demonstrate compelling legal grounds to do so,
- Processing your personal information for direct marketing purposes,
- Processing data for research unless such processing is necessary for the performance of a task carried out in the public interest.
Automated decision making and profiling
If we have made a decision about you based solely on an automated process (e.g. through automatic profiling) that affects your ability to use the services or has another significant effect on you, you can ask to not to be subject to such a decision unless we can demonstrate to you that such decision is necessary for entering into, or the performance of, a contract between you and us. Even where a decision is necessary for entering into or performing a contract, you may contest the decision and require human intervention.
Making a Subject Access Request (SAR)
If you wish to make a SAR you should contact us by email at email@example.com with details of the information that you are requesting. We kindly request that when contacting us you provide a brief description of the data that you require or an explanation of which right you wish to exercise.
However, if your requests are manifestly unfounded or excessive, in particular because of their repetitive character, we may either: (a) charge a reasonable fee taking into account the administrative costs of providing the information or taking the action requested; or (b) refuse to act on the request.
We may require proof of identity before we start to process your request.
Your duty to inform us of changes.
Please ensure that when any of your personal details change, such as your telephone number, you notify us immediately so that the data we hold about you is accurate and up to date.