Last updated: March 5, 2018
Table of Contents
- Data controller
- Information we may collect about you
- IP addresses and cookies
- Legal basis for data processing
- Uses made of your information
- Profiling or other automated individual decision making
- Retention of your information
- Disclosure of your information
- Transfers outside the European Economic Area (EEA)
- Your rights under the GDPR
- Links to other websites
For the purpose of the General Data Protection Regulation (the “GDPR”), which applies in the UK on May 25, 2018, and other data protection laws applicable in the UK, the data controller is Compliance Online Limited (Company Registration 05706431), having its registered address at St Clare House, 33 Minories, London, EC3N 1DD.
Information we may collect about you
Data regarding you and your business is collected, retained and processed subject to and in accordance with the requirements of the GDPR. We may collect personal data, that includes: name, job title, contact information including email address and mailing address, telephone number, demographic information such as postcode, preferences and interests, employer details, pay data/information, IP address, other information relevant to customer surveys and/or offers.
We may collect and process the following data about you:
(a) Information you provide when you use our website www.paymentscompliance.com (the “website”). This includes information provided by you at the time you place an order for any of our products or services. We may also ask you for information if you report a problem with our website.
(b) If you contact us by email, through our contact form, by telephone or in writing, We may keep a copy of that correspondence or communication.
(c) Details of any transactions you carry out with us through the website or by any other means, including those contained in an order form, and of fulfilment of your orders.
(d) Details of your visits to the website and the resources that you access.
If you have provided us with the personal data of another person, you confirm that he/she consents to the processing of his/her personal data and that you have informed him/her of our identity as a data controller and provided him/her with a copy of our Terms and Conditions and this policy.
We also monitor visitors to and content on our message board and blog sites to meet our obligations to ensure that rules as to content are being followed. We will review and, if appropriate, edit content on these sites.
IP addresses and cookies
We may collect information about your mobile phone, computer or other device from which you access the website. Such information may include your domain name and IP address, details of your computer operating system and browser, the website you visited prior to visiting our website and unique number identifiers that are automatically generated by our systems when you visit our website. This will include details of the choices you make on our website indicating whether you wish to receive information on other products and services.
Legal basis for data processing
We can process personal data on various legal bases.
For processing operations for which we obtain consent for a specific processing purpose, Article 6(1)(a) of the GDPR is our legal basis.
If the processing of personal data is necessary for the performance of a contract to which the data subject is party, as for example when processing operations are necessary to provide our service, the processing is based on Article 6(1)(b) of the GDPR. The same applies to such processing operations which are necessary for carrying out pre-contractual measures, for example in the case of inquiries concerning our products or services.
If our company is subject to a legal obligation by which processing of personal data is required, such as for the fulfilment of tax obligations, our processing is based on Article 6(1)(c) of the GDPR.
Finally, we can base our processing operations on Article 6(1)(f) of the GDPR: this legal basis is used for processing operations which are not covered by the abovementioned legal grounds, if processing is necessary for the purposes of the legitimate interests pursued by our company or by a third party, except where such interests are overridden by the interests or fundamental rights and freedoms of the data subject which require protection of personal data.
Uses made of your information
We use the information collected about you for the following purposes:
- To ensure the products and services you have chosen are delivered to you in the most effective way, and to assist with the performance of our internal contract, accounting and administrative functions.
- To carry out our obligations arising from any contracts entered into between you and us.
- To report aggregate information to our advertisers. This is statistical data about our users’ browsing actions and patterns and does not identify any individual.
- To assist us in developing new and improved products as indicated by user practice and preferences, based on our analysis of patterns of site usage.
- To provide you with details of changes to our products or of other product offerings which we believe may be of interest to you from PaymentsCompliance or other third-party providers. We will not share your data with third parties for marketing purposes unless we have procured your express consent to do so.
Profiling or other automated individual decision making
Automated individual decision making refers to a decision made solely on the basis of automated processing of your personal data, without human involvement. For instance, this means processing using an algorithm or a software code. Profiling is defined as automated processing of personal data to evaluate certain things about an individual: profiling can be part of an automated decision-making process.
We may conduct automated decision making or profiling to better understand your centre of interests and preferences and adapt our communications to your profile. However, we want you to know that you have certain rights in respect of automated decision making and profiling, where that decision produces a legal effect on you. Please see below the section on “Your rights under the GDPR” for more information about your rights.
Retention of your information
We take appropriate measures to ensure that any information collected from you is kept only for so long as is necessary for the purpose for which such information is used.
We normally update your personal data within seven (7) working days of any new or updated personal data being provided to us, to ensure that the personal data we hold about you is as accurate as possible.
We protect your data by:
Offering you a secure transmission method to send us personal or company information.
Implementing security policies and technical measures to protect data from:
- unauthorised access;
- improper use or disclosure;
- unauthorised modification; and
- unlawful destruction or accidental loss.
Disclosure of your information
We may disclose your personal information to any member of our group, which means our subsidiaries, our ultimate holding company and its subsidiaries as defined in Section 1159 of the UK Companies Act 2006.
We may disclose your personal information to third parties:
(a) In the event that we sell or buy any business or assets, in which case we may disclose your personal data to the prospective seller or buyer of such business or assets.
(b) If we or substantially all of our assets are acquired by a third party, in which case personal data held about our customers will be one of the transferred assets.
(c) If we are under a duty to disclose or share your personal data to comply with any legal obligation.
(d) To enforce or apply our Terms and Conditions and other agreements.
(e) If it is required to do so to deliver our services. We sometimes outsource certain functions of our business to service providers: some of these service providers may use cloud-based systems: in that case, your personal data would be hosted on their servers, but under our direction and control.
(e) To protect the rights, property or safety of PaymentsCompliance, our customers or others.
(f) Where we have received your permission for us to do so.
Transfers outside the European Economic Area (EEA)
We will only transfer your personal data to countries which are considered as providing an adequate level of legal protection or where alternative arrangements are in place to protect your rights.
We may transfer your personal data outside the EEA in the unlikely event that we receive a legal request from a foreign law enforcement body. All requests for information we receive from these bodies will be carefully checked before personal data is transferred.
We may use remote website server hosts to provide and maintain some aspects of our service and website, which may be based outside the EEA (in “the cloud”). Transfers to service providers outside the EEA will be protected by contractual commitments and, where appropriate, further assurances, such as certification schemes (including the EU-US Privacy Shield for the protection of personal data transferred from the EU to the US and accessed in the US).
You have the right to ask for more information about the safeguards we have put in place as mentioned above.
Your rights under the GDPR
- Right of access
The GDPR gives you the right to access information held about you. If you wish to exercise such right, please submit a request to us in writing at firstname.lastname@example.org.
Any access request shall be subject to your providing acceptable proof of identification.
If we are processing your personal data, we will provide you with a copy of that personal data.
If you require additional copies, we may charge a reasonable administrative fee.
- Right of rectification
You are entitled to have your personal data rectified if it is inaccurate or incomplete. You should instruct us to correct or update any personal data we hold about you (for instance if you change your address or your name).
You can instruct us to do this at any time by contacting us at email@example.com.
- Right to erasure
You have a right to have your personal data erased and to prevent processing in specific circumstances. If you wish to exercise such right, please submit a request to us in writing at firstname.lastname@example.org.
- Right to restrict processing
In certain circumstances, you have the right to obtain from us restriction of processing (especially when the accuracy of the personal data is contested by you, for a period enabling us to verify the accuracy of the personal data).
- Right to withdraw your consent
In certain circumstances, we must have your consent before we contact you. You have the right to withdraw your consent to processing of your personal data at any time by contacting us at email@example.com.
- Right to data portability
With effect from May 25, 2018, you have the right, in certain circumstances, to obtain personal data you have provided us with, in a structured, commonly used and machine-readable format, and to reuse it elsewhere or ask us to transfer this to a third party of your choice.
- Right to object
You have the right to object to:
- Processing based on legitimate interests or the performance of a task in the public interest/exercise of official authority (including profiling).
- Direct marketing (including profiling).
- Processing for purposes of scientific/historical research and statistics.
- Rights related to automated decision-making and profiling
You have the right not to be subject to a decision based solely on automated processing, including profiling, which produces legal effects concerning you or similarly significantly affects you, as long as the decision is not necessary for entering into, or the performance of, a contract between you and us; or is not based on your explicit consent.
- Right to lodge a complaint with a supervisory authority
You have a right to lodge a complaint with a supervisory authority, to enforce your rights, as specified above. You can find details about how to do this on the UK Information Commissioner’s Office (ICO) website at https://ico.org.uk/concerns/.
Links to other websites
Our website offers links to many third-party websites. We are not responsible for the accuracy or efficacy of the information or data policies or procedures of these third parties. If you access these sites using the links provided on our website, you should satisfy yourself as to the relevant data policies in effect on these sites.