This Privacy Policy sets out how we, FINTECH Circle Ltd, collect, store
and use information about you when you use or interact with
www.PAYTECHBOOK.com (our website) and where we otherwise obtain or
collect information about you. This Privacy Policy is effective from 15
Sept 2018.
Contents
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Summary
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Our details
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Information we collect when you visit our website
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Information we collect when you contact us
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Information we collect when you interact with our website
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Information we collect when you place an order on our website
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How we collect or obtain information about you from third
parties
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Our use of automated decision-making and profiling
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Disclosure and additional uses of your information
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How long we retain your information
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How we secure your information
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Transfers of your information outside the European Economic
Area
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Your rights in relation to your information
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Your right to object to the processing of your information for
certain purposes
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Sensitive Personal Information
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Changes to our Privacy Policy
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Children’s Privacy
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Copyright, credit and logo
Summary
This section summarises how we obtain, store and use information about
you. It is intended to provide a very general overview only. It is not
complete in and of itself and it must be read in conjunction with the
corresponding full sections of this Privacy Policy.
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Data controller: FINTECH Circle Ltd
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How we collect or obtain information about you:
when you provide it to us (e.g. by contacting us, signing up as a
new member, co-author, lecturer, student, placing an order on our
website and by signing up to your e-newsletter and/or surveys),
from your use of our website, using cookies and similar
technologies, and
occasionally, from third parties.
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Information we collect: name, contact details, payment information
e.g. your credit or debit card details (if applicable), IP address,
information from cookies, information about your computer or device
(e.g. device and browser type), information about how you use our
website (e.g. which pages you have viewed, the time when you view
them and what you clicked on, the geographical location from which
you accessed our website (based on your IP address), company name
or business name (if applicable), VAT number (if applicable), and
if you complete the joining form you provide us with the following
information which we collect such as your linkedin ID, your
title/position, your areas of expertise, membership in other
networks, membership type, investor categorization, amount,
objectives for joining, any comments and declaration of experience
status.
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How we use your information: for administrative and business
purposes (particularly to contact you and process orders you place
on our website), to improve our business and website, to fulfil our
contractual obligations, to advertise our goods and services, to
analyse your use of our website, and in connection with our legal
rights and obligations.
Disclosure of your information to third parties: only to the extent
necessary to run our business, to our service providers, to fulfil
any contracts we enter into with you, where required by law or to
enforce our legal rights.
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Do we sell your information to third parties (other than in the
course of a business sale or purchase or similar event): No
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How long we retain your information: for no longer than necessary,
taking into account any legal obligations we have (e.g. to maintain
records for tax purposes), any other legal basis we have for using
your information (e.g. your consent, performance of a contract with
you or our legitimate interests as a business). For specific
retention periods in relation to certain information which we
collect from you, please see the main section below entitled How
long we retain your information.
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How we secure your information: using appropriate technical and
organisational measures such as storing your information on secure
servers, encrypting transfers of data to or from our servers using
Secure Sockets Layer (SSL) technology, encrypting payments you make
on or via our website using Secure Sockets Layer (SSL) technology,
only granting access to your information where necessary.
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Use of cookies and similar technologies: we use cookies and similar
information-gathering technologies such as web beacons on our
website including essential, functional, analytical and targeting
cookies. For more information, please visit our cookies policy
here: [insert link to cookies policy]
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Transfers of your information outside the European Economic Area:
in certain circumstances we transfer your information outside of
the European Economic Area, including to the following countries:
USA and Canada. Where we do so, we will ensure appropriate
safeguards are in place for data transfers outside the European
Economic Area e.g. the third parties we use who transfer your
information outside the European Economic Area have self-certified
themselves as compliant with the EU-U.S. Privacy Shield.
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Use of automated decision making and profiling: we use automated
decision making and profiling e.g. use of web analytics, cookies,
web beacons or server logs analysis tools
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Your rights in relation to your information
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to access your information and to receive information about
its use
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to have your information corrected and/or completed
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to have your information deleted
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to restrict the use of your information
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to receive your information in a portable format
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to object to the use of your information
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to withdraw your consent to the use of your information
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to complain to a supervisory authority
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Sensitive personal information: we do not knowingly or
intentionally collect what is commonly referred to as ‘sensitive
personal information’. Please do not submit sensitive personal
information about you to us. For more information, please see the
main section below entitled Sensitive Personal Information.
Our details
The data controller in respect of our website is FINTECH Circle Ltd,
Company Number:
09141483 of 50 Liverpool Street, London, EC2M 7PY. You
can contact the data controller by writing to FINTECH Circle ltd, c/o
Intelletec Ltd, The Office Group, 50 Liverpool Street, London, England,
EC2M 7PY or sending an email to [email protected]
If you have any questions about this Privacy Policy, please contact the
data controller.
Information we collect when you visit our website
We collect and use information from website visitors in accordance with
this section and the section entitled Disclosure and additional uses of
your information.
Web server log information
We use third party servers to host our websites called:
Our website servers automatically log the IP address you use to access
our website as well as other information about your visit such as the
pages accessed, information requested, the date and time of the
request, the source of your access to our website (e.g. the website or
URL (link) which referred you to our website), and your browser version
and operating system.
Our servers are located in the United States and, accordingly, your
information is transferred outside the European Economic Area (EEA).
For further information and information on the safeguards used, please
see the section of this privacy policy entitled Transfers of your
information outside the European Economic Area.
Use of website server log information for IT security purposes
We and our third party hosting providers collect and store server logs
to ensure network and IT security and so that the server and website
remain uncompromised. This includes analysing log files to help
identify and prevent unauthorised access to our network, the
distribution of malicious code, denial of services attacks and other
cyber attacks, by detecting unusual or suspicious activity.
Unless we are investigating suspicious or potential criminal activity,
we do not make, nor do we allow our hosting provider to make, any
attempt to identify you from the information collected via server logs.
Legal basis for processing: compliance with a legal obligation to which
we are subject (Article 6(1)(c) of the General Data Protection
Regulation).
Legal obligation: we have a legal obligation to implement appropriate
technical and organisational measures to ensure a level of security
appropriate to the risk of our processing of information about
individuals. Recording access to our website using server log files is
such a measure.
Legal basis for processing: our legitimate interests (Article 6(1)(f)
of the General Data Protection Regulation).
Legitimate interests: we have a legitimate interest in using your
information for the purposes of ensuring network and information
security.
Use of website server log information to analyse website use and
improve our website
We use the information collected by our website server logs to analyse
how our website users interact with our website and its features. For
example, we analyse the number of visits and unique visitors we
receive, the time and date of the visit, the location of the visit and
the operating system and browser used.
We use the information gathered from the analysis of this information
to improve our website. For example, we use the information gathered to
change the information, content and structure of our website and
individual pages based according to what users are engaging most with
and the duration of time spent on particular pages on our website.
Legal basis for processing: our legitimate interests (Article 6(1)(f)
of the General Data Protection Regulation).
Legitimate interest: improving our website for our website users and
getting to know our website users’ preferences so our website can
better meet their needs and desires.
Cookies and similar technologies
Cookies are data files which are sent from a website to a browser to
record information about users for various purposes.
We use cookies and similar technologies on our website, including
essential, functional, analytical and targeting cookies and web
beacons. For further information on how we use cookies, please see our
cookies policy which is available here: Cookie Policy.
You can reject some or all of the cookies we use on or via our website
by changing your browser settings or non-essential cookies by using our
cookie control tool, but doing so can impair your ability to use our
website or some or all of its features. For further information about
cookies, including how to change your browser settings, please visit
www.allaboutcookies.org
or see our cookies policy.
Information we collect when you contact us
We collect and use information from individuals who contact us in
accordance with this section and the section entitled Disclosure and
additional uses of your information.
Email
When you send an email to the email address displayed on our website we
collect your email address and any other information you provide in
that email (such as your name, telephone number and the information
contained in any signature block in your email).
Legal basis for processing: our legitimate interests (Article 6(1)(f)
of the General Data Protection Regulation).
Legitimate interest(s): responding to enquiries and messages we receive
and keeping records of correspondence.
Legal basis for processing: necessary to perform a contract or to take
steps at your request to enter into a contract (Article 6(1)(b) of the
General Data Protection Regulation).
Reason why necessary to perform a contract: where your message relates
to us providing you with goods or services or taking steps at your
request prior to providing you with our goods and services (for
example, providing you with information about such goods and services),
we will process your information in order to do so).
Transfer and storage of your information
We use a third party email provider to store emails you send us. Our
third party email provider is Google Mail (Gmail). Their privacy policy
is available here:
https://policies.google.com/privacy
Emails you send us will be stored outside the European Economic Area on
our third party email provider’s Gmail servers in North America. For
further information please see the section of this privacy policy
entitled Transfers of your information outside the European Economic
Area.
Contact form
When you contact us using our contact form, we collect your name, email
address, IP address and your request for information. We also collect
any other information you provide to us when you complete the contact
form, including any optional information, such as your company name,
title, phone number or social media profile.
If you do not provide the mandatory information required by our contact
form, you will not be able to submit the contact form and we will not
receive your enquiry.
Legal basis for processing: our legitimate interests (Article 6(1)(f)
of the General Data Protection Regulation).
Legitimate interest(s): responding to enquiries and messages we receive
and keeping records of correspondence.
Legal basis for processing: necessary to perform a contract or to take
steps at your request to enter into a contract (Article 6(1)(b) of the
General Data Protection Regulation).
Reason why necessary to perform a contract: where your message relates
to us providing you with goods or services or taking steps at your
request prior to providing you with our goods and services (for
example, providing you with information about such goods and services),
we will process your information in order to do so).
Transfer and storage of your information
Messages you send us via our contact form will be stored outside the
European Economic Area on our third party hosting and email provider’s
servers in North America. Our third party email provider is
Google/Gmail and our hosting provider is WP Engine or Amazon Web
Services AWS, both located in North America. Their privacy policy is
available below:
Google’s privacy policy is available here:
https://policies.google.com/privacy
.
WP Engine’s privacy policy is available here:
https://wpengine.co.uk/legal/privacy
.
Amazon Web Services, AWS’ privacy policy is available here:
https://aws.amazon.com/privacy
.
We also use a third party contact form provider to store messages you
send us. Our contact form provider is located in North America. Their
privacy policy is available here: https://www.wufoo.co.uk/privacy/.
Messages you send to us via our contact form will be stored outside the
European Economic Area on our contact form provider’s servers in North
America.
For further information about the safeguards used when your information
is transferred outside the European Economic Area, see the section of
this privacy policy below entitled Transfers of your information
outside the European Economic Area.
Phone
When you contact us by phone, we collect your phone number and any
information provided to us during your conversation with us.
We do not record phone calls.
Legal basis for processing: our legitimate interests (Article 6(1)(f)
of the General Data Protection Regulation).
Legitimate interest(s): responding to enquiries and messages we receive
and keeping records of correspondence.
Legal basis for processing: necessary to perform a contract or to take
steps at your request to enter into a contract (Article 6(1)(b) of the
General Data Protection Regulation).
Reason why necessary to perform a contract: where your message relates
to us providing you with goods or services or taking steps at your
request prior to providing you with our goods and services (for
example, providing you with information about such goods and services),
we will process your information in order to do so).
Transfer and storage of your information
Information about your call, such as your phone number and the date and
time of your call, is processed by our third party telephone service
provider, Vodafone, located in the European Economic Area. Their
privacy policy is available here:
https://www.vodafone.co.uk/about-this-site/our-privacy-policy
.
Information about your phone call will be stored by our third party
telephone service provider within the European Economic Area.
Post
If you contact us by post, we will collect any information you provide
to us in any postal communications you send us.
Legal basis for processing: our legitimate interests (Article 6(1)(f)
of the General Data Protection Regulation)
Legitimate interest(s):
responding to enquiries and messages we receive and keeping records of
correspondence.
Legal basis for processing: necessary to perform a contract or to take
steps at your request to enter into a contract (Article 6(1)(b) of the
General Data Protection Regulation).
Reason why necessary to perform a contract: where your message relates
to us providing you with goods or services or taking steps at your
request prior to providing you with our goods and services (for
example, providing you with information about such goods and services),
we will process your information in order to do so).
Information we collect when you interact with our website
We collect and use information from individuals who interact with
particular features of our website in accordance with this section and
the section entitled Disclosure and additional uses of your
information.
E-Newsletter
When you sign up for our e-newsletter on our website or opt to receive
news and offers from us by entering your name and email address and
clicking subscribe or by ticking a box at checkout indicating that you
would like to receive our e-newsletter, we collect your name and email
address.
Legal basis for processing: your consent (Article 6(1)(a) of the
General Data Protection Regulation).
Consent: you give your consent to us sending you our e-newsletter by
signing up to receive it using the steps described above.
Transfer and storage of your information
We use a third party service to send out our e-newsletter and
administer our mailing list, MailChimp. Their privacy policy is
available here:
https://mailchimp.com/legal/privacy
.
Information you submit to subscribe for our e-newsletter will be stored
outside the European Economic Area on our Mailchimp servers in North
America. For further information about the safeguards used when your
information is transferred outside the European Economic Area, see the
section of this privacy policy below entitled Transfers of your
information outside the European Economic Area.
Use of web beacons and similar technologies in emails
We use technologies such as web beacons (small graphic files) in the
emails we send to allow us to assess the level of engagement our emails
receive by measuring information such as the delivery rates, open rates
and click through rates which our emails achieve. We will only use web
beacons in our emails if you have consented to us doing so.
For more information on how we use web beacons in our e-newsletter
emails, see our cookies policy which is available here: Cookie Policy
For more information about our third party mailing list provider and
they use web beacons, please see their privacy policy which is
available here:
https://mailchimp.com/legal/privacy
.
Registering on our website
When you register and create an account on our website (where
applicable), we collect the following information: name, email address,
IP address and any other information you provide to us when you
complete the registration form, including your company name, title and
country.
If you do not provide the mandatory information required by the
registration form, you will not be able to register or create an
account on our website.
Legal basis for processing: necessary to perform a contract or to take
steps at your request prior to entering into a contract (Article
6(1)(b) of the General Data Protection Regulation).
Reason why necessary to perform a contract: creating an account on our
website is necessary to allow you to access the goods and services you
have purchased from us
Transfer and storage of your information
Information you submit to us via the registration form on our website
will be stored outside the European Economic Area on our third party
hosting provider’s servers in North America. Our third party hosting
provider is WP Engine and AWS located in North America. Their privacy
policy is available below:
For further information about the safeguards used when your information
is transferred outside the European Economic Area, see the section of
this privacy policy below entitled Transfers of your information
outside the European Economic Area.
Information we collect when you place an order on our website
We collect and use information from individuals who place an order on
our website in accordance with this section and the section entitled
Disclosure and additional uses of your information.
Information collected when you place an order
Mandatory information
When you place an order for goods or services on our website, we
collect your name, email address, billing address, shipping address,
company name (if applicable), VAT number (if applicable), and which
product you want to purchase.
If you do not provide this information, you will not be able to
purchase goods or services from us on our website or enter into a
contract with us.
Legal basis for processing: necessary to perform a contract (Article
6(1)(b) of the General Data Protection Regulation).
Reason why necessary to perform a contract: we need the mandatory
information collected by our checkout form to establish who the
contract is with and to contact you to fulfil our obligations under the
contract, including sending you receipts and order confirmations.
Processing your payment
After you place an order on our website you will need to make payment
for the goods or services you have ordered. In order to process your
payment we use the third party payment processor PayPal.
Paypal collects, uses and processes your information, including payment
information, in accordance with their privacy policies. You can access
their privacy policy via the following link:
https://www.paypal.com/en/webapps/mpp/ua/privacy-full
.
Transfer and storage of your information
Paypal is located in North America. Information relating to the
processing of your payment is stored outside the European Economic Area
on Paypal’s servers in North America.
For further information about the safeguards used when your information
is transferred outside the European Economic Area, see the section of
this privacy policy below entitled Transfers of your information
outside the European Economic Area.
Legal basis for processing: necessary to perform a contract (Article
6(1)(b) of the General Data Protection Regulation).
Reason why necessary to perform a contract: to fulfil your contractual
obligation to pay for the goods or services you have ordered from us.
Marketing communications
At checkout you will have the option of receiving marketing
communications from us.
Our goods and services
You can opt in to receiving marketing communications from us in
relation to our goods and services by email, and text message by
ticking a box indicating that you would like to receive such
communications.
We will send you marketing communications in relation to our goods and
services only if you opt-in to receive them.
Legal basis for processing: consent (Article 6(1)(a) of the General
Data Protection Regulation).
Consent: you give your consent to us sending you information about our
goods and services by signing up to receive such information in
accordance with the steps described above.
Transfer and storage of your information
We use a third party service to administer our mailing list, MailChimp.
Information you submit to subscribe for our e-newsletter will be stored
outside the European Economic Area on our third party mailing list
provider’s servers in North America. For further information about the
safeguards used when your information is transferred outside the
European Economic Area, see the section of this privacy policy below
entitled Transfers of your information outside the European Economic
Area.
Use of web beacons and similar technologies in emails
We use technologies such as web beacons (small graphic files)] in the
emails we send to allow us to assess the level of engagement our emails
receive by measuring information such as the delivery rates, open rates
and click through rates which our emails achieve. We will only use web
beacons in our emails if you have consented to us doing so.
For more information on how we use web beacons in our emails, see our
cookies policy which is available here:
Cookie Policy
.
For more information about our third party mailing list provider and
how they use web beacons, please see their privacy policy which is
available here:
https://mailchimp.com/legal/privacy
.
Information collected or obtained from third parties
This section sets out how we obtain or collect information about you
from third parties.
Information received from third parties
Generally, we do not receive information about you from third parties.
It is also possible that third parties with whom we have had no prior
contact may provide us with information about you.
Information we obtain from third parties will generally be your name
and contact details, but will include any additional information about
you which they provide to us.
Legal basis for processing: necessary to perform a contract or to take
steps at your request to enter into a contract (Article 6(1)(b) of the
General Data Protection Regulation).
Reason why necessary to perform a contract: where a third party has
passed on information about you to us (such as your name and email
address) in order for us to provide services to you, we will process
your information in order to take steps at your request to enter into a
contract with you and perform a contract with you (as the case may be).
Legal basis for processing: consent (Article 6(1)(a) of the General
Data Protection Regulation).
Consent: where you have asked that a third party to share information
about you with us and the purpose of sharing that information is not
related to the performance of a contract or services by us to you, we
will process your information on the basis of your consent, which you
give by asking the third party in question to pass on your information
to us.
Legal basis for processing: our legitimate interests (Article 6(1)(f)
of the General Data Protection Regulation).
Legitimate interests: where a third party has shared information about
you with us and you have not consented to the sharing of that
information, we will have a legitimate interest in processing that
information in certain circumstances.
For example, we would have a legitimate interest in processing your
information to perform our obligations under a sub-contract with the
third party, where the third party has the main contract with you. Our
legitimate interest is the performance of our obligations under our
sub-contract.
Similarly, third parties may pass on information about you to us if you
have infringed or potentially infringed any of our legal rights. In
this case, we will have a legitimate interest in processing that
information to investigate and pursue any such potential infringement.
Where we receive information about you in error
If we receive information about you from a third party in error and/or
we do not have a legal basis for processing that information, we will
delete your information.
Information obtained by us from third parties
In certain circumstances (for example, to verify the information we
hold about you or obtain missing information we require to provide you
with a service) we will obtain information about you from certain
publicly accessible sources, both EU and non-EU, such as Companies
House, business directories, media publications, social media, and
websites (including your own website if you have one).
Legal basis for processing: necessary to perform a contract or to take
steps at your request to enter into a contract (Article 6(1)(b) of the
General Data Protection Regulation).
Reason why necessary to perform a contract: where you have entered into
a contract or requested that we enter into a contract with you, in
certain circumstances, we will obtain information about you from public
sources in order to enable us to understand your business and provide
services to you or services to a sufficient standard.
For example, we would obtain and/or verify your email address from your
website or from a directory where you ask us to send you information by
email if we do not possess the information or we need to confirm that
we have recorded your email address correctly.
Legal basis for processing: our legitimate interests (Article 6(1)(f)
of the General Data Protection Regulation).
Legitimate interests: in certain circumstances, we will have a
legitimate interest in obtaining information about you from public and
private sources. For example, if you have infringed or we suspect that
you have infringed any of our legal rights, we will have a legitimate
interest in obtaining and processing information about you from such
sources in order to investigate and pursue any suspected or potential
infringement.
Our use of automated decision-making and profiling
We use profiling on our website. We do not consider that this has any
legal effect on you or similarly significantly affects you.
You have the right to object to our use of profiling described in this
section. You can do that by opting-out of cookies and similar
technologies in accordance with the method described in the relevant
section below. If you do not want us to process your actual IP address
(usually the IP address assigned to you by your Internet Service
Provider) when you visit our website, you can use a Virtual Private
Network (VPN) or a free service such as Tor.
You can find out more about our use of cookies and similar technologies
(including the legal basis on which we use them) and how to opt out
from them in our cookies policy, which is available here:
Cookie Policy
.
Automated decision making
Automated decision making is decision making by technological means
(i.e. by a machine) without human involvement. We currently do not use
automated decision making.
Profiling
Profiling is any form of automated processing of your information to
evaluate personal aspects about you, in particular to analyse or
predict things like your personal preferences, interests, behaviour, or
location.
Use of profiling for web analytics
Our web analytics service, Google Analytics collects information such
as your location (based on your IP address) and your behaviour (based
on cookies) when you access our website (such as the pages you visit
and what you click on. We will only process information from cookies if
you have consented to us setting cookies on your computer in accordance
with our cookies policy ([insert link to cookies policy]).
Logic involved: by automatically analysing and categorising information
such as the location (based on IP address) as well as the behaviour and
devices of visitors to our website (using cookies), we are able to gain
a better understanding of what our website visitors want (in terms of
the content of our website and our products), how to improve our
website and how to advertise and market our services to them.
Significance and envisaged consequences: cookies will be used to track
and store information about your behaviour and device on our website
(unless you have opted out from receiving such cookies by using our
cookie management tool) and your location will be analysed based on
your IP address.
Legal basis for processing: our legitimate interests (Article 6(1)(f)
of the General Data Protection Regulation).
Legitimate interest:
improving our website for our website users and getting to know our
website users’ preferences so our website can better meet their needs
and desires.
Use of profiling in marketing emails
We use web beacons in our marketing emails to analyse who opens our
emails and what actions they take (for example, what they click on). We
will only process information from web beacons if you have consented to
their use in accordance with our cookies policy ([insert link to
cookies policy]).
Logic involved: By analysing how our email recipients respond to our
emails, we are able to improve the content and effectiveness of our
emails and gauge who is most interested.
Significance and envisaged consequences: your behaviour when you open
our emails will be tracked using small gif files (web beacons),
including open rates, and click through rates.
How to object: You can object to our use of web beacons by emailing [email protected].
Legal basis for processing: legitimate interests (Article 6(1)(f) of
the General Data Protection Regulation).
Legitimate interest: analysing the level of engagement and
effectiveness of our marketing emails and content
Disclosure and additional uses of your information
This section sets out the circumstances in which we disclose
information about you to third parties and any additional purposes for
which we use your information.
Disclosure of your information to service providers
We use a number of third parties to provide us with services which are
necessary to run our business or to assist us with running our
business. These include the following:
Apart from Vodafone which are located in the UK, our service providers
are located in the United States.
Your information will be shared with these service providers where
necessary to provide you with the service you have requested, whether
that is accessing our website or ordering goods and services from us.
Legal basis for processing: legitimate interests (Article 6(1)(f) of
the General Data Protection Regulation).
Legitimate interest relied on: where we share your information with
these third parties in a context other than where is necessary to
perform a contract (or take steps at your request to do so), we will
share your information with such third parties in order to allow us to
run and manage our business efficiently.
Legal basis for processing: necessary to perform a contract and/or to
take steps at your request prior to entering into a contract (Article
6(1)(b) of the General Data Protection Regulation).
Reason why necessary to perform a contract: we may need to share
information with our service providers to enable us to perform our
obligations under that contract or to take the steps you have requested
before we enter into a contract with you.
Disclosure of your information to other third parties
We disclose your information to other third parties in specific
circumstances, as set out below.
Providing information to third parties such as Google Inc. Google
collects information through our use of Google Analytics on our
website. Google uses this information, including IP addresses and
information from cookies, for a number of purposes, such as improving
its Google Analytics service. Information is shared with Google on an
aggregated and anonymised basis. To find out more about what
information Google collects, how it uses this information and how to
control the information sent to Google, please see the following page:
https://www.google.com/policies/privacy/partners
.
Legal basis for processing: our legitimate interests (Article 6(1)(f)
of the General Data Protection Regulation).
Legitimate interest(s): meeting our contractual obligations to Google
under our Google Analytics Terms of Service (
https://www.google.com/analytics/terms/us.html
).
You can opt out of Google Analytics by installing the browser plugin
here:
https://tools.google.com/dlpage/gaoptout
.
Transfer and storage of your information
Information collected by Google Analytics is stored outside the
European Economic Area on Google’s servers in the United States of
America.
For further information about the safeguards used when your information
is transferred outside the European Economic Area, see the section of
this privacy policy below entitled Transfers of your information
outside the European Economic Area.]
Sharing your information with third parties, which are either related
to or associated with the running of our business, where it is
necessary for us to do so. These third parties include our accountants,
advisors, affiliates, business partners, independent contractors, and
insurers. Further information on each of these third parties is set out
below.
Legal basis for processing: our legitimate interests (Article 6(1)(f)
of the General Data Protection Regulation).
Legitimate interest: running and managing our business efficiently.
Accountants
We share information with our accountants for tax purposes. For
example, we share invoices we issue and receive with our accountants
for the purpose of completing tax returns and our end of year accounts.
Our accountants are located in the European Economic Area.
Advisors
Occasionally, we obtain advice from advisors, such as financial
advisors, lawyers and public relations professionals. We will share
your information with these third parties only where it is necessary to
enable these third parties to be able to provide us with the relevant
advice. Our advisors are located in the European Economic Area.
Affiliates
Affiliates are individuals or entities we work with to promote our
business by various means, including by advertising our services on
their websites, for example. Affiliates will share information with us
and we will share information with them where you have expressed an
interest in our products or services. Our affiliates are located both
inside and outside of the European Economic Area.
Business partners
Business partners are businesses we work with which provide goods and
services which are complementary to our own or which allow us to
provide goods or services which we could not provide on our own. We
share information with our business partners where you have requested
services which they provide whether independently from, or in
connection with or own services. Our affiliates are located both inside
and outside of the European Economic Area.
Independent contractors
We use independent contractors in our business. Your information will
be shared with independent contractors only where it is necessary for
them to perform the function we have hired them perform in relation to
our business. Our independent contractors are located in the UK.
Insurers
We will share your information with our insurers where it is necessary
to do so, for example in relation to a claim or potential claim we
receive or make or under our general disclosure obligations under our
insurance contract with them. Our insurers are located in the UK.
Sharing your information with a prospective or actual purchaser or
seller in the context of a business or asset sale or acquisition by us,
a merger or similar business combination event, whether actual or
potential.
Legal basis for processing: legitimate interests (Article 6(1)(f) of
the General Data Protection Regulation).
Legitimate interest(s): sharing your information with a prospective
purchaser, seller or similar person in order to allow such a
transaction to take place.
Disclosure and use of your information for legal reasons
Indicating possible criminal acts or threats to public security to a
competent authority
If we suspect that criminal or potential criminal conduct has been
occurred, we will in certain circumstances need to contact an
appropriate authority, such as the police. This could be the case, for
instance, if we suspect that fraud or a cyber crime has been committed
or if we receive threats or malicious communications towards us or
third parties.
We will generally only need to process your information for this
purpose if you were involved or affected by such an incident in some
way.
Legal basis for processing: our legitimate interests (Article 6(1)(f)
of the General Data Protection Regulation).
Legitimate interests: preventing crime or suspected criminal activity
(such as fraud).
In connection with the enforcement or potential enforcement of our
legal rights
We will use your information in connection with the enforcement or
potential enforcement of our legal rights, including, for example,
sharing information with debt collection agencies if you do not pay
amounts owed to us when you are contractually obliged to do so. Our
legal rights may be contractual (where we have entered into a contract
with you) or non-contractual (such as legal rights that we have under
copyright law or tort law).
Legal basis for processing: our legitimate interests (Article 6(1)(f)
of the General Data Protection Regulation).
Legitimate interest: enforcing our legal rights and taking steps to
enforce our legal rights.
In connection with a legal or potential legal dispute or proceedings
We may need to use your information if we are involved in a dispute
with you or a third party for example, either to resolve the dispute or
as part of any mediation, arbitration or court resolution or similar
process.
Legal basis for processing: our legitimate interests (Article 6(1)(f)
of the General Data Protection Regulation).
Legitimate interest(s): resolving disputes and potential disputes.
For ongoing compliance with laws, regulations and other legal
requirements
We will use and process your information in order to comply with legal
obligations to which we are subject. For example, we may need to
disclose your information pursuant to a court order or subpoena if we
receive one.
Legal basis for processing: compliance with a legal obligation (Article
6(1)(c) of the General Data Protection Regulation).
Legal obligation(s): legal obligations to disclose information which
are part of the laws of England and Wales or if they have been
integrated into the United Kingdom’s legal framework (for example in
the form of an international agreement which the United Kingdom has
signed).
Legal basis for processing: our legitimate interests (Article 6(1)(f)
of the General Data Protection Regulation).
Legitimate interest: where the legal obligations are part of the laws
of another country and have not been integrated into the United
Kingdom’s legal framework, we have a legitimate interest in complying
with these obligations.
How long we retain your information
This section sets out how long we retain your information. We have set
out specific retention periods where possible. Where that has not been
possible, we have set out the criteria we use to determine the
retention period.
Retention periods
Server log information: we retain information on our server logs for 6
years.
Order information: when you place an order for goods and services, we
retain that information for six years following the end of the
financial year in which you placed your order, in accordance with our
legal obligation to keep records for tax purposes.
Correspondence and enquiries: when you make an enquiry or correspond
with us for any reason, whether by email or via our contact form or by
phone, we will retain your information for as long as it takes to
respond to and resolve your enquiry, and for 12 further months after
which point we will delete your information.
E-Newsletter: we retain the information you used to sign up for our
e-newsletter for as long as you remain subscribed (i.e. you do not
unsubscribe) or if we decide to cancel our e-newsletter service,
whichever comes earlier.
Criteria for determining retention periods
In any other circumstances, we will retain your information for no
longer than necessary, taking into account the following:
-
the purpose(s) and use of your information both now and in the
future (such as whether it is necessary to continue to store that
information in order to continue to perform our obligations under a
contract with you or to contact you in the future);
-
whether we have any legal obligation to continue to process your
information (such as any record-keeping obligations imposed by
relevant law or regulation);
-
whether we have any legal basis to continue to process your
information (such as your consent);
-
how valuable your information is (both now and in the future);
-
any relevant agreed industry practices on how long information
should be retained;
-
the levels of risk, cost and liability involved with us continuing
to hold the information;
-
how hard it is to ensure that the information can be kept up to
date and accurate; and
-
any relevant surrounding circumstances (such as the nature and
status of our relationship with you).
How we secure your information
We take appropriate technical and organisational measures to secure
your information and to protect it against unauthorised or unlawful use
and accidental loss or destruction, including:
-
only sharing and providing access to your information to the
minimum extent necessary, subject to confidentiality restrictions
-
where appropriate, and on an anonymised basis wherever possible;
-
using secure servers to store your information;
-
verifying the identity of any individual who requests access to
information prior to granting them access to information;
-
using Secure Sockets Layer (SSL) software to encrypt any payment
transactions you make on or via our website.
Transmission of information to us by email
Transmission of information over the internet is not entirely secure,
and if you submit any information to us over the internet (whether by
email, via our website or any other means), you do so entirely at your
own risk.
We cannot be responsible for any costs, expenses, loss of profits, harm
to reputation, damages, liabilities or any other form of loss or damage
suffered by you as a result of your decision to transmit information to
us by such means.
Transfers of your information outside the European Economic Area
Your information will be transferred and stored outside the European
Economic Area (EEA) in the circumstances set out below. We will also
transfer your information outside the EEA or to an international
organisation in order to comply with legal obligations to which we are
subject (compliance with a court order, for example). Where we are
required to do so, we will ensure appropriate safeguards and
protections are in place.
Server log information
Information collected when you visit our website is transferred outside
of the EEA and stored on the servers of our third party hosting
companies, AWS and WP Engine. You can access their privacy policy here:
Country of storage: United States of America. This country is not
subject to an adequacy decision by the European Commission.
Safeguard(s) used: AWS and WP Engine have self-certified their
compliance with the EU-U.S. Privacy Shield which is available here:
https://www.privacyshield.gov/welcome
. The EU-U.S. Privacy Shield is an approved certification mechanism
under Article 42 of the General Data Protection Regulation, which is
permitted under Article 46(2)(f) of the General Data Protection
Regulation. You can access the European Commission decision on the
adequacy of the EU-U.S. Privacy Shield here:
http://ec.europa.eu/justice/data-protection/international-transfers/adequacy/index_en.htm
Contact form
Information you submit to us via our contact form is transferred
outside the EEA and stored on our third party hosting and email
provider’s servers. Our hosting provider are WP Engine and AWS, our
form provider is Wufoo and our email provider is Google/Gmail. You can
access their privacy policy here:
Country of storage: United States of America. This country is not
subject to an adequacy decision by the European Commission.
Safeguard(s) used: AWS, WP Engine, Wufoo and Google have self-certified
their compliance with the EU-U.S. Privacy Shield which is available
here: https://www.privacyshield.gov/welcome. The EU-U.S. Privacy Shield
is an approved certification mechanism under Article 42 of the General
Data Protection Regulation, which is permitted under Article 46(2)(f)
of the General Data Protection Regulation. You can access the European
Commission decision on the adequacy of the EU-U.S. Privacy Shield here:
http://ec.europa.eu/justice/data-protection/international-transfers/adequacy/index_en.htm
Email
Information you submit to us by email is transferred outside the EEA
and stored on our third party email provider’s servers. Our third party
email provider is: Google. You can access their privacy policy here:
https://policies.google.com/privacy
Country of storage: United States of America. This country is not
subject to an adequacy decision by the European Commission.
Safeguard(s) used: Google has self-certified its compliance with the
EU-U.S. Privacy Shield which is available here:
https://www.privacyshield.gov/welcome
. The EU-U.S. Privacy Shield is an approved certification mechanism
under Article 42 of the General Data Protection Regulation, which is
permitted under Article 46(2)(f) of the General Data Protection
Regulation. You can access the European Commission decision on the
adequacy of the EU-U.S. Privacy Shield here:
http://ec.europa.eu/justice/data-protection/international-transfers/adequacy/index_en.htm
E-Newsletter
Information you submit to us when you sign up for our e-newsletter is
transferred outside the EEA and stored on our third party mailing list
provider’s servers. Our third party mailing list provider is:
Mailchimp. You can access their privacy policy here:
https://mailchimp.com/legal/privacy
.
Country of storage: United States of America. This country is not
subject to an adequacy decision by the European Commission.
Safeguard(s) used: Mailchimp has self-certified its compliance with the
EU-U.S. Privacy Shield which is available here:
https://www.privacyshield.gov/welcome
. The EU-U.S. Privacy Shield is an approved certification mechanism
under Article 42 of the General Data Protection Regulation, which is
permitted under Article 46(2)(f) of the General Data Protection
Regulation. You can access the European Commission decision on the
adequacy of the EU-U.S. Privacy Shield here:
http://ec.europa.eu/justice/data-protection/international-transfers/adequacy/index_en.htm
Online Surveys
Information you submit to us when you sign up for our online surveys is
transferred outside the EEA and stored on our third party mailing list
provider’s servers. Our third party mailing list provider is: Survey
Monkey. You can access their privacy policy here:
https://www.surveymonkey.com/mp/legal/privacy-policy
.
Country of storage: United States of America. This country is not
subject to an adequacy decision by the European Commission.
Safeguard(s) used: Survey Monkey has self-certified its compliance with
the EU-U.S. Privacy Shield which is available here:
https://www.privacyshield.gov/welcome
. The EU-U.S. Privacy Shield is an approved certification mechanism
under Article 42 of the General Data Protection Regulation, which is
permitted under Article 46(2)(f) of the General Data Protection
Regulation. You can access the European Commission decision on the
adequacy of the EU-U.S. Privacy Shield here:
http://ec.europa.eu/justice/data-protection/international-transfers/adequacy/index_en.htm
Google Analytics
Information collected by Google Analytics (your IP address and actions
you take in relation to our website) is transferred outside the EEA and
stored on Google’s servers. You can access Google’s privacy policy
here:
https://www.google.com/policies/privacy/
Country of storage: United States of America. This country is not
subject to an adequacy decision by the European Commission.
Safeguard(s) used: Google has self-certified its compliance with the
EU-U.S. Privacy Shield which is available here:
https://www.privacyshield.gov/welcome
. The EU-U.S. Privacy Shield is an approved certification mechanism
under Article 42 of the General Data Protection Regulation, which is
permitted under Article 46(2)(f) of the General Data Protection
Regulation. You can access the European Commission decision on the
adequacy of the EU-U.S. Privacy Shield here:
http://ec.europa.eu/justice/data-protection/international-transfers/adequacy/index_en.htm
Your rights in relation to your information
Subject to certain limitations on certain rights, you have the
following rights in relation to your information, which you can
exercise by writing to FINTECH Circle ltd, c/o Intelletec Ltd, The
Office Group, 50 Liverpool Street, London, England, EC2M 7PY or sending
an email to [email protected]:
-
to request access to your information and information related to
our use and processing of your information;
-
to request the correction or deletion of your information;
-
to request that we restrict our use of your information;
-
to receive information which you have provided to us in a
structured, commonly used and machine-readable format (e.g. a CSV
file) and the right to have that information transferred to another
data controller (including a third party data controller);
-
to object to the processing of your information for certain
purposes (for further information, see the section below entitled
Your right to object to the processing of your information for
certain purposes); and
-
to withdraw your consent to our use of your information at any time
where we rely on your consent to use or process that information.
Please note that if you withdraw your consent, this will not affect
the lawfulness of our use and processing of your information on the
basis of your consent before the point in time when you withdraw
your consent.
In accordance with Article 77 of the General Data Protection
Regulation, you also have the right to lodge a complaint with a
supervisory authority, in particular in the Member State of your
habitual residence, place of work or of an alleged infringement of the
General Data Protection Regulation.
For the purposes of the UK, the supervisory authority is the
Information Commissioner’s Office (ICO), the contact details of which
are available here:
https://ico.org.uk/global/contact-us
.
Further information on your rights in relation to your personal data as
an individual
The above rights are provided in summary form only and certain
limitations apply to many of these rights. For further information
about your rights in relation to your information, including any
limitations which apply, please visit the following pages on the ICO’s
website:
https://ico.org.uk/for-organisations/guide-to-the-general-data-protection-regulation-gdpr/individual-rights/
; and
https://ico.org.uk/for-the-public/is-my-information-being-handled-correctly/
.
You can also find out further information about your rights, as well as
information on any limitations which apply to those rights, by reading
the underlying legislation contained in Articles 12 to 22 and 34 of the
General Data Protection Regulation, which is available here:
http://ec.europa.eu/justice/data-protection/reform/files/regulation_oj_en.pdf
.
Verifying your identity where you request access to your information
Where you request access to your information, we are required by law to
use all reasonable measures to verify your identity before doing so.
These measures are designed to protect your information and to reduce
the risk of identity fraud, identity theft or general unauthorised
access to your information.
How we verify your identity
Where we possess appropriate information about you on file, we will
attempt to verify your identity using that information.
If it is not possible to identity you from such information, or if we
have insufficient information about you, we may require original or
certified copies of certain documentation in order to be able to verify
your identity before we are able to provide you with access to your
information.
We will be able to confirm the precise information we require to verify
your identity in your specific circumstances if and when you make such
a request.
Your right to object to the processing of your information for certain
purposes
You have the following rights in relation to your information, which
you may exercise in the same way as you may exercise by writing to
FINTECH Circle ltd, c/o Intelletec Ltd, The Office Group, 50 Liverpool
Street, London, England, EC2M 7PY or sending an email to
[email protected]:
-
to object to us using or processing your information where we use
or process it in order to carry out a task in the public interest
or for our legitimate interests, including ‘profiling’ (i.e.
analysing or predicting your behaviour based on your information)
based on any of these purposes; and
-
to object to us using or processing your information for direct
marketing purposes (including any profiling we engage in that is
related to such direct marketing).
You may also exercise your right to object to us using or processing
your information for direct marketing purposes by:
-
clicking the unsubscribe link contained at the bottom of any
marketing email we send to you and following the instructions which
appear in your browser following your clicking on that link;
-
sending an SMS message containing only the words “OPT OUT” in reply
to any marketing communication we send by text message;
-
sending an email to [email protected],
asking that we stop sending you marketing communications or by
including the words “OPT OUT”.
For more information on how to object to our use of information
collected from cookies and similar technologies, please see the section
entitled How to accept or reject cookies in our cookies policy, which
is available here:
Cookie Policy
Sensitive Personal Information
‘Sensitive personal information’ is information about an individual
that reveals their racial or ethnic origin, political opinions,
religious or philosophical beliefs, or trade union membership, genetic
information, biometric information for the purpose of uniquely
identifying an individual, information concerning health or information
concerning a natural person’s sex life or sexual orientation.
We do not knowingly or intentionally collect sensitive personal
information from individuals, and you must not submit sensitive
personal information to us.
If, however, you inadvertently or intentionally transmit sensitive
personal information to us, you will be considered to have explicitly
consented to us processing that sensitive personal information under
Article 9(2)(a) of the General Data Protection Regulation. We will use
and process your sensitive personal information for the purposes of
deleting it.
Changes to our Privacy Policy
We update and amend our Privacy Policy from time to time.
Minor changes to our Privacy Policy
Where we make minor changes to our Privacy Policy, we will update our
Privacy Policy with a new effective date stated at the beginning of it.
Our processing of your information will be governed by the practices
set out in that new version of the Privacy Policy from its effective
date onwards.
Major changes to our Privacy Policy or the purposes for which we
process your information
Where we make major changes to our Privacy Policy or intend to use your
information for a new purpose or a different purpose than the purposes
for which we originally collected it, we will notify you by email
(where possible) or by posting a notice on our website.
We will provide you with the information about the change in question
and the purpose and any other relevant information before we use your
information for that new purpose.
Wherever required, we will obtain your prior consent before using your
information for a purpose that is different from the purposes for which
we originally collected it.
Children’s Privacy
Because we care about the safety and privacy of children online, we
comply with the Children’s Online Privacy Protection Act of 1998
(COPPA). COPPA and its accompanying regulations protect the privacy of
children using the internet. We do not knowingly contact or collect
information from persons under the age of 18. The website is not
intended to solicit information of any kind from persons under the age
of 18.
It is possible that we could receive information pertaining to persons
under the age of 18 by the fraud or deception of a third party. If we
are notified of this, as soon as we verify the information, we will,
where required by law to do so, immediately obtain the appropriate
parental consent to use that information or, if we are unable to obtain
such parental consent, we will delete the information from our servers.
If you would like to notify us of our receipt of information about
persons under the age of 18, please do so by sending an email to
[email protected].
Copyright, credit and logo
This Privacy Policy is based on a General Data Protection Regulation
(Regulation (EU) 2016/769) (GDPR) compliant template provided by GDPR
Privacy Policy. For further information, please visit
https://gdprprivacypolicy.org
The copyright in this Privacy Policy is either owned by, or licensed
to, us and is protected by copyright laws around the world and
copyright protection software. All intellectual property rights in this
document are reserved.
Where we display the GDPR Privacy Policy logo on our website, this is
used to indicate that we have adopted a privacy policy template
provided by GDPR Privacy Policy as the basis for this Privacy Policy.