Who am I?
Introduction
MyPulseLimited (“MyPulse”) needs to collect and use certain personal data about living individuals, including past, present and prospective customers in order to run our business effectively and meet our customers’ requirements.
Please read this Policy carefully to help you understand the approach we take to handling your personal data and the rights you have as an individual.Terms under data protection law which are used in this Policy are defined in it or in the Glossary at the end of it.
All personal data will only be held and used in accordance with this Policy, the Privacy and Electronic Communications (E.C. Directive) Regulations 2003 (as amended), the Data Protection Act 2018 (“DPA”), and the retained UK law version of the General Data Protection Regulation (“GDPR”) together with replacement, amending or supplementary laws or regulations relating to the protection of personal data.
The DPA and GDPR are important laws governing the use of personal data which give you, the individual, certain rights and remedies in respect of that personal data.
MyPulse takes its responsibilities concerning the privacy, protection and security of personal data extremely seriously. The purpose of this Privacy Policy (“Policy”) is to explain how the personal data we and our affiliated companies collect from you, or that you provide to us, will be processed by us.
MyPulse has appointed a Data Protection Manager at a senior level with specific responsibility for day today matters of data protection, who acts as our contact point with the Information Commissioner’s Office (“ICO”). Please contact our Data Protection Manager with any questions or concerns you may have about our use of personal data.
Data Protection Manager Details
Postal address: Data Protection Manager, MyPulse Limited, Mezzanine Floor, St Albans House, 57-59 Haymarket, London SW1Y 4QX.
Telephone number 0203793 0630
Email address: support@mypulse.io
The Group Companies
MyPulse operates as part of a group of companies (“the Group”) within the UK and overseas and this Policy provides privacy information about how the Group collectively uses personal data. The Group companies will use personal data for their own purposes, will also share personal data between them as independent data controllers and group companies may also process your personal data on each other’s behalf. This Policy explains how Group companies use and share personal data, including with Group companies based outside the UK.
The Group companies for the purposes of this Policy are:
MyPulse Limited Registered in England and Wales with company number 14792698 and a registered address at Mezzanine Floor, St Albans House, 57-59 Haymarket, London SW1Y 4QX; and
MyPulse.io Limited (“MyPulse.io”), a company incorporated in the Republic of India under corporate identification number U74999MH2016PTC280925, with an address at E-505, Corporate Avenue, A K Road, Andheri (East), Mumbai 400093.
From time to time, we may add additional legal entities to the Group and we will update our Policy to identify them when this happens. New entities will form part of the Group for purposes of this Policy and they will deal with your personal data on the same basis as other members of the Group.
What Kind of Data Does My Pulse Collect and on Whom?
What Kind of Data Does MyPulse Collect and on Whom?
We use different methods to collect personal data from and about you, including:
- Direct interactions. You may give us your information by filling in forms, on the telephone, or by corresponding with us by post, fax, email or otherwise. This includes personal data you provide when you:
- ask us to send information to you;
- Group companies. Group companies who obtain data in direct interactions with you or from third parties or publicly available sources may share your personal data with other members of the Group.
We may collect, use, store and transfer different kinds of personal data about you. The personal data we collect will depend on the relationship you have with MyPulse.
If you are:
An employee of MyPulse, someone working with us under a contract for services, or someone who applies for employment or work with us, we will provide you with specific privacy information and may ask for your consent to use your personal data. We will also collect the following information on you:
- Identity Data including first name, last name, title, job title, role or similar identifier, and gender, as well as proof of identity and your right to work in the UK.
- Contact Data which may include your address, email address and telephone numbers.
- Financial Data to provide pay, benefits and conduct other financial transactions with you.
A business contact, including persons who supply us with goods (including hiring things to us) or services and any contacts at a company or other organisation which does so, and clients or prospective clients (including contacts at companies or other organisations) to whom we supply or may in future wish to supply our products and services, as well as the customers and debtors of our clients, we may collect the following types of data on you:
- Identity Data includes first name, last name, title, job title, role or similar identifier, and gender.
- Contact Data includes your work address, email address and telephone numbers.
- Financial Data if we supply or purchase goods and services to or from you as an individual (including some sole traders and partnerships), we may record and retain details of those transactions.
A person associated with a customer or debtor of one of our clients, whose data may be relevant to the business you or your organisation does with our client, with contracts entered into, debts incurred or to be incurred or historic business transactions between you/your organisation and our client, and for preventing fraud and setting credit limits and availability, we may collect the following types of data on you:
- Identity Data includes first name, last name, title, job title, role or similar identifier, and gender.
- Contact Data includes your work address, email address and telephone numbers. Where you are personally a party to a transaction with us or with our client, we may obtain your home address.
- Financial Data if our client supplies or purchase goods and services to or from you as an individual (including some sole traders and partnerships), or if you are involved in financial transactions with our client (e.g. as a guarantor) we may record and retain details of those transactions and may include bank statements, business accounts and any other financial documents provided by our client or you.
A person associated with a supplier or other creditor of one of our clients, whose data may be relevant to the business you or your organisation does with our client or their obligations to you or your organisation, with contracts entered into, debts incurred or to be incurred or historic business transactions between you/your organisation and our client, and for preventing fraud and making payments on behalf of our clients from any facility they may from time to time have with us:
- Identity Data includes first name, last name, title, job title, role or similar identifier, and gender.
- Contact Data includes your work address, email address and telephone numbers. Where you are personally a party to a transaction with us or with our client, we may obtain your home address.
- Financial Data if you are involved in financial transactions with our client (e.g. as a guarantor) or its creditor, we may record and retain details of those transactions including bank statements or any other financial documents provided by our client or you.
If you are a director, officer, shareholder or proposed personal guarantor in relation to a facility with one of our clients, then ahead of entering into a customer agreement with you or with our client, we will as a matter of course undertake anti money-laundering checks and may conduct credit reference checks with third-party agencies. These checks are a crucial and necessary step MyPulse must undertake before we are able to enter into a contract with your organisation.
When CRAs receive a search request from MyPulse they may:
- Place a credit search “footprint” on the consumer credit file of the Directors, officers, beneficial owners or those who financially guarantee obligations of a client or prospective client following each credit application, whether or not that application proceeds. The footprint may be seen by other organisations when the client or prospective client applies for credit in the future;
- Link together the previous and subsequent names advised by you of anyone that is a party to the account;Place an enquiry or identification search on the record of any shareholder or beneficial owner and who MyPulse has checked; and
- Create a record of the name and address of your business and its proprietors (if there is not one already).
We will give details of all financial commitments of a client or prospective client to us or which we become aware of during our enquiries, and how those commitments are managed, to the CRAs. If you borrow and do not repay in full and on time, the CRAs will record the outstanding debt and, in some cases, the length of time that the debt remains outstanding; other organisations may see these updates and this may affect your ability to obtain credit in the future.
Any records shared with CRAs will remain on file for six years after your account is closed, whether any outstanding sums have been settled by you or following a default. The CRAs are responsible for data held on their files and you should contact them with concerns regarding any information they hold or may hold on you.
You can contact the CRAs currently operating in the UK. The information they hold may not be the same, so you may consider contacting them all. They will charge you a small statutory fee. They are:
- Experian, Consumer Help Service, PO Box 8000, Nottingham NG80 7WF or call 0844 4818000 or log on to www.experian.co.uk
- Creditsafe Business Solutions Limited, Bryn House Caerphilly Business Park, Van Road, Caerphilly, CF83 3GG, or call 02920 886 500
If you fail to provide personal data
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 offer our services to your organisation and if your organisation is an existing client, it may be placed in breach of the terms of any agreement with us
- If you have personally guaranteed or been asked to personally guarantee obligations of a client or prospective client, we may not accept your guarantee, you may be placed in breach of your obligations under an existing guarantee, and in each case this may affect whether we will provide or continue providing finance to the client or prospective client, who may also be placed in breach of its obligations to us as a result
- We may not be able to agree, enter in to or perform a contract we have or are trying to enter into with you, a client, or a person or organisation associated with you. Our client may also be placed in breach of the terms of a finance agreement with us
- If you are an employee, contractor or applicant for a position with us, we may not be able to consider your application, provide you with pay or benefits, or administer a contract for services or contract of employment with you
We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for (or any purpose which is not incompatible with those purposes), including for the purposes of satisfying any legal, accounting, or reporting requirements.
Purposes for Which We will Use your Personal Data
We will only use your personal data when the law allows us to. Most commonly, we will use, analyse and assess your We will only use your personal data when the law allows us to. Most commonly, we will use your personal data:
- To provide you with information, products or services that you ask for;
- To let you know about other products and services that we think you might be interested in (if you have said that you are happy to be contacted in this way or the law otherwise permits us to communicate with you in this way);To share your data with other controllers who may wish to offer goods and services to you or your business;To make financial risk assessments, prevent money laundering, fraud or other wrongdoing;To make payments to you and/ or your business;To recover monies;For training, product and statistical analysis, improving our products and services and the development of new products (which will include creating aggregated, anonymised data from personal data which we hold);To protect our interests (including the provision of the information to third parties retained by us for them to conduct their services for us);In the event that this is necessary for a sale of or investment or other transaction relating to our business or any of the Group companies; or
- To decide whether to extend credit to a client or prospective client, or whether to vary the terms of our agreements with a client;
In obtaining or storing information about you we may:
- Store and process information about you including on our computers and in any other way;
- Search your record at a credit reference or fraud prevention agency of our choice. Details of our searches may be kept by such agency and may be seen by other organisations that makes searches with the agency;
- Monitor and/ or record telephone conversations with you for training and/ or security purposes;
- Approach you for market research or direct marketing purposes;
- Seek and record any further information that we may require from any source, including banks for any of the purposes set out above;
- Create aggregated and anonymised data from your personal data and personal data of third parties; and
- Transfer such of the information that we may have to other members of a group of companies of which MyPulse is a part; to our financiers; to associates or persons acting on our behalf; to guarantors or indemnifiers and to businesses providing similar services to those of MyPulse, acting as our processors, all of whom may use such information for any of the purposes set out herein (including transfer within the group of companies).
We have set out below, in a table format, a description of 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.
We do not use any fully automated decision-making process.
Note that we may process your personal data on 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 ground we are relying on to process your personal data where more than one ground has been set out in the table below.
| Purpose/Activity | Type of data | Lawful basis for processing including basis of legitimate interest |
| To assess and make decisions about prospective clients who may wish to obtain financial products and services from us | (a) Identity data (b) Contact data (c) Financial data (for credit purposes) | (a) Performance of a contract with you (b) Necessary for our legitimate interests in promoting or providing our products and services to you or your organisation (c) Your consent |
| To register you (or your employer or a person or entity to whom you provide services) as a new client. | (a) Identity data (b) Contact data (c) Financial data (for credit purposes) | (a) Performance of a contract with you (b) Necessary for our legitimate interests in promoting or providing our products and services to you or your organisation (c) Your consent |
| To fulfil our contractual obligations to a client, to you or your organisation or to enforce your or your organisation’s obligations to us or to our client, including to (a) Manage payments, fees and charges (b) Collect and recover money owed to us | (a) Identity data (b) Contact data (c) Financial data (d) Transaction data | (a) Performance of a contract with you (b) Necessary for our legitimate interests (to recover debts due to us) |
| To manage our relationship with you which will include: (a) Notifying you about changes to our terms or Policy (b) Contacting you about products or services we obtain from or provide to you or your employer | (a) Identity data (b) Contact data | (a) Performance of a contract with you (b) Necessary to comply with a legal obligation (c) Necessary for our legitimate interests (to keep our records updated and to study how our products/services are used and received) |
| To administer and protect our business which may include: a) Financial risk assessment, preventing money laundering, fraud or other wrongdoing; b) Contacting credit reference agencies and making credit related decisions; c) Recovering monies and making payments to you and/ or your business. | (a) Identity data (b) Contact data | (a) Necessary for our legitimate interests (b) Necessary to comply with a legal obligation |
| To share your information with selected third parties, acting as data controllers, who wish to offer goods or services to you or your business or to improve their goods and services | (a) Identity data (b) Contact data (c) Financial data | (a) Necessary for our legitimate interests in providing you or your business with goods and services; (b) necessary for the legitimate interests of such selected third parties in being able to offer you or your business goods and services or improve their goods and services |
| To administer a contract for services or contract of employment between us – we will provide you with further information about this when we collect information from you and during the course of our relationship) | (a) Identity data (b) Contact data (c) Financial data | (a) Performance of a contract with you (b) Necessary for our legitimate interests (to administer the economic relationship between us) (c) Necessary to comply with a legal obligation (related to your work or workplace or our obligations under the law in relation to these) |
We will also use personal data about you for our own marketing purposes. Further information is set out in the Marketing section of the Policy, below.
Disclosure of your Information to Third Parties
We may share your personal data with the parties set out below for the purposes set out in the table above.
- Other members of our Group;
- Organisations associated with fraud prevention;Selected third parties outside of our Group, acting as independent data controllers, who may wish to offer goods or services to you or your business or organisation or to improve their goods and services;Other External Third Parties as set out in the Glossary; Specific third parties listed in the table above; and
- 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 Notice.
We may also engage processors to conduct processing of your personal data on our behalf, including:
- Other members of our Group of companies (who may act as controllers for some purposes and our processors for other purposes);
- Providers of data hosting and storage for those purposes;
- Third parties who may host, manage and support our website and who may therefore have access to any data that you submit via this website;
- Providers of marketing and promotional services;
- Processors who provide us with outsourced services in connection with offering facilities (or other goods and services) to you or your organisation, managing those facilities during their lifetime and bringing them to an end.
We may share data with some third parties in the categories above, as controllers, for the purposes set out above who also act as processors on our behalf for other lawful purposes.
Marketing
We may from time to time wish to contact you via email, telephone, letter or SMS in order to keep you informed about
We may from time to time wish to contact you via email, telephone, letter or SMS in order to keep you informed about products, goods or services which may be of interest to you and to provide news and information about our business and that of any business within our Group.
We may also provide you from time to time with information about products and services from selected third parties which may be of interest to you or your organisation.
Where we send electronic marketing to an individual subscriber (under the Privacy and Electronic Communications (E.C. Directive) Regulations 2003 (as amended)(“Privacy Regulations”)), MyPulse will only do so where we have received explicit consent from you to do so and for each separate method of electronic communication.
We are not required by law to obtain prior consent to send you marketing information if you have purchased products or services from us personally, or if we are contacting you at your organisation which is a “corporate subscriber” under the Privacy Regulations.
You always have the right to refuse direct marketing communications directed to you personally. Should you wish to do so, please contact our Data Protection Manager.
We may use your personal information and information about your computer (including, where available, your IP address, operating system and browser type) for market research and other marketing purposes such as announcements on our pricing, product launches, updates on the company, etc. We may also share your personal information with third parties for the purpose of conducting market research and running marketing campaigns.. We will take steps to ensure that the transfer and any on-going processing by those third parties is carried out securely and in accordance with applicable data protection and privacy laws and regulations. We also collect and retain:
- Copies of our correspondence with you as well as other data we collect relating to your activities on the website and your arrangements with MyPulse;
- Details about visitors to our website for the purposes of aggregating statistics or reporting purposes and to calculate referral fees; and
- Comments made on blogs and discussion forums in connection with the marketplace.
Where you submit personal data to us using an online form, please ensure that you select the appropriate option on the form if you do not want your data to be used by us or selected third parties for marketing purposes. You can also notify us at any time if you do not wish your data to be used in this way. If you do not select the appropriate option, but wish to do so subsequently, please contact our Data Protection Manager so we can update our records.
Overseas Transfers
We are part of a global Group of companies and, in order to support our business in the most efficient manner possible, we share infrastructure and functions across our business internationally. This means that we may transfer your personal data to ( or your personal data may be accessible in) any location in which we do business or where our service providers are located.
If your information is transferred to or accessible in a country which is not considered by the European Community to provide adequate protection for your rights and freedoms in relation to the processing of personal data, we will take alternative steps as required by GDPR to ensure your information is adequately protected and that those transfers comply with data protection law.
We may transfer your information to other countries, including those outside the European Economic Area, where our Group companies have operations in other countries, for hosting and storage purposes, or if we engage suppliers, sub-contractors or third-party data processors who are based or have operations overseas.
In particular, our Group companies may transfer any personal data they hold or obtain from time to time related to prospective clients to overseas contractors acting as both data processors and data controllers (for different purposes) to help review and assess data on prospective clients provided by the Group companies. Data processed by these contractors may be used to help one or more Group companies determine whether they wish to do business with a prospective client and on what terms or to offer other relevant goods and services to a client or prospective client.
Our Group companies may also transferto brokers, introducers and other selected third parties personal data relating to current and prospective clients (as part of other data relating to them), including but not limited to any client or prospective client to which they are or would be unable to offer facilities, to enable these brokers and introducers to identify and introduce alternative providers and to enable other selected third parties to offer goods and services to you or your organisation. These brokers, introducers and third parties will act as data controllers and some of these partiesmay be located outside the UK.
Each Group company that shares personal data with such third parties provides adequate protection for the rights and freedoms of data subjects by:
Taking other measures recognised under Chapter 5 of UK GDPR from time to time as capable of providing adequate protection for the rights and freedoms of data subjects.
entering into International Data Transfer Agreements in the form approved by the Information Commissioner’s Office with the third party as (i) a processor; and/or (ii) a controller, of personal data which is shared with it; or
entering into EU-approved model contracts with each broker and introducer as a controller of personal data which is shared with it; or
Your Rights
You have the right to make a complaint about our use of your personal data at any time to the Information
Commissioner’s Office (“ICO”). The ICO is the UK’s supervisory authority for data protection issues (www.ico.org.uk).
If you do have a problem, question or concern about our use of your personal data, we would really appreciate the
chance to try to help you before you approach the ICO, so please feel free to contact us in the first instance using
the data protection compliance officer’s contact details above. You can contact us about data privacy issues in
other ways, but if you contact the data protection compliance officer, that will make it much easier for us to help
you.
You have the right to:
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.
When we receive such a request we will endeavour to provide you with these details without delay and at the latest
within one month of receipt. We may extend the period of compliance by a further two months where requests are
complex or numerous. In such instances My Pulse will inform you within one month of the receipt of the request and
explain why the extension is necessary.
When My Pulse receives a subject access request we will provide a copy of the information held free of charge. My Pulse
may charge a reasonable fee to comply with requests for further copies of the same information. This does not mean
that we will charge for all subsequent access requests rather that the My Pulse reserves the right to charge a fee
based on the administrative cost of providing the information.
If the after reviewing a request the Data Protection Manager believes a request is manifestly unfounded or excessive,
particularly if it is repetitive, then My Pulse may charge a ‘reasonable fee’ which will be decided on a case by case
basis. In certain circumstances My Pulse may even refuse to respond to such requests.
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.
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.
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. In some cases, we may
demonstrate that we have compelling legitimate grounds to process your information which override your rights and
freedoms.
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. You can exercise your right to prevent such processing by refraining from ticking certain boxes on the forms we
use to collect your data whether that is on this website of via any other means. Alternatively, you can also
exercise the right at any time by contacting us at support@mypulse.io
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.
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.
Complaints Policy
At MyPulse we value your business and we want you to be entirely satisfied with the service you receive. If we make a mistake, or we fail to meet your expectations in some other way, we want the opportunity to put things right as quickly as we can. Furthermore, we will take steps, where appropriate, to prevent a recurrence.
Contact details:
Complaints can be raised by any channel at any time. Please follow one of the steps below when making your first contact:
By e-mail: You can e-mail support@mypulse.io with details of your complaint.
By post:
Complaints Manager
MyPulse Limited, Mezzanine Floor, St Albans House, 57-59 Haymarket, London SW1Y 4QX.
What to include: In order for us to help you the best way we can, we ask that you provide:
You full name, business address, phone number and email address
Your account number
Details of your complaint
What you would like us to do to resolve the issue
Our complaints process: We will acknowledge your complaint within 3 working days of receipt and inform you of the steps we are taking to investigate it, or when you can expect a final response.
We treat all complaints fairly and will aim to resolve your complaint as soon as possible within 5 working days.
Where the complaint or problem is complex, we may need longer to look into the issue and ask you for more information.
We will keep you updated on the progress of your complaint throughout the process and provide contact information for the complaint handler dealing with your case.
If we have been unable to resolve your complaint within 8 weeks, have not sent you a final response within 8 weeks, or you are unhappy with the outcome of your complaint, you can ask the Financial Ombudsman Service (“FOS”) to carry out an independent review.
The FOS can help with most complaints if you are:
A consumer
A business employing fewer than 10 persons that has an annual turnover that doesn’t exceed €2 million
A charity with an annual turnover of less than £1 million
A trustee of a trust with a net asset value of less than £1 million
The contact details for the Financial Ombudsman Service are:
The Financial Ombudsman Service, Exchange Tower, London, E14 9SR
E-mail: Complaint.info@financial-ombudsman.org.uk
Website: www.financial-ombudsman.org.uk
Telephone: 0800 023 4567
FOS consumer leaflet
Recording the Complaint
Please note that, in accordance with its regulatory obligations, MyPulse will compile a report of each complaint. These records will be retained for no less than three years from the date the complaint was received.
Information Security and Encryption
Information that is transmitted via the internet is never completely secure.
We have put suitable protection in place, however any transmission of personal data to us via the internet is at your own risk.
Where necessary we use encryption to protect the integrity of data during submission.
We also employ similar technologies and access control methods to keep any stored data secure.
Policy Changes
Any changes to this Policy will be posted here and will take immediate effect.
If you have any questions about this Policy or about our use of your personal details, then please contact the Data Protection Manager
Glossary
“Personal data” means any information about an individual, held by a data controller, from which the controller can identify a specific, living person. It does not include data about a living person that the controller can’t identify.
Some personal data falls into “Special Categories” under the GDPR and are given greater protection. These include any personal data revealing your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, and information about your health, as well as genetic and biometric data. Information about criminal convictions and offences is also treated differently from ordinary personal data under the GDPR.
”Lawful Basis”
There are a number of different lawful bases for processing your personal data under the GDPR. These include:
Legitimate Interest means the legitimate interests of MyPulse or of a third party, including in conducting a business, which must be balanced against the effect of the processing of personal data on individuals’ rights and freedoms.
In most cases where our legal basis for processing your personal data is a legitimate interest, this will be the legitimate interest of MyPulse, of members of its Group or our clients in conducting our and their business. In the case of MyPulse and its Group, this will be to provide financing in the most efficient and effective way we can. 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 or those of others. 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 to which we are subject.
Protecting your vital interests applies where we would otherwise require your consent to use data, but you are physically or legally incapable of giving consent, and processing is to protect your interests.
”Third Parties”
External Third Parties
These include
Governments and public authorities in other countries where we carry on businesswho require information on our employeesand contractors.
To the extent not mentioned elsewhere in this notice, our and our Group’s service providers, acting as data processors, based inside and outside the EEA who provide technical, financial, logistical, information technology, data storage or other support for our work;
Professional advisers acting as processors or joint controllers including lawyers, bankers, auditors, insolvency practitioners, and insurers based in the EEA and of it who provide consultancy, banking, legal, insurance and accounting services;
HM Revenue & Customs, regulators and other authorities based in the United Kingdom or in any other country who require reporting of processing activities in certain circumstances; and
Cookies Policy
To enhance your experience on our site, our web pages use “cookies” to distinguish you from other users. If you use this website, then you accept that we can use the cookies set out below.
- What are cookies? Cookies are small data files that we place in your computer or mobile’s browser to store your preferences. Cookies, by themselves, do not tell us your email address or other personal information unless you choose to provide this information to us by, for example, registering at one of our sites. Once you choose to provide a web page with personal information, this information may be linked to the data stored in the cookie. A cookie is like an identification card. It is unique to your computer and can only be read by the server that gave it to you.
- Why do we use cookies? We use cookies to understand site usage and to improve the content and offerings on our site. For example, we may use cookies to personalise your experience on our web pages and to provide you with a better service.
- What cookies do we use? We use the following cookies:
- Strictly necessary cookies. These are cookies that are required for the operation of our sites. There is no way to prevent these cookies being set other than to not use our site or not use that particular feature.
- Analytical/performance cookies. They allow us to recognise and count the number of visitors and to see how visitors move around our sites when they are using it. This helps us to improve the way our sites work, for example, by ensuring that users are finding what they are looking for easily.
- Functionality cookies. These are used to recognise you when you return to our site. This enables us to personalise our content for you, greet you by name and remember your preferences and improve your visit.
- Targeting cookies. These cookies record your visit to our sites, the pages you have visited and the links you have followed. We will use this information to make our sites and the advertising displayed on them more relevant to your interests. We may also share this information with third parties for this purpose.
Generally, cookies which are strictly necessary for the operation of the website will expire when you leave the website. Other cookies may be more permanent or not expire unless you actively delete them.
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How to reject cookies You can block cookies by activating the setting on your browser that allows you to refuse the setting of all or some cookies. Doing so however will likely limit the functionality of our and a large proportion of the world’s websites as cookies are a standard part of most modern websites. If you are unsure as to how to manage your cookies or require more information, we have provided the following links to the settings pages for the most commonly used web browsers:
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