INTRODUCTION

This website (“Website”) is operated by Authoripay Limited and we are committed to protecting and respecting your privacy.

This policy sets out the basis on which any personal data we collect from you, or that you provide to us, will be processed by us. Please read the following carefully to understand our views and practices regarding your personal data and how we will treat it. By visiting Authoripay’s website you are accepting and consenting to the practices described in this policy.

For the purpose of data protection legislation, the data controller is Authoripay Limited, Milton Hall, Ely Road, Cambridge, CB24 6WZ.

PERSONAL AND NON-PERSONAL INFORMATION

Personal information is information that can be used to uniquely identify a single person. We also collect non-personal information or may anonymise personal information in order to make it non-personal. Non-personal information is information that will not allow a specific individual to be identified. We may collect, store, use, transfer and disclose non-personal information for any purpose; for example, the use of aggregated transactional information for commercial purposes.

INFORMATION WE COLLECT FROM YOU

We will collect and process the following data about you:

Information you give us.

We collect personal data, or personal information, directly from you, for example when you:

• Visit any of our websites, and complete a form;
• Contact us by any means to enquire about us, our services etc.
• Engage with one of our marketing emails or on social media.
• Engage us to provide services;
• Subscribe to our services;

Other data controllers (including our clients) may also provide your personal data to us.

We may, also, obtain information about you from publicly available sources and collect website usage information using cookies (see “Cookies” section below).

Information we collect about you.

With regard to each of your visits to our site we will automatically collect the following information:

technical information, including the Internet protocol (IP) address used to connect your computer to the Internet, your login information (if relevant), browser type and version, time zone setting, browser plug-in types and versions, operating system and platform; information about your visit, including the full Uniform Resource Locators (URL), clickstream to, through and from our site (including date and time), products you viewed or searched for, page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs), methods used to browse away from the page, and any phone number used to call our customer service number.

Information we receive from other sources.

This is information we receive about you if you use any of the other websites we operate or the other services we provide. We are also working closely with third parties (including, for example, business partners, sub-contractors in technical, payment and delivery services, advertising networks, analytics providers, search information providers, credit reference agencies) and may receive information about you from them. In this case we will have informed you when we collected that data if we intend to share such data internally and combine it with data collected on this site. We will also have told you for what purpose we will share and combine your data. We are working closely with third parties (including, for example, business partners, sub-contractors in technical, payment and delivery services, advertising networks, analytics providers, search information providers, credit reference agencies). We will notify you when we receive information about you from them and the purposes for which we intend to use that information.

THE PERSONAL DATA WE COLLECT

The different types of personal data we may collect about you could include:

• Identity Data: includes your title, full name and maiden name if applicable, date of birth, sex, marital status, passport, driving licence data or other identity card;
• Contact Data: includes email address, telephone numbers and home address;
• Financial Data: includes bank account details and related information;
• Transaction Data: includes details about payments to and from you and other details of products and services you have purchased from us;
• Usage Data: includes information about how you use our website, products and services;
• Recruitment Data

How information is used

We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:

• To provide FCA compliance advice and to answer your specific questions;
• Carry out our obligations arising from any contracts entered into by you and us;
• To fulfil our legal and regulatory obligations;
• Seek your views or comments on the services we provide;
• Notify you of changes to our services;
• Send you communications which you have requested and that may be of interest;
• Process a job application;
• For marketing purposes and based on ‘Legitimate Interests’.  You are free to opt out of at any time;
• For other legitimate business purposes.
• If you wish to change how we use your data, you’ll find details in the ‘Your Rights’ section below. Remember, if you choose not to share your personal data with us, or refuse certain contact permissions, we might not be able to provide some services you’ve asked for.

Retention period for using your personal data

• We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, regulatory or reporting requirements. To determine the appropriate retention period for personal data, we consider:
• the amount, nature, and sensitivity of the data;
• the potential risk of harm from unauthorised use or disclosure of the data;
• the purposes for which we process the data; and
• the applicable legal requirements.
• Personal data will generally not be held for more than seven years after the end of the relationship/appointment, unless otherwise prescribed by law or regulation.

How we share your information

We do not sell or distribute your personal data for commercial gain.  We may process your personal data without your knowledge where this is required or permitted by law.

We may have to share your personal data with

• Trusted third party service providers;
• Our auditors, insurers or regulatory bodies;
• Our clients’ funders;
• Our mutual clients, whom you have given permission for us to share your data with;
• Third parties to whom we may sell or merge our businesses or assets.
• All our third-party service providers are required to take appropriate security measures to protect your personal information in line with our policies. We work closely with them to ensure that your privacy is respected at all times. We only permit them to process your personal information for specified purposes and in accordance with our instructions.

DISCLOSURE OF YOUR INFORMATION

We may share your personal information with any member of our group, as defined in section 1159 of the UK Companies Act 2006.

You agree that we have the right to share your personal information with:

• Any member of our group, as defined in section 1159 of the UK Companies Act 2006.
• Selected third parties including:
• business partners, suppliers and sub-contractors for the performance of any contract we enter into with them or you;
• advertisers and advertising networks that require the data to select and serve relevant adverts to you and others. We do not disclose information about identifiable individuals to our advertisers, but we will provide them with aggregate information about our users (for example, we may inform them that 500 men aged under 30 have clicked on their advertisement on any given day). We may also use such aggregate information to help advertisers reach the kind of audience they want to target (for example, women in SW1). We may make use of the personal data we have collected from you to enable us to comply with our advertisers’ wishes by displaying their advertisement to that target audience;
• analytics and search engine providers that assist us in the improvement and optimisation of our site;
• Anti-Money Laundering Software and criminal records search providers. where this is a condition of us entering into a contract with you.
• If we are under a duty to disclose or share your personal data in order to comply with any legal obligation, or in order to enforce or apply our terms of conditions

WHERE WE STORE YOUR PERSONAL DATA

The data that we collect from you may be transferred to, and stored at, a destination outside the European Economic Area (“EEA”). It may also be processed by staff operating outside the EEA who work for us or for one of our suppliers. Such staff may be engaged in, among other things, the fulfilment of your order, the processing of your payment details and the provision of support services. By submitting your personal data, you agree to this transfer, storing or processing. We will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this privacy policy.

Where we have given you (or where you have chosen) a password, you are responsible for keeping this password confidential. We ask you not to share a password with anyone, and you authorise us to act upon instructions and information from any person that enters your user id or password.

Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted to our site; any transmission is at your own risk. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorised access.

YOUR RIGHTS

You have the right to object to how we use your personal information. You also have the right to see what personal information we hold about you. In addition, you can ask us to correct inaccuracies, delete or restrict personal information or to ask for some of your personal information to be provided to someone else.  To make enquires for further information about exercising any of your rights in this Privacy Notice, please contact us at Contact@authoripay.co.uk.

You are entitled to exercise any of the following privacy rights:

• Right to object: You can object to our processing of your personal information. Please contact us as noted below, providing details of your objection.
• Access to your personal information: You can request access to a copy of your personal information that we hold, along with information on what personal information we use, why we use it, who we share it with, how long we keep it for and whether it has been used for any automated decision making.
• Right to withdraw consent: If you have given us your consent to use your personal information to send you marketing emails, you can withdraw your consent at any time by clicking the “unsubscribe” link in any marketing email which you receive.
• Rectification: You can ask us to change or complete any inaccurate or incomplete personal information held about you.
• Erasure: You can ask us to delete your personal information where it is no longer necessary for us to use it, you have withdrawn consent, or where we have no lawful basis for keeping it.
• Portability: You can ask us to provide you or a third party with some of the personal information that we hold about you in a structured, commonly used, electronic form, so it can be easily transferred.
• Restriction: You can ask us to restrict the personal information we use about you where you have asked for it to be erased or where you have objected to our use of it.
• Make a complaint: You can make a complaint about how we have used your personal information to us by contacting us as noted below, or to a supervisory authority – for the UK this is the Information Commissioner’s Office, at https://ico.org.uk/.

Please make all requests to exercise your privacy rights in writing to our DPO at contact@authoripay.co.ukwe are required to verify your identity in order to process your request and may ask you to provide valid identification documents to allow us to do so.

We will not make any charge for responding to any request from you to exercise your privacy rights, and we will respond to your requests in accordance with our obligations under data protection legislation.

THIRD PARTY WEBSITES

Our site may, from time to time, contain links to and from the websites of our partner networks, advertisers and affiliates. If you follow a link to any of these websites, please note that these websites have their own privacy policies and that we do not accept any responsibility or liability for these policies. Please check these policies before you submit any personal data to these websites.

INFORMATION ABOUT OUR USE OF COOKIES

Our website uses cookies to distinguish you from other users of our website. This helps us to provide you with a good experience when you browse our website and also allows us to improve our site. By continuing to browse the site, you are agreeing to our use of cookies.

A cookie is a small file of letters and numbers that we store on your browser or the hard drive of your computer if you agree. Cookies contain information that is transferred to your computer’s hard drive.

We use the following cookies:

• Strictly necessary: These are cookies that are required for the operation of our website. They include, for example, cookies that enable you to log into secure areas of our website.
• Analytical/performance: They allow us to recognise and count the number of visitors to our website and to see how visitors move around our website when they are using it. This helps us to improve the way our website works, for example, by ensuring that users are finding what they are looking for easily. This is statistical information and does not identify any individual.
• Functionality: These are used to recognise you when you return to our website. This enables us to personalise our content for you, greet you by name and remember your preferences (for example, your choice of language or region).
• Targeting: These cookies record your visit to our website, the pages you have visited and the links you have followed. We will use this information to make our website and the advertising displayed on it more relevant to your interests. We may also share this information with third parties for this purpose.

Please note that third parties (including, for example, providers of external services like web traffic analysis services, or social media websites) may also use cookies, over which we have no control. These cookies are likely to be analytical/performance cookies or targeting cookies.

If you wish, you can set your browser to notify you before you receive a cookie so you have the chance to accept it and you can also set your browser to refuse to receive or send all cookies. The website www.allaboutcookies.org (run by the Interactive Marketing Bureau) contains step-by-step guidance on how cookies can be switched off by users. Please be aware that if you do not accept cookies our website may not function correctly.

You block cookies by activating the setting on your browser that allows you to refuse the setting of all or some cookies. However, if you use your browser settings to block all cookies (including essential cookies) you may not be able to access all or parts of our site.

DATA RETENTION

We will only retain your personal information for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.

To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.

In some circumstances we may anonymise your personal information so that it can no longer be associated with you, in which case we may use such information without further notice to you.

We may also hold your personal information for longer where it is necessary to do so for the management of any active or potential legal proceedings, to resolve or defend claims, and for the purpose of making any necessary remediation payments.

CHANGES TO OUR PRIVACY POLICY

Any changes we make to our privacy policy in the future will be posted on this page and, where appropriate, notified to you by e-mail. Please check back frequently to see any updates or changes to our privacy policy.

CONTACT

Questions, comments and requests regarding this privacy policy are welcomed and should be addressed to contact@authoripay.co.uk