2. Personal information we collect about you
Personal information (or personal data) means any information about you from which you can be identified. It does not include information where your identity has been removed (this is anonymous data).
We may collect and use the following personal information about you:
i. Identity Data including your first name, last name, username or similar identifier;
ii. Contact Data including your billing address, delivery address, email address and telephone numbers;
iii. Financial and Payment Data including your bank account, billing information, payment card details and other data necessary for processing payments and fraud prevention, and also details of services you have purchased from us;
iv. Business Information including information provided in the course of the contractual or client relationship between you or your organisation and us, or otherwise voluntarily provided by you or your organisation;
v. Technical Data including internet protocol (IP) address, your login data, device type, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, and other technology on the devices you use to access this website;
vi. Profile Data including your username and password, purchases or orders made by you, information from accounts you link to us (e.g. Facebook), preferences, feedback and survey responses;
viii. Marketing and Communications Data including your preferences in receiving marketing from us and our third-party partners, and your communication preferences.
ix. Special Categories of Personal Data: We do not collect any special categories of personal data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health, and genetic and biometric data). Nor do we collect any information about criminal convictions or offences.
If you provide information to us about any person other than yourself, your employees, counterparties, your advisers or your suppliers, you must ensure that they understand how their information will be used, and that they have given their permission for you to disclose it to us and for you to allow us, and our outsourced service providers, to use it.
3. How we collect your personal information
Generally, we collect your personal information directly from you, through your use of our website. In particular, this may occur in the following circumstances:
i. when you or your organisation seek our services or use any of our online services;
ii. when you or your organisation offer to provide, or provides, products and/or services;
iii. when you correspond with us by phone, email or other electronic means, or in writing, or when you provide other information directly to us, including with our consultants and staff;
iv. when you create an account on our website;
v. when you subscribe to our service or publications;
vi. when sign up to attend and/or attend our events, or sign up to receive marketing communication and offers from us;
vii. when you enter a competition, promotion or survey; and
viii. give us feedback or contact us.
We may also collect information about you indirectly, including:
a. from publicly accessible sources, e.g. company registers;
b. from third parties, e.g. sanction screening providers, credit reference agencies, customer due diligence providers;
c. from third parties with your consent, e.g. your bank;
e. through our IT systems monitoring your interaction with us, e.g. automated monitoring of your interaction with our websites and other technical systems, such as our computer networks and connections, communications systems, email and instant messaging systems.
4. How we use your personal information
Under data protection law, we can only use your personal information if we have a proper reason for doing so, for example:
i. for the performance of our contract with you or to take steps at your request before entering into a contract;
ii. to comply with our legal and regulatory obligations;
iii. for our legitimate interests or those of a third party; or
iv. where you have given consent.
A legitimate interest is when we have a business or commercial reason to use your information, so long as this is not overridden by your own rights and interests.
Generally, we do not rely on consent as a legal basis for processing your personal information although we will get your consent before sending third party direct marketing communications to you via email or text message. You have the right to withdraw consent to marketing at any time by contacting us.
We will only use your personal information for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If we need to use your personal information for an unrelated purpose, we will notify you and explain the legal basis which allows us to do so. Please note that we may process your personal information without your knowledge or consent, in compliance with the rules set out in this section, where this is required or permitted by law.
We will use your personal information for the following purposes and on the following grounds:
a. On the basis of fulfilling our contract with you or entering into a contract with you on your request, in order to:
a) register you as a new customer and update our customer records;
b) register you as a new supplier and update our supplier records;
c) process and deliver the agreed services to you, including sending you updates and managing payments, fees and charges;
d) manage your subscriptions and user accounts; and
e) deal with and respond to requests, enquiries and complaints;
b. On the basis of our legal obligations, we process your personal information when it is necessary:
a) for compliance with tax, accounting, anti-money laundering and other applicable law and obligations which we are subject to;
b) for managing your statutory rights;
d) for ensuring security of your personal data by preventing unauthorised access to it.
c. On the basis of our legitimate interest, we will use your personal information for:
a) allowing effective performance of our business by ensuring necessary internal administrative, commercial, and security processes (including in finance, controlling, business intelligence, legal & compliance, information security);
b) verifying your identity, and preventing and detecting fraud against you or us;
c) collecting and recovering money you owed to us;
d) asking you to provide feedback, leave a review or take a survey;
e) sending you information about and enabling you to participate in events (including online events) organised by us (with or without another party), including seminars and training; leisure, sports and/or charity events; prize draws and competitions; and surveys, marketing campaigns, market analysis or other promotional activities;
f) communicating with you and keeping you up-to-date on the latest developments, announcements, and other information about our services and solutions (including briefings, newsletters and other information), events and initiatives;
g) promoting (including by delivering advertisements) and making suggestions and recommendations to you (including by email or when you visit our website) about products and services that may be of interest to you, as well as to personalise content you see on our website, and measuring and analysing the effectiveness of the promotions and suggestions we serve you;
h) using statistical data analytics about your use of our website and services to improve the website, our services, marketing, customer relationships and experiences;
I) preventing unauthorised access and modifications to systems;
j) carrying out and dealing with security-related tasks, such as troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data; and
k) establishing, exercising and/or defending our legal rights.
5. Promotional Communications
We may use your personal information to send you updates (by email, text message, telephone or post) about our products and services, including exclusive offers, promotions or information about new products and services.
We have a legitimate interest in processing your personal information for promotional purposes (see above). This means we do not usually need your consent to send you promotional communications. However, where consent is needed, we will ask for this consent separately and clearly.
We will not sell your personal information to or share it with other organisations for marketing purposes, except where we remain the controller of your personal information and share it with third parties who act as a data processor on our behalf and only process the personal information on our instructions and for the purposes set out above.
You have the right to opt out of receiving promotional communications at any time by:
i. contacting us at privacy@iScribo.com;
ii. using the ‘unsubscribe’ link in emails or ‘STOP’ number in texts; or
iii. updating your marketing preferences in your user profile on our website.
We may ask you to confirm or update your marketing preferences if you instruct us to provide further products or services in the future, or if there are changes in the law, regulation, or the structure of our business.
6. Who we share your personal information with
We routinely share personal information with:
i. service providers we use to help deliver products and/or services to you, such as security providers, payment service providers, app and website management companies, sticker, label, and other similar printing service providers, and delivery service providers. We only allow our service providers to handle your personal information if we are satisfied they take appropriate measures to protect your personal information. We also impose contractual obligations on service providers to ensure they can only use your personal information to provide services to us and to you. We may also share personal information with external auditors, e.g. in the audit of our accounts; and
ii. other users you request information or services from.
We may also share personal information with:
a. credit reference agencies who may, for example, supply anti-fraud and credit-insight information to us;
b. social media companies and our advertising partners. For example, we might match your email address with Facebook and Twitter to enable us to run promotions on their platforms;
c. our professional advisors such as our lawyers, accountants or auditors when they need to give us their professional advice;
d. public authorities, agencies and other government bodies. We may disclose and exchange information with law enforcement agencies and regulatory bodies to comply with our legal and regulatory obligations; and
e. potential corporate buyer. We may also share some personal information in the case of transfer of some or all of our business, during re-structuring or change of ownership of the business. Usually, information will be anonymised but this may not always be possible. The recipient of the information will be bound by confidentiality obligations.
Your personal information may be held at our offices and those of our third-party agencies, service providers, representatives and agents as described above. Some of these third parties may be based outside the European Union or the European Economic Area. For more information, including on how we safeguard your personal information when this occurs, see Section 9 below.
7. How long your personal information will be kept
We will keep your personal information while you have an account with us or we are providing products and/or services to you. Thereafter, we will keep your personal information for as long as is necessary:
i. to respond to any questions, complaints or claims made by you or on your behalf;
ii. to show that we treated you fairly; and
iii. to keep records required by law.
We will not retain your personal information for longer than necessary for the purposes set out in this policy. Different retention periods apply for different types of personal information. By law we have to keep basic information about our customers (including Identity, Contact, Financial and Payment Data and Business Information) for six years after they cease being customers. If you want to learn more about our specific retention periods for your personal information, please contact us at privacy@iScribo.com
When it is no longer necessary to retain your personal information we will securely destroy your personal information in accordance with applicable laws and regulations. In some circumstances we will anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes, in which case we may use this information indefinitely without further notice to you.
8. International transfers of your personal information
If, to deliver our services to you, it is necessary for us to share or transfer your personal information outside the European Union or the European Economic Area (EEA), then some additional safeguards will apply.
Where we need to make a transfer of this nature, we will only do so if such a transfer is safe and your personal information will be secure.
This means that when we transfer your personal information outside the EU or EEA we will only do so where (i) there are Binding Corporate rules in place; or (ii) the country where are making the transfer to is a country deemed by the European Commission to have an adequate level of protection in place for your personal information; or (iii) if there is no adequacy decision, where we have contractual arrangement with the service provider containing protections for your personal information (the EU Commission approved Standard Contractual Clauses, for example) or (iv) where the service provider is part of an approved scheme.
Please contact us if you want further information on the mechanisms used by us when transferring your personal information out of the EU or EEA.
9. Your rights
Under the applicable data protection laws you have a number of rights, as set out below:
i. Right to access your personal information. You may request confirmation that we hold personal information about you, as well as access to a copy of any such data.
ii. Right to rectification. You may ask us to correct any inaccurate information we hold about you.
iii. Right to erasure (or Right to be forgotten). You may, in certain circumstances, ask us to delete your personal information.
iv. Right to restriction. You may ask us to restrict the processing of your personal information if (i) you want us to establish the accuracy of the information, (ii) where our use of the information is unlawful but you do not want us to erase it, (iii) where you need us to hold the information even if we no longer require it as you need it to establish, exercise or defend legal claims, or (iv) you have objected to our use of your personal information but we need to verify whether we have overriding legitimate grounds to use it.
v. Right to portability. You may request the receipt of the personal information that you have provided to us, in a structured, commonly used and machine-readable form, or its transfer to another organisation.
vi. Right to object. You may object to our processing of your personal information (i) at any time when your personal information is being processed for direct marketing, or (ii) 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.
vii. Right not to be subject to automated individual decision making. You have the right not be subject to a decision based solely on automated processing (or profiling) that produces legal effects concerning you or similarly significantly affects you.
viii. Right to withdraw consent. Where our processing of your personal information is based on your consent, you may withdraw this consent at any time, although this will not affect the lawfulness of any prior processing where we relied on your consent.
For further information on each of these rights, including the circumstances in which they apply, please contact us or see the Guidance from the UK Information Commissioner’s Office (ICO) on individuals’ rights under the General Data Protection Regulation available via the following link: https://ico.org.uk/for-organisations/guide-to-data-protection/guide-to-the-general-data-protection-regulation-gdpr/individual-rights/.
If you would like to exercise any of these rights, please contact us using our contact details set out below.
You will not have to pay a fee to access your data or to exercise any of the other rights. However, we may charge a reasonable fee of your request is clearly unfounded, repetitive or excessive. Alternatively, we could refuse to comply with your request in these circumstances.
We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal information (or to exercise any of your other rights). This is a security measure to ensure that personal information is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.
We try to respond to all legitimate requests within one month. Occasionally it could take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.
10. Keeping your personal information secure
We have put in place appropriate security measures to prevent personal information from being accidentally lost, used or accessed unlawfully, altered or disclosed. We limit access to your personal information to those who have a genuine business need to access it. Those processing your information will do so only in an authorised manner and are subject to a duty of confidentiality.
We also have procedures in place to deal with any suspected data security breach. We will notify you and any applicable regulator of a suspected data security breach where we are legally required to do so.
11. How to complain
We hope that we can resolve any query or concern you may raise about our use of your personal information.
Applicable data protection laws also give you the right to lodge a complaint with the Information Commissioner who may be contacted at https://ico.org.uk/concerns or telephone: 0303 123 1113.
13. How to contact us
Email address: privacy@iScribo.com
Postal address: Tudor Wood, Henley Road Maidenhead, England SL6 6QW