Last Updated: June 3 2018
- When you make use of our website, Apps or SDKs, (“Website”);
- When you exchange business cards with us;
- When you attend a marketing event and provide Personal Data; and
- When we acquire your Personal Data from third-party sources (such as lead-generation companies).
Table of contents:
- What Information we Collect, Why we Collect it, and How it is Used;
- How we Protect and Store your Personal Data;
- How we share your Personal Data
- Additional Information Regarding Transfers of Personal Data
- Your Rights
- Use by Children
- How to Contact Us
- WHAT INFORMATION WE COLLECT, WHY WE COLLECT IT, AND HOW IT IS USED
We may collect, use, store and transfer different kinds of personal information about you and process the following information about you:
- Identity information – such as your first name, maiden name, last name, username or similar identifier, marital status, title, date of birth and gender
- Contact information –such as your postal address, email address and telephone numbers
- Financial information – such as your bank account and payment card details
- Transaction information – such as details about payments to and from you and other details of products and services you have purchased from us
- Technical information – such as information from your visits to our website, your 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 and/ or the App
- Profile information – such as your username and password, orders made by you, your interests, preferences, feedback and survey responses
- Usage information – including information about how you use our website and services
- Any other information relating to you which you may provide to us
If you fail to provide personal information to us where we need to collect it 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 be able to perform the contract we have or are trying to enter into with you (for example, to provide you with our services). In this case, we may have to cancel a product or service you have with us but we will notify you if this is the case at the time.
- We do not collect any special categories of personal information 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 and offences.
How we use your personal information
We use information held about you in a number of ways in the provision of our services as follows:
- to administer and protect our business and website, including troubleshooting, auditing and monitoring its use data analysis, system maintenance and support and survey processes
- to register new customers of our business who have signed up to our website or our App or opened an account via our website
- to process your order including managing payments, fees and charges
- to carry out our obligations arising from any contracts entered into between you and us and to provide you with the information, products and services that you request from us
- to provide and improve our services to you
- to deliver relevant website content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you
- to ensure that content from our website and/ or our App is presented in the most effective manner for you and for your computer
- to make suggestions and recommendations to you about goods or services that may be of interest to you
We use your personal information on the following bases:
- To perform a contract, such as engaging with an individual to provide our services
- To comply with legal and regulatory requirements
- Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests, such as:
- to keep our records updated and to study how customers use our products or services
- to develop our products and services and grow our business
- for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise)
Cookies and Other Tracking Technologies. Our Website may utilize "cookies", anonymous identifiers and other tracking technologies in order to for us to provide our Website and present you with information that is customized for you. A "cookie" is a small text file that may be used, for example, to collect information about activity on the Website. Certain cookies and other technologies may serve to recall Personal Information, such as an IP address, previously indicated by a user. Most browsers allow you to control cookies, including whether or not to accept and/or remove them. You may set most browsers to notify you if you receive a cookie, or you may choose to block cookies with your browser.
- HOW WE PROTECT AND STORE YOUR INFORMATION
- Retention of your Personal Data. In addition to the retention periods mentioned in Section 1 above, in some circumstances we may store your Personal Data for longer periods of time, for example: (i) where we are required to do so in accordance with legal, regulatory, tax or accounting requirements, or (ii) for us to have an accurate record of your dealings with us in the event of any complaints or challenges, or (iii) if we reasonably believe there is a prospect of litigation relating to your Personal Data or dealings.
- HOW WE SHARE YOUR PERSONAL INFORMATION
In addition to the recipients described in Section 1, we may share your information as follows:
- To the extent necessary, with regulators, to comply with all applicable laws, regulations and rules, and requests of law enforcement, regulatory and other governmental agencies or if required to do so by court order.
- If, in the future, we sell or transfer some or all of our business or assets to a third party, we will (to the minimum extent required) disclose information to a potential or actual third party purchaser of our business or assets. In the event that we are acquired by or merged with a third party entity, or in the event of bankruptcy or a comparable event, we reserve the right to transfer or assign Personal Data in connection with the foregoing events.
- Where you have provided your consent to us sharing the Personal Data (e.g., where you provide us with marketing consents or opt-in to optional additional services or functionality).
- ADDITIONAL INFORMATION REGARDING TRANSFERS OF PERSONAL INFORMATION
Where we transfer your Personal Data outside of MyCheck for example to third parties who help provide our products and services, we will obtain contractual commitments from them to protect your Personal Data.
Some of the assurances relating to transfers of Personal Data are well-recognized certification schemes like the EU - US Privacy Shield for the protection of Personal Data transferred from the EU to the United States (or Swiss-US Privacy Shield for transfers of Personal Data from Switzerland to the United States); or
Where we receive requests for information from law enforcement or regulators, we use commercially reasonable efforts to validate these requests before any Personal Data is disclosed.
- YOUR RIGHTS
The following rights (which may be subject to certain exemptions or derogations), shall apply to individuals who are protected by the GDPR:
- You have a right to access information held about you. Your right of access may normally be exercised free of charge, however we reserve the right to charge an appropriate administrative fee where permitted by applicable law;
- You have the right to request that we amend any Personal Data we hold that it is inaccurate or misleading;
- You have the right to request the erasure of the Personal Data that relates to you. Please note that there may be circumstances in which we are required to retain your data, for example for the establishment, exercise or defense of legal claims;
- The right to object to or to request restriction of the processing. However, there may be circumstances in which we are legally entitled to refuse your request;
- The right to data portability. This means that you may have the right to receive your Personal Data in a structured, commonly used and machine-readable format, and that you have the right to transmit that data to another controller;
- You have the right to object to profiling;
- You have a right to lodge a complaint with your local data protection supervisory authority (i.e., your place of habitual residence, place or work or place of alleged infringement) at any time. We ask that you please attempt to resolve any issues with us before you contact your local supervisory authority.
- The right to withdraw your consent. Please note that there may be circumstances in which we are entitled to continue processing your data, in particular if the processing is required to meet our legal and regulatory obligations.
- You also have a right to request details of the basis on which your Personal Data is transferred outside the European Economic Area, but you acknowledge that data transfer agreements may need to be partially redacted for reasons of commercial confidentiality.
You can exercise your rights by contacting us at email@example.com Subject to legal and other permissible considerations, we will make every reasonable effort to honor your request promptly or inform you if we require further information in order to fulfil your request. When processing your request, we may ask you for additional information to confirm your identity and for security purposes, before disclosing the Personal Data requested to you. We reserve the right to charge a fee where permitted by law, for instance if your request is manifestly unfounded or excessive.
In the event that your request would adversely affect the rights and freedoms of others (for example, would impact the duty of confidentiality we owe to others) or if we are legally entitled to deal with your request in a different way than initial requested, we will address your request to the maximum extent possible, all in accordance with applicable law.
- USE BY CHILDREN
We do not offer our products or services for use by children. If you are under 18, you may not use the Website, or provide any information to the Website without involvement of a parent or a guardian. We do not knowingly collect information from, and/or about, children.
- CONTACT US
If you have any questions, concerns or complaints regarding our compliance with this notice and the data protection laws, or if you wish to exercise your rights, we encourage you to first contact us at firstname.lastname@example.org