MasterCard® Terms of Use

MasterCard® Geo-Insights

Terms of Use

Please read these terms and conditions carefully before using any product or content created by Huq Industries that makes of MasterCard® Geo-Insight data or derivative works.

This document contains the proprietary and confidential information, including data (“Information”) of Mastercard Europe SA (“Mastercard”). This document and Information are strictly confidential and are provided for internal use only. Except with the prior written permission of Mastercard, Information shall not be used for any unauthorized purpose, shall not be modified, reproduced, published or disclosed to any third parties. The Information is provided “AS IS” at your own risk.

You acknowledge and agree that inaccuracies and inconsistencies may be inherent in Information, and that consequently, Information and your analysis may itself be inaccurate or inconsistent and that no assurances are given that any of the projections, estimates, or expectations will be achieved, or that the Information provided is error-free. Mastercard expressly disclaims any and all representations or warranties, express or implied, as to the merchantability, fitness for a particular purpose or use, non-infringement, completeness, quality, accuracy, projections, estimates or expectations. In no event shall Mastercard be held responsible for any inaccuracies, inconsistencies, formatting errors, or omissions in the Information.

Mastercard assumes no liability whatsoever to you or any other third party in connection with any conclusions or actions taken by you or any other party in connection with the use or reliance on the Information and shall not be liable for any loss of business or profits or any loss or damages, whether direct or indirect, including special, incidental, consequential damages, exemplary or punitive damages, in connection with the Information, resulting from the use thereof or any results obtained from such use. Nothing in the Information is intended to constitute, nor should it be relied upon as, investment advice or otherwise advice on the merits of the acquisition, disposal or holding of any security or is intended to amount to an inducement to engage in any investment activity of any description in any part of the world, and shall not be relied upon by you or any person, for the purpose of investment, non-security investments (such as acquiring retail properties) or other financial decisions.


Modern Slavery Policy

Anti-Slavery Policy Statement

Our zero-tolerance approach to modern slavery

Modern slavery is a crime and a violation of fundamental human rights. It takes various forms, such as slavery, servitude, forced and compulsory labour and human trafficking, all of which have in common the deprivation of a person’s liberty by another in order to exploit them for personal or commercial gain.

Huq Industries has a zero-tolerance approach to modern slavery, and we are committed to acting ethically and with integrity in all our business dealings and relationships and to implementing and enforcing effective systems and controls to ensure modern slavery is not taking place anywhere in our own business or in any of our supply chains.

We are also committed to ensuring there is transparency in our own business and in our approach to tackling modern slavery throughout our supply chains, consistent with our disclosure obligations under the Modern Slavery Act 2015.

We expect the same high standards from all of our contractors, suppliers and other business partners, and as part of our contracting processes, in the coming year we will include specific prohibitions against the use of forced, compulsory or trafficked labour, or anyone held in slavery or servitude, whether adults or children, and we expect that our suppliers will hold their own suppliers to the same high standards.

This policy applies to all persons working for us or on our behalf in any capacity, including employees at all levels, directors, o!cers, agency workers, seconded workers, volunteers, interns, agents, contractors, external consultants, third-party representatives and business partners.

This policy does not form part of any employee’s contract of employment and we may amend it at any time.

Responsibility for the policy

Huq Industries has overall responsibility for ensuring this policy complies with our legal and ethical obligations, and that all those under our control comply with it. Huq Industries has primary and day-to-day responsibility for implementing this policy, monitoring its use and effectiveness, dealing with any queries about it, and auditing internal control systems and procedures to ensure they are effective in countering modern slavery.

Management at all levels are responsible for ensuring those reporting to them understand and comply with this policy and are given adequate and regular training on it and the issue of modern slavery in supply chains. You are invited to comment on this policy and suggest ways in which it might be improved. Comments, suggestions and queries are encouraged and should be addressed to the Chief Executive Officer.

Compliance with the policy

You must ensure that you read, understand and comply with this policy. The prevention, detection and reporting of modern slavery in any part of our business or supply chains is the responsibility of all those working for us or under our control. You are required to avoid any activity that might lead to, or suggest, a breach of this policy.

You must notify your line manager OR a company Director as soon as possible if you believe or suspect that a conflict with this policy has occurred or may occur in the future. You are encouraged to raise concerns about any issue or suspicion of modern slavery in any parts of our business or supply chains of any supplier tier at the earliest possible stage. If you believe or suspect a breach of this policy has occurred or that it may occur, you must notify your line manager or company Director.

You should note that where appropriate, and with the welfare and safety of local workers as a priority, we will give support and guidance to our suppliers to help them address coercive, abusive and exploitative work practices in their own business and supply chains. If you are unsure about whether a particular act, the treatment of workers more generally, or their working conditions within any tier of our supply chains constitutes any of the various forms of modern slavery, raise it with your line manager or company Director.

We aim to encourage openness and will support anyone who raises genuine concerns in good faith under this policy, even if they turn out to be mistaken. We are committed to ensuring no one suffers any detrimental treatment as a result of reporting in good faith their suspicion that modern slavery of whatever form is or may be taking place in any part of our own business or in any of our supply chains. Detrimental treatment includes dismissal, disciplinary action, threats or other unfavourable treatment connected with raising a concern.

If you believe that you have suffered any such treatment, you should inform your line manager immediately. If the matter is not remedied, and you are an employee, you should raise it formally using our Grievance Procedure, which can be found in the current employee handbook. This Modern (Anti) Slavery Policy and Statement is intended for businesses in all countries, especially the United Kingdom.

Communication & awareness of this policy

Training on this policy, and on the risk our business faces from modern slavery in its supply chains, forms part of the induction process for all individuals who work for us, and updates will be provided using established methods of communication between the business and you. Our zero-tolerance approach to modern slavery must be communicated to all suppliers, contractors and business partners at the outset of our business relationship with them and reinforced as appropriate thereafter.

Breaches of this policy

Any employee who breaches this policy will face disciplinary action, which could result in dismissal for misconduct or gross misconduct. We may terminate our relationship with other individuals and organisations working on our behalf if they breach this policy.

Conrad Poulson, CEO, 2022


Terms of Use

Terms of Use

Please read these terms and conditions carefully before using this site.

Huq Industries Limited, a company incorporated and registered in England and Wales with company number 09202565 whose registered office is at Cromwell House, 15 Andover Rd, Winchester SO23 7BT, United Kingdom (“Huq”) owns https://huq.io (the “Website”).

Terms of use

These Terms of Use (together with the documents referred to in it) set out the terms on which you may use our Website as a guest. Use of our Website includes accessing or browsing.

Please read these Terms of Use carefully before you start to use our Website, as these will apply to your use of our Website.

By using our Website, you confirm that you accept these Terms of Use and that you agree to comply with them. If you do not agree to these Terms of Use, you must not use our Website.

Other applicable terms

These Terms of Use refer to the following additional terms, which also apply to your use of our Website:

Our Privacy and Security Policy (located at https://huq.io/terms/our-privacy-policy), which sets out the terms on which we process any personal data we collect from you, or that you provide to us. By using our Website, you consent to such processing and you warrant that all data provided by you is accurate.

Our Website uses cookies. By using our Website, you consent to our use of cookies in accordance with the terms of our Privacy Policy.

Changes to these terms

We may revise these Terms of Use at any time by amending this page.

Please check this page from time to time to take notice of any changes we made, as they are binding on you.

Changes to our website

We may update our Website from time to time, and may change the content at any time. However, please note that any of the content on our Website may be out of date at any given time, and we are under no obligation to update it.

We do not guarantee that our Website, or any content on it, will be free from errors or omissions.

Accessing our website

Basic access to our Website is made available free of charge. If you register as a customer and gain full access to our Website and services, please note that you may be charged for doing so.

We do not guarantee that our Website, or any content on it, will always be available or be uninterrupted. Access to our Website is permitted on a temporary basis. We may suspend, withdraw, discontinue or change all or any part of our Website without notice. We will not be liable to you if for any reason our Website is unavailable at any time or for any period.

You are responsible for making all arrangements necessary for you to have access to our Website.

You are also responsible for ensuring that all persons who access our Website through your internet connection are aware of these Terms of Use and other applicable terms and conditions, and that they comply with them.

We may limit the availability of our Website or any service or product described on our Website to any person or geographic area at any time.

Intellectual property rights

We are the owner or the licensee of all intellectual property rights in our Website, and in the material published on it. Those works are protected by copyright laws and treaties around the world. All such rights are reserved.

You must not use any part of the content on our Website for commercial purposes without obtaining a licence to do so from us.

No reliance on information

The content on our Website is provided for general information only. It is not intended to amount to advice on which you should rely. You must obtain professional or specialist advice before taking, or refraining from, any action on the basis of the content on our Website.

Although we make reasonable efforts to update the information on our Website, we make no representations, warranties or guarantees, whether express or implied, that the content on our Website is accurate, complete or up-to-date.

Limitation of our liability

Nothing in these Terms of Use excludes or limits our liability for death or personal injury arising from our negligence, or our fraud or fraudulent misrepresentation, or any other liability that cannot be excluded or limited by English law.

To the extent permitted by law, we exclude all conditions, warranties, representations or other terms which may apply to our Website or any content on it, whether express or implied.

We will not be liable to any user for any loss or damage, whether in contract, tort (including negligence), breach of statutory duty, or otherwise, even if foreseeable, arising under or in connection with:

  • use of, or inability to use, our Website; or
  • use of or reliance on any content displayed on our Website.

We will not be liable for any loss or damage caused by a virus, distributed denial-of-service attack, or other technologically harmful material that may infect your computer equipment, computer programs, data or other proprietary material due to your use of our Website or to your downloading of any content on it, or on any website linked to it.

We assume no responsibility for the content of websites linked on our Website. Such links should not be interpreted as endorsement by us of those linked websites. We will not be liable for any loss or damage that may arise from your use of them.

Viruses

We do not guarantee that our Website will be secure or free from bugs or viruses.

You are responsible for configuring your information technology, computer programmes and platform in order to access our Website. You should use your own virus protection software.

You must not misuse our Website by knowingly introducing viruses, trojans, worms, logic bombs or other material which is malicious or technologically harmful. You must not attempt to gain unauthorised access to our Website, the server on which our Website is stored or any server, computer or database connected to our Website. You must not attack our Website via a denial-of-service attack or a distributed denial-of service attack. By breaching this provision you would commit a criminal offence. We will report any such breach to the relevant law enforcement authorities and we will co-operate with those authorities by disclosing your identity to them. In the event of such a breach, your right to use our Website will cease immediately.

Linking to our website

You may link to our home page, provided you do so in a way that is fair and legal and does not damage our reputation or take advantage of it. You must not establish a link in such a way as to suggest any form of association, approval or endorsement on our part where none exists.

You must not establish a link to our Website in any website that is not owned by you.

Our Website must not be framed on any other site, nor may you create a link to any part of our Website other than the home page.

We reserve the right to withdraw linking permission without notice.

If you wish to make any use of content on our Website other than that set out above, please contact [email protected].

Third party links and resources in our website

Where our Website contains links to other sites and resources provided by third parties, these links are provided for your information only. We have no control over the contents of those sites or resources.

Applicable law

These Terms of Use, its subject matter and its formation, are governed by English law. You agree that the courts of England and Wales will have non-exclusive jurisdiction.

Contact us

To contact us, please email [email protected].


Privacy Policy

Privacy Policy

Huq Industries respects your privacy and is committed to protecting your personal data. This privacy policy will inform you as to how we look after your personal data when you visit our website (regardless of where you visit it from) and tell you about your privacy rights and how the law protects you.

This privacy policy is provided in a layered format so you can click through to the specific areas set out below. Please also use the Glossary to understand the meaning of some of the terms used in this privacy policy.

Important information and who we are

Purpose of this Privacy Policy

This privacy policy aims to give you information on how Huq Industries collects and processes your personal data through your use of this website, apps or mobile app partners’ apps when you sign up to our newsletter, product demonstrations or if you are an end-user of a mobile partners’ app and have agreed to provide the necessary consents via that app.

This website, our app and/or mobile partners’ apps are not intended for children and we do not knowingly collect data relating to children.

It is important that you read this privacy policy together with any other privacy policy or fair processing policy we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. This privacy policy supplements other notices and privacy policies and is not intended to override them.

Controller

Huq Industries Limited is the controller and responsible for your personal data (collectively referred to as Huq Industries, “we”, “us” or “our” in this privacy policy).

If you have any questions about this privacy policy, including any requests to exercise your legal rights, please contact us using the details set out below.

Contact details

If you have any questions about this privacy policy or our privacy practices, please contact our DPO in the following ways:

Full name of legal entity Huq Industries Limited
Email address [email protected]
Postal address 154-160 Fleet St, London, Greater London, EC4A 2DQ, United Kingdom

You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.

Changes to the Privacy Policy and your duty to inform us

We keep our privacy policy under regular review. This version was last updated on 2024-08-14. Historic versions can be obtained by contacting us.

It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.

Third-party links

This website, app or mobile app partners’ app may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites, apps or mobile app partners’ apps and are not responsible for their privacy statements. When you leave our website, app or mobile app partners’ app, we encourage you to read the privacy policy of every website, app or mobile app partners’ app you visit.

The data we collect about you

Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).

We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:

  1. Identity Data includes first name, maiden name, last name, username or similar identifier, marital status, title, date of birth, gender and location data.
  2. Contact Data includes billing address, delivery address, email address and telephone numbers.
  3. Financial Data includes bank account and payment card details.
  4. Transaction Data includes details about payments to and from you and other details of products and services you have purchased from us.
  5. Technical Data includes internet protocol (IP) address, your login data, 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.
  6. Profile Data includes your username and password, purchases or orders made by you, your interests, preferences, feedback and survey responses.
  7. Usage Data includes information about how you use our website, products and services.
  8. Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.
  9. Source Data is collected via our SDK installed on our mobile partners’ apps. In the case that you have one such app installed on your device, we may collect the following information: operating system (e.g., iOS or Android), date and time as set by device, latitude and longitude when an app which uses our SDK uses the device’s GPS, the accuracy of that location, the bearing of the device, the altitude of the device, the speed of the device, the SSID and MAC address of the WiFi router when the device using an app which uses our SDK interacts with/connects to a Wi-Fi network, the bundle ID (name of app), the device model, the device manufacturer, the language that the device is set to, the locale that the device is set to, the carrier code (the mobile network that the device is currently using), the SIM code (the mobile network that the SIM is registered to).

We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data could be derived from your personal data but is not considered personal data in law as this data will not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data and Source Data to calculate the percentage of users accessing a specific website, app or mobile partners’ apps’ features, your location and network interaction data thereof. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy policy.

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 and offences.

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 be able to perform the contract we have or are trying to enter into with you (for example, to provide you with goods or 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.

How is your personal data collected?

We use different methods to collect data from and about you including through:

    1. Direct interactions. You may give us your Identity, Contact and Financial Data by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:
      • apply for our products or services;
      • create an account on our website;
      • subscribe to our service or publications;
      • request marketing to be sent to you;
      • give us feedback or contact us.
  1. Automated technologies or interactions. As you interact with our website, app or mobile partners’ apps, we will automatically collect Technical Data about your equipment, location, browsing actions, network interactions and patterns and the Source Data described above. We collect this personal data by using cookies, server logs, embedded mobile app SDKs and other similar technologies. We do not collect any Source Data unless our mobile app partners have obtained your prior explicit consent to our SDKs collecting your data via that mobile app partner’s app.
  2. Third parties or publicly available sources. We will receive personal data about you from various third parties and public sources as set out below:
    • Technical Data and Source Data from the following parties:
      (a) analytics providers such as Google based outside the EU;
      (b) from our own SDK embedded within our mobile partners’ mobile apps, of which you may be a user

How we use your personal data

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:

  1. In order to carry out our business practices, which include but are not limited to the analysis of consumer trends and real-world interactions based on the Technical Data and Source Data that you are about to or have agreed to provide via our mobile partner apps.
  2. Where we need to perform the contract we are about to enter into or have entered into with you.
  3. 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.
  4. Where we need to comply with a legal obligation.

Click here to find out more about the types of lawful basis that we will rely on to process your personal data.

Generally, we do not rely on consent as a legal basis for processing your personal data 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.

Purposes for which we use your personal data

We have set out below, in a table format, a description of all 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.

Note that we may process your personal data for more than one lawful ground 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 register you as a new customer (a) Identity Performance of a contract with you
(b) Contact
To process and deliver your order including: (a) Identity (a) Performance of a contract with you
(a) Manage payments, fees and charges (b) Contact (b) Necessary for our legitimate interests (to recover debts due to us)
(b) Collect and recover money owed to us (c) Financial
(d) Transaction
(e) Marketing and Communications
To manage our relationship with you which will include: (a) Identity (a) Performance of a contract with you
(a) Notifying you about changes to our terms or privacy policy (b) Contact (b) Necessary to comply with a legal obligation
(b) Asking you to leave a review or take a survey (c) Profile (c) Necessary for our legitimate interests (to keep our records updated and to study how customers use our products/services)
(d) Marketing and Communications
To enable you to partake in a prize draw, competition or complete a survey (a) Identity (a) Performance of a contract with you
(b) Contact (b) Necessary for our legitimate interests (to study how customers use our products/services, to develop them and grow our business)
(c) Profile
(d) Usage
(e) Marketing and Communications
To administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data) (a) Identity (a) Necessary for our legitimate interests (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)
(b) Contact (b) Necessary to comply with a legal obligation
(c) Technical
To deliver relevant website content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you (a) Identity Necessary for our legitimate interests (to study how customers use our products/services, to develop them, to grow our business and to inform our marketing strategy)
(b) Contact
(c) Profile
(d) Usage
(e) Marketing and Communications
(f) Technical
To use data analytics to improve our website, products/services, marketing, customer relationships and experiences (a) Technical Necessary for our legitimate interests (to define types of customers for our products and services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy)
(b) Usage
To make suggestions and recommendations to you about goods or services that may be of interest to you (a) Identity Necessary for our legitimate interests (to develop our products/services and grow our business)
(b) Contact
(c) Technical
(d) Usage
(e) Profile
(f) Marketing and Communications

Marketing

We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising. We have the following personal data control mechanisms:

Promotional offers from us

We may use your Identity, Contact, Technical, Usage and Profile Data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which products, services and offers may be relevant for you (we call this marketing).

You will receive marketing communications from us if you have requested information from us, enquired about or purchased goods or services from us and you have not opted out of receiving that marketing.

Third-party marketing

We will obtain your express opt-in consent before we share your personal data with any third party for marketing purposes.

Opting out

You can ask us or third parties to stop sending you marketing messages at any time by following the opt-out links on any marketing message sent to you or by contacting us at any time.

Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of a product / service purchase, warranty registration, product / service experience, data provided to us via our mobile partner apps or other transactions.

Cookies

You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of this website may become inaccessible or not function properly.

Change of purpose

We will only use your personal data 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 you wish to receive an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.

If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.

Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

Disclosures of your personal data

We may share your personal data with the parties set out below for the purposes set out in the table Purposes for which we will use your personal data above.

  1. Internal Third Parties as set out in the Glossary.
  2. External Third Parties as set out in the Glossary.
  3. 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 privacy policy.

We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.

Data security

We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.

We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

Data retention

How long will you use my personal data for?

We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We do not delete any Source Data that you provide to us via apps that have installed our SDK, however, we do not disclose or allow any third party to access the Source Data. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.

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, regulatory, tax, accounting or other requirements.

By law we have to keep basic information about our customers (including Contact, Identity, Financial and Transaction Data) for six years after they cease being customers for tax purposes.

In some circumstances you can ask us to delete your data: see your legal rights below for further information.

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.

Your legal rights

Under certain circumstances, you have rights under data protection laws in relation to your personal data. Please click on the links below to find out more about these rights:

  1. Request access to your personal data.
  2. Request correction of your personal data.
  3. Request erasure of your personal data.
  4. Object to processing of your personal data.
  5. Request restriction of processing your personal data.
  6. Request transfer of your personal data.
  7. Right to withdraw consent.

If you wish to exercise any of the rights set out above, please contact us.

No fee usually required

You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we could refuse to comply with your request in these circumstances.

What we may need from you

We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data 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.

Time limit to respond

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.

Glossary

Lawful basis

Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give you the best service/product and the best and most secure experience. 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. 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.

Third parties

  1. Service providers based in the US, UK, FR, RU, SG and as listed here, or as may change from time to time, who provide IT and system administration services.
  2. Professional advisers acting as processors or joint controllers including lawyers, bankers, auditors and insurers based in the US, UK, FR or as may change from time to time who provide consultancy, banking, legal, insurance and accounting services.
  3. HM Revenue & Customs, regulators and other authorities acting as processors or joint controllers based in the United Kingdom who require reporting of processing activities in certain circumstances.

Your legal rights

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.
  • 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. You also have the right to object where we are processing your personal data for direct marketing purposes. 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:
    • If you want us to establish the data’s accuracy.
    • Where our use of the data is unlawful but you do not want us to erase it.
    • 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.
    • You have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
  • 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.