Privacy Policy

INTRODUCTION  

Welcome to the Demapal Ltd’s privacy notice.

Demapal Ltd respects your privacy and is committed to protecting your personal data. This privacy policy notice will inform you as to how we look after your personal data when you enter contractual relationship with us and to tell you about your privacy rights and how the law protects you.

Please use the Glossary to understand the meaning of some terms used in this privacy notice.

1. IMPORTANT INFORMATION AND WHO WE ARE

2. THE DATA WE COLLECT ABOUT YOU

3. HOW IS YOUR PERSONAL DATA COLLECTED

4. HOW WE USE YOUR PERSONAL DATA

5. DISCLOSURES OF YOUR PERSONAL DATA

6. INTERNATIONAL TRANSFERS

7. DATA SECURITY

8. DATA RETENTION

9. YOUR LEGAL RIGHTS

10. GLOSSARY

1.  IMPORTANT INFORMATION AND WHO WE ARE   

PURPOSE OF THIS PRIVACY NOTICE  

This privacy notice aims to give you information on how Demapal Ltd collects and processes your personal data when you enter contractual relationship with us.

It is important that you read this privacy notice together with any other privacy notice or fair processing notice 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 notice supplements the other notices and is not intended to override them.

CONTROLLER  

Demapal Ltd is the controller and responsible for your personal data (collectively referred to as “Demapal Ltd”, “we”, “us” or “our” in this privacy notice).

CONTACT DETAILS  

Full name of legal entity: Demapal Ltd

Name of data privacy manager: Ivan Zharikov

Email address: ivan@demapal.com

Postal address: Demapal Ltd, 63 St. Mary Axe, London, EC3A 8AA

Telephone number: +44 (0) 207 183 60 90

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 NOTICE AND YOUR DUTY TO INFORM US OF CHANGES  

This version was last updated on 22February 2019. We may change this privacy notice from time to time by updating it in order to reflect changes in the law and/or our privacy practices.

2.  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:

  • Identity Data includes first name and last name of the client or his representative and company name (if available).
  • Contact Data includes billing address, email address and telephone number.
  • Phone Calls Data includesrecording of phone calls between you and us.
  • Personal Data includes information which you disclose to us in the course of our contractual agreement.
  • Financial Data includes bank account and payment card details.
  • 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 services.
  • Marketing and Communications Data includes your preferences in receiving marketing from us and third parties.

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 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.

3.  HOW IS YOUR PERSONAL DATA COLLECTED?  

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

  • Direct interactions. You may give us your Identity, Contact, Personal, Transaction, Marketing and Communications Data 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 services;
  • request marketing to be sent to you;
  • give us some feedback.

4.  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:

  • Where we need to perform the contract, we are about to enter into or have entered into with you.
  • Where it is necessary for our legitimate interests, when we are acting in pursue of our business purposes and your interests and fundamental rights do not override those interests.
  • Where we need to comply with a legal or regulatory obligation.
  • Where you consent to us using your data.

Generally, we do not rely on consent as a legal basis for processing your personal data other than in relation to sending our and third party direct marketing communications to you via email or text message, and when sending your information to third party service providers and recording telephone calls between you and us. You have the right to withdraw consent to marketing at any time by Contacting us.

PURPOSES FOR WHICH WE WILL USE YOUR PERSONAL DATA  

We have set out below 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 (b) Contact (c) Personal (d) Financial (e) Phone Call    Performance of a contract with you Consent  
To process and deliver your services including: (a) Manage payments, fees and charges (b) Arrange bookings and payments with third parties  (a) Identity (b) Contact (c) Transaction (d) Financial (e) Personal (f) Phone CallPerformance of a contract with you Necessary for our legitimate interests (to recover debts due to us) Consent  
To manage our relationship with you which will include: (a) Notifying you about changes to our terms or privacy policy  (a) Identity (b) Contact  (c) Phone Call (d) Financial Data  Performance of a contract with you Necessary for our legitimate interests (to keep our records updated and to study how customers use our products/services)  
Asking you to leave a review, take a survey, or updating or keeping you informed about our or our partners’ products and services(a) Marketing and Communications  Consent
To run, administer and protect our business  (a) Identity (b) Contact  (a) Necessary for our legitimate interests (for running our business and provision of administration.) (b) Necessary to comply with a legal obligation  
To use data analytics to improve our services, marketing, customer relationships and experiences   (a) Usage  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)
TrainingIdentityContactPersonalPhone CallsRecording phone calls between you and us for training and monitoring purposes.

MARKETING  

We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising. If you do not want to receive communications from us, please contact us or you can unsubscribe at any time with the link included in every email we send.

PROMOTIONAL OFFERS FROM US  

We may use your Identity, Contact, 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 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 or purchased services from us or if you provided us with your details or registered for a promotion and, in each case, you have opted in for receiving that marketing.

THIRD-PARTY MARKETING  

We will get your express opt-in consent before we share your personal data with any company outside the Demapal Ltd group of companies for marketing purposes and for the purposes of performance of our contract with you.

OPTING OUT  

You can ask us or third parties to stop sending you marketing messages at any time by Contacting us at any time.

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 get 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.

5.  DISCLOSURES OF YOUR PERSONAL DATA  

We may have to share your personal data with the parties set out below for the purposes set out in paragraph 4 above.

  • Internal Third Parties as set out in the Glossary.
  • External Third Parties as set out in the Glossary.

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.

6.  INTERNATIONAL TRANSFERS  

We do not transfer your personal data outside the European Economic Area (EEA).

7.  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.

8.  DATA RETENTION  

HOW LONG WILL YOU USE MY PERSONAL DATA FOR?  

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 legal purposes.

In some circumstances you can ask us to delete your data.

In some circumstances we may 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.

9.  YOUR LEGAL RIGHTS  

Under certain circumstances, you have rights under data protection laws in relation to your personal data. In particular, you have the right to:

  • Request access to your personal data.
  • Request correction of your personal data.
  • Request erasure of your personal data.
  • Object to processing of your personal data.
  • Request restriction of processing your personal data.
  • Request transfer of your personal data.
  • Right to withdraw consent.

Please, refer to our Glossary for more information.

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

10.  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.

Comply with a legal or regulatory obligation means processing your personal data where it is necessary for compliance with a legal or regulatory obligation that we are subject to.

THIRD PARTIES  

INTERNAL THIRD PARTIES  

Other companies in the Demapal Ltd acting as joint controllers.

EXTERNAL THIRD PARTIES  

  • Professional advisers acting as processors including bankers, solicitors, auditors and insurers based in the United Kingdom who provide banking, accounting, consultancy and insurance services.
  • HM Revenue & Customs, regulators and other authorities acting as processors based in the United Kingdom who require reporting of processing activities in certain circumstances.
  • Service providers, such as Xero, GoCardless, acting as processors who provide IT and system administration services.
  • Any third party which provides services in area you instructed us to find services in.

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, the further retention of the personal data should be lawful where it is necessary, for exercising the right of freedom of expression and information, for compliance with a legal obligation, for the performance of a task carried out in the public interest or in the exercise of official authority vested in the controller, on the grounds of public interest in the area of public health, for archiving purposes in the public interest, scientific or historical research purposes or statistical purposes, or for the establishment, exercise or defence of legal claims. 

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: (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.

    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.