We are Financial Inclusion Forum Ltd, a company incorporated in England and Wales. Our company number is 07476278 and our registered office is at Well Court C/O Knox Cropper, Well Court, London, England EC4M 9DN (“FIF” / “we”/ “our” / “us”). We are committed to ensuring that your privacy is protected. We will continue to comply with the provisions of the Data Protection Act (“DPA”) until midnight at the start of 25 May 2018, after which we will comply with the General Data Protection Regulation ((EU) 2016/679) (“GDPR”) unless and until the GDPR is no longer directly applicable in the UK, together with any national implementing laws, regulations and secondary legislation as amended or updated from time to time in the UK, and any successor legislation to the GDPR and the DPA (together “Data Protection Legislation”). We are the data controller of data you pass to us pursuant to this policy.
- What information do we hold and how will we use it?
- We may collect and process the following data about you:
- Information you give us: You may give us information about you by completing enquiry forms on the Website or by corresponding with us by phone, email or otherwise. The information you give us may include your name, email address, address / location and phone number. We will retain this information while we are corresponding with you or fulfilling an order you have placed with us or until you unsubscribe from communications we send to you.
- Information we collect about you: We may collect the following information from you when you visit our Website:
- technical information, including the Internet protocol (IP) address used to connect your computer to the Internet, your login information, browser type and version, time zone setting, browser plug in types and versions, operating system and platform; and
- information about your visit, including the full Uniform Resource Locators (URL), clickstream to, through and from the Site (including date and time), products you viewed or searched for, page response times, Website errors, length of visits to certain pages, page interaction information, methods used to browse away from the page and any phone number used to call our customer services number.
We collect this information via Google Analytics which will retain the information for 26 months from the date it is collected.
- Use made of the information
- Provided that we have obtained your consent to the extent we are required to under the Data Protection Legislation, we may use the information we receive and/or collect about you to:
- fulfil our obligations under any contract we have entered into with you and to provide you with information, products and services you have requested;
- send you newsletters and marketing information if you have consented to us doing so or if there are other grounds in GDPR which mean we are entitled to send marketing communications to you;
- notify you of other products and services we feel may interest you, or permit third parties to do so if you have consented to us doing so;
- notify you of changes to our services and products; and
- monitor Website usage and provide statistics to third parties for the purposes of improving and developing the Website and the services we provide via the Website.
- We collect and process much of your personal information on the grounds of legitimate interests, which include some or all of the following:
- where the processing enables us to enhance, modify, personalise or otherwise improve the Website, our services and communications for the benefit of our customers;
- to enhance the security of our network and information systems;
- to better understand how people interact with our websites;
- administer the Website and carry out data analysis, troubleshooting and testing; and
- to determine the effectiveness of promotional campaigns and advertising.
- If we require your personal data to provide services you have requested, we may be unable to fulfil the contract without your personal data.
- If we are unable to rely on legitimate interests or any other ground set out in the GDPR to process your personal data, we will obtain consent from you to the processing.
- If we obtain consent from you to do so, we may provide your personal details to third parties so that they can contact you directly in respect of services and/or products in which you may be interested.
- We will not share, sell or distribute any of the information you provide to us (other than as set out in this policy) without your prior consent, unless required to do so by law.
- Third Party Sites
- How safe is your information?
- Protecting your security and privacy is important to us and we make every effort to secure your information and maintain your confidentiality in accordance with the terms of the Data Protection Legislation. The Website is protected by various levels of security technology, which are designed to protect your information from any unauthorised or unlawful access, processing, accidental loss, destruction and damage.
- We will do our best to protect your personal data but the transmission of information via the Internet is not completely secure. Any such transmission is therefore at your own risk.
- Disclosure of your information
- Please note that we may need to disclose your personal information where we:
- sell any or all of our business or assets or we buy another business or assets in which case we may disclose your personal data to the prospective buyer or seller;
- are under a legal duty to comply with any legal obligation or in order to enforce or apply our terms and conditions; or
- need to disclose it to protect our rights, property or safety of our customers or others, including the exchange of information with other companies, organisations and/or governmental bodies for the purposes of fraud protection and credit risk reduction.
- [Where we store your personal data
- Your rights in respect of your data
- There are a number of rights available to you under GDPR:
- Access to your information
We will provide the information you request as soon as possible and in any event within one month of receiving your request, unless there are extenuating circumstances. If we need more information to comply with your request, we’ll let you know.
- Rectification of your data
We will comply with your request within one month of receiving it, unless we don’t feel it’s appropriate for us to do so in which case we’ll let you know why. We’ll also let you know if we need more time to comply with your request.
In some circumstances, you have the right to ask us to delete personal data we hold about you. This right is available to you:
- where we no longer need your personal data for the purpose for which we collected it;
- where we have collected your personal data on the grounds of consent and you withdraw that consent;
- where you object to the processing and we don’t have any overriding legitimate interests to continuing processing the data;
- where we have unlawfully processed your personal data (i.e. we have failed to comply with GDPR);
- where the personal data has to be deleted to comply with a legal obligation; and
- where the personal data we process relates to the offer of online services to a child.
There are certain scenarios in which we are entitled to refuse to comply with a request. If any of those apply, we’ll let you know
- Right to restrict / object to processing
In some circumstances you are entitled to ask us to suppress processing of your personal data. This means we will stop actively processing your personal data but we don’t have to delete it. This right is available to you:
- if you believe the personal data we hold isn’t accurate – we’ll cease processing it until we can verify its accuracy;
- if you have objected to us processing the data (see below) – we’ll cease processing it until we have determined whether our legitimate interests override your objection;
- if the processing is unlawful; or
- if we no longer need the data but you would like us to keep it because you need it to establish, exercise or defend a legal claim.
You are entitled to object to us processing your personal data:
- if the processing is based on legitimate interests or performance of a task in the public interest or exercise of official authority;
- for direct marketing purposes (including profiling); and/or
- for the purposes of scientific or historical research and statistics.
In order to object, you must have grounds for doing so based on your particular situation. We will stop processing your data unless we can demonstrate that there are compelling legitimate grounds which override your interests, rights and freedoms or the processing is for the establishment, exercise or defence of legal claims.
You have the right to ask us to provide your personal data in a structured, commonly used and machine-readable format so that you are able to transmit the personal data to another data controller. This right only applies:
- to personal data you provide to us;
- where processing is based on your consent or for performance of a contract (i.e. the right does not apply if we process your personal data on the grounds of legitimate interests); and
- where we carry out the processing by automated means.
We’ll respond to your request as soon as possible and in any event within one month from the date we receive it. If we need more time, we’ll let you know.
- If you have any complaints about our use of your personal data, please contact us. You are also entitled to report any concerns which you may have to supervisory authority in your jurisdiction. The supervisory authority in the UK is the Information Commissioner’s Office. You can call the ICO on 0303 123 1113 or get in touch via other means as set out on the ICO website at https://ico.org.uk/concerns/.