This Policy applies, to the User of this Web Site and WireBoon the owner and provider of this Web Site. This Policy covers our use of any and all Data collected by us in relation to your use of the Web Site and any Services or Systems therein.
1.1 Our website is not intended for under 18 and we do not knowingly collect data relating to children.
1.2 This Privacy Policy supplements the other policies (including our terms of use (Terms)) and is not intended to override them.
1.3 WireBoon is the controller and responsible for your personal data (we, us or our).
1.4 To assist you further in understanding this Privacy Policy, we have set out in Part 5 of Schedule 1 a glossary of terms used, examples of types of personal data we collect, how we use it, the lawful basis for processing such data and further details of your rights.
1.5 We have appointed a data privacy manager (DPM). If you have any questions about this Privacy Policy, including any requests to exercise your legal rights, please contact our DPM in writing, either:
1.6 By email to: [info@WireBoon.com] write to Address 200, Brook Drive, RG2 6UB, Reading UK
2.1 We may collect, use, store and transfer the types of personal data about you listed in Part 1 of Schedule 1.
2.2 We also collect, use and share aggregated data. However, if we combine aggregated data with your personal data so that it can directly or indirectly identify you, we treat this as your personal data.
2.3 We do not collect any special categories of personal data [or any information about criminal convictions and offences].
2.4 If we are required by law, or under the terms of a contract we have with you, to collect your personal data and you fail to provide it, we may not be able to enter into perform the contract with you and, we may have to cancel a product or service. We will notify you of this at the relevant time.
We collect personal data in the following ways:
| direct interactions | You must provide personal data when you complete online registration forms, request products/services, subscribe to our services, create a user account, or otherwise or correspond with us (by post, phone or email) |
| automated technology | we automatically collect personal data (technical and usage) when you browse or interact with our website, by using cookies, and other similar technologies. We may also receive technical data about you if you visit other websites which use our cookies. |
| publicly available sources | We may collect personal data from publicly availably sources as Companies House and the Electoral Register and credit reference agencies, based inside the UK when need be |
| third parties | In connection with identify verification, fraud prevention and similar security purposes, we collect and/or confirm certain identity-related information, financial background and similar information through third parties sources such as our business customers, government agencies and consumer reporting agencies |
4.1 We will only use your personal data when the law allows us to. Most commonly, we will use your personal data:
4.2 To perform the contract or Service we are to enter into or have entered into with you;
4.3 To comply with a legal obligation; and
4.4 Where it is necessary to carry out our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
4.5 Part 2 of Schedule 1 sets out the lawful basis we will rely on to process your personal data.
4.6 We do generally only rely on consent as a legal basis for processing your personal data to send email and SMS marketing communications and you have the right to withdraw your consent at any time by contacting us. Please 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 information.
4.7 We may analyse your personal data to form a view on what products and or services we think may be of interest to you. You will only receive marketing communications from us, if you have requested information from us or purchased services from us, if you consent to marketing at the time we collect your personal data and you have not subsequently opted out or withdrawn your consent or if we have another basis to send you the marketing communications.
4.8 [We will get your express opt-in consent before we share your personal data with any third party for marketing purposes.] [We will not share your personal data with third parties for their marketing purposes.
4.9 You can opt out of email marketing by clicking the unsubscribe button within the marketing email. You can also withdraw your consent to marketing at any time by contacting our DPM.
4.10 Even if you opt out of receiving marketing, we may still use your personal data for other purposes provided we have a lawful basis to do so.
4.11 We will only use your personal data for the purpose that we originally collected it for, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose.
4.12 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 use your personal data in this manner.
4.13 We may process your personal data (without your knowledge or consent) where this is required or permitted by law.
5.1 We may have to share your personal data with third parties further details of which are set out in Part 4 of Schedule 1. 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. They can only process your personal data for specified purposes and in accordance with our instructions.
6.1 [We do not transfer your personal data outside the European Economic Area (EEA).]
6.2 [Whenever we transfer your personal data out of the EEA, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:
6.3 We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data by the European Commission.
6.4 We use specific contracts approved by the European Commission which give personal data the same protection it has in Europe with our services providers;
6.5 We may transfer data to US based service providers under the Privacy Shield which requires them to provide similar protection to personal data shared between the Europe and the US.]
6.6 Please contact us if you want further information on the specific mechanism used by us when transferring your personal data.
7.1 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. We also limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know and they can only process your personal data on our instructions and will be subject to a duty of confidentiality.
7.2 We have procedures in place 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.
8.1 We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.
8.2 Details of retention periods for different aspects of your personal data are available in our retention policy which you can request from us. However, we are legally required 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.
8.3 We may also anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes. We can use anonymised information indefinitely without further notice to you.
9.1 You have certain rights in certain circumstances under data protection law. These are set out in full in Part 3 of Schedule 1. If you wish to exercise any of your rights, please contact our DPM.
9.2 You will not have to pay a fee to exercise any of your rights. However, if your request is clearly unfounded, repetitive or excessive, we may charge a reasonable fee for this information or refuse to comply with your request.
9.3 We may request specific information from you to help us confirm your identity when you contact us and ensure. This is a security measure to ensure that personal data is not disclosed to any person who does not have the right to receive it.
9.4 We try to respond to all legitimate requests within one month. Occasionally it may 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.
| contact data | billing address, delivery address, email address and telephone number |
| financial data | bank account and payment card details |
| identity data | first name, maiden name, last name, username or similar identifier, [marital status, title, date of birth and gender] |
| marketing and communication data | your preferences in receiving marketing from us [and our third parties and your communication preferences] |
| profile data | your username and password, [purchase or orders made by you,] preferences, feedback [and survey responses] |
| technical data | 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 our website |
| transaction data | [details about payments to and from you and other details of products and services you have purchased from us] |
The lawful basis upon which we may rely on to process your personal data are:
| Consent | you have given your express consent for us to process your personal data for a specific purpose |
| Contract | the processing is necessary for us to perform our contractual obligations with you under our contract, or because you have asked us to take specific steps before entering into a contract with you |
| legal obligation | the processing is necessary for us to comply with legal or regulatory obligation. |
| legitimate interests | the processing is necessary for our or a third party’s legitimate interest e.g. in order for us to provide the best service to you via our website. Before we process your personal data on this basis we make sure we consider and balance any potential impact on you, and we will not use your personal data on this basis where such impact outweighs our interest |