Personal Information is information about you that is personally identifiable to you, like your name, address, email address, phone number or financial and credit card information, as well as other non-public information that is associated with you.
We do not sell, trade, or rent your personal information to others for marketing purposes.
We may process your Personal information in the country where it was collected, as well as other countries where laws regarding processing of Personal Information may be less stringent than the laws in your country.
For the purpose of the Data Protection Act 1998, the General Data Protection Regulations 2016, and any and all other applicable laws and regulations relating to the processing of personal data and privacy (the Data Protection Legislation), we act as the data controller and data processor. For clarity:
- a controller determines the purposes and means of processing personal data;
- a processor is responsible for processing personal data on behalf of a controller.
Notification of changes
This policy is effective from the 25th May 2018.
Information we collect
We may collect and process the following data about you:
Information you give us
You may give us information about you by filling in forms on our site or by corresponding with us by phone, e-mail or otherwise.
The information you give us may include your name, address, email address, phone number or financial and credit card information.
We may also collect information from third parties (such as credit reference or fraud prevention agencies, joint account holders, your employees or officers of your business, other organisations who introduced us, or act on your behalf) which, where you are a sole trader or partnership, may relate to you and or your business partners and guarantors and where you are a limited company or limited liability partnership, may relate to your officers, shareholders, partners, owners or guarantors.
If you give us information on behalf of someone else, you confirm that you have given them the information set out in this notice and that they have given permission for us to use their information as set out in this notice.
Information we collect about you>
If you contact us electronically we may collect your electronic identifier, e.g. Internet Protocol (IP) address or phone number supplied by your service provider. We may also collect your geographical location, browser type, referral source, length of visit and number of page views.
Information we receive from other sources
We may receive information about you if you use any of the other websites we operate or the other services we provide.
We are also working closely with third parties (including, for example, business partners, acquirers and payment gateways) and may receive information about you from them.
Personal and non-personal information
Personal information is information that can be used to uniquely identify a single person. We also collect non-personal information or may anonymise personal information in order to make it non-personal.
You agree that LibertyPay may collect, store, use, transfer and disclose non-personal information for any purpose. Under this notice, information collected by cookies and similar technologies are dealt with as non-personal information.
We use Google Analytics to analyse the use of this website utilising both session cookies and persistent cookies.
We use your information for the following purposes
Where it is necessary to use your information in order to provide our services to you and to respond to any queries or complaints.
To conduct anti-money laundering checks and fulfil our regulatory obligations in connection with the services.
To comply with legal requirements and Card Scheme Rules.
Legal obligation, contractual necessity and legitimate interests
To carry out credit checks and other enquiries to help us make decisions about whether to enter into a contract with you and to evaluate our ongoing relationship with you.
For the prevention, investigation and detection of crime & fraud and for security reasons.
To analyse and improve the running of our business, including contacting you for market research purposes.
To keep you informed about changes to your service e.g. notification of price changes, changes in the way we provide our services and any other legal or regulatory information.
To provide you with information, products or services that you request from us or which we feel may interest you, where you have expressly consented (new customers) or have not unsubscribed from our previous communications (existing customers before 25th May 2018) to be contacted for such purposes. You may unsubscribe at any time from receiving further communications from us for such purposes.
For analytical purposes and we may share this aggregated information with others from time to time. This means use of records of transactions in combination with the records of our customers in an aggregated form.
Uses made of the information
- 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.
- third parties may deliver some of our products to you or provide all or part of the service requested by you. In these instances, whilst the information you provide will be disclosed to them, it will only be used for the administration of the service provided, for pricing purposes, testing and to maintain management information for business analysis;
- to notify you about changes to our service;
- we make outbound phone calls for a number of reasons relating to many of our products and are fully committed to comply with regulations as set out by Ofcom;
- our own security procedures mean that we may occasionally have to request proof of identity or check your presence on the electoral roll;
- in the event of phone calls from you, we also reserve the right to ask security questions (which we in our sole discretion deem appropriate) in order to satisfy ourselves with regard to your identity;
- to improve our site and ensure that content from our site is presented in the most effective manner for you and for your computer; and
- to keep our site safe and secure;
We may combine the information we receive from other sources with information you give to us and information we collect about you. We may use this information and the combined information for the purposes set out above.
E-Newsletters and promotional email
We may use a third-party provider to deliver our periodic e-newsletters and other promotional communications. We gather statistics around email opening and clicks using industry standard technologies.
Disclosure of your information
We may share your personal information with:
- any member of our group, which means any subsidiaries, our ultimate holding company and its subsidiaries, as defined in section 1159 of the UK Companies Act 2006;
- business partners, suppliers and sub-contractors for the performance of any contract we enter into with them or you;
- analytics and search engine providers that assist us in the improvement and optimisation of our site, although ordinarily only non-personal information is shared;
- credit reference agencies for the purpose of assessing your credit score where this is a condition of us entering into a contract with you;
- in the event that we sell or buy any business or assets, in which case we may disclose your personal information to the prospective seller or buyer of such business or assets;
- if LibertyPay or substantially all of its assets are acquired by a third party, in which case personal information held by it about its customers will be one of the transferred assets;
Where we store your personal data
Where we have given you (or where you have chosen) a password or access code which enables you to access certain parts of our site, you are responsible for keeping this password confidential. We ask you not to share a password with anyone, and you authorise LibertyPay to act upon instructions and information from any person that enters your user id or password.
Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted to our site; any transmission is at your own risk.
Once we have received your information, we will use strict procedures and security features to try to prevent unauthorised access.
How long we keep your information
We will keep your information for as long as we have a contract with you and for as long as we need your information for regulatory or evidential purposes for up to 6 years after expiry of termination of your contract.
Individuals have the following rights under data protection legislation:
- a right to ask for a copy of their personal data;
- a right to ask us to delete or correct any information we hold about them that is inaccurate;
- a right to request erasure of information in certain circumstances;
- a right to data portability;
- a right to restrict processing and a right to object to processing activities in certain circumstances;
- a right to stop your information from being used for direct marketing purposes; and;
- a right to lodge a complaint with the Data Protection Commissioner (or other supervisory authority in the European Union) if you believe that your information has not been processed in accordance with the requirements of the data protection legislation.
Where any processing is based on consent you have a right to withdraw consent at any time, without affecting the lawfulness of processing based on consent before its withdrawal.
You can request any amendments or rectifications to your data by contacting us and to notify us if you would like us to delete or erase your data or, in certain circumstances, if you would like us to restrict the way in which we process your data.
Please note that, in certain circumstances, we may not be able to delete or erase your personal data such as where this is still required for the purpose for which it was provided or where we have overriding legitimate interests in retaining your data.
You can exercise your right to prevent such processing by checking certain boxes on the forms we use to collect your data or by clicking the unsubscribe link on any marketing communications we send to you by email or by updating your preferences in the client portal.
Our website may, from time to time, contain links to and from the websites of our partner networks, advertisers and affiliates. If you follow a link to any of these websites, please note that these websites have their own privacy policies and that we do not accept any responsibility or liability for these policies. Please check these policies before you submit any personal data to these websites.
If you are unhappy with the way in which we have collected or processed your data or have any other complaint in relation to our handling of your data you can make a complaint to the information Commissioner, further information can be found on the information Commissioner’s website at www.ico.org.uk or via their helpline on 0303 123 1113.
Changes to our privacy notice
This Policy and any dispute or claim arising out of it or in connection with it or its subject matter shall be governed by and construed in accordance with the laws of England and Wales and the parties irrevocably agree that the courts of England have exclusive jurisdiction to settle any dispute or claim arising out of or in connection with this policy or its subject matter.
All comments, queries and requests relating to our use of your information are welcomed.
If you wish to exercise any of your rights or receive further information about this policy, you should write to the address below marked for the attention of Legal.
LibertyPay Limited, Studio 6, Capability House, Wrest Park, Silsoe, Bedfordshire, MK45 4HS.
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Unless otherwise specified, no part of this publication may be reproduced or utilised in any form or by any means, electronic or mechanical, including photocopying and microfilm, without permission in writing from LibertyPay or subsidiary organisations.
The information contained in this website is for general information purposes only.
The information is provided by LibertyPay and while we endeavour to keep the information up to date and correct, we make no representations or warranties of any kind, express or implied, about the completeness, accuracy, reliability, suitability or availability with respect to the website or the information, products, services, or related graphics contained on the website for any purpose. Any reliance that you place on any such information is therefore strictly at your own risk.
In no event will we be liable for any loss or damage including without limitation, indirect or consequential loss or damage, or any loss or damage whatsoever arising from loss of data or profits arising out of, or in connection with, the use of this or any of our other websites and associated services.
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