Privacy Policy - TrustQuay

Who we are: We are TrustQuay Limited registered in England and Wales under number 12003494 with registered office Sentinel House, Harvest Crescent, Fleet, England, GU51 2UZ (“TrustQuay”). TrustQuay Group (“TrustQuay Group”) comprises TrustQuay and its directly and indirectly controlled subsidiary companies.

About Our Privacy Notice: Our Privacy Notice (our “Privacy Notice”) describes our collection, use, disclosure, retention and protection of your personal information. Our Privacy Notice applies to any website, application or service which references it and to all applications and services offered by TrustQuay that do not have a separate privacy notice for which we are responsible for controlling or processing personal data.

Data Controller/ Data Processors: TrustQuay is the Data Controller within TrustQuay Group. When handling personal data, TrustQuay subsidiary companies act as a Data Processor to Trustquay or to a Data Controller outside of TrustQuay Group.

Your agreement to use your personal data: Where you provide us with your personal information in any of the ways described below, you agree that we may collect, store and use it: (a) in order to perform our contractual obligations to you; (b) based on our legitimate interests for processing (such as for internal administrative purposes, data analytics and benchmarking, direct marketing, maintaining automated back-up systems or for the detection or prevention of crime); or (c) based on your consent, which you may withdraw at any time, as described in Our Privacy Notice.

What types of data do we collect: We may collect, store and use the following types of data depending on the activity being undertaken:

Activity/ person	Type of personal data we typically collect, store and use
Customers of our applications and services.	General Data, Preference Data, Business Data
Users of our applications and services.	Cookie Data, Device Data, General Data, Preference Data, Business Data
Completing online surveys, download information such as our publications, participate in interactive areas on our websites.	Cookie Data, Device Data, General Data, Preference Data, Business Data
Opt-in mailing lists, technical updates, event invitations etc	General Data, Preference Data, Business Data
Contacting us offline by telephone, email, post etc	General Data, Business Data
Analysis of website usage, marketing and business performance	Anonymised Data
Browsing our websites.	Cookie Data, Device Data.
Interacting with us using social media.	Cookie Data, Device Data, General Data, Business Data
Our suppliers	General Data, Business Data
Our employees (for our business operations) and people applying to work for us	Cookie Data, Device Data, General Data, Preference Data, Business Data, Anonymised Data, Sensitive Data

The types of data mentioned in the table above may include:

Type of data	Personal data included for the type
Cookie Data	Cookies (see below)
Device Data	Device identification number and type, location information and connection information such as statistics on page views, traffic to and from the sites, referral URL, ad data, IP address, browsing history and web log information.
General Data	Names, addresses, email addresses, telephone number
Preference Data	Preferences you tell us about
Anonymised Data	Information relating to individuals with personally identifying data removed
Business Data	Job titles, place of work, payment details, correspondence and similar data that might identify a person
Sensitive Data	Sensitive personal data relating to confidential, private and medial details

We may enhance personal information we collect from you with information we obtain from third parties that are entitled to share that information; for example, information from sanction lists, credit agencies, search information providers or public sources (e.g. for customer due diligence purposes), but in each case as permitted by applicable laws.

We may monitor and record our communications with you.

Providing us with information about others

If you provide us with personal information about someone else, you are responsible for ensuring that you comply with any obligation and consent obligations under applicable data protection laws in relation to such disclosure. In so far as required by applicable data protection laws, you must ensure that you have provided the required notices and have obtained the individual’s explicit consent to provide us with the information and that you explain to them how we collect, use, disclose and retain their personal information or direct them to read our Privacy Notice.

How we use your information

To the extent permissible under applicable law, we use your information for:

Operational activities:

provide, maintain, protect and improve our services and applications that you purchase and licence from us and manage and administer your use of them;
provide you with any information that we are required to send you to comply with our regulatory or legal obligations;
monitor, measure, improve and protect our content, website, applications and services and provide an enhanced, personal, user experience for you;
detect, prevent, investigate or remediate, crime, illegal or prohibited activities or to otherwise protect our legal rights (including liaison with regulators and law enforcement agencies for these purposes);

Customer relations:

manage our relationship with you (for example, customer services and support activities);
contact you to see if you would like to take part in our customer research (for example, feedback on your use of our applications and services);

Marketing activities:

deliver targeted advertising, marketing (including in-product messaging) or information to you which may be useful to you, based on your use of our applications and services or any other information we have about you;
to monitor, carry out statistical analysis and benchmarking, provided that in such circumstances it is on an aggregated basis;
deliver joint content and services with third parties with whom you have a separate relationship (for example, social media providers);

Employees and job applicants

to carry out all our business operations, such as for payroll and for managing staff;
to carry out background checks to ensure the suitability of people to work in our business such as criminal record checks and obtaining references;

Your right to object

You have the right to object to processing based on our legitimate interests, and if you wish to do so, please contact us (see below) to discuss this further. If you object, this may affect our ability to provide certain services and/or solutions for your benefit.

Sharing your information

For the purposes set out in Our Privacy Notice we may share your information with:

any company within the TrustQuay Group;
our service providers and agents (including their sub-contractors) or third parties which process information on our behalf so that they may help us to provide you with the applications, services and information you have requested or which we believe is of interest to you;
third parties to comply with our regulatory or legal obligations such as auditors, professional advisors, government departments, regulators, law enforcement agencies so that they may detect or prevent crime or prosecute offenders, any third party in the context of actual or threatened legal proceedings, provided we can do so lawfully (for example in response to a court order)
third parties where you have a relationship with that third party and you have consented to us sending information;
third parties for marketing purposes where you have consented or where there is a legitimate business interest;
another organisation if we sell or buy (or negotiate to sell or buy) any business or assets; and
another organisation to whom we may transfer our agreement with you.

We may share non-personally identifiable information about the use of our website, applications or services publicly or with third parties but this will not include information that can be used to identify you.

Marketing

From time to time, we may use your information to contact you with details about our applications and services which we feel may be of interest to you. We may also share your information with our group companies and our contracted third parties with whom we have data processing terms to carry out services for us on a subcontracted basis. We or they may wish to contact you for this purpose by telephone, post, SMS or email. You have the right at any time to stop us from contacting you for marketing purposes. You may also request at any time that we do not share your information with third parties referred to in this paragraph. If you wish to exercise these rights you can do so by selecting your contact preferences at the point where you provide us with your information on our websites, applications or services, using any preference centres we give you access to or by sending us an email to privacy@trustquay.com. You can also unsubscribe from any email marketing using the links provided in the emails we send to you.

Your information and your rights

If you are based within the EU or within another jurisdiction having similar data protection laws, in certain circumstances you have the following rights:

the right to be told how we use your information and obtain access to your information;
the right to have your information rectified or erased or place restrictions on processing your information;
the right to object to the processing of your information e.g. for direct marketing purposes or where the processing is based on our legitimate interests;
the right to have any information you provided to us on an automated basis returned to you in a structured, commonly used and machine-readable format, or sent directly to another company, where technically feasible (“data portability”);
where the processing of your information is based on your consent, the right to withdraw that consent subject to legal or contractual restrictions;
the right to object to any decisions based on the automated processing of your personal data, including profiling; and
the right to lodge a complaint with the supervisory authority responsible for data protection matters (e.g. in the UK, the Information Commissioner’s Office).

If we hold any information about you which is incorrect or if there are any changes to your details, please let us know so that we can keep our records accurate and up to date.

If you withdraw your consent to the use of your personal information for purposes set out in our Privacy Notice, we may not be able to provide you with access to all or parts of our website, applications, and services.

Changes to Our Privacy Notice

We may change Our Privacy Notice from time to time by updating it on our website.

Security and storage of information

We will retain your personal information for the duration of our business relationship and afterwards for as long as is necessary and relevant for our legitimate business purposes as permitted by applicable laws and regulations. Where we no longer need your personal information, we will dispose of it in a secure manner (without further notice to you).

We will keep your information secure by taking appropriate technical and organisational measures against its unauthorised or unlawful processing and against its accidental loss, destruction or damage. We will do our best to protect your personal information but we cannot guarantee the security of your information which is transmitted to our website, applications or services or to other website, applications and services via an internet or similar connection.

Transfers outside of the European Union

Personal information in the European Union is protected by data protection laws but other countries do not necessarily protect your personal information in the same way.

We may use service providers based outside of the EU to help us provide our website, marketing, applications and services to you and may transfer your information to them for the purposes in Our Privacy Notice. We endeavour to ensure that where your information is transferred outside of the EU by our service providers and hosting providers, appropriate measures and controls in place to protect that information in accordance with applicable data protection laws and regulations.

By using our website, applications or services or by interacting with us in the ways described in Our Privacy Notice, you consent to the transfer of your information outside the EU where needed for the purposes set out in Our Privacy Notice.

Other sites and social media

If you follow a link from our website, application or service to another site or service, Our Privacy Notice will no longer apply. We are not responsible for the information handling practices of third-party sites or services.

Cookies, Analytics and Traffic Data

We use cookies to help us provide you with a personalised service, and to help make our websites, applications and services better for you. Our cookies may be:

Necessary cookies: needed for our websites, applications or services to function properly.

Performance cookies: These collect information about how visitors and users use our websites, applications and services. We only use these cookies to improve how our website, applications and services work.

Functionality cookies: These allow our websites, applications and services to remember choices you make and provide enhanced, more personal features.

Targeting or advertising cookies: These cookies are used to deliver adverts more relevant to you and your interests. They remember that you have visited a website and this information may be shared with other organisations such as advertisers.

Web tracking: We use these cookies to count users who have visited our website after clicking through from one of our advertisements on another website or in emails and to collect details of the users activity.

IP Address and traffic data: We keep a record of traffic data which is logged automatically by our servers, such as your Internet Protocol (IP) address, device information, the website that you visited before ours and the website you visit after leaving our site. We also collect some site, application and service statistics such as access rates, page hits and page views. We are not able to identify any individual from traffic data or site statistics.

Google analytics: Google Analytics uses “cookies”, to help the website analyse how users use the websites, applications or services. To find out more, see on google.com “How Google uses data when you use our partners’ sites or apps”. To opt out of being tracked by Google Analytics across all websites visit: http://tools.google.com/dlpage/gaoptout.

Other cookies: We use cookies from third party websites through whom we conduct our marketing and advertising such as Linkedin and Hubspot.

How to disable cookies

You may be able to configure your browser or our website, application or service to restrict cookies or block all cookies but you may find this affects your ability to use certain parts of our website, applications or services.

Further information and contacting us

If you have any queries about how we treat your information, the contents of Our Privacy Notice, your rights, how to update your records or how to obtain a copy of the information that we hold about you, please email privacy@trustquay.com or write to Company Secretary, TrustQuay Limited, Sentinel House, Harvest Crescent, Ancells Business Park, Fleet, GU51 2UZ.

May 2020