How we use your personal information
We use personal information in order to promote and provide our services, to ensure the security of our infrastructure and content, and to run our business. We have set out below more information on:
- the categories of personal information that we collect;
- the specific ways in which that personal information is processed by us;
- the legal bases which permit us to do this;
- the types of partners with whom we share your personal information; and
- your rights with respect to your personal data.
In some cases where we ask for your personal information, we do so in order to provide our services and will only collect and process any such personal information for the purposes which it is collected for and any other compatible purposes. If you do not provide that personal information, we may not be able to process your personal data where it is required for the purpose of providing our services or any other purpose communicated to you.
What personal information do we collect?
We collect and process different personal information and personal sensitive information according to the context in which you interact with us. This information includes:
Type of interaction
Personal information collected
Registered users of the Foliio platform
Name; telephone number; email address; logs of usage of the Foliio platform (including content uploaded and accessed, and interactions with other users); records of participation in any promotional campaigns; your marketing preferences, including any consents you may have given us.
Individuals on our marketing database who aren’t registered users of the Foliio platform
Name; email address; records of participation in our promotional campaigns; your marketing preferences, including any consents you may have given us.
All users of our website and online digital resources
We may process data about your use of our website and services which we obtain through our analytics tracking systems such as your IP address; geographical location; browser type and version; operating system; referral source; length of visit; page views and website navigation paths; and information about the timing, frequency and pattern of your service use. We may also process your name and contact details if you provide them to us through any forms on our website.
We collect this information when you provide it to us directly, or from your interaction with our services.
We endeavour to minimize the amount of personal data that we collect from you, and we keep the data anonymized wherever possible.
How do we use your information?
We use your information as follows:
- To fulfil our contracts with you:
- providing you with access to our online platform;
- providing information and technical support if you ask for this;
- contacting you with information about changes to our services;
- processing payments for our services and fraud prevention.
- As required by us to conduct our business and pursue our legitimate interests, in particular:
- contacting you with regard to anything in connection with our platform;
- letting you know about our services by post, email, and phone in accordance with your marketing preferences and law relating to direct marketing;
- analysing how you use our services so we can improve our levels of service and develop future products and services, including through the use of surveys;
- ensuring the security of our website and information technology systems and protecting our rights.
– Where you have provided your consent:
- if we need your consent in order to send marketing or otherwise provide our services to you; and/or;
- to place cookies on your device(s) and use similar technologies.
– For purposes which are required by law:
- we may share your personal information in order to comply with legal obligations to which we are subject.
- Other purposes:
- in order to protect your vital interests or those of another individual; and/or
- for the purposes of record-keeping and hosting, back-up and restoration of our systems.
How will we share your information?
We share your personal details:
- with people within our organisation who are involved in carrying out the processing described above;
- with third party service providers who process your information on our behalf for the purposes above – such as IT hosting providers, payment service providers, data analytics specialists and other professionals retained by us.
We will also share your personal information:
- if we think this is necessary to in order to protect the rights, property, or safety of our business, our employees, our partners, or our customers. This includes sharing information for the purposes of fraud protection and credit risk reduction;
- third parties to whom we may choose to sell, transfer, or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal information in the same way as set out in this policy; and/or
- with government authorities and/or law enforcement officials if required by law.
We require all third parties to respect the security of your personal information and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal information for their own purposes and only permit them to process your personal information for specified purposes and in accordance with our instructions.
Giving and withdrawing your consent and updating your personal information
Where your consent is required for us to process your personal information, we will ask for your consent at the point at which you provide your data. You have the right to withdraw that consent at any time. You can also update your personal information at any time. If you wish to do either, contact us at firstname.lastname@example.org.
Storing your personal information; transfers outside the United Kingdom and data retention
We may use our secure servers to store your personal data. We take appropriate physical, electronic and procedural measures to ensure that we keep your information secure, accurate and up to date in accordance with this policy.
Your personal information may be stored and processed outside of the country where it is collected, including outside of the United Kingdom or the European Economic Area (EEA). When transferring information to others, we ensure that appropriate and suitable safeguards and technical measures are in place to protect your personal data. To do this, we may make use of standard contractual clauses that have been approved by the European Commission, or we implement other similar measures required by laws around the world.
We will only keep records of your personal information for as long as is reasonably necessary for the purposes for which we have collected it, and in order to comply with any statutory or regulatory obligations in relation to retention of records. We aim to keep personal information for no more than 12 months unless reasonably required.
We may retain your personal data longer:
- to comply with law;
- to protect your vital interests or those of another individual; or
- in connection with any legal claims (to the extent those claims are continuing after the end of the relevant retention period).
We may create anonymised or aggregated records relating to demographics or the use of our website or services, from which no individual is identifiable. We may retain those records, which are not personal data, indefinitely, and use them for our own business purposes without restriction.
We respect requests to stop processing your personal data for marketing purposes. This includes keeping a record of your request indefinitely so that we can respect your request in future.
Personal data relating to someone else
Prior to providing to us any personal information concerning another individual, you must (unless we agree otherwise):
- obtain their permission (where possible) to share their personal information with us in accordance with this policy.
You have the right to request access to and rectification or erasure of personal information, the right to restrict processing of your personal information, and the right to object to processing of your personal information. You have the right to object to your personal information being processed on the grounds of our legitimate interests. You have the right to object to us sending you direct marketing and profiling you for the purposes of direct marketing.
If you have a complaint or concern about how we use your personal information, please contact us in the first instance and we will attempt to resolve the issue as soon as possible. You have the right to lodge a complaint regarding our processing of your personal information with a data protection supervisory authority in a country where you live, work, or where you believe a breach may have occurred. In the United Kingdom, that is the Information Commissioner’s Office (www.ico.org.uk).
The data controller for our website and services is Foliio Ltd of 7b Florence Road, London, England, N4 4BU. We can be reached by email at email@example.com.