Privacy Notice

Effective date:
2 Dec
,
2024
  1. IMPORTANT INFORMATION AND WHO WE ARE
    1. Privacy notice. This privacy notice (“Privacy Notice”) is provided by Saible Limited (company number 14949907) and where applicable, other companies within our group (collectively referred to as “Saible”, “we”, “our”, or “us”).
    2. Saible takes its responsibilities under applicable privacy laws and regulations seriously and is committed to respecting and protecting your privacy. This Privacy Notice aims to give you information on how we collect and process your personal data online and in connection with our Services and applies to all personal data in our possession or under our control, including personal data in the possession of organisations which we have engaged to collect, use, disclose or process personal data on our behalf. Personal data means any information about an individual from which that person can be identified.
      If you have any questions about this Privacy Notice, including any requests to exercise your legal rights (paragraph 8), please contact us using the information set out in the contact details section (paragraph 1.8).
    3. Scope of application. This Privacy Notice specifically applies to:
      1. individuals who access our website (https://www.saible.co.uk/) and where applicable our mobile application and any other resources made available to you from time to time that are developed or owned by Saible, through which you access and use our services (together our “Platforms”)
      2. individuals who access the services supplied by us from time to time in connection with the facility for digital parallel payments through our Platforms (our “Services”);
      3. individuals with whom Saible has had contact, either for business purposes or otherwise, whether on their own account or on behalf of third parties or organisations;
      4. individuals who have opted to receive communications from Saible; and anyone else who provides personal data to Saible. The Platforms are not intended for children and we do not knowingly collect data relating to children.
    4. Controller. The controller of your personal data will be the relevant company in the Saible group who is responsible for processing your personal data. Saible Limited is the controller responsible for personal data received through our Platforms. Saible Limited is registered with the Information Commissioner’s Office (the “ICO”), the UK regulator for data protection issues, under registration number ZB644698.
    5. Our Head of Compliance shall be responsible for overseeing questions in relation to this Privacy Notice. Please feel free to contact us using the details set out in paragraph 1.8 should you have any queries or wish to exercise your rights.
    6. Acknowledgement. By interacting with us, using our Platforms, or accessing the Services, you acknowledge the practices, requirements, and/or policies outlined in this Privacy Notice. It is important that you read this Privacy Notice together with any other privacy notice or fair processing policy we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. Our Platforms may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our Platforms, we encourage you to read the privacy notice of every website you visit.
    7. Amendments. We keep our Privacy Notice under regular review. We may revise or update this Privacy Notice at any time by posting a revised version on our Platforms. It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.
    8. Contact and Complaints. If you have any questions about this Privacy Notice or our privacy practices, you can contact us in the following ways:
      Full name of legal entity: Saible Limited.
      Email address: dpo@saible.co.uk
      Postal address: 71-75 Shelton Street, London, England, WC2H 9JQ Telephone number: +44 (0) 1218160898
      You have the right to make a complaint at any time to the ICO (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.
  2. TYPES OF PERSONAL DATA WE COLLECT ABOUT YOU
    1. Type of Data Collected. We may collect, use, store and transfer different kinds of personal data (including
      sensitive personal data) including but not limited to:
      1. Identity Data including first name, last name, any previous names, username or similar identifier, title, date of birth and gender.
      2. Contact Data including billing address, email address and telephone numbers.
      3. Financial Data including bank account and sort code numbers.
      4. Transaction Data including details about payments to and from you and other details of Services you have used.
      5. Technical Data including 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, device ID and other technology on the devices you use to access our Platforms. Please see our cookie policy available at: https://saible.co.uk (“our Cookie Policy”) for further details.
      6. Profile Data including your username and password, your previous projects, your interests, preferences, feedback and survey responses.
      7. Usage Data including information about how you interact with and use our Platforms and services.
      8. Marketing and Communications Data including your preferences in receiving marketing from us and our third parties and your communication preferences.
        We also collect, use and share aggregated data such as statistical or demographic data which is not personal data as it does not directly (or indirectly) reveal your identity. For example, we may aggregate individuals' Usage Data to calculate the percentage of users accessing a specific website feature in order to analyse general trends in how users are interacting with our Platforms to help improve the Platforms and our service offering.
    2. Collection of Personal Data. We may collect personal data from you:
      1. when you register for and create an account with Saible on our Platforms;
      2. when you use our Platforms (whether online or offline) and/or Services;
      3. when you contact Saible for business purposes or otherwise, including via email or communication with a Saible;
      4. when you respond to or submit any queries or feedback to Saible, request to be on our mailing list, or submit personal data to us for any other reason;
      5. when you interact with our Platforms and you accept our use of cookies and other similar technologies, we may collect technical information about your equipment, use of our Platforms. Please see our Cookie Policy for further details;
      6. when we need your personal data in order to perform our obligations under a contract that we are about to enter into or have entered into with you;
      7. when we conduct due diligence checks, anti-money laundering checks, fraud monitoring, financial compliance activities and other activities;
      8. when it is necessary for our legitimate interests;
      9. where we need to comply with a legal or regulatory obligation,
      10. from various third parties and public sources as set out below:
        1. Technical Data is collected from the following parties:
          1. analytics providers such as Google Analytics based outside the UK;
          2. advertising networks such as Mailchimp based outside the UK; and
          3. search information providers such as Google Search based outside the UK.
        2. Contact, Financial and Transaction Data is collected from providers of technical, payment and delivery services.
        3. Identity and Contact Data is collected from data brokers or aggregators such as Experian based inside the UK.
        4. Identity and Contact Data is collected from publicly available sources such as Companies House and the Electoral Register based inside the UK.
          Where we need to collect personal data by law, or under the terms of a contract we have with you, and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with the Services). In this case, we may have to cancel the Service you have with us but we will notify you if this is the case at the time.
  3. PERSONAL DATA OF OTHER INDIVIDUALS
    1. Provision of Personal Data of Other Individuals. To the extent that you have provided, or will provide, personal data about directors, shareholders, employees, representatives, agents (if you are a corporate, an entity or an organisation) and/or other individuals, you confirm that you have explained or will explain to them that their personal data will be provided to, and processed by, us and you represent and warrant that you have made them aware of how we process their personal data and the existence of this notice.
    2. Provision of Personal Data of Children. As per paragraph 1.3 (above), the Platforms and Services are not directed to individuals under the age of eighteen (18), and we request that they do not provide personal data through access to or use of the Platforms and Services.
  4. USE OF PERSONAL DATA
    1. Purpose. We will only use your personal data when the law allows us to. We have set out below, in a table format, a description of all the ways we plan to use the various categories of your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.
      Purpose/Use Type of data Legal basis

      To provide the Services

      (a) Identity
      (b) Contact
      (c) Profile
      (d) Financial
      (e) Transaction

      Performance of a contract with you

      To register you as a new User and create your account

      (a) Identity
      (b) Contact
      (c) Financial
      (d) Profile

      Performance of a contract with you

      To manage our relationship with you which will include:
      (a) Notifying you about changes to our Terms of Use, Privacy Notice or Cookie Policy
      (b) Dealing with your requests, complaints and queries

      (a) Identity
      (b) Contact
      (c) Profile

      (a) Performance of a contract with you
      (b) Necessary to comply with a legal obligation
      (c) Necessary for our legitimate interests (to keep our records updated, communicate with you and manage our relationship with you)

      To enable you to complete a survey

      (a) Identity
      (b) Contact
      (c) Profile
      (d) Usage
      (e) Marketing and Communications

      (a) Performance of a contract with you
      (b) Necessary for our legitimate interests (to study how customers use our products/services, to develop them and grow our business)

      To administer and protect our business and our Platforms (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data, security)

      (a) Identity
      (b) Contact
      (c) Technical
      (d) Financial
      (e)Transaction

      (a) Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise)
      (b) Necessary to comply with a legal obligation

      To use data analytics to improve our Platforms, Services, customer relationships and experiences and to measure the effectiveness of our communications and marketing

      (a) Technical
      (b) Usage

      Necessary for our legitimate interests (to define types of customers for our products and services, to keep our Platforms updated and relevant, to develop our business, to inform our marketing strategy and to ensure that content from our Platforms is presented in the most effective manner for you and for your device

      To send you relevant marketing communications and make personalised suggestions and recommendations to you about goods or services that may be of interest to you based on your Profile Data

      (a) Identity
      (b) Contact
      (c) Technical
      (d) Usage
      (e) Profile
      (f) Marketing and Communications

      Consent, having obtained your prior consent to receiving direct marketing communication

      To carry out market research through your voluntary participation in surveys

      (a) Identity
      (b) Contact
      (c) Marketing and communications

      Necessary for our legitimate interests (to study how customers use our Services and to help us improve and develop our Services).

      To carry out any reasonable business activities such as audits, risk management or business reporting

      (a) Identity
      (b) Contact
      (c) Technical
      (d) Usage
      (e) Profile
      (f) Marketing and Communications
      (g) Transaction

      Necessary for our legitimate interests (to manage and administer our business and Platforms, to identify risks and to report to our key stakeholders).

      To establish, exercise and defend our rights, contractual or otherwise, including investigations and participating inpotentialoractuallitigation, arbitration, or other legal processes

      (a) Identity
      (b) Contact
      (c) Profile
      (d) Usage
      (e) Financial
      (f) Transaction

       

      Necessary to comply with a legal obligation.

      Necessary for our legitimate interest (for the purpose of establishing, exercising or defendingourlegalrights).

      To comply with any internal policies, applicable laws, regulations, or to assist with any law enforcement or investigations conducted by any governmental and/or regulatory authority

      (a) Identity
      (b) Contact
      (c) Profile
      (d) Usage
      (e) Financial
      (f) Transaction

       

      Necessary to comply with our legal obligations

      Necessary for our legitimate interests (for the purpose of managing and administering the Platform).

       

      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 data. Please contact us if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table above.
    2. Consent. Generally, we do not rely on consent as a legal basis for processing your personal data although we will get your consent before sending direct marketing communications to you via email or text message (as detailed in the table above). You have the right to withdraw consent to marketing at any time by contacting us. See directly below under Marketing for further details.
  5. DISCLOSURES OF YOUR PERSONAL DATA
    1. We may share your personal data with the third parties set out below for the purposes set out in the table above:
      1. other companies within our group;
      2. specific third parties such as Google; Twilio; Keyless;
      3. our professional advisors;
      4. third parties to whom we may choose to sell or transfer parts of our business or our assets; and
      5. third parties who we may seek to acquire or merge with.
    2. We may also need to disclose or share your personal data with regulators and other authorities where we are under a legal or regulatory obligation to do so.
    3. 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 (where acting as processors on our behalf) to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.
  6. MARKETING
    1. Direct marketing. During the onboarding process on our Platforms when your personal data is collected, you will be asked to indicate your preferences for receiving direct marketing communications from us via events@saible.co.uk.
    2. Third-party marketing. We will get your express consent before we share your personal data with any third party for their own direct marketing purposes.
    3. Opting out of marketing. You can ask to stop sending you marketing communications at any time by following the opt-out links within any marketing communication sent to you or by contacting us at events@saible.co.uk. If you opt out of receiving marketing communications, you will still receive service-related communications that are essential for administrative or customer service purposes.
  7. INTERNATIONAL TRANSFERS
    1. We may transfer your personal data to service providers that carry out certain functions on our behalf. This may involve transferring personal data outside of the UK.
    2. Whenever we transfer your personal data out of the UK to service providers, we ensure a similar degree of protection is afforded to it as in the UK. We do this by ensuring that one of the following safeguards is in place:
      1. The transfer of your personal data is to a country that has been deemed by the UK to provide an adequate level of protection for personal data; or
      2. Where a country does not have an adequacy decision, the transfer is made in accordance with standard contractual clauses approved for use in the UK which give the transferred personal data the same protection as it has in the UK. To obtain a copy of these contractual safeguards, please contact us using the information set out in the contact details section (paragraph 1.8).
  8. YOUR RIGHTS
    In certain circumstances, you have rights under data protection laws in relation to your personal data,
    including the following rights:
    1. Request for Access. You have the right to request for access to, request for a copy of, request to update or correct, your personal data held by us.
    2. Request correction of your personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
    3. Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local laws. Please note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
    4. Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground, as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
    5. Request restriction of processing your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios: (i) if you want us to establish the data's accuracy; (ii) where our use of the data is unlawful but you do not want us to erase it; (iii) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; (iv) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
    6. Request transfer of your personal data to you or to a third party. You have the right to request a copy of your personal data in a structured, commonly used, machine-readable format for the purposes of transferring it to a third party. Please note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
    7. Withdrawal of Consent. You have the right to withdraw consent (where we are relying on consent to process your personal data). If you withdraw your consent, this will not affect the lawfulness of processing based on consent before its withdrawal.
    8. No fee usually required. You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we could refuse to comply with your request in these circumstances.
    9. What we may need from you. We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.
    10. Time limit to respond. We try to respond to all legitimate requests within one month from receipt of your request. If we have requested ID from you pursuant to paragraph 8.9 (What we may need from you) or if we require the payment of a fee by you pursuant to paragraph 8.8 (No fee usually required), the one month period shall start from the date on which we receive the information and/or fee (as applicable). Occasionally it could 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.
  9. RETENTION OF PERSONAL DATA
    1. Storage of Personal Data. All information you provide to us is stored on our secure servers. Any payment transactions will be encrypted using SSL technology. Where we have given you (or where you have chosen) a password which enables you to access certain parts of our Platforms, it is your responsibility to ensure that the password is kept confidential and that you do not share the password with any third party.
    2. Duration of Retention. We will only retain your personal data for as long as it is necessary to fulfil the purpose for which it was collected, or as required or permitted by applicable laws. We will cease to retain your personal data or remove the means by which the data can be associated with you as soon as it is reasonable to assume that such retention no longer serves the purpose for which the personal data was collected, and is no longer necessary for legal or business purposes. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect of our relationship with you.
    3. Appropriate Retention Periods. To decide the appropriate retention period, we consider the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements. By law we have to keep basic information about our clients (including Contact, Identity, Financial and Transaction Data) for six years after they cease being clients for tax purposes.
    4. Anonymise Personal Data. In some circumstances, we will anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes, in which case we may use this information indefinitely without further notice to you.
  10. DATA SECURITY
    1. Data Security. 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. They will only process your personal data on our instructions (to the extent that such contractors and third parties are acting as a processor on our behalf), and they are subject to a duty of confidentiality.
    2. Data Breach. We have put in place procedures 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.
  11. COOKIES
    1. For more information about the cookies we use on our Platforms, and how to change your cookie preferences, please see https://saible.co.uk (“our Cookie Policy”)

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