Fidsy Ltd
Company Number 09786552
The Retreat, 406 Roding Lane South, Woodford Green, IG8 8EY, United Kingdom
08 September 2022
Privacy Policy
BACKGROUND:
Fidsy understands that your privacy is important to you and that you care about how your personal data is used. We respect and value the privacy of everyone who visits this website, www.fidsy.com (“Our Site”) and will only collect and use personal data in ways that are described here, and in a way that is consistent with our obligations and your rights under the law.
Please read this Privacy Policy carefully and ensure that you understand it.
1.Definitions and Interpretation
In this Policy the following terms shall have the following meanings:
| “Account” | means an account required to access and/or use certain areas and features of Our Site; |
| “Cookie” | means a small text file placed on your computer or device by Our Site when you visit certain parts of Our Site and/or when you use certain features of Our Site. Details of the Cookies used by Our Site are set out in Part 14, below; and |
| “Cookie Law” | means the relevant parts of the Privacy and Electronic Communications (EC Directive) Regulations 2003; |
2.Information About Us OR Me
Our Site is owned and operated by Fidsy LTD, a limited company registered in England under company number 09786552.
Registered address: The Retreat, 406 Roding Lane South, Essex, England, IG8 8EY
Data Protection Officer: 2A Partners LTD.
Email address: [email protected].Postal address: 8 Kingsbridge Avenue, London, England, W3 9AJ.Representative: Vahap Atalay.
Email address: [email protected].Telephone number: +44 774 578 0014.3.What Does This Policy Cover?
This Privacy Policy applies only to your use of Our Site. Our Site may contain links to other websites. Please note that we have no control over how your data is collected, stored, or used by other websites and we advise you to check the privacy policies of any such websites before providing any data to them.
4.What Is Personal Data?
Personal data is defined by the UK GDPR and the Data Protection Act 2018 (collectively, “the Data Protection Legislation”) as ‘any information relating to an identifiable person who can be directly or indirectly identified in particular by reference to an identifier’.
Personal data is, in simpler terms, any information about you that enables you to be identified. Personal data covers obvious information such as your name and contact details, but it also covers less obvious information such as identification numbers, electronic location data, and other online identifiers.
5.What Are My Rights?
Under the Data Protection Legislation, you have the following rights, which we will always work to uphold:
- a)The right to be informed about our collection and use of your personal data. This Privacy Policy should tell you everything you need to know, but you can always contact us to find out more or to ask any questions using the details in Part 15.
- b)The right to access the personal data we hold about you. Part 13 will tell you how to do this.
- c)The right to have your personal data rectified if any of your personal data held by us is inaccurate or incomplete. Please contact us using the details in Part 15 to find out more.
- d)The right to be forgotten, i.e. the right to ask us to delete or otherwise dispose of any of your personal data that we hold. Please contact us using the details in Part 15 to find out more.
- e)The right to restrict (i.e. prevent) the processing of your personal data.
- f)The right to object to us using your personal data for a particular purpose or purposes.
- g)The right to withdraw consent. This means that, if we are relying on your consent as the legal basis for using your personal data, you are free to withdraw that consent at any time.
- h)The right to data portability. This means that, if you have provided personal data to us directly, we are using it with your consent or for the performance of a contract, and that data is processed using automated means, you can ask us for a copy of that personal data to re-use with another service or business in many cases.
For more information about our use of your personal data or exercising your rights as outlined above, please contact us using the details provided in Part 15.
It is important that your personal data is kept accurate and up-to-date. If any of the personal data we hold about you changes, please keep us informed as long as we have that data.
Further information about your rights can also be obtained from the Information Commissioner’s Office or your local Citizens Advice Bureau.
If you have any cause for complaint about our use of your personal data, you have the right to lodge a complaint with the Information Commissioner’s Office. We would welcome the opportunity to resolve your concerns ourselves, however, please contact us first, using the details in Part 15.
6.What Data Do You Collect and How?
Depending upon your use of Our Site, we may collect and hold some or all of the personal data set out below. Please also see Part 14 for more information about our use of Cookies and similar technologies. We do not collect any ‘special category’ or ‘sensitive’ personal data or personal data relating to children or data relating to criminal convictions and/or offences.
- • Create or register an account, or when you manage your account
- • Upload information, data or content to our service
- • Communicate with us via our email, chat, or via any other form
- • Contact us for customer support
- • Integrate third party products and services with your Fidsy account
- • Visit any of our websites or download any of our apps
- • Participate in any promotions, demonstrations, contests, surveys, or other marketing events
7.How Do You Use My Personal Data?
Under the Data Protection Legislation, we must always have a lawful basis for using personal data. The following table describes how we may use your personal data, and our lawful bases for doing so:
| Purpose | Type of Data | Our Lawful Basis |
|---|---|---|
| User visiting the public website for the first time Technical Data Legitimate Interest | (a) Technical (b) Usage | Legitimate Interest We need to understand where you are logging in from so we know whether you can take advantage of our services, and what browser you are using so we can understand our customer demographic to help diagnose service provision issues, to keep our records up-to-date and analyse how customers use our services. |
| When a user uses our submit feedback service and voluntarily leaves their email address or has previously logged into the Platform | (a) Identity (b) Contact (c) Profile (d) Marketing and communication | Consent We ask you for your email so we can easily get back in touch with you and connect the conversation history to an individual. Legitimate Interest We need to understand where you are logging in from so we know whether you can take advantage of our services, and what browser you are using so we can understand our customer demographic to help diagnose service provision issues, to keep our records up-to-date and analyse how customers use our services. |
| A User requesting and attending a live demo of our products/services or inquiring into our services through a call with members of our sales/support team | (a) Identity (b) Contact (c) Profile. | Consent Certain company information will be taken at this time, including names of founders and existing shareholders in the Company. It also allows us to register you as a User to be able to enter into a contract with you. |
| User signing up to the platform and creating an account | (a) Identity (b) Contact (c) Technical (d) Profile (e) Usage (f) Marketing and communications | Consent You will need to include Personal Data when filling in the Company profile on the platform so the content you create is linked to your profile Contractual Obligation In order to use our Platform you need to contract with us under our Terms of Service and so this data is necessary to form the contract between us Legitimate Interest We need to understand where you are logging in from so we know whether you can take advantage of our services, and what browser you are using so we can understand our customer demographic to help diagnose service provision issues, to keep our records up-to-date and analyse how customers use our services |
| User makes a purchase on Our Site | (a) Financial (b) Transaction (c) Profile (d) Usage | Consent You will need to include Personal Data when filling in the Company profile on the Platform so the content you create is linked to your profile Contractual Obligation In order to use our Platform you need to contract with us under our Terms of Service and so this is necessary to form the contract between us We need to retain your Transactional Data so that we can comply with our legal obligation to send you an invoice following a purchase Legitimate Interest We need to know who you are so that we know who to deliver the service to once it has been purchased. It also enables us to provide support to the right individual in case there is an issue with the purchased product |
| User support with specific products | (a) Identity (b) Transaction (c) Profile (d) Usage | Consent We may need your telephone number or other further contact details if reaching out to you is best achieved via those details instead of email Legitimate Interest We will retain records of the transactions you have made with us and what you have used on the Platform so when you come to us with an issue we can quickly identify what your issue relates to and provide you with the most efficient support |
| To administer and protect our business (the Site and Platform) including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data | (a) Identity (b) Contact (c) Technical | Legitimate Interest 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 Contractual Obligation To be able to comply with all legal obligations surrounding data collection, processing and retention. |
| To use data analytics to improve our website, products/services, marketing, customer relationships and experiences | (a) Technical (b) Usage | Legitimate Interest To define types of customers for our products and services, to keep our Site and Platform updated and relevant, to develop our business and to inform users about marketing strategy |
With your permission or where permitted by law, we may also use your personal data for marketing purposes, which may include contacting you by email or telephone or text message or post with information, news, and offers on our products and services. You will not be sent any unlawful marketing or spam. We will always work to fully protect your rights and comply with our obligations under the Data Protection Legislation and the Privacy and Electronic Communications (EC Directive) Regulations 2003, and you will always have the opportunity to opt-out. We will always obtain your express opt-in consent before sharing your personal data with third parties for marketing purposes and you will be able to opt-out at any time.
Third Parties whose content appears on Our Site may use third-party Cookies, as detailed below in Part 14. Please refer to Part 14 for more information on controlling cookies. Please note that we do not control the activities of such third parties, nor the data that they collect and use themselves, and we advise you to check the privacy policies of any such third parties.
We will only use your personal data for the purpose(s) for which it was originally collected unless we reasonably believe that another purpose is compatible with that or those original purpose(s) and need to use your personal data for that purpose. If we do use your personal data in this way and you wish us to explain how the new purpose is compatible with the original, please contact us using the details in Part 15.
If we need to use your personal data for a purpose that is unrelated to, or incompatible with, the purpose(s) for which it was originally collected, we will inform you and explain the legal basis which allows us to do so.
In some circumstances, where permitted or required by law, we may process your personal data without your knowledge or consent. This will only be done within the bounds of the Data Protection Legislation and your legal rights.
8.Information We Collect
Fidsy uses information we collect to operate, maintain and provide you the features and functionality of the Service, to analyse how the Service is used, diagnose service or technical problems, maintain security, personalize content, remember information to help you efficiently access your account, monitor aggregate metrics such as total number of visitors, traffic, and demographic patterns.
9.How and Where Do You Store or Transfer My Personal Data?
We will only store or transfer personal data in or to countries that are deemed to provide an adequate level of protection for personal data. For further information about adequacy decisions and adequacy regulations, please refer to the Information Commissioner’s Office.
10.Do You Share My Personal Data?
Fidsy may share your personally identifiable information with other third parties for the purpose of providing a better service for you. These parties include data processing services, maintenance services, payment processing, database management, email providers, analytics tools to help us understand how you use Our Site, CRM providers, marketing and sales solutions, data providers about your company, and services that help us secure the Service. These third parties may have access to your personal data for the purpose of performing these tasks according to our instructions. Such third parties’ use of your information will be bound by this Privacy Policy. We may also store personal information in locations outside the direct control of Fidsy (for instance, on servers or databases co-located with hosting providers).
We will not share any of your personal data with any third parties for any purposes, subject to the above and below exceptions.
If we sell, transfer, or merge parts of our business or assets, your personal data may be transferred to a third party. Any new owner of our business may continue to use your personal data in the same way(s) that we have used it, as specified in this Privacy Policy.
In some limited circumstances, we may be legally required to share certain personal data, which might include yours, if we are involved in legal proceedings or complying with legal obligations, a court order, or the instructions of a government authority.
11.How Can I Control My Personal Data?
In addition to your rights under the Data Protection Legislation, set out in Part 5, when you submit personal data via Our Site, you may be given options to restrict our use of your personal data. In particular, we aim to give you strong controls on our use of your data for direct marketing purposes (including the ability to opt-out of receiving emails from us which you may do by unsubscribing using the links provided in our emails.
12.Can I Withhold Information?
You may access certain areas of Our Site without providing any personal data at all. However, to use all features and functions available on Our Site you may be required to submit or allow for the collection of certain data.
You may restrict our use of Cookies. For more information, see Part 14.
13.How Can I Access My Personal Data?
If you want to know what personal data we have about you, you can ask us for details of that personal data and for a copy of it (where any such personal data is held). This is known as a “subject access request”.
All subject access requests should be made in writing and sent to the email or postal addresses shown in Part 15. To make this as easy as possible for you, a Subject Access Request Form is available for you to use. You do not have to use this form, but it is the easiest way to tell us everything we need to know to respond to your request as quickly as possible.
There is not normally any charge for a subject access request. If your request is ‘manifestly unfounded or excessive’ (for example, if you make repetitive requests) a fee may be charged to cover our administrative costs in responding.
We will respond to your subject access request within 2 weeks and, in any case, not more than one month of receiving it. Normally, we aim to provide a complete response, including a copy of your personal data within that time. In some cases, however, particularly if your request is more complex, more time may be required up to a maximum of three months from the date we receive your request. You will be kept fully informed of our progress.
14.How Do You Use Cookies?
Our Site may place and access certain first-party Cookies on your computer or device. First-party Cookies are those placed directly by us and are used only by us. We use Cookies to facilitate and improve your experience of Our Site and to provide and improve our services. We have carefully chosen these Cookies and have taken steps to ensure that your privacy and personal data is protected and respected at all times.
By using Our Site, you may also receive certain third-party Cookies on your computer or device. Third-party Cookies are those placed by websites, services, and/or parties other than us. For more details, please refer to the table below. These Cookies are not integral to the functioning of Our Site and your use and experience of Our Site will not be impaired by refusing consent to them.
All Cookies used by and on Our Site are used in accordance with current Cookie Law.
Before Cookies are placed on your computer or device, you will be shown a pop-up requesting your consent to set those Cookies. By giving your consent to the placing of Cookies you are enabling us to provide the best possible experience and service to you. You may, if you wish, deny consent to the placing of Cookies; however certain features of Our Site may not function fully or as intended.
Certain features of Our Site depend on Cookies to function. Cookie Law deems these Cookies to be “strictly necessary”. These Cookies are shown in the table below. Your consent will not be sought to place these Cookies, but it is still important that you are aware of them. You may still block these Cookies by changing your internet browser’s settings as detailed below, but please be aware that Our Site may not work properly if you do so. We have taken great care to ensure that your privacy is not at risk by allowing them.
The following first-party Cookies may be placed on your computer or device:
| Name of Cookie | Purpose | Strictly Necessary |
|---|---|---|
| _ga | Contains a unique identifier used by Google Analytics to determine that two distinct hits belong to the same user across browsing sessions | Yes |
| _gid | Contains a unique identifier used by Google Analytics to determine that two distinct hits belong to the same user across browsing sessions | Yes |
| _gat_* | Used by Google Analytics to throttle request rate (limit the collection of data on high traffic sites) | Yes |
and the following third-party Cookies may be placed on your computer or device:
| Name of Cookie | Purpose | Provider |
|---|---|---|
| YSC | Youtube.com | This cookie is set by Youtube video service on pages with Youtube embedded videos or track views. |
| VISITOR_INFO1_LIVE | Youtube.com | A cookie that Youtube sets that measures our bandwidth to determine whether you get the new player interface or the old |
In addition to the controls that we provide, you can choose to enable or disable Cookies in your internet browser. Most internet browsers also enable you to choose whether you wish to disable all Cookies or only third-party Cookies. By default, most internet browsers accept Cookies, but this can be changed. For further details, please consult the help menu in your internet browser or the documentation that came with your device. You can choose to delete Cookies on your computer or device at any time, however you may lose any information that enables you to access Our Site more quickly and efficiently including, but not limited to, login and personalisation settings. It is recommended that you keep your internet browser and operating system up-to-date and that you consult the help and guidance provided by the developer of your internet browser and manufacturer of your computer or device if you are unsure about adjusting your privacy settings.
15.How Do I Contact You?
To contact us about anything to do with your personal data and data protection, including to make a subject access request, please use the following details (for the attention of Vahap Atalay:
Email address: [email protected]
16.Changes to this Privacy Policy
We may change this Privacy Policy from time to time. This may be necessary, for example, if the law changes, or if we change our business in a way that affects personal data protection.
Any changes will be immediately posted on Our Site and you will be deemed to have accepted the terms of the Privacy Policy on your first use of Our Site following the alterations. We recommend that you check this page regularly to keep up-to-date. This Privacy Policy was last updated on 18 July 2022.