This version was last updated on 24th of May 2018.
1. Purpose of this privacy noticeThis privacy notice aims to give you information on how MatchPlace collects and processes your personal data through your use of this website, including any data you may provide through this website when you engage our services. This privacy notice shall be read together with any other privacy notice or fair processing notice we may provide on specific occasions when we are collecting and/or processing personal data about you so that you are fully aware of how and why we are using your data. This privacy notice supplements the other notices and is not intended to override them.
2. Data protection officerMatchPlace Limited is the controller and responsible for your personal data (collectively referred to as MatchPlace, “we”, “us” or “our” in this privacy notice). We have appointed a data protection officer (DPO) who is responsible for overseeing questions in relation to this privacy notice. If you have any questions about this privacy notice, including any requests to exercise your legal rights, please contact our DPO using the details set out below. Full name of legal entity: MatchPlace Limited DPO: Christophe Monget Email address: [email protected] Postal address: 30 Moorgate, London EC2R 6DN Email: [email protected]
3. ComplaintsYou have the right to make a complaint at any time to the Information Commissioner’s Office (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 at the details set out above (see 3.).
4. Your duty to inform us of changes in your dataIt 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 at the details set out above.
5. Third-party linksThis website 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.
The data we collect about you
Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data) or information about a legal person (i.e., business entity or non-governmental organization, government).
1. Data we collect
We may collect, use, store and transfer different kinds of personal data about you which we have grouped together follows:
– Identity Data includes first name, maiden name, last name, username or similar identifier, marital status, title, date of birth and gender.
– Contact Data includes billing address, delivery address, email address and telephone numbers.
– Financial Data includes bank account details.
– Transaction Data includes details about payments to and from you and other details of products and services you have purchased from us.
– Technical Data includes 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 and other technology on the devices you use to access this website.
– Profile Data includes your username and password, your interests, preferences, feedback and survey responses.
– Usage Data includes information about how you use our website, products and services.
– Marketing and Communications Data includes 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 for any purpose. Aggregated Data may be derived from your personal data but is not considered personal data in law as this data does not directly or indirectly reveal your identity. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy notice.
2. If you fail to provide personal data
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 goods or services). In this case, we may have to cancel a product or service you have with us but we will notify you if this is the case at the time.
How is your personal data collected?
We use different methods to collect data from and about you including through:
1. Direct interactions
You may give us your Identity, Contact and Financial Data by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:
– When prospective members are sent a full application form to be accepted as a customer of MatchPlace
– When you subscribe or are added to our newsletters
– When you download specific brochures/online documents
– When you ‘contact us’ on our various sites via an online form
– When you submit surveys and feedback forms
– When you telephone or email us
2. Automated technologies or interactions
3. Third parties or publicly available sources
We may receive personal data about you from various third parties as set out below:
– Technical Data from analytics providers such as Google based outside the EU;
– Contact, Financial and Transaction Data from providers of technical, payment and delivery services.
– Identity and Contact Data from data brokers or aggregators.
How we use your personal data
1. Performance of ContractPerformance of Contract means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract. We need to perform the contract when we are about to enter into relation or have entered into relation with you.
2. Legitimate interestLegitimate Interest means the interest of our business in conducting and managing our business to enable us to give you the best service and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us.
3. Comply with a legal or regulatory obligationComply with a legal or regulatory obligation means processing your personal data where it is necessary for compliance with a legal or regulatory obligation that we are subject to. Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
Purposes for which we will use your personal data.
1. Our use of your personal dataWe have set out below, in a table format, a description of all the ways we plan to use your personal data. 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
|Purpose||Type of data||Lawful basis for processing including basis of legitimate|
|To register you as a new customer or member||(1) Identity
(3) Shareholder information (detail of the shares)
|(1) Performance of a contract with you
(2) Comply with a legal or regulatory obligation
|To process and deliver our services including:
(1) Foreign Exchange
(2) Invoice Financing
(5) Marketing and Communications
|(1) Performance of Contract with you
(2) Legitimate interest
|To manage our relationship with you including :
(2) Asking you to leave a review or take a survey
|(1) Performance of Contract with you
(2) Comply with a legal or regulatory obligation
(3) Legitimate interest
|To administer and protect our business and this website||(1) Identity
|(1) Comply with a legal or regulatory obligation
(2) Legitimate interest
|To use data analytics to improve our website, products/services, marketing, customer relationships and experiences||(1) Technical
|(1) Legitimate interest|
2. Third-party marketingWe will get your express opt-in consent before we share your personal data with any other company for marketing purposes. You can ask us or third parties to stop sending you marketing messages at any time by contacting us. Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of the provision of our services to you.
4. Change of purposeIf we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so. Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.
Disclosures of your personal data to external third parties
We may have to share your personal data with service providers acting as processors based in the United Kingdom / EU / US who provide IT, software and administration systems and payments processing including Google, LemonWay and Currency cloud.
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. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. 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.
Data retention period
To determine the appropriate retention period for personal data, 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 requirements.
By law we have to keep basic information about our customers (including Contact, Identity, Financial and Transaction Data) for six years after they cease being customers for tax purposes.
Your legal rights
Under certain circumstances, you have rights under data protection laws in relation to your personal data.
1. Request access to your personal data.
Commonly known as a “data subject access request. This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
2. Request correction of the 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. 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.
When 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 of your personal data.
This enables you to ask us to suspend the processing of your personal data in the following scenarios:
(a) if you want us to establish the data’s accuracy;
(b) where our use of the data is unlawful but you do not want us to erase it;
(c) 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; or
(d) 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 the transfer of your personal data to you or to a third party.
We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. 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. 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 above). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.
8. 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.
9. Time limit to respond.
We try to respond to all legitimate requests within one month. Occasionally it may 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.