Data Protection and Privacy

<H1>Data Protection and Privacy </H1>

financEagle Limited (we/us/our) is committed to protecting and respecting your privacy.  

This notice together with our terms of business set out the basis on which any personal data we collect from you, or that you provide to us, will be processed by us and the purpose for our collection of it.  

<H2>Data protection</H2>

For the purpose of the Data Protection Act 2018 (the Act) and the provisions of Regulation (EU) 2016/679 as transposed into UK law under the Data Protection, Privacy and Electronic Communications (Amendments etc) (EU Exit) Regulations 2019 (the General Data Protection Regulation or GDPR), financEagle Limited is the data controller of your personal information and is entered in the Information Commissioner’s Office (ICO) Register of Data Controllers with registration number ZB311160.  

<H2>What personal information do we collect and why do we collect it?</H2>

We may collect and process personal information about you including information that you provide to us through our website (including but not limited to traffic data), by email or other correspondence or that you provide when you use our professional services as a client.

We may also collect information about you in other ways, for example:
<ul>
<li>	if you are a customer of one of our clients, and we are undertaking services on our client’s behalf
<li>	if you have any other dealings with one or more of our clients which are related to services which we are providing to our client or on our client’s behalf
<li>	indirectly, through one of our people, a client or a third party
<li>	from publicly available sources, for example Companies House
<li>	from third party data sources, including databases, where they have a legal basis for providing information to us
</ul>
<H2>How we use your personal data</H2>

The way we process your personal data we collect as set out above varies depending on our relationship with you.  In each case the purposes for which we request the information will be clear from the context in which it is acquired. These include:
<ul>
<li>	providing our services to you or an entity for which you work
<li>	verifying your identity
<li>	keeping a record of the services you have subscribed to and deliver services you may have requested
<li>	administration, billing and record-keeping purposes
<li>	communicating with you by telephone, email or post
<li>	meeting our legal, regulatory and contractual obligations arising from any our relationship with you
<li>	providing and improving customer service and support
<li>	administering our website, enhancing operational capabilities and for internal operations
<li>	verifying or enforcing compliance with this notice and applicable laws
<li>	to inform you of services which we think may be of interest to you (unless you have opted out of receiving such marketing communications)
</ul>
<H2>Disclosure of your personal data</H2>

We will only disclose your personal information to another person or organisation where we:
<ul>
<li>	need to share the information to provide a product or service you have requested
<li>	need to send the information to persons or organisations who engage us to conduct services on their behalf, including where you are that third party’s customer
<li>	need to send the information to persons or organisations that work on our behalf to provide a product or service to you
<li>	are required to disclose the information in order to comply with the law or the requirements of a regulatory authority
</ul>

Where a person or organisation does work on our behalf we will ensure that they are contractually required to take appropriate technical and organisational measures to protect your personal information against unauthorised or unlawful processing and against accidental loss or destruction of, or damage to, personal information and only use the information in order to provide a product or service on our behalf.

<H2>Our legal basis for using your personal data</H2>

Our use of your personal data as outlined above is subject to different legal bases for processing, including where necessary for:
<ul>
<li>	the purposes of the performance of any contract we enter into with you or to take steps at your request prior to entering into a contract with you
<li>	our legitimate interests, for example in providing services to an entity you work for, managing and monitoring our website operation, preventing fraud and for our business promotion and compliance purposes
<li>	compliance with our legal and regulatory responsibilities.
</ul>
If you do not agree to provide your personal data to us we may not be able to provide you with services. Where our use of your data is not necessary for one of the purposes outlined above we may use it in a particular way with your consent. Where we ask for your consent you are free to refuse our use of your personal data for those purposes and you may withdraw your consent at any time by contacting us using the details set out below.  This shall not affect the lawfulness of any processing that was based on your consent before you withdrew it.

<H2>Storage and transfer of your personal data</H2>

The personal information that we collect from you may be transferred to, and stored at, a destination outside the United Kingdom or the European Economic Area (EEA).  It may also be processed by staff operating outside the United Kingdom or the EEA who work for us or one of our suppliers or in circumstances where your instruction has international considerations and/or parties related to your matter are located overseas.  Before we transfer your personal data outside the United Kingdom or EEA we will take all steps reasonably necessary to ensure that any such transfer is made securely and that there is adequate protection in place in order to protect your personal data, as required by the Act and Chapter V of the GDPR. Please contact us if you wish to obtain more information regarding relevant safeguards. By submitting your personal information you agree to this transfer, storing or processing outside the United Kingdom and the EEA.

<H2>Retention of your personal data</H2>

We will retain your personal information for a minimum of six years and so long as is reasonably necessary for the purpose for which it was obtained and in accordance with our legal obligations and follow our data destruction policy and processes thereafter.

<H2>Your rights</H2>

Your personal information is protected under data protection law and you have a number of rights (see below) which you can seek to exercise. Please contact us in writing or by email using the details below if you wish to do so, or if you have any queries in relation to your rights. Please note these rights do not apply in all circumstances.

<ul>
<li>	Right of access – subject to certain exceptions, you have the right of access to your personal data that we hold
<li>	Right to rectify your personal information – if you discover that the information we hold about you is inaccurate or incomplete, you have the right to have this information rectified (i.e. corrected)
<li>	Right to be forgotten – you may ask us to delete information we hold about you in certain circumstances. This right is not absolute and it may not be possible for us to delete the information we hold about you, for example, if we have an ongoing contractual relationship or are required to retain information to comply with our legal obligations.
<li>	Right to restriction of processing – in some cases you may have the right to have the processing of your personal information restricted. For example, where you contest the accuracy of your personal information, its use may be restricted until the accuracy is verified
<li>	Right to object to processing – you may object to the processing of your personal information (including profiling) when it is based upon our legitimate interests. You may also object to the processing of your personal information for the purposes of direct marketing and for the purposes of statistical analysis
<li>	Right to data portability – you have the right to receive, move, copy or transfer your personal information to another controller when we are processing your personal information based on consent or on a contract and the processing is carried out by automated means
</ul>

<H2>IP addresses</H2>

We may collect information about your computer, including where available your IP address, operating system and browser type, for system administration and to collect aggregate information for us to use.  This is statistical data about our users’ browsing actions and patterns, and does not identify any individual.

<H2>Cookies</H2>

We may use cookies to enable our website to operate properly, to ‘remember’ who you are, and to monitor website traffic and usage.  You can accept, delete or disable cookies through your browser if you wish.  Unless necessary for the functioning of our website or for the transmission of communications, we will only place cookies where you have previously provided your consent.

<H2>Security</H2>

We will keep your information secure by taking appropriate technical and organisational measures against unauthorised or unlawful processing, accidental loss, destruction and damage.  However, the transmission of information via the internet is not completely secure.  Although we will do our best to protect your personal information we cannot guarantee the security of your personal information transmitted to our website so any transmission is at your own risk.

<H2>Changes to this notice</H2>

We may change this notice at any time by amending this page.  If we make any substantial changes in the way we use your personal information we will notify you by posting a prominent notice on our website.

<H2>Contact & complaints</H2>

If you have any questions about how we treat your personal data and protect your privacy, or if you have any comments or wish to seek to exercise any of your rights as outlined above, to opt-out of receiving marketing communications from us or to complain about our use of your personal data, please write to The Director, financEagle Limited at 86-90 Paul Street, London EC2A 4NE or by email at <a href="admin@financeagle.com">admin@financeagle.com</a>. 

You may also lodge a complaint with the ICO by writing to the Information Commissioner’s Office, Water Lane, Wilmslow, SK9 5AF telephone 0303 123 1113. <a href="www.ico.org.uk/">www.ico.org.uk/</a>.  <p>ICO registration number: ZB311160</p>