The purpose of this Notice
When we provide our services to you, we will collect personal information about you and we want to be open and transparent with you as to the types of information we collect about you, why we collect it, how we use it and who we may share it with.
The data controller of your personal information is Need2Protect, a limited liability company, registered in England at 37th Floor, One Canada Square, Canary Wharf, London England E14 5AA, with company number 10515337 (“we”, or “us”, or “our”).
If you have any questions or concerns about our use of your personal information, then please contact us using the contact details provided at the bottom of this Notice in the ‘How to contact us’ section.
What type of personal information will be processed and why?
We may ask you to provide personal information by filling in hard copy forms and documents or by corresponding with us by phone, e-mail, letter or otherwise, or during the course of our meetings with you
|Types of personal information||Why we collect it|
Identity details including your name and date of birth.
We may ask for copies of identity documents in which case we may collect details including your place of birth and residential address.
● To carry out money laundering and financial checks and for fraud and crime prevention and detection purposes.
● We will only ever use copies of identity documents for this purpose.
● We collect and process this personal information in order to comply with our legal and regulatory requirements.
Your contact details including your name, postal, phone and email address(es) and other personal details about you including your title, job title, marital status and date of birth.
Website Cookies and Google Analytics:
When someone visits www.need2protect.com we may use Google Analytics to collect standard internet data and details of visitor behaviour patterns. We do this to find out things such as the number of visitors and where the visit on the site. Visitors and their data are kept anonymous to both Google and ourselves.
● To contact you in order for us to manage, administer and provide our services to you.
● To respond to any correspondence and service-related enquiries you send to us in respect of our services.
● To discuss products or services for which you apply or may be interested in applying for.
● To manage any applications you make for products or services.
● To communicate any updates to you including any changes to our services, the terms and conditions of any services which we have provided to you, any changes to this Notice and to our websites.
● To contact you in order to receive your feedback on our services and to participate in related surveys.
|● To allow us to provide a professional service to you and to contact you with information about other services of ours that we think you may be interested in.|
● We collect and process this personal information for our legitimate business interests.
|Details of services you have received.|
|Client experience and other feedback and information you provide to us.|
● To review your feedback and experience with us so that we can improve our products and services for you and for our other clients.
● We collect and process this personal information for our legitimate business interests (and we record calls both for quality and training purposes and to comply with our legal and regulatory obligations).
Please see section below entitled “When we record communications” for more information.
|Information about complaints and incidents.|
|All of the personal information described above.|
● We may disclose your personal information to third parties where we are required to do so to comply with applicable laws and regulatory requirements including in circumstances where we are required to do so by a court Order, regulatory authority or any other third party with the lawful right to request and receive the personal information we hold about you (including law enforcement agencies and tax authorities).
● We may also use your personal information where it is necessary for us to take legal advice in order to establish our legal rights, to bring a claim against you or any related parties or to defend a claim from you or any related parties.
● We collect and process this personal information for our legitimate business interests including to carry out our own internal business planning, compliance, training, audit and quality assurance purposes.
Who might my personal information be shared with?
We may disclose your personal information to the following categories of recipients:
- to our suppliers and partners in order for them to help us provide our services to you, this includes:
- our IT systems providers to assist us with providing you with an efficient, modern and professional service;
- our suppliers of audit and regulatory compliance support services who may review our records containing your personal information in order to audit and report to us on our compliance with applicable laws and regulatory requirements;
- our accountants, solicitors, insurer(s) and insurance broker(s) and any other provider of professional services to us;
- to any national and/or international regulatory, enforcement body, government agency or court where we believe disclosure is necessary
- as a matter of applicable law or regulation (including where we are required by law to provide information to organisations such as HMRC),
- to exercise, establish or defend our legal rights, or
- to protect your vital interests of those of any other person; and
- to any other person with your consent to the disclosure or where we are permitted to do so by law.
Our legal basis for processing personal information
Our legal basis for collecting and using your personal information will depend on the personal information concerned and the specific context in which we collect it. In respect of the personal information and the purposes for which we may process your personal information which are set out in this Notice, we have confirmed the legal basis upon which we collect and process your personal information in the ‘What type of personal information will be processed and why?’ section above.
If we ask you to provide personal information to comply with a legal requirement or to perform a contract with you or with your explicit consent, we will make this clear at the relevant time and advise you whether the provision of your personal information is mandatory or not (as well as of the possible consequences if you do not provide your personal information).
Similarly, if we collect and use your personal information in reliance on our legitimate interests (or those of any third party), we will make clear to you at the relevant time what those legitimate interests are.
If you have questions about or need further information concerning the legal basis on which we collect and use your personal information, please contact us using the contact details provided under the “How to contact us” heading below.
International Data Transfers
Your personal information may be transferred to, and processed in, countries other than the country in which you are resident. These countries may have data protection laws that are different to the laws of your country (and, in some cases, may not be as protective). Specifically, our servers are located in Germany. The server of the program which stores your data is located in England.
Therefore the countries listed above fall under the same laws and regulations outlined in this Notice and within the whole of the European Union, and no further steps are required to ensure the safety of your data.
Your data protection rights
You have the following data protection rights:
- If you wish to access, correct, update or request deletion of your personal information, you can do so at any time by contacting us using the contact details provided under the “How to contact us” heading below;
- In addition, you can object to processing of your personal information, ask us to restrict processing of your personal information or request portability of your personal information. Again, you can exercise these rights by contacting us using the contact details provided under the “How to contact us” heading below.
- You have the right to opt-out of marketing communications we send you at any time. You can exercise this right by clicking on the “unsubscribe” or “opt-out” link in the marketing e-mails we send you. To opt-out of other forms of marketing (such as postal marketing or telemarketing), then please contact us using the contact details provided under the “How to contact us” heading below.
- Similarly, if we have collected and process your personal information with your consent, then you can withdraw your consent at any time. Withdrawing your consent will not affect the lawfulness of any processing we conducted prior to your withdrawal, nor will it affect processing of your personal information conducted in reliance on lawful processing grounds other than consent. For specific information about our processing of your sensitive category personal data with your consent, please see the “Your consent to us processing your special category personal data” heading below.
- You have the right to complain to a data protection authority about our collection and use of your personal information. For more information, please contact your local data protection authority. (Contact details for data protection authorities in the European Economic Area, Switzerland and certain non-European countries (including the US and Canada) are available at http://ec.europa.eu/justice/data-protection/article-29/structure/data-protection-authorities/index_en.htm.
We respond to all requests we receive from individuals wishing to exercise their data protection rights in accordance with applicable data protection laws.
We retain personal information we collect from you where we have an ongoing legitimate need to do so, for example:
- to provide you with a product or service you have requested us to provide,
- to perform our contractual obligations to you;
- to comply with applicable legal, tax or accounting requirements;
- to defend or manage any claims or complaints between us, you and any relevant third party including taking legal advice in respect of such claims in order to establish, exercise or defend our legal rights or such claims. This would include complaints and claims which you may bring against us or which are submitted to a court, regulatory authority or ombudsman.
When we have no ongoing legitimate need to process your personal information, we will either delete or anonymise it or, if this is not possible (for example, because your personal information has been stored in backup archives), then we will securely store your personal information and isolate it from any further processing until deletion is possible.
Updates to this Notice
We may change or update this Notice in order to maintain our compliance with applicable law and regulation or following an update to our internal practices. When we update our Notice, we will take appropriate measures to inform you, consistent with the significance of the changes we make.
How to contact us
If you would like to contact us in relation to this Notice or if you have any other questions in respect of our processing of your personal information, please contact the Data Protection Officer on (0) 203 951 0906 or in writing at 37th Floor, One Canada Square, Canary Wharf, London, England E14 5AA.