This website is not intended for children and we do not knowingly collect data relating to children.
Full name of legal entity: Farillio Limited
Name: Merlie Calvert
Email address: firstname.lastname@example.org
Postal address: Farillio Limited, Kemp House, 160 City Road, London, England EC1V 2NX
You have the right to make a complaint at any time to the Information Commissioner's Office ( ICO ), the UK supervisory authority for data protection issues (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.
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).
We may collect, use, store and transfer different kinds of personal data about you which we have grouped together follows:
We do not actively collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data). Nor do we actively collect any information about criminal convictions and offences.
Where we need to collect personal data by law, or under the terms of our Subscription Partner's contract 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 (for example, to provide products or services). In this case, we may have to cancel a product or service but we will notify the relevant Farillio account holder if this is the case at the time.
We use different methods to collect data from and about you, including through:
We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:
Where we need to perform the contract we are about to enter into or have entered into with you (" Contract Reason").
Where we need to comply with a legal or regulatory obligation that we are subject to (" Legal Obligations Reason").
Generally we do not rely on consent as a legal basis for processing your personal data other than in relation to sending third party direct marketing communications to you via email or text message (" Consent Reason" ). You have the right to withdraw consent to marketing at any time by contacting us or by using the opt-out/unsubscribe link in any email which we send to you.
We have set out below, in a table format, a description of all the ways we plan to use 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/Activity||Lawful basis for processing including basis of legitimate interest|
|To register a customer as a new customer (including to contact those who have started the sign up process but not completed it).||(a) Contract Reason.(b) Legitimate Interests Reason (because of a contract we have entered or are about to enter into with a customer in order to fulfil that contract, which is in our and their legitimate interests).|
|To carry out our obligations to a customer under our contract with them, including to provide them with products and services which they request from us.||(a) Contract Reason.(b) Legitimate Interests Reason (because of a contract we have entered into with a customer in order to fulfil that contract, which is in our and their legitimate interests).|
|To process and deliver a customer's order including:(a) Manage payments, fees and charges(b) Collect and recover money owed to us||(a) Contract Reason.(b) Legitimate Interests Reason (because of a contract we have entered into with a customer in order to fulfil that contract, which is in our and their legitimate interests and in order to recover debts due to us).|
|To carry out our obligations to a Subscription Partner under our contract with them, including information to assist them with verifying your access to our site this includes your email address, details relating to your usage, email address, business sector and type of business.||(a) Contract Reason.(b) Legitimate Interests Reason (because of a contract we have entered into with the Subscription partner in order to fulfil that contract, which is in our and their legitimate interests).|
|To allow a customer to participate in interactive features of our website.||(a) Contract Reason(b) Legitimate Interests Reason (because of a contract we have entered into with a customer in order to fulfil that contract, which is in our and their legitimate interests).|
|Where a customer requests this, to put them in touch with our expert partners.||(a) Contract Reason(b) Legitimate Interests Reason (because of a contract we have entered into with a customer in order to fulfil that contract, which is in our and their legitimate interests).|
|To carry out anti-money laundering checks on behalf of our expert partners, prior to a customer receiving advice from them.||(a) Contract Reason(b) Legitimate Interests Reason (because of a contract we have entered into with a customer in order to fulfil that contract, which is in our and their legitimate interests)|
|To provide customer service and support.||(a) Contract Reason(b) Legitimate Interests Reason (because of a contract we have entered into with a customer in order to fulfil that contract, which is in our and their legitimate interests and to ensure that we give the best customer service to our customers)|
|To enable a customer to take part in a prize draw, competition or complete a survey||(a) Contract Reason.(b) Legitimate Interests Reason (to study how customers use our products/services, to develop them and grow our business).|
|To administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)||(a) Legitimate Interests Reason (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) Legal Obligations Reason.|
|To monitor the use of our website.||Legitimate Interests Reason (to ensure that our website is being used in accordance with our acceptable use policy)|
|To deliver relevant website content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you||Legitimate Interests Reason (to study how customers use our products/services, to develop them, to grow our business and to inform our marketing strategy)|
|To use data analytics to improve our website, products/services, marketing, customer relationships and experiences||Legitimate Interests Reason (to define types of customers for our products and services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy)|
|To make suggestions and recommendations to our customers about goods or services that may be of interest to them||(a) Legitimate Interests Reason (to develop our products/services and grow our business)(b) Consent Reason.|
We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising.
We may use your Identity, Contact, Technical, Usage and Profile Data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which products, services and offers may be relevant for you (we call this marketing).
You will receive marketing communications from us if you have signed up to our mailing list and consented to receive marketing, or if you have requested information from us or purchased products or services from us, or if you provided us with your details when you entered a competition or registered for a promotion and, in each case, you have not opted out of receiving that marketing.
We will get your express opt-in consent before we share your personal data with any third party for marketing purposes.
Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of a product/service purchase, product/service experience or other transactions.
If 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.
We may have to share your personal data with the parties set out below for the purposes set out in the table in section 4 above.
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 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.
Some of our external third parties are based outside the European Economic Area ( EEA ) so their processing of your personal data will involve a transfer of data outside the EEA.
Whenever we transfer your personal data out of the EEA, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:
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. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.
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.
For how long will you use my personal data?
We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.
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, Transaction, KYC, Profile and Customer Service Data) for seven years after they cease being customers for tax purposes.
We keep Technical and Usage Data for 12 months from the date of collection.
We keep Marketing and Communications for 12 months after you opt out/unsubscribe for marketing communications.
In some circumstances you can ask us to delete your data: please see section 9 below for further information.
In some circumstances we may 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.
Under certain circumstances, you have rights under data protection laws in relation to your personal data. These rights enable you to:
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 may refuse to comply with your request in these circumstances.
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.
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.