We collect, use and are responsible for certain personal information about you. When we do so we are subject to the General Data Protection Regulation, which applies across the European Union (including in the United Kingdom) and we are responsible as ‘controller’ of that personal information for the purposes of those laws.
Key terms: It would be helpful to start by explaining some key terms used in this policy:
We, us, our: Firstbase Inc
Personal information: any information relating to an identified or identifiable individual
Special category personal information: Personal information revealing racial or ethnic origin, political opinions, religious beliefs, philosophical beliefs or trade union membership. Genetic and biometric data. Data concerning health, sex life or sexual orientation.
Personal information we collect about you:
We may collect and use the following personal information about you:
Your name and contact information, including email address, home address and telephone number.
Your photograph if you choose to provide it to us.
Information from accounts you link to us, eg Facebook, Google, Twitter.
Information about how you use our website, IT, communication and other systems.
This personal information is required to provide services to you. If you do not provide personal information we ask for, it may delay or prevent us from providing services to you.
How your personal information is collected:
We collect most of this personal information directly from you or from your employee via our website or our web API your employer has access to.
From a third party with your consent, eg: your employers HR system.
Via our IT systems, eg: website usage logging.
How and why we use your personal information:
Under data protection law, we can only use your personal information if we have a proper reason for doing so, eg:
To comply with our legal and regulatory obligations;
For the performance of our contract with you or to take steps at your
request before entering into a contract;
For our legitimate interests or those of a third party; or
Where you have given consent.
A legitimate interest is when we have a business or commercial reason to use your information, so long as this is not overridden by your own rights and interests.
The table below explains what we use (process) your personal information for and our reasons for doing so:
What we use your personal information for: Our reasons.
To provide services to you: For the performance of our contract with you or to take steps at your request before entering into a contract.
To prevent and detect fraud against you or Firstbase Inc: For our legitimate interests or those of a third party, ie to minimise fraud that could be damaging for us and for you.
Conducting checks to identify our customers and verify their identity: To comply with our legal and regulatory obligations.
Screening for financial and other sanctions or embargoes: To comply with our legal and regulatory obligations.
Other processing necessary to comply with professional, legal and regulatory obligations that apply to our business: e.g. under health and safety regulation or rules issued by our professional regulator: To comply with our legal and regulatory obligations
Gathering and providing information required by or relating to audits, enquiries or investigations by regulatory bodies: To comply with our legal and regulatory obligations
Ensuring business policies are adhered to, eg policies covering security and internet use: For our legitimate interests or those of a third party, ie to make sure we are following our own internal procedures so we can deliver the best service to you
Operational reasons, such as improving efficiency, training and quality control: For our legitimate interests or those of a third party, ie to be as efficient as we can so we can deliver the best service for you at the best price
Statistical analysis to help us manage our business, eg in relation to our financial performance, customer base, product range or other efficiency measures: For our legitimate interests or those of a third party, ie to be as efficient as we can so we can deliver the best service for you at the best price
Preventing unauthorised access and modifications to systems: For our legitimate interests or those of a third party, ie to prevent and detect criminal activity that could be damaging for us and for you. To comply with our legal and regulatory obligations
Updating and enhancing customer records: For the performance of our contract with you or to take steps at your request before entering into a contract. To comply with our legal and regulatory obligations. For our legitimate interests or those of a third party, eg making sure that we can keep in touch with our customers about existing orders and new products
Statutory returns: To comply with our legal and regulatory obligations
Ensuring safe working practices, staff administration and assessments: To comply with our legal and regulatory obligations. For our legitimate interests or those of a third party, eg to make sure we are following our own internal procedures and working efficiently so we can deliver the best service to you
Marketing our services to:
Existing and former customers; Third parties who have previously expressed an interest in our services; Third parties with whom we have had no previous dealings.
For our legitimate interests or those of a third party, i.e. to promote our business to existing and former customers.
External audits and quality checks, e.g. for ISO or Investors in People accreditation and the audit of our accounts: For our legitimate interests or a those of a third party, ie to maintain our accreditations so we can demonstrate we operate at the highest standards. To comply with our legal and regulatory obligations.
The above table does not apply to special category personal information, which we will only process with your explicit consent.
We may use your personal information to send you updates (by email, text message, telephone or post) about our services, including exclusive offers, promotions or new products AND/OR services.
We have a legitimate interest in processing your personal information for promotional purposes (see above ‘How and why we use your personal information’). This means we do not usually need your consent to send you promotional communications. However, where consent is needed, we will ask for this consent separately and clearly.
We will always treat your personal information with the utmost respect and never sell OR share it with other organisations for marketing purposes.
You have the right to opt out of receiving promotional communications at any time by:
Contacting us at firstname.lastname@example.org
Using the ‘unsubscribe’ link in emails or reply ‘STOP’
We may ask you to confirm or update your marketing preferences if you instruct us to provide further services in the future, or if there are changes in the law, regulation, or the structure of our business.
Who we share your personal information with:
We routinely share personal information withOther third parties we use to help us run our business, eg marketing agencies or website hosts or API service providers;
Third parties approved by you, eg social media sites you choose to link your account to or third party payment providers;
We only allow our service providers to handle your personal information if we are satisfied they take appropriate measures to protect your personal information. We also impose contractual obligations on service providers relating to ensure they can only use your personal information to provide services to us and to you. We may also share personal information with external auditors, eg in relation to ISO accreditation and the audit of our accounts.
We may disclose and exchange information with law enforcement agencies and regulatory bodies to comply with our legal and regulatory obligations.
We may also need to share some personal information with other parties, such as potential buyers of some or all of our business or during a restructuring.
Usually, information will be anonymised but this may not always be possible. The recipient of the information will be bound by confidentiality obligations.
We will not share your personal information with any other third party.
Where your personal information is held:
Information may be held at our offices and those of our group companies, third party agencies, service providers, representatives and agents as described above (see above: ‘Who we share your personal information with’).
Some of these third parties may be based outside the European Economic Area. For more information, including on how we safeguard your personal information when this occurs, see below: ‘Transferring your personal information out of the EEA’.
How long your personal information will be kept:
We will keep your personal information while you have an account with us or we are providing services to you. Thereafter, we will keep your personal information for as long as is necessary:
To respond to any questions, complaints or claims made by you or on your behalf;
To show that we treated you fairly;
To keep records required by law.
We will not retain your personal information for longer than necessary for the purposes set out in this policy. Different retention periods apply for different types of personal information.
When it is no longer necessary to retain your personal information, we will delete or anonymise it.
Transferring your personal information out of the EEA:
To deliver services to you, it is sometimes necessary for us to share your personal information outside the European Economic Area (EEA), eg:
With our offices outside the EEA;
With your and our service providers located outside the EEA;
If you are based outside the EEA;
Where there is an international dimension to the services we are providing to you.
These transfers are subject to special rules under European and UK data protection law.
If you would like further information please contact us (see ‘How to contact us’ below).
You have the following rights, which you can exercise free of charge:
Access: The right to be provided with a copy of your personal information (the right of access)
Rectification: The right to require us to correct any mistakes in your personal information
To be forgotten: The right to require us to delete your personal information—in certain situations
Restriction of processing: The right to require us to restrict processing of your personal information—in certain circumstances, eg if you contest the accuracy of the data
Data portability: The right to receive the personal information you provided to us, in a structured, commonly used and machine-readable format and/or transmit that data to a third party—in certain situations
To object: The right to object: at any time to your personal information being processed for direct marketing (including profiling); in certain other situations to our continued processing of your personal information, e.g. processing carried out for the purpose of our legitimate interests.
Not to be subject to automated individual decision-making: The right not to be subject to a decision based solely on automated processing (including profiling) that produces legal effects concerning you or similarly significantly affects you.
For further information on each of those rights, including the circumstances in which they apply, please contact us or see the Guidance from the UK Information Commissioner’s Office (ICO) on individuals’ rights under the General Data Protection Regulation.
If you would like to exercise any of those rights, please:
Email, call or write to us —see below: ‘How to contact us’; and
Let us have enough information to identify you (eg your full name, address and customer or matter reference number);
Let us have proof of your identity and address (a copy of your driving licence or passport and a recent utility or credit card bill); and
Let us know what right you want to exercise and the information to which your request relates.
We have appropriate security measures to prevent personal information from being accidentally lost, or used or accessed unlawfully. We limit access to your personal information to those who have a genuine business need to access it.
Those processing your information will do so only in an authorised manner and are subject to a duty of confidentiality. We continually test our systems and the systems follow ISO 27001 standards, which means we follow top industry standards for information security. We also have procedures in place to deal with any suspected data security breach. We will notify you and any applicable regulator of a suspected data security breach where we are legally required to do so.
If you want detailed information from Get Safe Online on how to protect your information and your computers and devices against fraud, identity theft, viruses and many other online problems, please visit www.getsafeonline.org. Get Safe Online is supported by HM Government and leading businesses.
We hope that we can resolve any query or concern you may raise about our use of your information.
The General Data Protection Regulation also gives you right to lodge a complaint with a supervisory authority, in particular in the European Union (or European Economic Area) state where you work, normally live or where any alleged infringement of data protection laws occurred. The supervisory authority in the UK is the Information Commissioner who may be contacted at https://ico.org.uk/concerns or telephone: 0303 123 1113.
This privacy notice was published on 26 May 2020.
We may change this privacy notice from time to time—when we do we will inform you via email and within the mobile application.
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