Safety

A. 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). We may collect, use, store, and transfer different kinds of personal data about you which include:

• Identity Data, which includes first name, maiden name, last name or similar identifier, marital status, title, date of birth, gender, country of residence, and nationality.
• Documentary Data, which includes copies of your passport, driver’s licence, ID card, proof of address, etc.
• Contact Data, which includes billing address, delivery address, email address, and telephone numbers.
• Financial Data, which includes bank account and payment card details. Contractual Data, which includes details about the products or services we provide to you.
• Transaction Data, which includes details about payments to and from you and other details of products and services you have purchased from or through us.
• Open Data, which includes details about you that are in public records, and information about you that is openly available on the internet.
• Social Relationships Data, which includes your family, friends, and other relationships.
• Location Data, which includes data we get about where you are.
• Technical Data, which includes internet protocol (IP) address, your login data (where applicable), 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 our websites.
• Communications Data, which includes what we learn from you from letters, emails (and other forms of electronic communication), and conversations between us. Profile Data, which includes your username and password (if any), purchases or services requested by you, your interests, preferences, and feedback.
• Usage Data, which includes information about how you use our website, products, and services.
• Marketing and Communications Data, which includes your preferences in receiving marketing from us and your communication preferences.
• Special Category Data, which includes details about your race or ethnicity and information about criminal convictions and offenses. We will only collect and use these types of data if the law requires or allows us to do so.

We also collect, use, and share Anonymous Data such as statistical or demographic data for any purpose. Anonymous 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.

B. HOW DATA WILL BE COLLECTED

We may collect personal information about you (or your business) from these sources: Data you give us:

• When you apply for our services or purchase our products;
• When you talk to us on the phone;
• In letters, emails, and other forms of electronic communication;
• In customer surveys or promotions;
• If your business is looking to enter into or has entered into a business arrangement with us;
• When you make payments to us in relation to the services or products we are providing to you.

C. HOW WE USE YOUR PERSONAL DATA

• Where we need to perform a contract we are about to enter into or have entered into with you.
• 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.
• Where we need to comply with a legal or regulatory obligation including any obligation arising out of applicable anti-money laundering regulations.
• Where we want to use your personal data for purposes similar to the one for which the personal data is provided.

Where we send direct marketing communications to you, or if we process any Special Category Data we will rely on your consent. For all other purposes, we generally do not rely on consent. You have the right to withdraw your consent at any time by contacting the DPO.

D. PURPOSES FOR WHICH WE WILL USE YOUR DATA

We usually collect your data for the following purposes:

• To register you (or your business) as a new customer or supplier
• To deliver our services/products including:
• To process your instructions and requests
• To Manage payments and fees/charges
• To Collect and recover money owed to us
• To manage our relationship with you
• Notifying you about changes to our terms and conditions or privacy policy
• Studying how our customers use products and services from us and other organizations
• Developing and carrying out marketing activities
• To develop and manage our brands, products, and services and to manage how we work with other companies that provide services to us and our customers
• To manage risk for us and our customers, to obey laws and regulations that apply to us, and to respond to complaints and seek to resolve them
• To run our business in an efficient and proper way. This includes managing our financial position, business capability, planning, communications, technical, and corporate governance
• To exercise our rights set out in agreements or contracts
• To deliver relevant website content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you
• To use data analytics to improve our website, products/services, marketing, customer relationships, and experiences
• To make suggestions and recommendations to you about goods or services that may be of interest to you.

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. We make sure we consider and balance any potential impact on you and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law).

Marketing

We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising. We have established the following personal data control mechanisms:

Promotional offers from us We may use your Identity, Contact, Technical, Usage, and Profile Data to form a view of 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. You will receive marketing communications from us if you have requested information from us, if you have provided your express consent for receiving that marketing, or, in certain cases if it is in our legitimate interest. We will not share your personal data with any company outside.

For Opting out You can ask us to stop sending you marketing messages by contacting us at any time. Where you opt out of receiving these marketing messages, you will still receive important information such as changes to your existing services or products purchased from us.