We ask that you read this website Privacy Policy carefully as it contains important information on who we are, how and why we collect, store, use and share personal information, your rights in relation to your personal information and on how to contact us and supervisory authorities in the event you have a complaint.
This website is not intended for use by children under the age of 18 and we do not knowingly collect or use personal information relating to children.
This website Privacy Policy is divided into the following sections:
Who we are
This website is owned and operated by Wisby Limited (‘we’, ‘us’, ‘our’), a company registered in England and Wales under company registration number 08626315. We are a provider of business services to other companies. We take your privacy very seriously, and we are committed to protecting and respecting your privacy, and to using technology to enhance your online security.
We collect, use and are responsible for certain personal information about you. When we do so, we are regulated under the General Data Protection Regulation (‘the Regulation’) which applies across the European Union (including in the United Kingdom) and for the purposes of the Regulation, we are the 'data controller', that is, the company which is responsible for and controls the processing of your personal data.
Our website
This privacy policy relates to your use of our website, www.wisby.com.
Throughout our website, we may link to other websites owned and operated by certain trusted third parties. These other third party websites may also gather information about you in accordance with their own separate privacy policies. For privacy information relating to these other third party websites, please consult their privacy policies as appropriate.
Our collection and use of your personal information
We collect personal information about you when you access our website, register with us, contact us, purchase services from us, post material to our website, complete customer surveys or send us feedback, by email or by telephone.
We collect this personal information from you either directly or indirectly, such as when you contact us, register with us, or purchase services from us, from third parties such as sanctions screening providers, credit reference agencies and customer due diligence providers, from cookies or automated monitoring of our website and other technical systems, such as our computer networks and connections, communications systems, email and instant messaging systems.
Whether information has to be provided by you, and if so why
This personal data is required to provide services to you. We will inform you at the point of collecting information from you, whether you are required to provide the information to us. If you do not provide the personal information we ask for, it may prevent us from providing services to you.
The personal information we collect about you depends on the particular activities carried out through our website. Such information might include:
We use this personal information to:
Our legal basis for processing your personal information
When we use your personal information we are required to have a legal basis for doing so. There are various different legal bases upon which we may rely, and these will depend on the personal information in question and the specific context in which we collect it.
The legal bases we may rely on include:
Further information—the personal information we collect, when and how we use it
For further details on when we collect personal information, what we collect as well as how we use it, please read the following sections:
| When you register with us | |
|---|---|
What information we ask for |
How we use your information |
Contact details: your name and email address |
We ask for this: — To create and manage your account with us — To communicate with you about your account and the services We will keep this information until: — You close your account with us — We close your account |
| What we use your personal information for | Our reasons |
|---|---|
|
To provide services to you and for billing and order fulfilment To help us identify you and any accounts you hold with us. To notify you of any changes to this website or to our services that may affect you. |
For the performance of our contract with our clients or to take steps at their request before entering into a contract |
To prevent and detect fraud against our company or you |
For our legitimate interests or those of a third party, i.e. to minimise fraud that could be damaging for us and for you |
|
Conducting checks to identify you and verify your identity Security vetting and screening for financial and other sanctions or embargoes Fraud prevention and detection Other processing necessary to comply with professional, legal and regulatory obligations that apply to us |
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, e.g. policies covering security and internet use |
For our legitimate interests or those of a third party, i.e. to make sure we are following our own internal procedures so we can deliver the best service to you |
Operational reasons, such as administration, improving efficiency, training and quality control |
For our legitimate interests or those of a third party, i.e. to be as efficient as we can so we can deliver the best service for you at the best price |
Ensuring the confidentiality of commercially sensitive information |
For our legitimate interests or those of a third party, i.e. to protect trade secrets and other commercially valuable information To comply with our legal and regulatory obligations |
|
Statistical and behavioural analysis, and research to help us manage our business, e.g. in relation to our financial performance, customer base, product range or other efficiency measures Customer profiling and analysing your purchasing preferences. |
For our legitimate interests or those of a third party, i.e. 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, i.e. 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, e.g. making sure that we can keep in touch with you about existing orders and new services |
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, e.g. 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 clients |
Credit reference checks via external credit reference agencies |
For our legitimate interests or those of a third party, i.e. to ensure you are likely to be able to pay for our services |
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, i.e. to maintain our accreditations so we can demonstrate we operate at the highest standards To comply with our legal and regulatory obligations |
Who we share your personal information with
We may share personal information with:
Some of those third party recipients may be based outside the European Economic Area — for further information including on how we safeguard your personal data when this occurs, see ‘Transfer of your information out of the EEA’.
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 to ensure they can only use your personal information to provide services to us and to you. We may share personal information with external auditors, e.g. in relation to ISO or Investors in People 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 re-structuring. Usually, information will be anonymised but this may not always be possible. The recipient of the information will be bound by confidentiality obligations.
Where your personal information is held
Information may be held at our offices and those of our associated 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 data while you have an account with us or we are providing products and services to you/your company. Thereafter, we will keep your personal information for as long as is necessary:
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.
Information about other individuals
If you give us information on behalf of someone else, you confirm that the other person has appointed you to act on his/her behalf and has agreed that you can:
Transferring your personal information out of the EEA
We may transfer your personal information to countries assessed by the European Commission as providing an adequate level of protection for personal information. We may equally transfer your personal information to third parties such as business partners and service providers, which are located outside the European Economic Area (EEA) for the purpose of fulfilling our obligations and providing our service. Such countries might not have the same data protection laws as the United Kingdom and EEA and any transfer of your personal information will be subject to the use of relevant safeguards, including but not limited to European Commission approved contracts, as permitted under Article 46 of the Regulation. We will ensure the transfer complies with data protection law and we will use standard data protection contract clauses that have been approved by the European Commission, thus safeguarding your privacy rights and giving you remedies in the unlikely event of a security breach.
When you used or contacted us via, or purchased a service from us or via this website, you agreed that we may transfer your personal data to countries outside the European Economic Area. Rest assured that we will always ensure any transfer is subject to appropriate security measures to safeguard your personal data.
If you would like further information please contact us (see ‘How to contact us’ below). We will not otherwise transfer your personal information outside of the United Kingdom or EEA or to any organisation (or subordinate bodies) governed by public international law or which is set up under any agreement between two or more countries.
Monitoring
We may monitor your use of this website through the use of cookies and similar tracking devices. For example, we may monitor how many times you visit, which pages you go to, traffic data, location data and the originating domain name of a user's internet service provider. This information helps us to build a profile of our users. Some of this data will be aggregated or statistical, which means that we will not be able to identify you individually. We may also monitor and record communications with you such as telephone conversations and emails for the purpose of training, quality assurance, fraud prevention and compliance.
Credit checking
We may receive information about you directly from other sources such as credit reference agencies or sanctions screening providers and customer due diligence providers, which we will add to the information we already hold about you in order to help us personalise our service to you.
To enable us and other companies in our group or partner companies to make credit decisions about you and for fraud prevention and money laundering purposes, we may search the files of credit reference and fraud prevention agencies (who will record the search). We may disclose information about how you conduct your account to such agencies and your information may be linked to records relating to other people living at the same address with whom you are financially linked. Other credit grantors may use this information to make credit decisions about you and the people with whom you are financially associated, as well as for fraud prevention, debtor tracing and money laundering purposes. If you provide false or inaccurate information and we suspect fraud, we will record this.
Cookies and similar technologies
A cookie is a small text file which is placed onto your device (e.g. computer, smartphone or other electronic device) when you use our website. We use cookies and other similar tracking technologies on our website. These help us recognise you and your device and store some information about your preferences or past actions.
For further information on our use of cookies, please see our Cookie Policy.
For further information on cookies generally visit www.aboutcookies.org or www.allaboutcookies.org or https://ico.org.uk/your-data-matters/online/cookies/.
Promotional communications
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 services.
We have a legitimate interest in processing your personal information for promotional purposes. 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. We may share your personal information with selected third parties, associated companies or organisations that are our business partners so that they may send you information about their products and services, depending on what you agree with us, and we or they may contact you by mail, email, telephone, SMS, text/picture/video message, fax, about our services, products, promotions, offers, charitable causes that may be of interest to you.
We will only ask whether you would like us and other businesses to send you marketing messages when you tick the relevant boxes when you complete our online order or consultation form or complete a purchase for the first time.
If you have previously agreed to being contacted in this way, you can unsubscribe at any time by:
—Emailing, calling or writing to us
—Using the ‘unsubscribe’ link in emails or ‘STOP’ number in texts
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.
For more information on your rights in relation to marketing, see 'Your rights’ below.
Your rights
Under the Regulation you have a number of important rights. In summary, those include rights to:
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, e.g. 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, 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:
Keeping your personal information secure
We have appropriate security measures in place to prevent personal information from being accidentally lost, or used or accessed in an unauthorised way. We limit access to your personal information to those who have a genuine business need to know it. Those processing your information will do so only in an authorised manner and are subject to a duty of confidentiality.
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.
We will use technical and organisational measures to safeguard your personal data, for instance, your data is stored on secure servers. While we will use all reasonable efforts to safeguard your personal data, you acknowledge that the use of the internet is not entirely secure and for this reason we cannot guarantee the security or integrity of any personal data that are transferred from you or to you via the internet.
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.
How to complain
We hope that we can resolve any query or concern you 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].
Changes to this website privacy policy
This website Privacy Policy was published on 25 May 2018 and last updated on 18 June 2018.
We may change this website privacy policy from time to time. You should check this privacy policy occasionally to ensure you are aware of the most recent version that will apply each time you access this Website.
How to contact us
Please contact us if you have any questions about this privacy notice or the information we hold about you. We welcome your feedback and questions.
If you wish to contact us, please send an email to support@wisby.com, write to 106 Lower Addiscombe Road, Croydon, UK, CR0 6AD or call +44 (0) 20 7084 6784.
Do you need extra help?
If you would like this website privacy policy in another format (for example: audio, large print, braille) please contact us (see ‘How to contact us’ above).
Last updated June 2018