1. What information about me is collected
Personal Information refers to information that identifies (whether directly or indirectly) a particular individual. The Personal Information you will be required to provide when you communicate with us through our Sites will typically include:
- Your name;
- postal address,
- email address,
- device information about your device you use to access the Site,
- home and mobile telephone number; and any other Personal Information you provide to us with when you contact us.
Other Information means information that does not directly or indirectly identify, and cannot reasonably be used to identify, a particular individual or business. You could provide Other Information or it could be collected automatically. Examples may include information about your internet browser, demographic data such as city and state, usage information about your use of the Site, additional traffic data such as time and date of access, software crash reports, session identification numbers and access time, and other information regarding your use of the Site.
2. How we collect information
We collect information from you or about you when you provide this information to us directly. For example, we may obtain information when you request products or services from us, respond to surveys, contact customer support or otherwise interact with us via a Site, or via any of our social media channels.
4. How do we use your information
We use the information we collect to help us personalise and continually improve your experience on the Site. We may also use that information in the following ways:
- Respond to queries you raised on our Sites
- Evaluate your application for Services
- Support Merchant Hub’s legal compliance obligations
- Communicate with you about changes to our policies
- Send you newsletters, offers and promotions for our services, third party products and services, or special events by e-mail, text, or another medium, at all times in compliance with your preferences
- Administer promotions and surveys
- Optimize or improve our products, services and operations
- Detect, investigate, and prevent activities that may violate our policies or be illegal
- Perform statistical, demographic, and marketing analyses of users of the Site
We will only collect, use and share your PersonalInformation where we are satisfied that we have an appropriate legal basis todo this. This may be because:
- Our use of your Personal Information is in our legitimate interest as a commercial organisation, for example to contact you when you submit a query or complaint on our website; to offer you other products and services and sell to you products and services offered by us, our affiliates or third parties; to followup with you and investigate your query or complaint (as applicable), administer promotions and surveys, make improvements to our products and services, undertake market research into the users of our Sites, and to detect fraud and other illegal activity. In these cases we will look after your information at all times in a way that is proportionate and respects your privacy rights and you have a right to object to processing as explained in the Your Legal Rights section below;
- Our use of your Personal Information is necessary to comply with a relevant legal or regulatory obligation that we have.
5. What happens if you do not provide the personal information that we request
We need some of your Personal Information in order to contact you and follow up with you in respect of the query or complaint you have submitted on our website. For example, we need to know your personal contact details to identify you and contact you.
Where information is needed for these purposes, if you do not provide it we will not be able to contact you and follow up with you in respect of the query or complaint you have submitted on our website. We explain when this is the case at the point where we collect information from you.
6. Who do we share your information with
SERVICE PROVIDERS. We may share Personal and OtherInformation with agents, subsidiaries, affiliates (certain of our services are provided to you by our affiliates), partners and other third parties that perform functions on our behalf, such as hosting, billing, content management tools, analytics, customer service, fraud protection, etc. These entities have access to the Personal Information needed to perform their functions and are obligated to maintain the confidentiality and security of that PersonalInformation. The Service Providers are restricted from using, selling, distributing or altering this data in any way other than to provide the requested services.
REGULATORY AND LAW ENFORCEMENT PURPOSES. We may also use or disclose Personal Information if required to do so by law or in the good-faith belief that such action is necessary to (a) conform to applicable law or comply with legal process served on us or the Site; (b) protect and defend our rights or property, the Site or our users, or (c) act under emergency circumstances to protect the personal safety of us, our affiliates, agents, or the users of the Site or the public.
BUSINESS PURCHASERS. We may change our ownership or corporate organisation while providing the Site and services or sell certain assets associated with the Site. As a result, please be aware that in such event and to the extent permitted by law we may transfer some or all of your information to a company acquiring all or part of our assets or to another company with which we have merged.
SHARING OTHER INFORMATION. To the extent permitted under applicable local laws, we may disclose or share Other Information (or other information, other than Personal Information) in any other manner that we deem appropriate or necessary. Among other things, we may disclose Other Information to third parties to help us determine how people use parts of the Site and who our users are so we can improve the Site.
7. What steps do we take to keep personal information secure
The security of your information is important to us. information collected by the Site is stored in operating environments that are not available to the public. We therefore restrict access to your information to those of our employees who need to know that information to provide products and services to you. We have established physical, technical and administrative security processes that are commensurate with the sensitivity of the information collected to safeguard Personal Information. We have routine internal and external oversight practices in place to assess and maintain appropriate technical and organizational measures to safeguard your information.
Our security procedures mean that we may occasionally request proof of identity before we disclose your Personal Information to you. In certain telephone and in person transactions we may ask for your account number or other information to verify your identity before conducting the transactions you have requested. Note that Merchant Hub will never initiate a request via email for your Personal Information (e.g., personal ID, password, PIN or account number). If you receive an email asking for your Personal Information, you should be suspicious of the request and promptly contact us to report the suspicious activity.
Please understand, however, that while we try our best to safeguard yourPersonal Information once we receive it, no transmission of data over theInternet or any other public network can be guaranteed to be 100% secure. We review our security procedures to consider appropriate technology and methods to secure information.
8. For how long de we keep personal information
As a general rule, Merchant Hub will not keep your information for longer than is necessary.
- If you submit a query and you are a merchant of ours, we will keep your information for as long as we have a contract with you and for as long as we need your information for regulatory or evidential purposes after expiry or termination of your contract.
- However, where we have statutory obligations to keepPersonal Information for a longer period or where we may need your PersonalInformation for a longer period in case of a legal claim, then the retention period may be longer. For more information on retention please Contact Us using the details below.
9. Transferring information
Merchant Hub operates on a global basis. Accordingly, yourPersonal Information may be transferred and stored in countries outside theUnited Kingdom and European Economic Area that are subject to different standards of data protection. We will take appropriate steps ensure that transfers of Personal Information are in accordance with applicable law and carefully managed to protect your privacy rights and interests and transfers are limited to countries which are recognised as providing an adequate level of legal protection or where we can be satisfied that alternative arrangement are in place to protect your privacy rights. To this end:
- We ensure where we transfer your Personal Information outside Merchant Hub or to third parties who help provide our products and services, we obtain contractual commitments from them to protect your PersonalInformation, in particular through standard data protection model clauses adopted by the European Commission and appropriate transfer mechanism adopted under United Kingdom law (if applicable); or
- Where we receive requests for information from law enforcement or regulators, we carefully validate these requests before anyPersonal Information are disclosed.
You have a right to Contact Us for more information about the safeguards we have put in place (including a copy of relevant contractual commitments) to ensure the adequate protection of your PersonalInformation when this is transferred as mentioned above.
10. Your legal rights
Subject to certain exemptions, and in some cases dependent upon the processing activity we are undertaking, you have the following rights under data protection legislation:
- a right to ask for a copy of your Personal Information;
- a right to ask us to delete or correct any PersonalInformation we hold about you that is inaccurate;
- a right to request erasure of your Personal Information in certain circumstances;
- a right to data portability (this is a right to ask for yourPersonal Information in a commonly used electronic format where such PersonalInformation has been provided by you and the legal basis for processing that information is consent or contractual necessity);
- a right to restrict processing and a right to object to processing activities in certain circumstances;
- a right to stop your Personal Information from being used for direct marketing purposes; and
- a right to lodge a complaint with the InformationCommissioner (or other competent supervisory authority in the European EconomicArea or in the United Kingdom) if you believe that your Personal Information has not been processed in accordance with the requirements of the data protection legislation.
Where any processing is based on consent you have a right to withdraw consent at any time, without affecting the lawfulness of processing based on consent before its withdrawal.
We may ask you for additional information to confirm your identity and for security purposes, before disclosing the Personal Information requested to you. We reserve the right to charge a fee where permitted by law, for instance if your request is manifestly unfounded or excessive.
You can exercise your rights by contacting us. Subject to legal and other permissible considerations, we will make every reasonable effort to honour your request promptly or inform you if we require further information in order to fulfil your request.
We may not always be able to fully address your request, for example if it would impact the duty of confidentiality we owe to others, or if we are legally entitled to deal with the request in a different way.
11. Contact us
Address: Data Protection Officer, 104 LancasterGate 3rd and 4th Floor Lancaster Gate, London W2 3NT
Email: [email protected]