Internet Privacy & Cookies Policy

Effective 09 January 2019

This is the Privacy Policy for Fair Pay Services Limited whose registered office address is at 5^th Floor, 42-50 Kimpton Road, Luton, Bedfordshire, LU2 0FP (Registered Company No. 11754947) (“Fair Pay”, “we”, or “us”).

We take privacy and the protection of personal data very seriously and therefore set out in this Privacy Policy our position regarding certain privacy matters.

This Privacy Policy covers all personal data that is shared with us in all forms. This includes the Website www.fairpayservices.co.uk (the “Website” and data shared by customers in order for us to provide our services (the “Services”).

This Privacy Policy provides an explanation as to what personal data will be collected from you when you access our Website, write to us, send us an email or speak to us on the phone, how it will be used, and how you can control the collection, correction and/or deletion of the data.

We may process your personal data as a Processor as defined in the Directive and the GDPR Directive 95/46/EC and the General Data Protection Regulation (GDPR) (EU) 2016/679, depending on your agreement with us. We are registered with the Information Commissioner’s Office (“ICO”) as a Data Controller, Registration Number ZA518445.

Information we collect

We may collect personally identifiable information about you, or “personal data”, such as your full name, phone number, email address or similar. We do not collect or process any data which falls into the category of “sensitive personal data” / “special category data” including, but not limited to, biometric data, genetic data, or other data relating to your health.

We may collect data from the following sources:

• Information provided to us when you communicate with us for any reason.
• Information that you provide by filling in forms on our Website, such as when you register to receive information such as a newsletter or contact us via the contact us page.
• Details of your visits to our Website and the resources that you access including, but not limited to, traffic data, location data, weblog statistics and other communication data.

Most of the services on our Website do not require any form of registration, allowing you to visit our pages without telling us who you are. However, some Services may require you to provide us with personal data. In these situations, if you choose to withhold any personal data requested by us, it may not be possible for you to gain access to certain parts of our Website and for us to respond to your query.

Use of your information

The information that we collect and store relating to you is primarily used to enable us to provide our Services to you. In addition, we may use the information for the following purposes:

• To provide you with information requested from us relating to our products or Services and to provide information on other products which we feel may be of interest to you if you have consented to receive such information.
• To meet our contractual commitments to you.
• To allow you to participate in interactive features of our online Service if you choose to use these.
• To notify you about any changes to our Website, such as improvements or Service/product changes, that may affect our Service.
• To comply with any our legal obligations
• If you are an existing customer, we may contact you with information about goods and Services similar to those which were the subject of a previous sale to you.
• We may use your data, or permit selected third parties to use your data, so that you can be provided with information about unrelated goods and Services which we consider may be of interest to you. We or they may contact you about these goods and Services by any of the methods that you consented to at the time your information was collected.
• If you are a new customer, we will only contact you or allow third parties to contact you only when you have provided consent and only by those means you provided consent for.
• If you do not want us to use your data for ourselves or third parties, you will have the opportunity to withhold your consent to this when you provide your details to us on the form on which we collect your data.

Protecting your information

• We will retain personal data we process for as long as it is needed to provide our Services. We may also retain personal information as necessary to comply with our legal obligations, resolve disputes and enforce our agreements. For any queries regarding our Data Retention practices, please use the contact details provided at the end of this Policy or on our website.
• Data that is provided to us is stored on our secure servers. Details relating to any transactions entered into via our site will be encrypted to ensure its safety. If you are visiting this website from outside of the United Kingdom, please be aware that you are sending information (including any personal data that you submit) to the United Kingdom where our servers are located. That information may be transferred within the United Kingdom depending on the type of information and how it is stored by us.
• Whilst we take steps to meet industry standard levels of security safeguarding, no method of the transmission of information via the internet is completely secure and therefore we cannot guarantee the security of data sent to us electronically and the transmission of such data is entirely at your own risk. Where we have given you (or where you have chosen) a password so that you can access certain areas of our site, you are responsible for keeping this password confidential.

Sharing your personal data

• We will not rent or sell your personal data to others. Any personal data which you elect to make publicly available on our Website, such as posting comments, will be available to others. If you remove information that you have made publicly available on our Website, copies may remain viewable in cached and archived pages of our Website, or if other users have copied or saved that information.
• We may share non-personally identifiable information (such as anonymous usage data, referring/exit pages and URLs, number of clicks, etc) with interested third parties to help them understand the usage patterns for our Website.
• We do not transfer data that we collect from you to locations outside of the European Economic area (EEA).

Disclosing your information

• We may disclose your personal information to partners of our services such as The Employment Management Platform (Flexr) for the fulfilment of services and contractual obligations.
• We may also disclose your personal information to third parties:
• Where we sell any or all of our business and/or our assets to a third party.
• Where we are legally required to disclose your information.
• To assist fraud protection and minimise credit risk.
• In the event that Personal Data is disclosed as a breach of security, we will promptly notify customers in accordance with the GDPR.

Your Rights

Right to be Informed

You have the right to be informed about the collection and use of your personal data.

Right of Access

You have the right to access your personal data. If you wish to access your personal data, including confirmation that we are processing your data, a copy of your personal data and any supplementary information, you can make a request known as a ‘Subject Access Request’ to us. These requests are free, and we have one month from receipt to respond.

Right to Rectification

If you believe the data we hold on you to be inaccurate, you have the right to have it rectified or completed (if it is incomplete).

Right to Erasure

You have the right to be ‘forgotten’ in certain circumstances. If your personal data is no longer necessary for the purpose if was originally collected for, if you withdraw consent, you object to its processing and there is no overriding legitimate interest, it has been processed unlawfully or you must comply with a legal obligation, you can request that the data be deleted.

Right to Restrict Processing

You have the right to restrict or suppress the processing of your personal data in certain circumstances. If you contest the accuracy of your data, it has been unlawfully processed, is no longer needed but you wish us to keep it in order to establish, exercise or defend a legal claim or you object to its processing and there is no overriding legitimate grounds to process it, you can request your data processing is restricted.

Right to Data Portability

You have the right to obtain and reuse your personal data for your own purposes across different services. This allows you to move, copy or transfer your personal data easily from one IT environment to another in a safe and secure way, without affecting its usability. This right only applies to information you have provided to a data controller.

Right to Object

You have the right to object to the processing of your information in certain circumstances. You have the absolute right to stop your data being used for direct marketing.

You can ask us not to use your personal data for marketing purposes. We will inform you, before collecting your data, if we intend to use your data for such purposes

You can tell us how you are happy for us to contact you whenever you provide your contact details, usually via tick boxes. You can also change your preferences at any time by contacting our team.

The Telephone Preference Service (TPS) is an official register on which an individual can opt out of receiving unsolicited sales or marketing calls. You can register online at: www.tpsonline.org.uk

Please note that it may take up to 28 days from when you register with TPS for the change to take effect on our communications with you.

Rights related to automated decision making including profiling

You have the right to human intervention in circumstances involving automated decision making. We will not make automated decisions about you or process your information in a way that would constitute profiling.

Use of cookies on our Website

You may notice that sometimes, after visiting a website, you see increased numbers of adverts from the site you visited. That’s because the website you visited has placed “cookies” on your web browser.

Cookies are small text files sent by a web server to your web browser, stored on your computer or mobile device and sent back to the web server each time you use their site. Cookies are not computer programs and cannot read other information saved on your hard drive. They cannot be used to disseminate viruses or get a user’s e-mail address. Using that cookie and web analytic tools, the website owner will be able to show you adverts on third-party websites that they think you might be interested in. The cookie does not give access to your computer or mobile device but may be able to identify you from your IP address.

There are two main kinds of cookies: session cookies and persistent cookies. Session cookies are deleted from your computer when you close your browser, whereas persistent cookies remain stored on your computer until deleted, or until they reach their expiry date.

By consenting to the Cookies and Privacy Policies and continuing to use this website, you agree to the use of cookies.

How we use Cookies

On occasion, we may gather information about your computer for our Services, and to provide statistical information regarding the use of our Website.

Such information will not identify you personally, it is statistical data about our visitors and their use of our site. This statistical data does not identify any personal details whatsoever. It is used by us to analyse how visitors interact with the Website so that we can continue to develop and improve this Website.

We may gather information about your general Internet use by using a cookie file that is downloaded to your computer. Where used, these cookies are downloaded to your computer automatically.  This cookie file is stored on the hard drive of your computer as cookies contain information that is transferred to your computer’s hard drive. They help us to improve our Website and the service that we provide to you.

All computers have the ability to decline cookies. This can be done by activating the setting on your browser which enables you to decline the cookies. Please note that should you choose to decline cookies, you may be unable to access particular areas of our Website.

Any advertising featured on our Website may also incorporate cookies, over which we have no control. Such cookies (if used) would be downloaded once you click on advertisements on our Website.

For more information on cookies you can read the guidance at All About Cookies.

Google cookies

Our Website uses Google Analytics to analyse the use of this website. Google Analytics generates statistical and other information about website use by means of cookies, which are stored on users’ computers. The information generated relating to our website is used to create reports about the use of the website. Google will store and use this information. Google’s Privacy Policy is available at: http://www.google.com/privacypolicy.html

Force24 Cookies & Tracking

Our organisation utilises Force24’s marketing automation platform.

Force24 cookies are first party cookies and are enabled at the point of cookie acceptance on this website. The cookies are named below:

• F24_autoID
• F24_personID

They allow us to understand our audience engagement thus allowing better optimisation of marketing activity.

f24_autoId – This is a temporary identifier on a local machine or phone browser that helps us track anonymous information to be later married up with f24_personid. If this is left anonymous it will be deleted after 6 months . Non-essential, first party, 10 years, persistent.

f24_personId – This is an ID generated per individual contact in the Force24 system to be able to track behaviour and form submissions into the Force24 system from outside sources per user. This is used for personalisation and ability to segment decisions for further communications. Non-essential, first party, 10 years, persistent.

The information stored by Force24 cookies remains anonymous until:

• Our website is visited via clicking from an email or SMS message, sent via the Force24 platform and cookies are accepted on the website.
• A user of the website completes a form containing email address from either your website or your Force24 landing pages.

The Force24 cookies will remain on a device for 10 years unless they are deleted.

Other Tracking

We also use similar technologies including tracking pixels and link tracking to monitor your viewing activities

Device & browser type and open statistics

All emails have a tracking pixel ( a tiny invisible image ) with a query string in the URL. Within the URL we have user details to identify who opened an email for statistical purposes.

Link Tracking

All links within emails and SMS messages sent from the Force24 platform contain a unique tracking reference, this reference help us identify who clicked an email for statistical purposes.

Refusing cookies

Most browsers allow you to refuse to accept cookies.

In Internet Explorer, you can refuse all cookies by clicking “Tools”, “Internet Options”, “Privacy”, and selecting “Block all cookies” using the sliding selector.

In Firefox, you can adjust your cookies settings by clicking “Tools”, “Options” and “Privacy”.

Blocking cookies will have an impact upon the usability of some of the features on this Website.

Third party links on our Website

You might find links to third party websites on our Website. These websites should have their own Privacy Policies which you should check. We do not accept any responsibility or liability for their policies whatsoever as we have no control over them.

Contacting us

We welcome any queries, comments or requests you may have regarding this policy. You can contact us at any time to exercise your rights as listed above.

For any additional questions you have about our collection and storage of data, please do not hesitate to contact us at [email protected]

If you would prefer to write to us then our contact address is Fair Pay Services Limited, 5th Floor, 42 – 50 Kimpton Road, Luton, Bedfordshire, LU2 0FP.

You can also contact us by telephone on +44 (0) 333 311 0633.

Changes to this Privacy Policy

Our Privacy Policy is reviewed regularly to ensure compliance with all applicable legal, regulatory and contractual obligations. This Privacy Policy was last updated in November 2020. Any updates to our Privacy Policy will be posted on our Website.