PRIVACY POLICY

Conferma Pay ("we", “us”, “our”) are committed to protecting and respecting your privacy.

This policy sets out the basis on which any personal data we collect from you, or that you provide to us, will be processed by us. Please read the following carefully to understand our views and practices regarding your personal data and how we will treat it.

For the purpose of this policy the data controller is Conferma Limited of 5 Brooks Drive, Cheadle Royal Business Park, Cheadle, Cheshire, SK8 3TD, United Kingdom (trading as “Conferma Pay”). If you’d like to contact us please write to us at the above address, marking your letter for the attention of The Data Protection Representative or email us at [email protected]

INFORMATION WE COLLECT FROM YOU

We collect and process the following information about you:

· Information you provide to us - You may provide us with information by answering questions or filling in forms on the registration pages for our products, by corresponding with us by e-mail or otherwise. The personal information you provide may include your name, e-mail address and telephone number and other information about yourself to enable us to provide you with our services.

· Information we collect about you - When you use certain products we may automatically collect information about your device, including your IP address, information about your visit, your transactions, and how you use those products. This information may be combined with other information you provide to us, as described above.

· Information we receive from other sources – We receive information about you from your organisation. We also work closely with third parties (including, for example, business partners, payment card providers, issuing banks, service providers, analytics providers, and search information providers) and may receive information about you from them. This may be combined with other information you provide to us, as described above.

· Data that allows us to remember you, any interests that you have recorded and how you use this website. This allows us to arrange our website content to match your preferred interests. We use "cookies” to collect this data. Cookies are text files of small amounts of information that are downloaded by your computer or mobile device when you visit a website. You have the ability to accept or decline cookies by modifying the settings of your web browser. See our cookie policy for more information on how we use cookies and how to manage them. If you would like further guidance on cookies please click here https://www.aboutcookies.org/.

If you use our “Invite a Colleague” functionality you are responsible for ensuring that they are genuinely interested in receiving information on our products. When we contact them, we may inform any such individuals that they were nominated by you.

WHAT WE DO WITH YOUR PERSONAL INFORMATION

We will use your personal information, and may share your personal information with other third parties acting on our behalf, for one or more of the following purposes:

· to create and maintain your account with us;

· to handle and fulfil your requests where you request our services;

· to provide you with information about our products and services or to otherwise respond to any enquiry or complaint you may make to us;

· to prevent or detect fraud or abuses of our products and services;

· to develop and improve our services and to notify you about changes to our services;

· for market research purposes, where we may contact you to ask for your feedback;

· for regulatory and legal compliance purposes; and

· for our own administrative purposes, including training our staff, conducting internal audits or transferring assets as part of a sale, purchase or investment in the business.

If at any time after you have consented to us using your personal information and you wish us to stop processing your information, please email us at [email protected].

GROUNDS FOR PROCESSING YOUR PERSONAL INFORMATION

To process your personal information lawfully we need to rely on one or more valid legal grounds. For example, we may rely on legal grounds, such as:

· your request for services necessitating steps including processing of your personal data to be taken prior to entering into contract with you and any processing that is necessary for the performance of such contract;

· your consent to us using your personal information for marketing purposes;

· our legitimate interests as a business (except where your interests or fundamental rights override these). For example, it is within our legitimate interests to use your personal information to prevent or detect fraud or abuses of our products and services; or

· our compliance with a legal obligation to which Conferma Pay is subject.

WHERE WE STORE YOUR PERSONAL DATA

The data that we collect from you may be transferred to, and stored at, a destination outside the European Economic Area ("EEA"). It may also be processed by staff operating outside the EEA, who work for us or for one of our suppliers. Such staff maybe engaged in, among other things, the fulfilment of your order, the processing of your payment details and the provision of support services. By submitting your personal data, you agree to this transfer, storing or processing. We will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this privacy policy.

All information you provide to us is stored on our secure servers. Any payment transactions will be encrypted. Where we have given you (or where you have chosen) a password which enables you to access certain parts of this site, you are responsible for keeping this password confidential. We ask you not to share a password with anyone.

DISCLOSURE OF YOUR PERSONAL INFORMATION

There are circumstances where we may wish to disclose or are compelled to disclose your personal information to third parties. This will only take place in accordance with the law and for the purposes listed above.

YOUR RIGHTS UNDER DATA PROTECTION LAW

Data protection law provides individuals with certain rights, including the right to: access, rectify, withdraw consent, erase, restrict, transport, and object to the processing of, their personal information. Individuals also have the right to lodge a complaint with the relevant information protection authority if they believe that their personal information is not being processed in accordance with the law. Further information about your rights is set out below:

· Right to obtain a copy of your personal information. You have the right to obtain a copy of the personal information we hold about you. If you like would to obtain a copy of this information please email us at [email protected]. You may be required to submit a proof of your identity and a fee.

· Right to rectification. You may request that we rectify any inaccurate and/or complete any incomplete personal information.

· Right to withdraw consent. You may, as permitted by law, withdraw your consent to the processing of your personal information at any time. Such withdrawal will not affect the lawfulness of processing based on your previous consent. Please note that if you withdraw your consent, you may not be able to benefit from certain service features for which the processing of your personal information is essential.

· Right to object to processing. You may, as permitted by law, request that we stop processing your personal information.

· Right to erasure. You may request that we erase your personal information and we will comply, unless there is a lawful reason for not doing so.

Your right to lodge a complaint with the supervisory authority. We suggest that you contact us about any questions or if you have a complaint in relation to how we process your personal information. However, you do have the right to contact the relevant supervisory authority directly. To contact the Information Commissioner’s Office in the United Kingdom, please visit the ICO website for instructions.

LINKED WEBSITES

Our products and websites may, from time to time, contain links to and from the websites of our partner networks, advertisers and affiliates. If you follow a link to any of these websites, please note that these websites are subject to their own privacy policy.

CHANGES TO OUR PRIVACY POLICY

Any changes we may make to our privacy policy in the future will be posted on this page.

Dated: 19 July 2019