Asset55 – Privacy Policy
Your privacy is very important to us. Please read below as it describes our collection, use, disclosure, retention and protection of your personal information. This policy applies to any website, application or service that references this Privacy Policy. Where you provide us with your personal information in any of the ways described in section 4 below, you agree that we may collect, store and use it:
a. in order to perform our contractual obligations to you
b. based on our legitimate interest for processing (i.e. for internal administrative purposes or for the detection or
prevention of crime)
c. based on your consent, which you may withdraw at any time, as described in this Privacy Policy
Who are we
Our Privacy Policy applies to all products, applications and services offered by Asset55 Ltd (a company incorporated in England with company registration number 08335379 and whose registered office address is 1 Merchant Court, Monkton Business Park, South Tyneside NE31 2EX, UNITED KINGDOM), and its affiliates, but excludes any products, applications or services that have separate privacy policies that do not incorporate this Privacy Policy.
How we collect information
To the extent permissible under applicable law, we collect information about you and any other party whose details
you provide to us when you:
• register to use our websites, applications or services (including free trials); this may include your name (including
business name), address, email address and telephone number – we may also ask you to provide additional information about your business and your preferences
• provide your contact details to us when registering to use or accessing any websites, applications or services we make available or when you update those details
• contact us offline, for example by telephone, fax, SMS, email or post
If you intend giving us personal information about someone else, you are responsible for ensuring that you comply with any obligation and consent obligations under applicable data protections laws. In so far as is required by applicable data protection laws, you must ensure that beforehand you have their explicit consent to do so and that
How we use your information
To the extent permissible under applicable law, we use your information to:
• provide information and services that you have requested or any application, products or services you have ordered
• provide, maintain, protect and improve any application, products or services you have ordered
• manage and administer your use of applications, products and services you have asked us to provide
• manage our relationship with you (for example, customer services and support activities)
• monitor, measure, improve and protect our content, website, applications and services and provide an enhanced, personal, user experience for you
• undertake internal testing of our website, applications, systems and services to test and improve their security and performance – in these circumstances, we would anonymise any information used for such testing purposes
• provide you with any information that we are required to send you to comply with our regulatory or legal obligations
• detect, prevent, investigate or remediate, crime, illegal or prohibited activities or to otherwise protect our legal rights (including liaison with regulators and law enforcement agencies for these purposes)
• contact you to see if you would like to take part in our customer research (for example, feedback on your use of
our applications, products and services)
Our website, applications (including mobile applications) and services may contain technology that enables us to:
• check specific information from your device or systems directly relevant to your use of the websites, applications
or services against our records to make sure the websites, applications or services are being used in accordance
with our end-user agreements and to troubleshoot any problems
• obtain information relating to any technical errors or other issues with our website, applications and services
• collect information about how you and users use the functions of the features of our website, applications and
services
• gather statistical information about the environment from which you access our applications or service
You can manage your privacy settings within your browser or our applications and services (where applicable).
Mobile data
We may obtain information through mobile applications that you or your users install on their mobile devices to
access and use our website, applications or services or that you or your users use to provide other services related
to that mobile application (for example, to sync information from our application or service with such mobile
application).
Mobile applications may provide us with information related to a user’s use of that mobile application and use of our applications and services accessed using that mobile application. We may use such information to provide and improve the mobile application or our own application or services. For example, activity undertaken within our mobile application may be logged.
Analytics and benchmarking
We may use information generated and stored during your use of our services for our legitimate business interests
to enable us to give you the best service and/or solutions and the best experience. These purposes include to:
• carry out research and development to improve our services, products and applications
• develop and provide new and existing functionality and services (including statistical analysis, benchmarking and
forecasting services)
• provide you with location-based services (for example location relevant content) where we collect geo-location
data to provide a relevant experience
Whenever we use your information for our legitimate interests, we will ensure that your information is processed
on a pseudonymised basis and displayed at aggregated levels, which will not be linked back to you or to any living
individual.
You have the right to object to processing based on our legitimate interests, and if you wish to do so, please contact
us at privacy@assetfiftyfive.com to discuss this further. If you object, this may affect our ability to provide certain
services and / or solutions for your benefit.
Sharing your information
We may share your information with:
• our service providers and agents (including their sub-contractors) or third parties that process information on our behalf (e.g. internet service and platform providers and those organisations we engage to help us send
communications to you) so that they may help us to provide you with the applications, products, services and
information you have requested
• third parties used to facilitate payment transactions, for example clearing houses, clearing systems, financial
institutions and transaction beneficiaries
• credit reference and fraud prevention agencies
• law enforcement agencies so that they may detect or prevent crime or prosecute offenders
• any third party in the context of actual or threatened legal proceedings, provided we can do so lawfully (e.g. in
response to a court order)
• any third party to meet our legal and regulatory obligations, including statutory or regulatory reporting or the
detection or prevention of unlawful acts
• another organisation if we sell or buy (or negotiate to sell or buy) any business or assets
• another organisation to whom we may transfer our agreement with you; and Government departments where reporting is mandatory under applicable law
Marketing
From time to time, we may use your information to contact you with details about our applications, products and
services that we feel may be of interest to you.
You have the right at any time to stop us from contacting you for marketing purposes. If you wish to exercise these rights you can do so by selecting your contact preferences at the point where you provide us with your information on our websites, applications or services, using any preference centres we give you access to or by sending us an email to privacy@assetfiftyfive.com. You can also unsubscribe from any email marketing using the links provided in the emails we send to you.
Your information and rights
If you are based within the EEA or within another jurisdiction having similar data protection laws, in certain circumstances you have the following rights:
• the right to be told how we use your information and obtain access to your information
• the right to have your information rectified or erased or place restrictions on processing your information
• the right to object to the processing of your information e.g. for direct marketing purposes or where the processing is based on our legitimate interests
• the right to have any information you provided to us on an automated basis returned to you in a structured, commonly used and machine-readable format, or sent directly to another company, where technically feasible (“data portability”)
• where the processing of your information is based on your consent, the right to withdraw that consent subject to legal or contractual restrictions
• the right to object to any decisions based on the automated processing of your personal data, including profiling
• the right to lodge a complaint with the supervisory authority responsible for data protection matters (e.g. in the UK, the Information Commissioner’s Office)
If we hold any information about you that is incorrect or if there are any changes to your details, please let us know
so that we can keep our records accurate and up to date by sending us an email to
privacy@assetfiftyfive.com.
If you withdraw your consent to the use of your personal information for purposes set out in our Privacy Policy, we
may not be able to provide you with access to all or parts of our website, applications, and services.
We will retain your personal information for the duration of our business relationship and afterwards for as long
as is necessary and relevant for our legitimate business purposes, in accordance with our Data Retention, Marking
and Destruction Policy or as otherwise permitted by applicable laws and regulations. Where we no longer need your
personal information, we will dispose of it in a secure manner (without further notice to you).
Changes to this privacy policy
We may change this Privacy Policy from time to time. However, we will not reduce your rights under this PrivacyPolicy. We will always update this Privacy Policy on our website, so please try to read it when you visit the website. The “last updated” reference tells you when we last updated this Privacy Policy.
Security and storage of information
We will keep your information secure by taking appropriate technical and organisational measures against its
unauthorised or unlawful processing and against its accidental loss, destruction or damage. We will do our best
to protect your personal information, but we cannot guarantee the security of your information that is transmitted
to our website, applications or services or to other website, applications and services via an internet or similar connection.
If we have given you (or you have chosen) a password to access certain areas of our websites, applications or
services please keep this password safe – we will not share this password with anyone.
If you believe your account has been compromised, please contact us at privacy@assetfiftyfive.com.
Transfers outside of the European Economic Area
Personal information in the European Union is protected by data protection laws but other countries do not
necessarily protect your personal information in the same way.
Our website and some of our applications or services or parts of them may also be hosted in the United States or otherwise outside of the EEA (this means all the EU countries plus Norway, Iceland and Liechtenstein) (“EEA”) and this means that we may transfer any information that is submitted by you through the website or the application or service outside the EEA to the United States or to other territories outside of the EEA. When you send an email to us, this will also be stored on our email servers that are hosted in the United States.
We may use service providers based outside of the EEA to help us provide our website, applications and services to you (for example, platform and payment providers who help us deliver our applications and services, or advertising or execute your payments) and this means that we may transfer your information to service providers outside the EEA for providing our applications, advertising and services to you.
We take steps to ensure that where your information is transferred outside of the EEA by our service providers and hosting providers, appropriate measures and controls in place to protect that information in accordance with applicable data protection laws and regulations. Transfers are made in accordance with the requirements of Regulations (EU) 2016/679 (the General Data Protection Regulations or “GDPR”) and may be based on the use of the European Commission’s Standard Model Clauses for transfers of personal data outside the EEA.
By using our website, products or services or by interacting with us in the ways described in this Privacy Policy, you consent to the transfer of your information outside the EEA in the circumstances set out in this Privacy Policy. If you do not want your information to be transferred outside the EEA you should not use our website, applications or
services.
Other sites and social media
If you follow a link from our website, application or service to another site or service, this Privacy Policy will no longer apply. We are not responsible for the information handling practices of third party sites or services and we encourage you to read the privacy policies appearing on those sites or services.
Our websites, applications or services may enable you to share information with social media sites or use social media sites to create your account or to connect your social media account. Those social media sites may automatically provide us with access to certain personal information retained by them about you (for example any content you have viewed). You should be able to manage your privacy settings from within your own third party social media account(s) to manage what personal information you enable us to access from that account.
Cookies, analytics and traffic data
Cookies are small text files that are transferred from our websites, applications or services and stored on your device. We use cookies to help us provide you with a personalised service, and to help make our websites, applications and services better for you.
Our cookies may be session cookies (temporary cookies that identify and track users within our websites,
applications or services that are deleted when you close your browser or leave your session in the application or
service) or persistent cookies (cookies that enable our websites, applications or services to “remember” who you are
and to remember your preferences within our websites, applications or services and that will stay on your computer
or device after you close your browser or leave your session in the application or service).
We use the following different types of cookies:
Strictly necessary cookies
These are cookies that are needed for our websites, applications or services to function properly, for example, these
cookies allow you to access secure areas of our applications.
Performance cookies and analytics technologies
These cookies collect information about how visitors and users use our websites, applications and services, for
instance, which functionality visitors use most often, and if they get error messages from areas of the websites,
applications or services. These cookies don’t collect information that identifies a visitor or user. All information these
cookies collect is aggregated and therefore anonymous. We only use these cookies to improve how our website,
applications and services work.
Functionality cookies
These cookies allow our websites, applications and services to remember choices you make (such as your user
name, language or the region you are in) and provide enhanced, more personal features. These cookies can also be
used to remember changes you have made to text size, fonts and other parts of web pages that you can customise.
They may also be used to provide services you have asked for. The information these cookies collect may be
anonymised and they cannot track your browsing activity on other websites.
IP address and traffic data
We keep a record of traffic data that is logged automatically by our servers, such as your Internet Protocol (IP)
address, device information, the website that you visited before ours and the website you visit after leaving our site.
We also collect some site, application and service statistics such as access rates, page hits and page views. We are
not able to identify any individual from traffic data or site statistics.
Description Purpose
Google Analytics
Google Analytics uses “cookies”, to help the website analyse how users use the websites, applications or services. The information generated by the cookie about your use of the websites, applications or services (including your IP address) will be transmitted to and stored by Google on servers in the United States. Google will use this information for evaluating your use of the websites, applications or services compiling reports on website activity for website operators and providing other services relating to website activity and internet usage.
Google may also transfer this information to third parties where required to do so by law, or where such third parties process the information on Google’s behalf. Google will not associate your IP address with any other data held by Google. You may refuse the use of cookies by selecting the appropriate settings on your browser or within the application, however please note that if you do this you may not be able to use the full functionality of this website. By using our websites, applications or services you consent to the processing of data about you by Google in the manner and for the purposes set out
How to disable cookies
You may be able to configure your browser or our website, application or service to restrict cookies or block all cookies if you wish, however if you disable cookies you may find this affects your ability to use certain parts of our website, applications or services. For more information about cookies and instructions on how to adjust your browser settings to accept, delete or reject cookies, see the www.allaboutcookies.org website.
Further Information
If you have any queries about how we treat your information, the contents of this Privacy Policy, your rights under
local law, how to update your records or how to obtain a copy of the information that we hold about you, please write
to us at:
Data Protection
Asset55 Ltd
1 Merchant Court
Monkton Business Park
South Tyneside
NE31 2EX
UNITED KINGDOM
Alternatively, send an email to privacy@assetfiftyfive.com.
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