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Alternative Payments Ltd (also known and trading as Judopay) is registered in the United Kingdom under Company Number 07959933, with its registered address at Rise London, 41 Luke Street, London, United Kingdom, EC2A 4DP. Alternative Payments Ltd is registered with the UK Information Commissioner’s Office (ICO) under number ZA080409.
Judopay respects your privacy and is committed to protecting your personal data. This privacy notice will inform you about how we use and look after your personal data when you visit our website or when we provide our services to you. We will tell you about your privacy rights and how the law protects you.
Please also use the Glossary to understand the meaning of some of the terms used in this privacy notice.
This privacy notice aims to give you information on how Judopay collects and processes your personal data through all of your engagements with us, when using our services, including use of this website (www.judopay.com), including any data you may provide when you sign up to our services or request information about other services from Judopay.
This website and our services are not intended for children and we do not knowingly collect data relating to children.
It is important that you read this privacy notice together with any other privacy notice or fair processing notice we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. This Privacy Notice supplements other current notices published by Judopay, i.e. for its employees and employment candidates, Judopay clients and third-party relationships and is not intended to replace them.
Alternative Payments Limited (also known and trading as Judopay) is the Data Controller and responsible for your personal data (collectively referred to as “Alternative Payments Limited”, “Judopay”, “Judo”, “us” or “our” in this privacy notice).
Judopay has appointed a Data Privacy Manager who is responsible for overseeing activities, any questions in relation to this privacy notice and responding to specific queries about the processing of data held by us.
If you have any questions about this privacy notice, including any requests to exercise your legal rights (including an opt-out mentioned in this privacy notice), please contact the Data Privacy Manager using the details set out below.
Data Privacy Manager
Judopay
Address: Rise London, 41 Luke Street, London, United Kingdom, EC2A 4DP
Email: Privacy@judopayments.com
Tel: +44 (0)203 503 0600
www.judopay.com
You have the right to make a complaint at any time to the competent supervisory authority for data protection issues. In the UK, this is the Information Commissioner’s Office (ICO). Contact details can be found at www.ico.org.
At Judopay we would, however, appreciate the chance to understand and address your concerns before you approach the competent supervisory authority so please contact our Data Privacy Manager in the first instance.
Changes to the privacy notice and your duty to inform us of changes:
We reserve the right to update this Privacy Notice at any time, and, where appropriate, we will notify you when we make any substantial updates. We may also notify you in other ways from time to time about the processing of your personal information.
This version was last updated on 27th June 2019 and previous versions can be obtained by contacting us.
It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.
We reserve the right to update this Privacy Notice at any time, and, where appropriate, we will notify you when we make any substantial updates. We may also notify you in other ways from time to time about the processing of your personal information.
This version was last updated on 27th June 2019 and previous versions can be obtained by contacting us.
It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.
This website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third-parties to collect or share personal data about you. We do not own or control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy notice of every website you visit.
Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed, i.e. aggregated or anonymous data.
For clients and users of our products and services, we may collect, use, store and transfer different kinds of personal data about you, which we have grouped together as follows:
We do not collect any Special Categories of Personal Data about you. This includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data.
For prospective employees and contractors of Judopay, we may collect, use, store and transfer different kinds of personal data about you when you apply for a job at Judopay. This includes information within your CV or resume and any additional information we may request over the phone or via email to support our processing of your job application. This typically includes: See Hiring Data above.
We use different methods to collect data from and about you including through:
We will only use your personal data for the purposes we communicate to you and when the law allows us to. Most commonly, we will use your personal data in the following circumstances:
Generally, we do not rely on consent as a legal basis for processing your personal data other than in relation to sending third-party direct marketing communications to you via email or text message. You have the right to withdraw consent to marketing at any time by contacting us at Privacy@judopayments.com.
We have set out below, in a table format, a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are, where appropriate.
Third-party marketing – We do not sell your personal details to third party partners for marketing purposes.
You can ask us to stop sending you marketing communications emails at any time by following the opt-out links on any marketing or communication message sent to you or by contacting us at any time, see below:
Data Privacy Manager
Alternative Payments Limited
Address: Rise London, 41 Luke Street, London, United Kingdom, EC2A 4DP
Email: Privacy@judopayments.com
Tel: +44 (0) 203 503 0600
www.judopay.com
Where you opt out of receiving these messages, this will not apply to personal data provided to us as a result of any contractual or legal relationship or obligations we have with you.
We employ cookie technology to help log visitors to our web site. Cookies are pieces of data that are often created when you visit a website, and which are stored in the cookie directory of your computer or mobile device. A number of cookies may be created when you visit the Judopay website. The cookies do not contain any personal information about you, and they cannot be used to identify an individual user.
You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some of the enhanced features of this website may become inaccessible or not function properly.
When you visit this website we collect web statistics concerning your visit, which are stored in a log file. Log files allow us to record visitors’ use of the site. Log files are also used to detect potential harmful users, which may be reported by us to the relevant authorities.
We may have to share your personal data with relevant third parties for the operation of your contract with Alternative Payments Limited.
We require all third parties to respect the security of your personal data and to treat it in accordance with applicable law(s) and our own strict requirements.
We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.
Judopay, as a Data Controller, will not transfer your personal data outside the European Economic Area (EEA).
Judopay will take all reasonable legal, technical, and organisational measures to ensure that if your data is required to be transferred outside of the EEA, it will be treated securely and with an adequate level of protection, which is comparable to the level of protection offered within the EEA.
We treat the privacy and security of the personal data we hold very seriously.
We have put in place appropriate security measures to prevent your personal data from being accidentally lost, transferred, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to the same duty of confidentiality.
We have put in place procedures to deal with any suspected or confirmed personal data breach and will notify you on the details held for you and any applicable regulator of a breach where we are legally required to do so.
How long will you use my personal data for?
We will only retain your personal data for as long as is necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, contractual, accounting, or reporting requirements.
To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.
In some circumstances you can ask us to delete your data: see [Request erasure] below for further information.
In some circumstances we may anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes in which case we may use this aggregated information indefinitely without further notice to you.
Under certain circumstances, you have rights under data protection laws in relation to your personal data. Please see these within the glossary below.
If you wish to exercise any of the rights set out below please contact us on Privacy@judopayments.com or write to:
Data Privacy Manager
Alternative Payments Limited
Address: Rise London, 41 Luke Street, London, United Kingdom, EC2A 4DP
Tel: +44 (0) 203 503 0600
www.judopay.com
No fee is usually required. You will not have to pay a fee to access your personal data (or to exercise any of your other rights). However, we reserve the right to charge a reasonable fee if we believe that your request is clearly repetitive or excessive.
Where we believe that a request is excessive, e.g. significant amounts of data are requested, we will attempt to clarify in more detail exactly what you are looking for.
Alternatively, we may refuse to comply with your request in these circumstances.
We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.
We endeavour to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated. In such cases we will respond within two months of the date we clarified your request or the fee to access the data was paid.
You have the right to make a complaint at any time to the competent supervisory authority for data protection issues. In the UK, this is the Information Commissioner’s Office (ICO). Contact details can be found at www.ico.org.
We would, however, appreciate the chance to understand and address your concerns before you approach the competent supervisory authority. So please contact our Data Protection Officer in the first instance.
Data Privacy Manager
Alternative Payments Limited
Address: Rise London, 41 Luke Street, London, United Kingdom, EC2A 4DP
Email: Privacy@judopayments.com
Tel: +44 (0) 203 503 0600
www.judopay.com
DATA SUBJECT
A living natural person, who has rights regarding their personal data and can be identified through personal identifiable information (PII).
DATA PROCESSING
The collection, storage, access, use, sharing, manipulation and deletion of personal data.
SUPERVISORY AUTHORITY
The national body that regulates the General Data Protection Regulations (GDPR) in an EU member state. In the UK, the Supervisory Authority is the Information Commissioner’s Office (ICO), details of which can be located at www.ico.org.
LAWFUL BASIS
Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give you the best service and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent, where required or are otherwise required or permitted to by applicable law).
You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us.
Performance of Contract means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.
Comply with a legal or regulatory obligation means processing your personal data where it is necessary for compliance with other legal or regulatory obligation that we are subject to.
THIRD PARTIES
YOUR LEGAL RIGHTS
As a Data Subject, you have the right to:
Request access to your personal data (commonly known as a “data subject access request”). This enables you to receive a copy, in an agreed machine-readable format, of the personal data we hold about you and to check that it is complete, current and we are lawfully processing it.
In certain situations, we may seek further clarification of your data access request, e.g. where the request is complex or sizeable.
Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us. Also known as the right to rectification.
Request erasure of your personal data. Also commonly known as the “right to be forgotten”. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law.
Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios:
(a) if you want us to establish the data’s accuracy;
(b) where our use of the data has not been lawful, but you do not want us to erase it;
(c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or
(d) you have objected to our use of your data, but we need to verify whether we have overriding legitimate grounds to use it.
Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format.
Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
Withdraw consent at any time where we are relying on your consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you advise us of your request to withdraw your consent.