Information we collect from you

We collect and process some or all of the following types of information from you in the course of your use of the website or providing our services:

• Information that you provide by filling in forms on the Website or filing in forms as part of the registration process. This includes information provided at the time of registering to use the Website, subscribing to our service, or requesting further information or services. We may also ask you for information when you report a problem with the Website.
• Specifically, personal details such as name, e-mail address, IP address, address (which may include separate billing and delivery address) or any information input by when using the Website, completing our survey forms, or using our Services.
• If you contact Us, We may keep a record of that correspondence.
• We may also ask you to complete surveys that We use for research purposes, although you do not have to respond to them.
• Details of your visits to the Website including, but not limited to, traffic data, location data, weblogs and other communication data, and the resources that you access.
• We may also receive information about you from third parties if you use any websites or social media platforms operated by third parties (for example, Facebook, Instagram, Pinterest, Twitter or LinkedIn) and, if such functionality is available, you have chosen to link your account with your profile on those other websites or social media platforms.

The provision of your name and e-mail address is required from you to enable Us to provide you with our Services. We will inform you at the point of collecting information from you, whether you are required to provide the information to Us.

Information We Collect From Other Sources

FullContact Inc. provides Us with the facility to link the data you provide to Us, with other publicly available information about you that you have published on the Internet – this may include sources such as LinkedIn and other social media profiles.

Lawful basis for processing

We process your data in order to perform our obligations pursuant to the Terms and Conditions, as displayed on our Website. This is the lawful basis on which We collect and use your personal data.

If you are engaged by one of our sellers or suppliers, we may process your data in order to perform our obligations pursuant to a contract with that seller or supplier. Where we do so we rely on "legitimate interest" and the legitimate interest is "carrying out a contract with a seller or supplier".

Where you have contacted us via e-mail and telephone or participated in any surveys, we rely on "legitimate interest" and the legitimate interest is "responding and contacting you regarding the enquiries you have made in relation to the services we offer".

To ensure that content on the Website is presented in the most effective manner for you and for the device(s) you use to access and view the Website. We rely on "legitimate interest" as the legal basis for this processing, and the legitimate interest is the "maintenance and improvement of our Website for the benefit of all our users".

We rely on your consent as the lawful basis where you have agreed to participate in a survey, and for the processing of such personal information as has been collected through that survey.

Purposes of processing

We use information held about you in the following ways:

• To carry out our obligations arising from any contracts entered into between you and Us. If you are a buyer this includes and is not limited to allowing you to download the products and informing the seller that you have purchased/downloaded their product. If you are a seller this includes and is not limited to notifying you of purchases and other information about our services.
• To provide you with our services.
• To provide you with information and offers that you request from Us or which We feel may interest you.
• To ensure that content on the Website is presented in the most effective manner for you and for the device(s) you use to access and view the Website.
• To allow you to participate in interactive features of our service, when you choose to do so.
• To notify you about changes to our service.
• We will not sell your data to third parties.

Marketing

In addition to the above uses, where you have consented, permit selected third parties to use your information, to notify you about goods or services which may be of interest to you.

We may disclose your personal data to third parties service providers, agents, subcontractors and other associated organisations for the purposes of completing tasks and providing services to you on our behalf (e.g. to host our servers).

Payment is handled separately, and securely, through the payment processor you have selected during checkout ("Payment Processor"). Your payment card details are never collected by Us. If you want to find out more about how the Payment Processor processes your personal data, you can refer to their own privacy notice.

We may also disclose your personal data to third parties:

• in the event that We sell or buy any business or assets, in which case We may disclose your personal data to the prospective seller or buyer of such business or assets; or
• if We or substantially all of our assets are acquired by a third party, in which case personal data held by Us about our customers will be one of the transferred assets; or
• if We are under a duty to disclose or share your personal data in order to comply with any legal obligation, or in order to enforce or apply our Terms and Conditions and other agreements; or
• to protect Our rights, property, or safety or that of our affiliated entities and our users and any third party We interact with the to provide the Website; or
• to update the relevant seller of the individuals who have purchased/downloaded their products via our Website.
• in relation to selected third parties only, only to the extent that you have consented to such selected third parties notifying you about certain goods or services, which may be if interest to you.

Other than as set out above, and save insofar as is necessary in order for Us to carry out our obligations arising from any contracts entered into between you and Us, We will not share your data with third parties unless We have procured your express consent to do so.

Security

We take appropriate measures to ensure that any personal data are kept secure, including security measures to prevent personal data from being accidentally lost, or used or accessed in an unauthorised way. We limit access to your personal data to those who have a genuine business need to know it. Those processing your information will do so only in an authorised manner and are subject to a duty of confidentiality. Where We have given you (or where you have chosen) a password which enables you to access certain parts of the Website, you are responsible for keeping this password confidential.

We also have procedures in place to deal with any suspected data security breach. We will notify you and any applicable regulator of a suspected data security breach where We are legally required to do so.

Although We will do our best to protect your personal data, We cannot guarantee the security of your data transmitted to the Website; any transmission is at your own risk. Once We have received your information, We will use strict procedures and security features to try to prevent unauthorised access.

Keeping your personal data up to dateIf your personal details change you may update them by accessing the relevant page of the Website, or by contacting Us using the contact details below. If you have any questions about how We use data collected which relates to you, please contact Us by sending a request by email to the contact details below.

We will endeavour to update your personal data within seven (7) working days of any new or updated personal data being provided to Us, in order to ensure that the personal data We hold about you is as accurate and up to date as possible.

• How long we keep your personal data We will hold details relating to any transaction you make, such as your name, e-mail address, IP address, billing address, location data for 10 years from the date of the transaction for EU VAT purposes in respect of digital products.
• In instances where you have not participated in a transaction We will hold your contact details, for as long as you are registered with the site and for 3 years after.
• If you are engaged by one of our sellers or suppliers, we will hold your contact details for the period that supplier or seller is registered with us and for 3 years after.
• Where you have contacted us via e-mail and telephone, We will hold your contact and enquiry details for 3 years, unless you register.
• Where you have participated in our surveys, We will hold your survey details for 2 years.

Where we store your personal data

All information We hold about you is stored on secure servers in the EU.

The data that We collect from you may be transferred to, and stored at, a destination outside the European Economic Area ("EEA"). We will take all steps reasonably necessary to ensure that your data is held securely and in accordance with this Policy. Countries outside the EEA do not have the same data protection laws as the United Kingdom and EEA and we have therefore ensured that any of our suppliers who may transfer your personal data outside the EEA has put in place appropriate measures to protect your data, either by being a member of the US-EU Privacy Shield, or by entering into a European Commission approved contract (as permitted under Article 46(5) of the General Data Protection Regulation).

We will not otherwise transfer your personal data outside the EEA or to any organisation (or subordinate bodies) governed by public international law or which is set up under any agreement between two or more countries. If you would like further information please contact Us (see ‘Contact' below).

Under the General Data Protection Regulation you have a number of important rights free of charge. In summary, those include rights to:

• access to your personal data and to certain other supplementary information that this Policy is already designed to address,
• require Us to correct any mistakes in your information which We hold,
• require the erasure of personal data concerning you in certain situations,
• receive the personal data concerning you which you have provided to Us, in a structured, commonly used and machine-readable format and have the right to transmit those data to a third party in certain situations,
• object at any time to processing of personal data concerning you for direct marketing,
• object to decisions being taken by automated means which produce legal effects concerning you or similarly significantly affect you,
• object in certain other situations to our continued processing of your personal data,
• otherwise restrict our processing of your personal data in certain circumstances,
• claim compensation for damages caused by our breach of any data protection laws.

For further information on each of those rights, including the circumstances in which they apply, see the Guidance from the UK Information Commissioner's Office (ICO) on individual's rights under the General Data Protection Regulation.

If you would like to exercise any of those rights, please:

• email, call or write to Us,
• let Us have enough information to identify you (user name, registration details),
• let Us have proof of your identity and address (a copy of your driving licence or passport and a recent utility or credit card bill), and
• let Us know the information to which your request relates ,including any account or reference numbers, if you have them.

We hope that We can resolve any query or concern you raise about our use of your information.

The General Data Protection Regulation also gives you right to lodge a complaint with a supervisory authority, in particular in the European Union (or European Economic Area) state where you work, normally live or where any alleged infringement of data protection laws occurred. The supervisory authority in the UK is the Information Commissioner.

CHANGES TO OUR PRIVACY POLICY

We reserve the right to modify this Policy at any time. Any changes We may make to our Policy in the future will be notified and made available to you using the Website. Your continued use of the services and the Website shall be deemed your acceptance of the varied privacy policy.

INFORMATION ABOUT OUR USE OF COOKIES AND IP ADDRESSES

We may collect information about your mobile phone, computer or other device from which you access the Website including where available your IP address, operating system and browser type, for systems administration and to report aggregate information to third parties affiliates. This is statistical data about our users' browsing actions and patterns, and does not identify any individual. We may, however, use such information in conjunction with the data We have about you in order to track your usage of our services.

Our Website uses cookies to distinguish you from other users of our Website. This helps Us to provide you with a good experience when you browse our Website and also allows Us to improve the Website. By using our Website you agree to our use of cookies as more specifically set out below.

A cookie is a small file of letters and numbers that We store on your browser or the hard drive of your computer if you agree. Cookies contain information that is transferred to your computer's hard drive.

The cookies We use include:

• "Analytical" cookies. They allow Us to recognise and count the number of visitors and to see how visitors move around the Website when they are using it. This helps Us to improve the way our Website works, for example, by ensuring that users are finding what they are looking for easily.
• "Strictly necessary" cookies. These are cookies that are required for the operation of our Website. They include, for example, cookies that enable you to log into secure areas of our Website, use a shopping cart or make use of e-billing services.

Please note that third parties affiliates may also use cookies, over which We have no control.

You may block cookies by activating the setting on your browser that allows you to refuse the setting of all or some cookies. However, if you use your browser settings to block all cookies (including essential cookies) you may not be able to access all or parts of the Website. Unless you have adjusted your browser setting so that it will refuse cookies, our system will issue cookies as soon as you visit our Website.

CONTACT

All questions, comments and requests regarding this Privacy and Cookies Policy should be addressed to privacy@payhip.com write to Us at Payhip Limited, 1st Floor, 2 Woodberry Grove, London, N12 0DR.