Privacy Policy
Privacy Policy - Last updated: 07th November 2023
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Introduction
- Luris Systems Ltd, trading as Safe Capital (“Safe Capital” or “us” or “we” or “our”), respects the privacy rights of our online visitors/customers and recognises the importance of protecting the information we collect about you. Our Privacy Policy is designed to help you understand how we collect, hold, use and disclose personally identifiable information about you.
- This Policy (together with our website Terms and Conditions and Cookie Policy, and any other documents referred to in it) sets out the basis on which Luris Systems Ltd with company number 15361556 and a registered address of 41 Bridgeman Terrace, Wigan, England, WN1 1TT will process any personal data we collect from you, or which you provide to us, in the course of using our website (“Platform”) https://www.safecapital.co.uk or as a user of our Safe Capital platform (“the Software”). For the purpose of this Privacy Policy, both the Platform and Software will be referred to as Platform (“Platform”).
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Your Information
- For the purpose of the UK Data Protection Act 2018 (“DPA’18”) Safe Capital is the data controller.
- The personal data of users is processed under the UK General Data Protection Regulation (“GDPR”) and DPA’18 on both the lawful basis of legitimate business interest and performance of a contract. All personal data collected from our customers is processed under the legal basis of performance of a contract, governed by the terms set out in the Terms and Conditions of Use. All other personal data, including the list below, is processed under the lawful basis of legitimate business interest. The provision of all personal data is necessary to facilitate the delivery of services.
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Information that may be collected about you
- The following personal data may be collected from you as a user when you use our Platform:
- Name;
- Date of birth;
- ID documentation (for example, passport images, photos/videos of your face);
- Company information (such as company name, number and address);
- Email address;
- Telephone number;
- Account identifier;
- Organisation name;
- Payment and account details; and
- Any information posted on the blog including, but not limited to, photographs, videos, opinions, articles and factual information.
- During the course of using our Platform other personal data may be collected from you as a user. The personal data that may be collected includes:
- Your Internet Protocol (“IP”) address;
- Referral source;
- Length of visit;
- Any referring or exit pages taking you to or from our Platform;
- Your web and browser type and version;
- Your device type, for example IOS or Android;
- Your time zone and location;
- Your account creation and modification dates;
- Your transaction details;
- Date and time stamps;
- Any browser plug-ins; and
- Your operating system.
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How your personal data may be used
- Safe Capital may use your data in the following ways:
- To provide the customer user with services.
- To display posts and comments on the blog.
- To conduct know your business (“KYB”) checks.
- To ensure that content from our Platform is presented in the most optimised and effective manner for you and for your computer.
- To diagnose or fix technology problems.
- To control unauthorised use or abuse of our Platform and our products and services, or otherwise detect, investigate or prevent activities that may violate Platform policies or be illegal.
- To carry out obligations arising from any interaction entered into between you and Safe Capital.
- To allow you to participate in interactive features of this service, when you choose to do so.
- To notify you about changes to any service.
- To administer our Platform including data analysis, testing, traffic monitoring, research, statistical and survey purposes.
- To provide you with information, products or services that you request or that we feel may interest you, where you have consented to be contacted for such purposes.
- To gather general statistical information which may then be provided to third parties. In such case any information provided to third parties will not allow you as a data subject to be personally identified.
- If you do not wish to be contacted for marketing purposes, please tick any relevant box on which you submit your data or unsubscribe from any marketing communication using the unsubscribe function in the footer of the email. You can also unsubscribe from any marketing communication by sending an email to privacy@safecapital.co.uk.
- Please note that if you click on, or follow, any links from our Platform to external websites, this privacy policy will no longer apply. Please check the privacy policies of any such external sites before submitting any personal data, as Safe Capital cannot accept any responsibility or liability in relation to them.
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How your data may be disclosed
- In order to provide services to you, Safe Capital may transfer your personally identifiable information to third parties, parents, affiliates, subsidiaries and service providers, some of which may process and/or store your personally identifiable information outside of the European Economic Area (“EEA”). However, in such an instance all reasonable steps will be taken to ensure that your personal data is treated securely and in accordance with this Privacy Policy (where possible). Any data transfers that take place outside of the EEA will be covered by appropriate safeguards, for example Standard Contractual Clauses (“SCCs”).
- Third parties in which your personally identifiable information may be disclosed to include, but are not limited to:
- Gocardless (direct debit services): https://gocardless.com/privacy/payers
- GoCardless (Open banking - Account Detail Service ("ADS")): https://gocardless.com/privacy/account-holders/
- Moneyhub (Open banking - ADS and Payment Initiation Services ("PIS")): https://www.moneyhub.com/privacy-policy-and-cookies
- Twilio (short message services ("SMS")): https://www.twilio.com/legal/privacy
- Brightbox (web hosting services): https://www.brightbox.com/legal/privacy/
- First Data Europe Ltd (card payment services): https://www.fiserv.com/en/about-fiserv/privacy-notice.html
- Hubspot (Customer Relation Management ("CRM")): https://legal.hubspot.com/privacy-policy
- Clickmeeting (Webinars): https://clickmeeting.com/legal
- Revolut (Confirmation of Payee ("COP")): https://www.revolut.com/privacy-policy/
- Stripe (card payment services): https://stripe.com/gb/privacy
- Amiqus (KYB/Know Your Customer ("KYC")): https://amiqus.co/policies/privacy
- Persona (KYB/KYC): https://withpersona.com/legal/privacy-policy
- In addition to the above listed organisations, there may be times where your data is shared with the local authority or regulator for the purpose of complying with legal and regulatory obligations.
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Servers
- All information you provide to us will be stored on our UK based secure servers encrypted using AES-256 encryption.
- We take your privacy seriously, and will take all reasonable steps to protect your personal data, but please beware that any data which you send to our Platform is sent at your own risk.
- The data that we collect from you may be transferred to, processed and/or stored at a destination outside of the EEA. By submitting your personal data, you agree to this. We will take all reasonable steps to ensure that your data is treated securely and in accordance with this Privacy Policy.
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Data Storage
- We hold personally identifiable information in a combination of hard copy and electronic files for the period necessary to support our Platform, comply with our legal obligations, resolve disputes, or otherwise fulfil the purposes outlined in this Privacy Policy. We use third-party information system providers who may store or have access to your personal information. We may also retain backup information on our servers for some time to comply with applicable law or our internal security policies. We do not always remove or delete all of your information for a number of reasons including due to technical and systems constraints and contractual or legal requirements.
- We operate a data retention period of 7 years (6 years plus 1-year longstop) from the date of our last interaction with a user. 7 years after the date of our last interaction with a user all of the personal data provided by the user during all of their interactions with us will be reviewed and securely deleted/destroyed. Once the period of 7 years has been reached, any posts from a user will be archived and anonymised, meaning that all personal data is removed from the posts. This personal data, along with any other data that identifies the individual, will then be reviewed and securely deleted/destroyed.
- We ask you not to send us, and you not to disclose, any special category personal data (such as information related to racial or ethnic origin, religion or other beliefs, health, criminal background or trade union membership) on or through our Platform or otherwise. If, contrary to this request, you do provide any sensitive information, in doing so you acknowledge that Safe Capital will be collecting and handling that information in accordance with this Privacy Policy.
- No method of transmission over the internet, method of electronic storage or other security methods is one hundred percent secure. Therefore, while we strive to use commercially acceptable means such as firewalls, password-protected databases with limited physical and electronic access, and encryption to protect your personally identifiable information against unauthorised use, disclosure or modification, we cannot guarantee its absolute security.
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Processing of personal data of those below the age of 13
- Our Platform is not intended for use by anyone under the age of 13 nor does Safe Capital knowingly collect or solicit personally identifiable information from anyone under the age of 13. If you are under the age of 13, you may not attempt to send any information about yourself to us, including your name, address, telephone number, or email address.
- In the event that we confirm that we have collected personally identifiable information from someone under the age of 13 without verification of parental consent, we will delete/destroy that information promptly. If you are a parent or legal guardian of a child under the age of 13 and believe that we might have any information from or about such child, please contact us at the email or mailing address provided at the end of this Privacy Policy.
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Data subject rights
- Subject access request - You have the right under DPA’18 to access the information we hold about you. If you wish to exercise this right, please send your request to privacy@safecapital.co.uk.
- Right to rectification – You have the right under DPA’18 to request the amendment or updating of all the information that we hold about you. If you wish to exercise this right, please send your request to privacy@safecapital.co.uk.
- Right to erasure – You have the right under DPA’18 to have all of the information that we hold about you deleted in line with our statutory and legal responsibilities. If you wish to exercise this right, please send your request to privacy@safecapital.co.uk.
- Right to restriction of processing – In line with Article 18 (1) (a) to (d) of GDPR, you have the right under DPA’18 to obtain from the controller restriction of processing. If you wish to exercise this right, please send your request to privacy@safecapital.co.uk.
- Right to data portability -You may have the right under DPA’18 to request a copy of all of the information we hold about you if the processing is based on consent, contract or the processing is being carried out by automated means. If you wish to exercise this right, please send your request to privacy@safecapital.co.uk.
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Enforcement
- We cooperate with the appropriate regulatory authorities, including local data protection authorities (the UK Information Commissioner’s Office (“ICO”)), to resolve any complaints regarding the collection, processing and disclosure of personally identifiable information that cannot be resolved between Safe Capital and the individual.
- If you have a concern about your privacy or you would like to know more about how your personally identifiable information is collected or used please contact us. We ask that when you contact us with a complaint, please include contact information and clearly describe your complaint. For any complaint regarding privacy please use privacy@safecapital.co.uk.
- We will respond to your request or complaint within a reasonable time and will let you know next steps in resolving your complaint. If you are not satisfied with our response, you may also contact your local and federal data protection authorities to lodge a complaint.
- Should you not be satisfied with the process, conduct or response to a request you may have made you have the right to complain to the ICO (https://ico.org.uk/make-a-complaint/).
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Notices and provisions
- We reserve the right to change our Privacy Policy at any time. These changes will take immediate effect unless you are notified otherwise. We recommend that you refer to this Privacy Policy on an ongoing basis so that you understand our current practice at the time of using our service. Unless stated otherwise in a separate agreement, this Privacy Policy applies to all information we hold about you.
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Contact us
- Safe Capital regularly reviews its compliance with relevant data protection laws and this Privacy Policy. If you have any questions or want to get in contact with us regarding this Privacy Policy, please feel free to email us at privacy@safecapital.co.uk or write to us at 41 Bridgeman Terrace, Wigan, England, WN1 1TT.
