ABOUT THIS NOTICE
RWA Compliance Services Limited is committed to protecting the privacy and security of your personal information. This privacy notice describes how we collect and use personal information about you in relation to your use of our Development Zone. Please read it carefully.
Data protection law says that the personal information we hold about you must be:
- Used lawfully, fairly and in a transparent way.
- Collected only for valid purposes that we have clearly explained to you and not used in any way that is incompatible with those purposes.
- Relevant to the purposes we have told you about and limited only to those purposes.
- Accurate and kept up to date.
- Kept only as long as necessary for the purposes we have told you about.
- Kept securely
If you have any questions about this notice or how we collect and use personal information about you please contact us.
For details of how we use your information in relation to our other products and services, please see our other privacy notices.
We will use certain information about you (described in more detail below) for the purposes of providing and administering our platform. We will act as a “controller” of that information, as we decide how we use it for those purposes. However, you may also be able to upload certain information to our platform, which we will not use for our own purposes. Instead we will simply store and make available that information to you and your firm. In respect of this information, because we do not decide when it is provided or what it includes (you or your firm will do this, when it is uploaded), or what to use it for (we simply store it and make it available on your firm’s instructions) we act as a “processor”. For more details on how that information is used by your firm, you should consult your firm’s privacy notice. We are not responsible for your firm’s use of that information.
1: INFORMATION ABOUT US
We are RWA Compliance Services Limited. Our registered office is at Number 22 Mount Ephraim, Tunbridge Wells, England, TN4 8AS and our registered company number is 05389491.
If you have any questions, you can contact us at firstname.lastname@example.org or email@example.com or on 01604 709509.
2: DEVELOPMENT ZONE ACCOUNT INFORMATION AND OTHER CORRESPONDENCE
If you are an individual, when you create an account with us (or someone does so on your behalf) there will be personal information about you relating to that account and your use of it, such as your name, contact details, who you work for, account details, memberships of professional bodies, training and certification records, and correspondence with us about your account. Limited information may be shared with or by your employer, or the organisation paying for your subscription, in order to administer your account and confirm your eligibility for a subscription.
If you are an individual, we need certain information from you to open and administer your account, and you must provide this in order to hold an account with us, if you do not, we may not be able to open or maintain an account for you. Mandatory information fields are generally set out when you are opening an account, but in particular, to open an account for you we must have the following information:
- Your name and work email address.
- The name of the company you work for.
Other correspondence or interaction (for example by email, telephone, post, SMS or via our website) between you and us, will include personal information (such as names and contact details) in that correspondence. This may include enquiries, reviews, follow-up comments or complaints lodged by or against you and disputes with you or your organisation.
Call information. We may also collect details of phone numbers used to call our organisation and the date, time and duration of any calls. Please note that if we record your calls to or from us, we will inform you of this.
We will keep and use that information to administer carry out our contract with you (in relation to your account), to comply with any legal requirements for us to maintain certain records or carry out certain verifications and money laundering checks, and/or for our legitimate interests in preventing fraud, dealing with a complaint or enquiry and administering your (or your organisation's) account or order and any services we offer, as well as to review and improve our offerings, including troubleshooting, data analysis, testing, research, statistical and survey purposes.
The information above is kept for a period of up to 10 years after your account is closed (or after your last correspondence with us) to enable us to deal with any enquiries or claims and as required for tax purposes.
We may collect your name and contact details (such as your email address, phone number or address) in order to send you information about our products and services which you might be interested in.
You always have the right to "opt out" of receiving our marketing. You can exercise the right at any time by contacting us. If we send you any marketing emails, we will always provide an unsubscribe option to allow you to opt out of any further marketing emails. If you "opt-out" of our marketing materials you will be added to our suppression list to ensure we do not accidentally send you further marketing. We may still need to contact you for administrative or operational purposes, but we will make sure that those communications don't include direct marketing.
For individuals. We may use your contact details as necessary for our legitimate interests in marketing to you and maintaining a list of potential customers (including, in particular, if we collected them as part of you signing up for an account). Otherwise (in particular if you are not an account-holder) we will only send you marketing emails or texts with your consent.
For businesses. If you are a company or LLP (or are acting in a professional capacity as part of one) we use your contact details as necessary for our legitimate interests in marketing to you (by various channels) and maintaining a list of potential customers.
We never share your name or contact details with third parties for marketing purposes unless we have your "opt-in" consent to share your details with a specific third party for them to send you marketing. We do use third party service providers (such as Mailchimp) to send out our marketing, but we only allow them to use that information on our instructions and where they have agreed to treat the information confidentially and to keep it secure.
We retain your details on our marketing list until you "opt-out" at which point we add you to our suppression list. We keep that suppression list indefinitely to comply with our legal obligations to ensure we don't accidentally send you any more marketing.
When we send marketing emails to you, we use "web beacons" to collect information about when you open the email, your IP address and browser or email client type, and other similar information. We do this as necessary for our legitimate interests in reviewing and improving our direct marketing activities.
4: WEBSITE INFORMATION
We may collect information about you and your use of our website via technical means such as webpage counters and other analytics tools. This may include your IP address, login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access a website as well as the date and time of your access, what you interact with on our website, and the website from which access is made. We use this as necessary for our legitimate interests in administering and improving our website and its content, to ensure it operates effectively and securely, to develop our business and inform our marketing strategy, and for other administrative purposes. We may also create aggregate statistical data from that information (for instance, overall numbers of website visitors) which is not personal information about you.
We keep this website information about you for the duration of your session with us, unless there is an issue or incident in which case it may be kept for longer.
Third party websites. Our website may, from time to time, contain 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 data about you. We do not 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.
5: PHOTOS, CONTENT AND PROMOTIONAL MATERIAL
This is information about you which you provide to us (whether through our website or otherwise), or images or recordings of you which you allow us (or someone on our behalf) to take (including at our premises or events), for publication or display. This may include reviews, comments, testimonials, photographs (including stock photos and advertising material) and videos.
We may display and publish this content (and, if relevant, attribute it to you) on our platforms as necessary for our legitimate interests in providing content and for promotional purposes (or, in some circumstances, because you have specifically consented to us doing this). This information is kept and published or displayed by us for as long as we consider it relevant for those purposes. You can ask us to remove or delete your content at any time (subject to any agreements about our right to use it) by contacting us. If we are displaying or publishing the information based on your consent, you have the right to withdraw that consent at any time.
6: PROFESSIONAL INFORMATION
If you work for one of our customers, suppliers or business partners, the information we collect about you may include your contact information, details of your employment and our relationship with you. This information may be collected directly from you, or provided by your organisation. Your organisation should have informed you that your information would be provided to us, and directed you to this policy. We use this as necessary for our legitimate interests in managing our relationship with your organisation. If we have a business relationship with you or your organisation, we may receive information about you from your organisation.
We keep this information for up to 10 years after the end of our relationship with your organisation.
7: LEGAL CLAIMS
Where we consider there to be a risk that we may need to defend or bring legal claims, we may retain your personal information as necessary for our legitimate interests in ensuring that we can properly bring or defend legal claims. We may also need to share this information with our insurers or legal advisers. How long we keep this information for will depend on the nature of the claim and how long we consider there to be a risk that we will need to defend or bring a claim.
8: WHY ELSE DO WE USE YOUR INFORMATION?
Common uses of your information. We will only use your personal information when the law allows us to do so. Although in limited circumstances we may use your information because you have specifically consented to it, we generally use your information in the ways set out in this notice because:
we need to perform a contract we have entered into with you.
we need to comply with a legal obligation.
it is necessary for our legitimate interests (or those of a third party) and your interests and rights do not override those interests.
we need to protect your interests (or someone else's interests) or where it is needed in the public interest (although these circumstances are likely to be rare).
Change of purpose. We will only use your personal information for the purposes for which we collected it as set out in this notice, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If we need to use your personal information for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.
9: INFORMATION WE RECEIVE FROM THIRD PARTIES
We may also receive information about you from the following sources:
Our professional networks and sponsors. If your subscription is managed or paid for by a third party (such as a professional network, or a third party insurer sponsoring your subscription) then they may provide us with your name, professional email address, and details of your eligibility for a subscription, in order for us to administer your subscription.
Our service providers and group marketing sites. We work closely with third parties (including, for example, partners who promote demonstration or trial sign-ups to our platform) who may provide us with information about you such as your name, professional email, and telephone number, to be used in order to offer you a trial subscription.
Businesses we have bought. If we have acquired another business, or substantially all of its assets, which originally held your information, we will hold and use the information you provided to them, or which they otherwise held about you, in accordance with this privacy notice. If we are reviewing whether to acquire a business, or substantially all of its assets, which holds your personal data (whether you are a customer or employee of that business or otherwise) we may receive limited personal data about you from that business or professional advisors involved in the transaction, as necessary for our legitimate interests in making decisions about that acquisition. If we do not acquire that business, any information we receive about you will be deleted as soon as practicable following the decision not to acquire.
Publicly available sources. If relevant as part of our relationship with you, we may obtain information from publicly available sources such as LinkedIn or the FCA financial services register.
10: SHARING YOUR INFORMATION
We never sell your data to third parties. But we may need to share your information with third parties, including third-party service providers and other entities in our group. Third parties are required to respect the security of your personal information and to treat it in accordance with the law.
Why might we share your personal information with third parties? We may share your personal information with third parties if we are under a duty to disclose or share your personal information in order to comply with any legal obligation, or in order to enforce or apply our agreements with you, or to protect the rights, property, or safety of us, our customers, or others or where we have another legitimate interest in doing so. This may include exchanging information with other companies and organisations for the purposes of fraud protection and credit risk reduction.
Which third-party service providers process your personal information? We may need to share your personal information with third-party service providers (including contractors and designated agents) so that they can carry out their services. We may use third-party service providers in relation to the following types of activity: contract administration, CRMs, IT services (such as Microsoft) and payment processing.
When might we share your personal information with other entities in the group? We may share your personal information with other entities in our group as part of our regular reporting activities on company performance, in the context of a business reorganisation or group restructuring exercise, and for system maintenance support and hosting of data.
How secure is your information with third-party service providers and other entities in our group? All our third-party service providers and other entities in the group are required to take appropriate security measures to protect your personal information. Where third parties process your personal information on our behalf as "data processors" they must do so only on our instructions and where they have agreed to treat the information confidentially and to keep it secure.
What about other third parties? We may share your personal information with other third parties, for example with potential buyers and professional advisers in the context of the possible sale or restructuring of the business where necessary in connection with the purposes which your information was collected for. We may also need to share your personal information with a regulator or to otherwise comply with the law.
11: WHERE WE STORE YOUR INFORMATION
Our office headquarters and our main data centre are located in the UK. However, where required to perform our contract with you or for our wider business purposes, the information that we hold about you may be transferred to, and stored at, a destination outside the UK and the EU, in particular if you or your employer are located outside of the UK and the EU.
We will take all steps reasonably necessary to ensure that your personal information is treated securely and in accordance with this privacy notice.
Some countries or organisations outside of the UK and the EU which we may transfer your information to will have an "adequacy decision" in place, meaning the EU considers them to have an adequate data protection regime in place. These are set out on the European Commission website: https://ec.europa.eu/info/law/law-topic/data-protection/data-transfers-outside-eu/adequacy-protection-personal-data-non-eu-countries_en.
If we transfer data to countries or organisations outside of the UK and the EU which the EU does not consider to have an adequate data protection regime in place, we will ensure that appropriate safeguards (for example, model clauses approved by the EU or a data protection authority) are put in place where required. To obtain more details of these safeguards, please contact us.
12: DATA SECURITY
As well as the measures set out above in relation to sharing of your information, we have put in place appropriate internal security measures to prevent your personal information from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal information to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal information on our instructions and they are subject to a duty of confidentiality.
We have put in place procedures to deal with any suspected data security breach and will notify you and any applicable regulator of a suspected breach where necessary.
13: HOW LONG WILL WE KEEP YOUR INFORMATION FOR?
We have set out above indications of how long we generally keep your information. In some circumstances, it may be necessary to keep your information for longer than that in order to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.
To determine the appropriate retention period for personal information, we consider the amount, nature, and sensitivity of the personal information, the potential risk of harm from unauthorised use or disclosure of your personal information, the purposes for which we process your personal information and whether we can achieve those purposes through other means, and the applicable legal requirements.
In some circumstances we may anonymise your personal information so that it can no longer be associated with you, in which case we may use such information without further notice to you.
14: YOUR RIGHTS
Data protection law gives you a number of rights when it comes to personal information we hold about you. The key rights are set out below. More information about your rights can be obtained from the Information Commissioner's Office (ICO). Under certain circumstances, by law you have the right to:
Be informed in a clear, transparent and easily understandable way about how we use your personal information and about your rights. This is why we are providing you with the information in this notice. If you require any further information about how we use your personal information, please let us know.
Request access to your personal information (commonly known as a "data subject access request"). This enables you to receive a copy of the personal information we hold about you and to check that we are lawfully processing it.
Request correction of the personal information that we hold about you. This enables you to have any incomplete or inaccurate information we hold about you corrected.
Request erasure of your personal information. This enables you to ask us to delete or remove personal information where there is no good reason for us continuing to process it (for instance, we may need to continue using your personal data to comply with our legal obligations). You also have the right to ask us to delete or remove your personal information where you have exercised your right to object to processing (see below).
Object to processing of your personal information 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 us using your information on this basis and we do not have a compelling legitimate basis for doing so which overrides your rights, interests and freedoms (for instance, we may need it to defend a legal claim). You also have the right to object where we are processing your personal information for direct marketing purposes.
Request the restriction of processing of your personal information. This enables you to ask us to suspend the processing of personal information about you, for example if you want us to establish its accuracy or the reason for processing it.
Request the transfer of your personal information to another party where you provided it to us and we are using it based on your consent, or to carry out a contract with you, and we process it using automated means.
Withdraw consent. In the limited circumstances where we are relying on your consent (as opposed to the other bases set out above) to the collection, processing and transfer of your personal information for a specific purpose, you have the right to withdraw your consent for that specific processing at any time. Once we have received notification that you have withdrawn your consent, we will no longer process your information for the purpose or purposes you originally agreed to, unless we have another compelling legitimate interest in doing so.
Lodge a complaint. If you think that we are using your information in a way which breaches data protection law, you have the right to lodge a complaint with your national data protection supervisory authority (if you are in the UK, this will be the ICO).
If you want to review, verify, correct or request erasure of your personal information, object to the processing of your personal information, withdraw your consent to the processing of your personal information or request that we transfer a copy of your personal information to another party, please contact us.
No fee usually required. You will not have to pay a fee to access your personal information (or to exercise any of the other rights). However, we may charge a reasonable fee if your request for access is clearly unfounded or excessive. Alternatively, we may refuse to comply with the request in such circumstances.
What we may need from you. We may need to request specific information from you to help us understand the nature of your request, to confirm your identity and ensure your right to access the information (or to exercise any of your other rights). This is another appropriate security measure to ensure that personal information is not disclosed to any person who has no right to receive it. If we request any identification from you for this purpose, it is on the basis that it is necessary to comply with our legal obligations, and we will only keep and use this until your identity has been verified.
Please consider your request responsibly before submitting it. We will respond to your request as soon as we can. Generally, this will be within one month from when we receive your request but, if the request is going to take longer to deal with, we will let you know.
15: CHANGES TO THIS PRIVACY NOTICE
Any changes we make to our privacy notice in the future will be posted on this page and, where appropriate, notified to you by e-mail or otherwise. Please check back frequently to see any updates or changes to our privacy notice.