Our Privacy and Cookies Policy
1.1 We are committed to safeguarding the privacy of our website visitors, service users, individual customers and customer personnel.
1.2 This policy applies where we are acting as a data controller with respect to the personal data of such persons; in other words, where we determine the purposes and means of the processing of that personal data.
1.3 Our website incorporates privacy controls which affect how we will process your personal data. By using the privacy controls, you can [specify whether you would like to receive direct marketing communications and limit the collection, sharing and publication of your personal data]. You can access the privacy controls via [URL].
1.5 In this policy, “we”, “us” and “our” refer to FTP London Ltd. [For more information about us, see Section 20.]
2. The personal data that we collect
2.1 In this Section 2 we have set out the general categories of personal data that we process and, in the case of personal data that we did not obtain directly from you, information about the source and specific categories of that data.
2.2 We may process data enabling us to get in touch with you (“contact data”).[ The contact data may include your name, email address, telephone number, postal address and/or social media account identifiers. The source of the contact data is you. If you log into our website using a social media account, we will obtain elements of the contact data from the relevant social media account provider.
2.3 We may process your website user account data (“account data”). The account data may include your account identifier, name, email address, business name, account creation and modification dates, website settings and marketing preferences. The primary source of the account data is you, although some elements of the account data may be generated by our website. If you log into our website using a social media account, we will obtain elements of the account data from the relevant social media account provider.
2.4 We may process your information included in your personal profile on our website (“profile data”). The profile data may include your name, address, telephone number, email address, profile pictures, gender, date of birth, relationship status, interests and hobbies, educational details and employment details. The source of the profile data is you. If you log into our website using a social media account, we will obtain elements of the profile data from the relevant social media account provider.
2.5 We may process information relating to our customer relationships (“customer relationship data”). The customer relationship data may include your name, your contact details, your classification / categorisation within our customer relationship management system and information contained in or relating to communications between us and you. The source of the customer relationship data is you.
2.6 We may process your personal data that are provided in the course of the use of our services and generated by our services in the course of such use (“service data”). The service data may include previous purchases. The source of the service data is you and/or our services.
2.7 We may process information relating to transactions, including purchases of services, that you enter into with us and/or through our website (“transaction data”). The transaction data may include your name, your contact details, your payment card details (or other payment details) and the transaction details. The source of the transaction data is you.
2.8 We may process [information contained in or relating to any communication that you send to us or that we send to you] (“communication data”). The communication data may include the communication content and metadata associated with the communication. Our website will generate the metadata associated with communications made using the website contact forms.
2.9 We may process data about your use of our website and services (“usage data”). The usage data may include [your IP address, geographical location, browser type and version, operating system, referral source, length of visit, page views and website navigation paths, as well as information about the timing, frequency and pattern of your service use. The source of the usage data is our analytics tracking system.
2.10 Please do not supply any other person’s personal data to us, unless we prompt you to do so.
3. Purposes of processing and legal bases
3.1 In this Section 3, we have set out the purposes for which we may process personal data and the legal bases of the processing.
3.2 Operations – We may process your personal data for the purposes of operating our website, the processing and fulfilment of orders, providing our services, supplying our goods, generating invoices, bills and other payment-related documentation, and credit control. The legal basis for this processing is our legitimate interests, namely the proper administration of our website, services and business OR the performance of a contract between you and us and/or taking steps, at your request, to enter into such a contract.
3.3 Publications – We may process account data, profile data and/or service data for the purposes of publishing such data on our website and elsewhere through our services in accordance with your express instruction.
3.4 Relationships and communications – We may process contact data, account data, customer relationship data, transaction data and/or communication data] for the purposes of managing our relationships, communicating with you (excluding communicating for the purposes of direct marketing) by email, SMS, post, fax and/or telephone, providing support services and complaint handling. The legal basis for this processing is our legitimate interests, namely communications with our website visitors, service users, individual customers and customer personnel, the maintenance of our relationships, enabling the use of our services, and the proper administration of our website, services and business.
3.5 Personalisation – We may process account data, service data and/or usage data for the purposes of personalising the content and advertisements that you see on our website and through our services to ensure that you only see material that is relevant to you. The legal basis for this processing is for our legitimate interests, namely offering the best possible experience for our website visitors and service users.
3.6 Direct marketing – We may process contact data, account data, profile data, customer relationship data and/or transaction data for [the purposes of creating, targeting and sending direct marketing communications by email, SMS, post and/or fax and making contact by telephone for marketing-related purposes. The legal basis for this processing is for our legitimate interests, namely promoting our business and communicating marketing messages and offers to our website visitors and service users.
3.7 Research and analysis – We may process usage data, service data and/or transaction data] for the purposes of researching and analysing the use of our website and services, as well as researching and analysing other interactions with our business. The legal basis for this processing is for our legitimate interests, namely monitoring, supporting, improving and securing our website, services and business generally.
3.8 Record keeping – We may process your personal data for the purposes of creating and maintaining our databases, back-up copies of our databases and our business records generally. The legal basis for this processing is our legitimate interests, namely ensuring that we have access to all the information we need to properly and efficiently run our business in accordance with this policy.
3.9 Security – We may process your personal data for the purposes of security and the prevention of fraud and other criminal activity. The legal basis of this processing is our legitimate interests, namely the protection of our website, services and business, and the protection of others.
3.10 Insurance and risk management – We may process your personal data where necessary for the purposes of obtaining or maintaining insurance coverage, managing risks and/or obtaining professional advice. The legal basis for this processing is our legitimate interests, namely the proper protection of our business against risks.
3.11 Legal claims – We may process your personal data where necessary for the establishment, exercise or defence of legal claims, whether in court proceedings or in an administrative or out-of-court procedure. The legal basis for this processing is our legitimate interests, namely [the protection and assertion of our legal rights, your legal rights and the legal rights of others].
3.12 Legal compliance and vital interests – We may also process your personal data where such processing is necessary for compliance with a legal obligation to which we are subject or in order to protect your vital interests or the vital interests of another natural person.
4. Providing your personal data to others
4.1 We may disclose your personal data to any member of our group of companies this means our subsidiaries, our ultimate holding company and all its subsidiaries insofar as reasonably necessary for the purposes, and on the legal bases, set out in this policy.
4.2 We may disclose your personal data to our insurers and/or professional advisers insofar as reasonably necessary for the purposes of [obtaining or maintaining insurance coverage, managing risks, obtaining professional advice.
4.3 Your personal data is held in our website database.
4.4 We may disclose your data to our trading portal third party suppliers and our third part trade funding partners.
4.5 Financial transactions relating to [our website and services are handled by our payment services providers, Stripe. We will share transaction data with our payment services providers only to the extent necessary for the purposes of processing your payments, refunding such payments and dealing with complaints and queries relating to such payments and refunds. You can find information about the payment services providers’ privacy policies and practices at https://stripe.com/en-gb/privacy.
4.7 In addition to the specific disclosures of personal data set out in this Section 5, we may disclose your personal data where such disclosure is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person. We may also disclose your personal data where such disclosure is necessary for the establishment, exercise, or defence of legal claims, whether in court proceedings or in an administrative or out-of-court procedure.
5. International transfers of your personal data
5.1 In this Section 6, we provide information about the circumstances in which your personal data may be transferred to a third country under UK and/or EU data protection law.
5.2 We may transfer your personal data from the European Economic Area (EEA) to the UK and process that personal data in the UK for the purposes set out in this policy, and may permit our suppliers and subcontractors to do so, during any period with respect to which the UK is not treated as a third country under EU data protection law or benefits from an adequacy decision under EU data protection law; and we may transfer your personal data from the UK to the EEA and process that personal data in the EEA for the purposes set out in this policy, and may permit our suppliers and subcontractors to do so, during any period with respect to which EEA states are not treated as third countries under UK data protection law or benefit from adequacy regulations under UK data protection law.
5.3 The hosting facilities for our website are situated in Europe, the UK and the USA. The competent data protection authorities have made an adequacy determination with respect to the data protection laws of each of these countries. Transfers to each of these countries will be protected by appropriate safeguards, namely the use of standard data protection clauses adopted or approved by the competent data protection authorities.
5.4 You acknowledge that [personal data that you submit for publication through our website or services] may be available, via the internet, around the world. We cannot prevent the use (or misuse) of such personal data by others.
7. Retaining and deleting personal data
7.1 This Section 7 sets out our data retention policies and procedures, which are designed to help ensure that we comply with our legal obligations in relation to the retention and deletion of personal data.
7.2 Personal data that we process for any purpose or purposes shall not be kept for longer than is necessary for that purpose or those purposes.
7.3 We will retain your personal data as follows:
(a) contact data will be retained for a minimum period of 7 days following the date of the most recent contact between you and us, and for a maximum period of 10 years following that date;
(b) account data will be retained for a minimum period of 1 year following the date of closure of the relevant account, and for a maximum period of 10 years following that date].
8. Security of personal data
8.1 We will take appropriate technical and organisational precautions to secure your personal data and to prevent the loss, misuse or alteration of your personal data.
8.2 We will store your personal data on secure servers, personal computers and mobile devices, and in secure manual record-keeping systems.
8.3 The following personal data will be stored by us in encrypted form: your name, contact information, password(s) and cardholder data.
8.4 Data relating to your enquiries and financial transactions that is sent from your web browser to our web server, or from our web server to your web browser, will be protected using encryption technology.
8.5 You acknowledge that the transmission of unencrypted (or inadequately encrypted) data over the internet is inherently insecure, and we cannot guarantee the security of data sent over the internet.
8.6 You should ensure that your password is not susceptible to being guessed, whether by a person or a computer program. You are responsible for keeping the password you use for accessing our website confidential and we will not ask you for your password (except when you log in to our website).
9. Your rights
9.1 In this Section 9, we have listed the rights that you have under data protection law.
9.2 Your principal rights under data protection law are:
(a) the right to access – you can ask for copies of your personal data;
(b) the right to rectification – you can ask us to rectify inaccurate personal data and to complete incomplete personal data;
(c) the right to erasure – you can ask us to erase your personal data;
(d) the right to restrict processing – you can ask us to restrict the processing of your personal data;
(e) the right to object to processing – you can object to the processing of your personal data;
(f) the right to data portability – you can ask that we transfer your personal data to another organisation or to you;
(g) the right to complain to a supervisory authority – you can complain about our processing of your personal data; and
(h) the right to withdraw consent – to the extent that the legal basis of our processing of your personal data is consent, you can withdraw that consent.
9.3 These rights are subject to certain limitations and exceptions. You can learn more about the rights of data subjects by visiting [https://edpb.europa.eu/our-work-tools/general-guidance/gdpr-guidelines-recommendations-best-practices_en and https://ico.org.uk/for-organisations/guide-to-data-protection/guide-to-the-general-data-protection-regulation-gdpr/individual-rights/].
9.4 You may exercise any of your rights in relation to your personal data [by written notice to us, using the contact details set out below].
10. Third party websites
10.1 Our website includes hyperlinks to, and details of, third party websites.
10.2 In general we have no control over, and are not responsible for, the privacy policies and practices of third parties.
11. Personal data of children
11.1 Our website and services are targeted at persons over the age of 18 OR.
11.2 If we have reason to believe that we hold personal data of a person under that age in our databases, we will delete that personal data.
12. Updating information
12.1 Please let us know if the personal information that we hold about you needs to be corrected or updated.
13. Acting as a data processor
14. About cookies
14.1 A cookie is a file containing an identifier (a string of letters and numbers) that is sent by a web server to a web browser and is stored by the browser. The identifier is then sent back to the server each time the browser requests a page from the server.
14.2 Cookies may be either “persistent” cookies or “session” cookies: a persistent cookie will be stored by a web browser and will remain valid until its set expiry date, unless deleted by the user before the expiry date; a session cookie, on the other hand, will expire at the end of the user session, when the web browser is closed.
14.3 Cookies may not contain any information that personally identifies a user, but personal data that we store about you may be linked to the information stored in and obtained from cookies.
15. Cookies that we use
16. Cookies used by our service providers
17. Managing cookies
17.1 Most browsers allow you to refuse to accept cookies and to delete cookies. The methods for doing so vary from browser to browser, and from version to version. You can however obtain up-to-date information about blocking and deleting cookies via these links:
(a) https://support.google.com/chrome/answer/95647 (Chrome);
(d) https://support.microsoft.com/en-gb/help/17442/windows-internet-explorer-delete-manage-cookies (Internet Explorer);
17.2 Blocking all cookies will have a negative impact upon the usability of many websites.
17.3 If you block cookies, you will not be able to use all the features on our website.
18. Cookie preferences
19.1 We may update this policy from time to time by publishing a new version on our website.
19.2 You should check this page occasionally to ensure you are happy with any changes to this policy.
19.3 We may notify you of significant changes to this policy by email.
20. Our details
20.1 This website is owned and operated by FTP London Ltd.
20.2 We are registered in England and Wales under registration number 13719292, and our registered office is at 7 Bell Yard, London WC2A 2JR.
20.3 Our principal place of business is online.
20.4 You can contact us:
(a) by post, to the postal address given above
(b) using our website contact form
(c) by telephone, on the contact number published on our website or
(d) by email, using the email address published on our website.
21. Data protection registration
21.1 We are registered as a data controller with the UK Information Commissioner’s Office.
21.2 Our data protection registration number is [number].
22.1 Our representative within the EU with respect to our obligations under data protection law is Simon Massey and you can contact our representative by email: [email protected]
22.2 Our representative within the UK with respect to our obligations under data protection law is Simon Massey and you can contact our representative by email: [email protected]
23. Data protection officer
23.1 Our data protection officer’s contact details are: Simon Massey, [email protected]