This Privacy Notice (the “Privacy Notice“) sets out how Multipli Limited (“Multipli“, “We” or “Us“) handles and treats your personal information.
We take your privacy very seriously and We ask that you read this privacy notice carefully, along with our subscription funding agreement as it contains important information on:
- the personal information We collect about you;
- what We do with your information;
- who your information might be shared with; and
- your rights.
Who we are
Multipli is a company registered in England & Wales with company number 10609487 . We are a “data controller” for the purposes of the Data Protection Act 1998 and, after 25th May 2018, the General Data Regulation (EU) 2016/679 (“Data Protection Laws“), and We are responsible for, and control the processing of, your personal information.
Useful Words and Phrases
Please familiarise yourself with the following words and phrases as they have particular meanings in the Data Protection Laws and are used throughout this Privacy Notice:
|Personal Data||means any information from which a living individual can be identified.
This will include information such as telephone numbers, names, addresses, e-mail addresses, photographs, voice recordings. It will also include expressions of opinion and indications of intentions about data subjects (and their own expressions of opinion/intentions).
It will also cover information which on its own does not identify someone but which would identify them if put together with other information which we have or are likely to have in the future.
|Special Categories of Personal Data (or Sensitive Personal Data)||means any information relating to:
· Racial or ethnic origin;
· Political opinions;
· Religious beliefs or beliefs of a similar nature;
· Trade union membership;
· Physical or mental health or condition;
· Sexual life;
· Genetic data or biometric data for the purpose of uniquely identifying you; or
· Offences or alleged offences or information relating to any offences committed or allegedly committed.
|Processing||This covers virtually anything anyone can do with personal data, including:
· obtaining, recording, retrieving, consulting or holding it;
· organising, adapting or altering it;
· disclosing, disseminating or otherwise making it available; and
· aligning, blocking, erasing or destroying it.
|Data Subject||The person whom the data is about.|
|Information Commissioner||The UK Information Commissioner, who is responsible for implementing, overseeing and enforcing the Data Protection Laws.|
What information we collect?
Personal information provided by you
We collect personal information about you such as your:
- contact details;
- date of birth;
- passport details; and
- driving licence
We ask you to provide Us with the information described above in order that We can:
- fulfil Our obligations under the subscription funding agreement (i.e. provide the funding to you for the software as described in such agreement); and
- provide you with information in accordance with the ‘Marketing’ section below.
Failure to provide Us with the information means We cannot provide the funding to you and fulfil any obligations to you under any contract We may have with you (including the subscription funding agreement).
Personal information provided by third parties
We will also receive information about you from other sources, such as:
- credit reference agencies;
- Electoral roll; and
- Government registries such as Companies House.
Personal information about other individuals
If you give Us information on behalf of someone else (including any fellow colleagues or partners), you confirm that the other person has appointed you to act on his/her behalf and has agreed that you can:
- give consent on his/her behalf to the processing of his/her personal data in accordance with this privacy notice;
- receive on his/her behalf any data protection notices;
- give consent to the transfer of his/her personal data abroad; and
- give consent to the processing of his/her sensitive personal information.
Sensitive personal information
We may ask you to provide sensitive personal information as part of your request to receive funding for the software. If We request such information, We will explain why We are requesting it and how We intend to use it.
Sensitive personal information includes information relating to:
- your ethnic origin;
- your political opinions;
- your religious or philosophical beliefs;
- whether you belong to a trade union;
- your physical or mental health;
- your sexual life or sexual orientation;
- your genetic data;
- your biometric data; and
- We will treat as sensitive data concerning whether you have committed a criminal offence.
We will only collect your sensitive personal information with your explicit consent, or where We are required to do so in order to process your request to receive funding for the software.
How will we use the information about you?
We collect information about you so that We can:
- process your request to receive funding for the purchase of software and/or equipment;
- identify you and manage your funding arrangement that you may have with Us or other funding partners;
- conduct research, statistical analysis and behavioural analysis;
- if you agree, let you know about other products or services that may be of interest to you—see ‘Marketing’ section below;
- detect and prevent fraud; and
- do a credit check—see ‘Credit checking’ section below.
How long will we keep your data for?
Data will be retained for up to a period of [Time period to be inserted].
Why processing your personal data is legal?
Processing your personal information is in our legitimate interests to ensure that you have the necessary funds in order to repay Us pursuant to the subscription funding agreement. We cannot process your funding request without your name, home address, contact details, date of birth or legal entity name.
Monitoring and recording communications
We may monitor and record communications with you (such as telephone conversations and emails) for the purpose of quality assurance, training, fraud prevention and compliance.
We would like to send you information by post, email, telephone or text message (SMS).
We will only ask whether you would like Us to send you marketing messages when you enter into the subscription funding agreement with Us.
If you have consented to such receive marketing from Us, you can opt out at any time. See ‘What rights do you have?’ below for further information.
You can also manage your preferences by calling Our support number on 0800 043 9588
We may do a credit check on you:
- so that we can make credit decisions about you; and
- to prevent and detect fraud and money laundering.
Our search will be recorded on the files of the credit reference agency.
We may also disclose information about how you conduct your account to credit reference agencies and your information may be linked to records relating to other people living at the same address with whom you are financially linked.
Other credit businesses may use your information to:
- make credit decisions about you and the people with whom you are financially associated;
- trace debtors; and
- prevent and detect fraud and money laundering
If you provide false or inaccurate information to Us and We suspect fraud, We will record this.
If you want to see your credit file, please contact the credit reference agency which We use Equifax Limited.
Who your information might be shared with
We may disclose your personal data to:
- other companies within Our group;
- Our agents, any suppliers or dealers of items which are subject to your application for funding, credit reference agencies, introducers, referrers and any other person associated with the logdement of your application for funding of the software and/or equipment, your referees, employers, next of kin and any person acting on your behalf in connection with your application for funding of the software;
- credit reference agents—see ‘Credit checking’ above;
- law enforcement agencies in connection with any investigation to help prevent unlawful activity; and
- Our business partners in accordance with the ‘Marketing and opting out’ section above.
We may need to disclose your details to organisations who provide services to Us. For example: Collection agents. Some of Our suppliers will be in other countries which have different laws about data protection. We impose contractual and technical measures to ensure that your data is secure.
Keeping your data secure
We will use technical and organisational measures to safeguard your personal data, for example: We maintain strict security systems designed to prevent unauthorised access to your personal data by anyone, including Our staff who are not authorised.
Transfers of your information out of the EEA
We may need to transfer your personal data to Australia which is located outside the European Economic Area, for the purpose of credit processing and contract management. Any transfer of your data will be subject to a European Commission approved contract or mechanism that will safeguard your privacy rights and give you remedies in the unlikely event of a security breach.
What rights do you have?
As a Data Subject, you have the following rights under the Data Protection Laws:
- the right of access to personal data relating to you;
- the right to correct any mistakes in your information;
- the right to ask us to stop contacting you with direct marketing;
- the right to restrict or prevent your personal data being processed;
- the right to have your personal data ported to another data controller (e.g. if you decide to contract with a different supplier);
- the right to erasure;
- compensation for damage caused by contravention of the Data Protection Laws; and
- the right to complain to the ICO if you believe We have not handled your personal data in accordance with the Data Protection Laws.
These rights are explained in more detail below, but if you have any comments, concerns or complaints about Our use of your personal data, please contact Us (see ‘How to contact us’ below). We will respond to any rights that you exercise within a month of receiving your request, unless the request is particularly complex, in which case We will respond within three months.
Right to access to personal data relating to you
You may ask to see what personal data We hold about you and be provided with:
- a copy;
- details of the purpose for which it is being or is to be processed;
- details of the recipients or classes of recipients to whom it is or may be disclosed, including if they are overseas and what protections are used for those oversea transfers;
- the period for which it is held (or the criteria We use to determine how long it is held); and
- any information available about the source of that data.
Requests for your personal data must be made to Us in writing (see ‘How to contact us’ below), and a copy will be retained on your personnel file.
To help Us find the information easily, please give Us as much information as possible about the type of information you would like to see.
If, to comply with your request, We would have to disclose information relating to or identifying another person, We may need to obtain the consent of that person if possible. If We cannot obtain consent, We may need to withhold that information or edit the data to remove the identity of that person if possible.
There are certain types of data which We are not obliged to disclose to you, which include personal data which records Our intentions in relation to any negotiations with you where disclosure would be likely to prejudice those negotiations.
Right to correct any mistakes in your information
You can require Us to correct any mistakes in your information which We hold free of charge. If you would like to do this, please:
- email, call or write to Us (see ‘How can you contact us’ below)
- let Us have enough information to identify you; and
- let Us know the information that is incorrect and what it should be replaced with.
Right to ask Us to stop contacting you with direct marketing
You can ask Us to stop contacting you for direct marketing purposes. If you would like to do this, please:
- email, call or write to Us (see ‘How can you contact us’ below); and
- let Us know what method of contact you are not happy with if you are unhappy with certain ways of contacting you only (for example, you may be happy for Us to contact you by email but not by telephone).
Right to prevent processing of personal data
From 25 May 2018 and in accordance with the General Data Protection Regulations 2018, you may request that We stop processing your personal data temporarily if:
- you do not think that your data is accurate (but We will start processing again once we have checked and confirmed that it is accurate);
- the processing is unlawful but you do not want Us to erasure your data;
- we no longer needs the personal data for Our processing, but you need the data to establish, exercise or defend legal claims; or
- you have objected to processing because you believe that your interests should override Our legitimate interests.
Right to erasure
From 25 May 2018 and in accordance with the General Data Protection Regulations 2018, you can ask Us to erase your personal data where:
- you do not believe that We need your data in order to process it for the purposes set out in this privacy notice;
- if you had given Us consent to process your data, you withdraw that consent and We cannot otherwise legally process your data;
- you object to Our processing and We do not have any legitimate interests that mean We can continue to process your data; or
- your data has been processed unlawfully or have not been erased when it should have been.
There may be exemptions which mean We may continue to process your data.
Complaints to the Information Commissioner
If you do not think that We have processed your data in accordance with this notice, please contact Us in the first instance.
If you are not satisfied, you can complain to the Information Commissioner’s Office. Information about how to do this is available at www.ico.org.uk.
How to contact Us
Please contact Us if you have any questions about this privacy notice or the information We hold about you.
If you wish to contact Us, please send an email to email@example.com or write to Us at The Privacy Officer, Multipli Limited, Level 1, Regal House, 70 London Road, Twickenham, tW1 3QS or call Us on 0800 043 9588.
Changes to this privacy notice
We may change this privacy notice from time to time. We will provide You with a copy of this privacy notice at the time We seek to obtain data from you.