Please read this privacy policy carefully before using this application and the www.simpletransfer.co.uk or https://web.simpletransfer.co.uk site. The term ‘website’ includes the use of our smartphone applications downloaded from Android Playstore or Apple Appstore.

We respect your privacy and are committed to protecting your personal data. This privacy policy will inform you as to how we look after your personal data when you visit our website or use our app (regardless of where you visit or use it from) and tell you about your privacy rights and how the law protects you.
This privacy policy is provided in a layered format so you can click through to the specific areas set out below. Please also use the GLOSSARY to understand the meaning of some of the terms used in this privacy policy.

1. PURPOSE OF THIS POLICY
2. THE DATA WE COLLECT
3. IF YOU FAIL TO PROVIDE PERSONAL DATA
4. HOW IS YOUR PERSONAL DATA COLLECTED?
5. HOW WE USE YOUR PERSONAL DATA
6. THIRD-PARTY LINKS
7. MARKETING
8. PROMOTIONAL OFFERS FROM US
9. THIRD-PARTY MARKETING
10. OPTING OUT
11. COOKIES
12. CHANGE OF PURPOSE
13. DISCLOSURES OF YOUR PERSONAL DATA
14. INTERNATIONAL TRANSFERS
15. DATA SECURITY
16. YOUR LEGAL RIGHTS

GLOSSARY

• 1.1 This privacy policy aims to give you information on how we collect and processes your personal data through your use of this website, including any data you may provide through this website when we update your profile, sign up to any service or interact with, or use any service, on our website.
• 1.2 This website is not intended for children and we do not knowingly collect data relating to children.
• 1.3 It is important that you read this privacy policy together with any other privacy policy or fair processing policy we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data.
• 1.4 We are the controller and responsible for your personal data (collectively referred to as (”Company”, “we”, “us” or “our” in this privacy policy).
• 1.5 We have appointed a data protection officer (DPO) who is responsible for overseeing questions in relation to this privacy policy. If you have any questions about this privacy policy, including any requests to exercise [your legal rights], please contact the DPO using the contact details set out in our website.
• 1.6 You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please https://www.simpletransfer.co.uk/contact in the first instance.

• 2.1 Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).
• 2.2 We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:
  Identity Data includes first name, maiden name, last name, username or similar identifier, marital status, title, date of birth and gender.
  Contact Data includes billing address, delivery address, email address and telephone numbers.
  Financial Data includes bank account and payment card details.
  Transaction Data includes details about payments to and from you and other details of products and services you have purchased from us.
  Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences
• 2.3 We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data could be derived from your personal data but is not considered personal data in law as this data will not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy policy.
• 2.4 We do not collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health, and genetic and biometric data). Nor do we collect any information about criminal convictions and offences.

Where we need to collect personal data by law, or under the terms of a contract we have with you, and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with goods or services). In this case, we may have to cancel a product or service you have with us but we will notify you if this is the case at the time.

We use different methods to collect data from and about you including through:

• • Direct interactions. You may give us the data by filling in forms or by corresponding with us by post, phone, email or otherwise.
• • Automated technologies or interactions. As you interact with our website, we may automatically collect Data. We collect this personal data by using cookies, server logs and other similar technologies.
• • Third parties or publicly available sources. We may receive personal data from various third parties and public sources as set out below:
  • - Technical Data from the following parties:
    • (a) analytics providers;
    • (b) advertising networks; and
    • (c) search information providers.
  • - Contact, Financial and Transaction Data from providers of technical, payment and delivery services.
  • - Identity and Contact Data from data brokers or aggregators.
  • - Identity and Contact Data from publicly available sources such as Companies House and the Electoral Register based inside the EU.

We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:

• ● to fulfill any contract or service which you may request from us, we may need to disclose your personal information to third parties such as data processors, suppliers or our partners; in doing so, your personal information may be processed automatically to determine the most appropriate way to meet your requirements
• ● to communicate with you in relation to our products and services and those of our selected partners about which you have enquired, or for any other purposes for which you have given consent
• ● to carry out a credit assessment or to provide information to credit reference agencies to carry out a credit assessment. (Information held by such agencies is available to other businesses for checking to prevent fraud and money laundering, to trace debtors and to assess credit applications)
• ● to provide anonymised statistics about our customers, sales, traffic patterns and related site information
• ● to identify you when you contact us

Click here (GLOSSARY) to find out more about the types of lawful basis that we will rely on to as set out in the table below.

This website may include 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 policy of every website you visit.

We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising.

We may use your Identity, Contact, Technical Usage and Profile Data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which products, services and offers may be relevant for you (we call this marketing).
You will receive regular updates and information in relation to our paid advertising options where you have signed up on our site. You may also receive marketing communications from us if you have requested information from us and you have not opted out of receiving that marketing.

We will get your express opt-in consent before we share your personal data with any third party for marketing purposes.

You can ask us or third parties to stop sending you marketing by logging into the website and checking or unchecking relevant boxes to adjust your marketing preferences or by following the opt-out links on any marketing message sent to you or by contacting us at any time. Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us.

• 11.1 Our Website does not currently use cookies but we reserve to start the use of cookies at any time during your contract with us . A cookie is a small file of letters and numbers that we put on your computer if you agree. These cookies allow us to distinguish you from other users of our website, which helps us to provide you with a good experience when you browse our website and also allows us to improve our site.
• 11.2 We may use the following cookies:
  • ❖ 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.
  • ❖ Analytical/performance cookies. They allow us to recognize and count the number of visitors and to see how visitors move around our 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.
  • ❖ Functionality cookies. These are used to recognize you when you return to our website. This enables us to personalize our content for you, greet you by name and remember your preferences (for example, your choice of language or region).
  • ❖ Targeting cookies. These cookies record your visit to our website, the pages you have visited and the links you have followed. We will use this information to make our website and the advertising displayed on it more relevant to your interests. We may also share this information with third parties for this purpose.
• 11.3 You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of this website may become inaccessible or not function properly.
• 11.4 Where an Advertiser wishes to drop cookies on users’ computers or use pixels, web beacons or other data collecting technology (the “Data Collecting Technology”) for the purpose of displaying or providing advertising on our Website and tracking impressions, analytics, measurement and verification of advertising campaigns (together, “Analytics Data”), it shall notify us in advance of booking an advertisement and provide all information requested by GNM regarding such Data Collecting Technology.
• 11.5 In no event shall Data Collecting Technology or the data collected from our Website: a) be used by the advertiser for the purposes of profiling users’ interests, segmentation, or tracking or targeting users when they leave the Website; or b) be combined with information collected from other sources. We reserve the right to scan the advertisements to ensure advertiser’s compliance with our privacy requirements.

• 12.1 We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.
• 12.2 If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.
• 12.3 Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

• 13.1 We may share your personal data with the parties set out below for the purposes set out in the table (Purposes for which we will use your personal data) above:
  Internal Third Parties as set out in the GLOSSARY.
  External Third Parties as set out in the GLOSSARY.
  Third parties to whom we may choose to transfer or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy policy.
• 13.2 We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.
• 13.3 We will not rent, sell or otherwise trade your personal information to anyone without your consent. If you do give your consent, we will provide information about you to other carefully selected organisations who we believe to be reputable for marketing purposes.
• 13.4 We shall never publicly disclose any personal or sensitive user data related to financial or payment activities or any government identification numbers.
• 13.5 When we need to share or disclose your personal information in order to provide the product or carry out the service you have requested, or to enable our partners or sub-contractors to do so on our behalf, we will use our reasonable endeavors to ensure this is done in a secure environment. These third parties are only allowed to use your personal information for the purpose of fulfilling your order or request.
• 13.6 When we are compelled to do so by law we will disclose your personal information to the appropriate authorities, bodies or persons in accordance with data protection law.
• 13.7 As a result of using our services over the Internet, your information may be transmitted to, from or through any country irrespective of the levels of information protection provided in those countries. We may transfer your data to persons outside the European Economic Area but will do so only in compliance with data protection law.
• 13.8 Under the Data Protection Act 1998, at any time (and notwithstanding any prior agreement to the contrary) you have a right to object to your personal data being used by us for the purposes of direct marketing. To exercise this right you must apply to us in writing to the email or postal address given below. We will stop using your personal data for the purposes of direct marketing within a reasonable period of the date of receipt of your request.
• 13.9 Additionally, we may also regularly consult opt-out registers (the Mailing Preference Service, Telephone Preference Service and Fax Preference Service) in respect of marketing activities.
• 13.10 When you send us an e-mail, we will keep your e-mail address, the content of your mail, and our response to it so that we can monitor our effectiveness and record our contact.

• 14.1 We do not transfer your personal data outside the European Economic Area (EEA).
• 14.2 Where a transfer out of EEA occurs, we ensure your personal data is protected by requiring all our affiliates to follow the same rules when processing your personal data. These rules are called “binding corporate rules”. Whenever we transfer your personal data out of the EEA, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:
  • ❖ We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data by the European Commission. For further details, see European Commission: Adequacy of the protection of personal data in non-EU countries.
  • ❖ Where we use certain service providers, we may use specific contracts approved by the European Commission which give personal data the same protection it has in Europe. For further details, see European Commission: Model contracts for the transfer of personal data to third countries.
  • ❖ Where we use providers based in the US, we may transfer data to them if they are part of the Privacy Shield which requires them to provide similar protection to personal data shared between the Europe and the US. For further details, see European Commission: EU-US Privacy Shield.

• 15.1 We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.
• 15.2 To determine the appropriate retention period for personal data, we consider the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements.
• 15.3 By law, we have to keep basic information about our customers (including Contact, Identity, Financial and Transaction Data) for six (6) years after they cease being customers for tax purposes.
• 15.4 In some circumstances you can ask us to delete your data: see your legal rights below for further information.
• 15.5 In some circumstances we will anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes, in which case we may use this information indefinitely without further notice to you.

• 16.1 Under certain circumstances, you have rights under data protection laws in relation to your personal data. Please click on the links below to find out more about these rights:
  • ✔ Request access to your personal data.
  • ✔ Request correction of your personal data.
  • ✔ Request erasure of your personal data.
  • ✔ Object to processing of your personal data.
  • ✔ Request restriction of processing your personal data.
  • ✔ Request transfer of your personal data.
  • ✔ Right to withdraw consent.
• 16.2 If you wish to exercise any of the rights set out above, please Contact us.
• 16.3 You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.
• 16.4 We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.
• 16.5 We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.

Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give you the best service/product and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by Contacting us.
Performance of Contract means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.
Comply with a legal or regulatory obligation means processing your personal data where it is necessary for compliance with a legal or regulatory obligation that we are subject to.
Internal third parties mean other companies in the acting as joint controllers or processor and provide IT and system administration and undertake leadership reporting.
External third parties means:

• ❖ Service providers acting as processors who provide IT and system administration services.
• ❖ Professional advisers acting as processors or joint controller including lawyers, bankers, auditors and insurers who provide consultancy, banking, legal, insurance and accounting services.
• ❖ HM Revenue & Customs, regulators and other authorities acting as processors or joint controllers based in the United Kingdom who require reporting of processing activities in certain circumstances.