Privacy Policy

General
1. PiPA Solutions Limited (“we” or “us”) takes the privacy of your information very seriously. Our Privacy Notice is designed to tell you, the user of our services about our practices regarding the collection, use and disclosure of personal information which may be provided to us via our websites, associated apps and other digital products we provide.
2. This notice applies to personal data provided by our users, whether they are an individual seeking to verify or authenticate their identity or documents or they are associated with one of our partners.
3. In this notice “you” refers to any individual whose personal data we hold or process (other than our staff). 4. In this notice references to the “Service” are references to any website, app or other means by which you provide personal data to us or access our services.
4. This notice is governed by the EU General Data Protection Regulation (the “GDPR”) the Data Protection Act 2018.
Personal data we collect
1. We may collect and process the following personal data (information that can be uniquely identified with you) about you:
  1. log-in details and information you provide when setting up an account on the Service including contact information (“Login Information”);
  2. information you provide to us relating to your account or profile with us (“Account Information”);
  3. identity information and documents you provide to us in order to verify or authenticate your identity (“ID Information”);
  4. information we collect in the course of providing services to you, including payment information (“Service Information”);
  5. a record and details of any correspondence or communication between you and us or relating to any complaint submitted to us (“Communication Information”);
  6. details of your visits to the Service, the resources and pages that you access and any searches you make (“Technical Information”);
  7. information we may hold for the purposes of marketing such as your email address (“Marketing Information”).
2. We will not collect any sensitive personal data without your prior consent. By sensitive personal data we mean data which falls within certain ‘special categories’ which are defined in the GDPR (e.g. health data) and which require additional protection and consent measures.
3. Generally we will collect personal data directly, but we may obtain data from third parties from time to time. For instance we may licence data from identity databases in order to verify information provided. If we do obtain your personal data from a third party your privacy rights under this notice are not affected and you are still able to exercise the rights contained within this notice.
4. You do not have to supply any personal information to us but the Service may not be operable without providing data to us.
5. You may withdraw our authority to process your personal data (or request that we restrict our processing – see clause 9) at any time but we will be entitled to complete any orders we are then processing and we may need to withhold some personal data for legal or other reasons (see below).
Cookies and IP Address
1. A cookie is a piece of data stored locally on your computer and contains information about your activities on the Internet. The information in a cookie does not contain any personally identifiable information you submit to our websites (“pipa.co”).
2. On our Site, we use cookies to track users' progress, allowing us to make improvements based on usage data. We also use cookies if you log in to one of our online services to enable you to remain logged in to that service. A cookie helps you get the best out of the Site and helps us to provide you with a more customised service.
3. Once you close your browser, our access to the cookie terminates. You have the ability to accept or decline cookies. Most web browsers automatically accept cookies, but you can usually modify your browser setting to decline cookies if you prefer. To change your browse settings you should go to your advanced preferences.
4. We are required to obtain your consent to use cookies. We will obtain this consent with a toolbar which appears when you first visit the Site.
5. If you choose not to accept the cookies, this will not affect your access to the majority of information available on our Site. However, you will not be able to make full use of our online services.
6. An Internet Protocol (IP) address is a number assigned to your computer by your Internet Service Provider (ISP), so you can access the Internet. We may use your IP address to diagnose problems with our server, report aggregate information, and determine the fastest route for your computer to use in connecting to our Site, and to administer and improve the Site.
How we process your personal data
1. We process each category of data in the following ways:
  1. Login Information - when you register or log in to the Service, update your details with us, and when you interact with the Service.
  2. Account Information - when you register with the Service, update your details with us and when we need to communicate with you.
  3. ID Information – when you use the Service to verify or authenticate your identity or documents.
  4. Service Information – when you use the Service for the provision of any of our services to you.
  5. Communication Information – when we communicate with you.
  6. Technical Information – when we administer or protect our business, undertake troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data, when we use data analytics to improve the Service, services, marketing, customer relationships and experiences.
  7. Marketing Information – when we promote or market our products or services to you.
2. Legal Basis for processing your data
  
  The legal basis we rely on for the processing outlined above is to perform our duties under our agreement with you (if you are an account holder with us) or our legitimate interest. A “legitimate interest” means a valid interest we have in processing your personal data which is not overridden by your interests in data privacy and security. If you would like further information please contact us (contact details are at the end of this notice).

Data Retention

Our current data retention policy is to delete or destroy (to the extent we are able to) the personal data we hold about you in accordance with the following:

Category of personal data	Length of retention
Records relevant for tax purposes	8 years from the end of the tax year to which the records relate
Personal data processed in relation to a contract between you and us	7 years from either the end of the contract or the date you last used our services or placed an order with us, being the length of time following a breach of contract in which a contract party is entitled to make a legal claim
Personal data held on marketing or business development records	3 years from the last date on which you have interacted with us

For any category of personal data not specifically defined in this notice, and unless otherwise specified by applicable law, the required retention period for any personal data will be deemed to be 7 years from the date of receipt by us of that data or (if later) the end of the relevant contract, arrangement or interaction with that person.
The retention periods stated in this notice can be prolonged or shortened as may be required (for example, in the event that legal proceedings apply to the data or if there is an on-going investigation into the data).
We review the personal data (and the categories of personal data) we are holding on a regular basis to ensure the data we are holding is still relevant to our business and is accurate. If we discover that certain data we are holding is no longer necessary or accurate, we will take reasonable steps to correct or delete this data as may be required.
If you wish to request that data we hold about you is amended or deleted, please see clause 10 below, which explains your privacy rights.

Sharing your information
1. If you subscribe for a paid service, credit and debit card information will be provided to our payment processing partner. This information will be supplied to our payment processing partner directly, even if you provide the information while on the Service. Our payment processing partner will be the data controller for credit and debit card information.
2. Our payment processing partner will have their own privacy policies and notices. But we will take steps to ensure that they are compliant with applicable data protection legislation and we will consult with them in relation to maintaining the security of payment information.
3. We do not disclose any personal data you provide to any third parties other than as follows:
  1. We may use third parties for the purposes of identity or document verification or authentication, credit checks, criminal records checks or international lists of politically exposed individuals. t These parties may receive personal data from our Services;
  2. certain third party suppliers including IT technical support providers, website developers, marketing and business development service providers may have access to personal data;
  3. where we carry out research to gain an insight into the use of our services, the results of this research (but not your personal data itself) may be transferred to interested third parties;
  4. if we are under a duty to disclose or share your personal data in order to comply with any legal obligation (for example, if required to do so by a court order or for the purposes of prevention of fraud or other crime);
  5. in order to enforce any terms and conditions or agreements for our services that may apply;
  6. we may transfer your personal information to a third party as part of a sale of some or all of our business and assets to any third party or as part of any business restructuring or reorganisation, but we will take steps with the aim of ensuring that your privacy rights continue to be protected;
  7. to protect our rights, property and safety, or the rights, property and safety of our users or any other third parties. This includes exchanging information with other companies and organisations for the purposes of fraud protection and credit risk reduction.
4. Other than as set out above, we shall not disclose any of your personal information unless you give us permission to do so. If we do supply your personal information to a third party we will take steps to ensure that your privacy rights are protected and that third party complies with the terms of this notice.
Email and Other Communications
1. If you have set up an account with us, we may need to communicate with you about your account. We may also from time to time contact you about similar goods or services but we will give you an opportunity to opt out. We may also contact you with information about our goods and services if you have expressly consented to receive such communications (e.g. by signing up to our newsletter) or if you are a business user.
2. When we send email and other electronic communications we will comply with applicable regulations including the Privacy and Electronic Communications Regulations 2003. In particular we will identify the nature of the message and the sender clearly and you will have an opportunity to opt out of receiving any further communications from us.
Security
1. We will take all reasonable steps to ensure that appropriate technical and organisational measures are carried out in order to safeguard the information we collect from you and protect against unlawful access and accidental loss or damage. These measures may include (as necessary):
  1. Encrypting all information and documents you provide to us (we will not have access to this information without your authorisation);
  2. protecting our servers by both hardware and software firewalls;
  3. locating our data processing storage facilities in secure locations;
  4. encrypting all data stored on our server with an industry standard encryption method that encrypts the data between your computer and our server so that in the event of your network being insecure no data is passed in a format that could easily be deciphered;
  5. ensuring that all communication with our servers is encrypted through Secure Sockets Layer (SSL), an industry standard encryption method that encrypts data between your computer and our servers so that in the event of your network being insecure no data is passed in a format that could easily be deciphered;
  6. when necessary, disposing of or deleting your data so it is done so securely;
  7. regularly backing up and encrypting all data we hold.
2. We will ensure that our employees are aware of their privacy and data security obligations. We will take reasonable steps to ensure that the employees of third parties working on our behalf are aware of their privacy and data security obligations.
3. This notice and our procedures for handling personal data will be reviewed as necessary.
4. Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted to the Service. Once we have received your information, we will use the procedures and security features referred to in this notice to try to prevent unauthorised access.

Your privacy rights

The GDPR gives you the following rights in respect of personal data we hold about you. Please note that because as a security feature much of your data is encrypted and cannot be accessed or altered by us we will only be able to supply you with data which we have access to:


The right to be informed	You have a right to know about our personal data protection and data processing activities, details of which are contained in this notice.
The right of access	You can make what is known as a Subject Access Request (“SAR”) to request information about the personal data we hold about you (free of charge, save for reasonable expenses for repeat requests). If you wish to make a SAR please contact us as described below.
The right to correction	Please inform us if information we hold about you is incomplete or inaccurate in any way and we will update our records as soon as possible, but in any event within one month. We will take reasonable steps to communicate the change to any third parties to whom we have passed the same information.
The right to erasure (the ‘right to be forgotten’)	Please notify us if you no longer wish us to hold personal data about you (although in practice it is not possible to provide our services without holding your personal data). Unless we have reasonable grounds to refuse the erasure, on receipt of such a request we will securely delete the personal data in question within one month. The data may continue to exist in certain backup, but we will take steps to ensure that it will not be accessible. We will communicate the erasure to any third parties to whom we have passed the same information.
The right to restrict processing	You can request that we no longer process your personal data in certain ways, whilst not requiring us to delete the same data.
The right to data portability	You have right to receive copies of personal data we hold about you in a commonly used and easily storable format (please let us know a format which suits you). You may also request that we transfer your personal data directly to third party (where technically possible).
The right to object	Unless we have overriding legitimate grounds for such processing, you may object to us using your personal data if you feel your fundamental rights and freedoms are impacted. You may also object if we use your personal data for direct marketing purposes (including profiling) or for research or statistical purposes. Please notify your objection to us and we will gladly cease such processing, unless we have overriding legitimate grounds.
Rights with respect to automated decision-making and profiling	You have a right not to be subject to automated decision-making (including profiling) when those decisions have a legal (or similarly significant effect) on you. You are not entitled to this right when the automated processing is necessary for us to perform our obligations under a contract with you, it is permitted by law, or if you have given your explicit consent.
Right to withdraw consent	If we are relying on your consent as the basis on which we are processing your personal data, you have the right to withdraw your consent at any time. Even if you have not expressly given your consent to our processing, you also have the right to object (see above).

All SARs and other requests or notifications in respect of your above rights must be sent to us in writing to Sher Khan at: s.khan@pipasolutions.com .
We will endeavour to comply with such requests as soon as possible but in any event we will comply within one month of receipt (unless a longer period of time to respond is reasonable by virtue of the complexity or number of your requests).

Data Breaches
1. If personal data we hold about you is subject to a breach or unauthorised disclosure or access, we will report this to the Information Commissioner’s Office (ICO).
2. If a breach is likely to result in a risk to your data rights and freedoms, we will notify you as soon as possible.
Other websites
1. Our Service may contain links and references to other services and websites. Please be aware that this notice does not apply to those services or websites.
2. We cannot be responsible for the privacy policies and practices of sites and services that are not operated by us, even if you access them via the Service. We recommend that you check the policy of each site you visit and contact its owner or operator if you have any concerns or questions.
Transferring your information outside Europe
1. As part of the services provided to you the information you provide to us may be transferred to, processed and stored at, countries or international organisations outside of the EEA.
2. We have users who are outside of the EEA or access our services from outside the EEA and in those circumstances personal data may be transferred outside of the EEA.
3. In order to provide our services certain information may be processed by partners outside of the EEA for instance manual verification of ID information may be undertaken by our partner in Canada.
4. If we transfer your information outside of the EEA, and the third country or international organisation in question has not been deemed by the EU Commission to have adequate data protection laws, we will provide appropriate safeguards and we will be responsible for ensuring your privacy rights continue to be protected as outlined in this notice. If you would like to obtain details of the safeguards we have put in place then please contact us using the contact details at the end of this notice.
Notification of changes to the contents of this notice
We will post details of any changes to our policy to help ensure you are always aware of the information we collect, how we use it, and in what circumstances, if any, we share it with other parties.
Contact us
If at any time you would like to contact us with your views about our privacy practices, or with any enquiry or complaint relating to your personal information or how it is handled, you can do so via the following email address: s.khan@pipasolutions.com. If we are unable to resolve any issues you may have or you would like to make a further complaint, you can contact the Information Commissioner’s Office by visiting http://www.ico.org.uk/ for further assistance.