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Privacy Policy

Introduction

Welcome to Red Flag A!ert LLP’s privacy notice. Red Flag A!ert LLP respects your privacy and is committed to protecting your personal data. This privacy
notice will inform you as to how we look after your personal data and tell you about your privacy rights and how the law protects you.

This privacy notice is provided in a layered format so you can click through to the specific areas set out below. Alternatively you can download a pdf version of the policy here https://www.redflagalert.com/privacypolicy/pdf

Please also use the Glossary to understand the meaning of some of the terms used in this privacy notice.

IMPORTANT INFORMATION AND WHO WE ARE
Purpose of this privacy notice

This privacy notice aims to give you information on how Red Flag A!ert LLP collects and processes
your personal data through your use of this website or any other online portal provided by us,
including any data you may provide when you sign up to our online services, subscribe to our
newsletter or request a free trial of our services.

This website is not intended for children and we do not knowingly collect data relating to children.
It is important that you read this privacy notice together with any other privacy notice or fair processing
notice 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. This privacy notice
supplements the other notices and is not intended to override them.

Controller

Red Flag A!ert LLP is the controller and responsible for your personal data (collectively referred to
as Red Flag, we, us or our in this privacy notice).

We have appointed a data privacy manager who is responsible for overseeing questions in relation
to this privacy notice. If you have any questions about this privacy notice, please contact the data
privacy manager using the details set out below.

Contact details

Our full details are:
Full name of legal entity: Red Flag A!ert LLP
Data privacy manager: Sharon Bryden
Email address: helpdesk@redflagalert.com
Postal address: 302 Chambers Business Centre, Chapel Road, Hollinwood. Oldham, Greater
Manchester, OL8 4QQ.
Telephone number: 0344 412 6699

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 contact us
in the first instance.

Changes to the privacy notice and your duty to inform us of changes

This version was last updated on 24 July 2018 and historic versions can be obtained by contacting
us.

It is important that the personal data we hold about you is accurate and current. Please keep us
informed if your personal data changes during your relationship with us.

Third-party links

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 notice of every website you visit.

THE DATA WE COLLECT ABOUT YOU

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).

We may collect, use, store and transfer different kinds of personal data about you which we have
grouped together follows:

2.1 Identity Data includes first name, last name, username or similar identifier, marital status, title, job
title, employer (company name and number).

2.2 Contact Data includes billing address, delivery address, email address, telephone numbers and fax
numbers.

2.3 Crime / Offence Data includes information about criminal convictions and offences, for example,
fraud or offences committed by a director or officer of a company, or directors’ disqualification
information. This is information which is publicly available from official sources such as Companies
House, the Insolvency Service and court records.

2.4 Financial Data includes bank account and payment card details.

2.5 Transaction Data includes details about payments to and from you and other details of services you
have purchased from us.

2.6 Technical Data includes internet protocol (IP) address, your 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 this website.

2.7 Profile Data includes your username and password, purchases or orders made by you, your interests,
preferences, feedback and survey responses.

2.8 Usage Data includes information about how you use our website and services.

2.9 Marketing and Communications Data includes your preferences in receiving marketing from us
and our third parties and your communication preferences.

Third Party Data. Where you provide us with a third party’s personal data (for example, any personal
data relating to your employees, officers and/or agents) it is your responsibility to ensure that: (i) you
have an appropriate legal basis to share such personal data with us; and (ii) the third party data
subject reads and understands this Privacy Policy. We will not be liable to any third party for your
failure to comply with this requirement.

We also collect, use and share Aggregated Data such as statistical or demographic data for any
purpose. Aggregated Data may be derived from your personal data but is not considered personal
data in law as this data does 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 notice.

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).

If you fail to provide personal data
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 services that you have
requested from us). In this case, we may have to cancel a service you have with us but we will notify
you if this is the case at the time.

3 HOW IS YOUR PERSONAL DATA COLLECTED?

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

3.1 Direct interactions. You may give us your Identity, Contact and Financial Data by filling in forms or
by corresponding with us by post, phone, email or otherwise. This includes personal data you provide
when you:

(a) subscribe to our services or request a free trial;
(b) create an account on our website;
(c) subscribe to our newsletter or otherwise request marketing to be sent to you;
(d) enter a competition, promotion or survey; or
(e) give us some feedback.

3.2 Automated technologies or interactions. As you interact with our website, we may automatically
collect Technical Data about your equipment, browsing actions and patterns. We collect this personal
data by using cookies, server logs and other similar technologies. Please see our cookie policy
https://www.redflagalert.com/cookie-policy for further details.

3.3 Third parties or publicly available sources. We may receive personal data about you from various
third parties and public sources as set out below:

(a) Identity, Contract and Crime / Offence Data from publicly available sources such as
Companies House, the Insolvency Service and court records, all based inside the EU.
(b) Technical Data from the following parties:

3.3.2.1 analytics providers [such as Google based outside the EU];

3.3.2.2 advertising networks [such as [Google or Bing] based [inside OR outside] the
EU]; and

3.3.2.3 search information providers [such as [Google or Bing] based [inside OR
outside] the EU].

(c) Contact, Financial and Transaction Data from providers of technical, payment and
delivery services [such as [Dun and Bradstreet] based [inside OR outside] the EU].
(d) Identity and Contact Data from data brokers or aggregators [such as [Dun and Bradstreet,
and Intelling Data services] based [inside OR outside] the EU].

4 HOW WE USE YOUR PERSONAL DATA

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:

4.1 Where we need to perform the contract we are about to enter into or have entered into with you.

4.2 Where it is necessary for our legitimate interests (or those of a third party) and your interests and
fundamental rights do not override those interests.

4.3 Where we need to comply with a legal or regulatory obligation.

4.4 Where you have given your explicit consent to receive marketing communications from us.

Purposes for which we will use your personal data

We have set out below, in a table format, a description of all the ways we plan to use your personal
data, and which of the legal bases we rely on to do so. We have also identified what our legitimate
interests are where appropriate.

Note that we may process your personal data for more than one lawful ground depending on the
specific purpose for which we are using your data. Pleas e contact us if you need details about the
specific legal ground we are relying on to process your personal data where more than one ground
has been set out in the table below.

Purpose/Activity Type of data Lawful basis for processing
including basis of legitimate
interest
To register you as a new
customer
(a) Identity
(b) Contact
Performance of a contract with
you
To process and deliver your
order for the services including:
(a) Manage payments, fees
and charges
(b) Collect and recover money
owed to us
(a) Identity
(b) Contact
(c) Financial
(d) Transaction
(e) Marketing and
Communications
(a) Performance of a contract
with you
(b) Necessary for our legitimate
interests (to recover debts
due to us)
To manage our relationship with
you which will include:
(a) Notifying you about
changes to our terms or
privacy policy
(b) Asking you to leave a
review or take a survey
(a) Identity
(b) Contact
(c) Profile
(d) Marketing and
Communications
(a) Performance of a contract
with you
(b) Necessary to comply with a
legal obligation
(c) Necessary for our legitimate
interests (to keep our
records updated and to
study how customers use
our products/services)
To process information which is
publicly available from official
sources such as Companies
House, the Insolvency Service
and court records, in order to
combine such information in our
database in order to provide our
services.
(a) Identity
(b) Crime / Offence
(a) Necessary for your legitimate
interests (to prevent fraud /
crime)
(b) Necessary for the purposes
of preventing or detecting
unlawful acts, for reasons o
substantial public interest
To administer and protect our
business and this website
(including troubleshooting, data
analysis, testing, system
maintenance, support, reporting
and hosting of data)
(a) Identity
(b) Contact
(c) Technical
(a) Necessary for our legitimate
interests (for running our
business, provision of
administration and IT
services, network security, to
prevent fraud and in the
context of a business
reorganisation or group
restructuring exercise)
(b) Necessary to comply with a
legal obligation
To deliver relevant website
content and advertisements to
you and measure or understand
the effectiveness of the
advertising we serve to you
(a) Identity
(b) Contact
(c) Profile
(d) Usage
(e) Marketing and
Communications
(f) Technical
Necessary for our legitimate
interests (to study how
customers use our
products/services, to develop
them, to grow our business and
to inform our marketing strategy)
To use data analytics to
improve our website,
products/services, marketing,
customer relationships and
experiences
(a) Technical
(b) Usage
Necessary for our legitimate
interests (to define types of
customers for our products and
services, to keep our website
updated and relevant, to
develop our business and to
inform our marketing strategy)
To make suggestions and
recommendations to you about
goods or services that may be
of interest to you
(a) Identity
(b) Contact
(c) Technical
(d) Usage
(e) Profile
(a) Necessary for our
legitimate interests (to
develop our
products/services and grow
our business)
(b) Data subject’s consent

Marketing

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

Promotional offers from us

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 marketing communications from us if you have requested information from us.

Third-party marketing

We will never share your personal data with any company outside the Red Flag group of companies
for marketing purposes.

Opting out

You can ask us to stop sending you marketing messages at any time 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 as a result of the purchase of services, registering for a free trial of our services or
other transactions.

Cookies

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. For more information about the cookies we use, please
see https://www.redflagalert.com/cookie-policy.

Change of purpose

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.

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.

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.

DISCLOSURES OF YOUR PERSONAL DATA

We may have to share your personal data with our third-party service providers, as listed in the table
below.

We may also share your personal data with third parties to whom we may choose to sell, 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 notice.

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.

INTERNATIONAL TRANSFERS

We do not transfer your personal data outside the European Economic Area (EEA).
Commented [A2]: Note this. If you ever decide that you want
to share personal data with a group company or other third
party for marketing purposes – you will need to make sure that
you get explicit consent to do this and you will need to change
this wording in this policy

DATA SECURITY

We have put in place appropriate security measures to prevent your personal data from being
accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit
access to your personal data to those employees, agents, contractors and other third parties who
have a business need to know. They will only process your personal data on our instructions and
they are subject to a duty of confidentiality.

We have put in place procedures to deal with any suspected personal data breach and will notify you
and any applicable regulator of a breach where we are legally required to do so.

DATA RETENTION

How long will you use my personal data for?

We will only retain your personal data for as long as necessary 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 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 requirements.

By law we have to keep basic information about our customers (including Contact, Identity, Financial
and Transaction Data) for six years after they cease being customers for tax purposes.

If you complete a form on our website requesting information from us, we will normally keep your
Identity, Contact and Marketing and Communications Data for twelve months after your request,
unless you wish to hear from us after expiry of that period.

We will normally keep your Marketing and Communications Data for up to twelve months after your
contract for services terminates or expires, unless you opt-out of receiving marketing from us (in
which case we will keep a record of your opt-out request on our suppression list).

YOUR LEGAL RIGHTS

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:

9.1 Request access to your personal data.
9.2 Request correction of your personal data.
9.3 Request erasure of your personal data.
9.4 Object to processing of your personal data.
9.5 Request restriction of processing your personal data.
9.6 Request transfer of your personal data.
9.7 Right to withdraw consent.

If you wish to exercise any of the rights set out above, please contact us.

No fee usually required

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.

What we may need from you

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.

Time limit to respond

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.

GLOSSARY

LAWFUL BASIS

Legitimate Interest means the interest of our business in conducting and managing our business to
enable us to give you the best service 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.

YOUR LEGAL RIGHTS

You have the right to:

Request access to your personal data (commonly known as a “data subject access request”). This
enables you to receive a copy of the personal data we hold about you and to check that we are
lawfully processing it.

Request correction of the personal data that we hold about you. This enables you to have any
incomplete or inaccurate data we hold about you corrected, though we may need to verify the
accuracy of the new data you provide to us.

Request erasure of your personal data. This enables you to ask us to delete or remove personal
data where there is no good reason for us continuing to process it. You also have the right to ask us
to delete or remove your personal data where you have successfully exercised your right to object to
processing (see below), where we may have processed your information unlawfully or where we are
required to erase your personal data to comply with local law. Note, however, that we may not always
be able to comply with your request of erasure for specific legal reasons which will be notified to you,
if applicable, at the time of your request.

Object to processing of your personal data 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 processing on this ground as you feel it impacts on your fundamental rights and freedoms. You
also have the right to object where we are processing your personal data for direct marketing
purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to
process your information which override your rights and freedoms.

Request restriction of processing of your personal data. This enables you to ask us to suspend
the processing of your personal data in the following scenarios: (a) if you want us to establish the
data’s accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) where
you need us to hold the data even if we no longer require it as you need it to establish, exercise or
defend legal claims; or (d) you have objected to our use of your data but we need to verify whether
we have overriding legitimate grounds to use it.

Request the transfer of your personal data to you or to a third party. We will provide to you, or a
third party you have chosen, your personal data in a structured, commonly used, machine-readable
format. Note that this right only applies to automated information which you initially provided consent
for us to use or where we used the information to perform a contract with you.

Withdraw consent at any time where we are relying on consent to process your personal data.
However, this will not affect the lawfulness of any processing carried out before you withdraw your
consent. If you withdraw your consent, we may not be able to provide certain products or services to
you. We will advise you if this is the case at the time you withdraw your consent.

Data processor
name
Type of personal
data
Purpose of
processing
Within the EEA?
Mail Chimp Identity and Contact
Data
For the purpose of
sending out email
marketing
communications to
customers
Yes
Vuture Identity and Contact
Data
For the purpose of
sending out email
marketing
communications to
customers
Yes
GBG Identity and Contact
Data
Production of KYC/
AML service
Yes
Allied Irish Bank Identity and Payment Payment Processing Yes
Santander Bank Identity and Payment Payment Processing Yes
Tech City Labs Identity and Contact
Data
Production of KYC/
AML service
Yes
Capsule Identity and Contact
Data
For the purpose of
sending out email
marketing
communications to
customers
Yes
Xero Identity and Contact
Data
Accounting and Invoice
Process
Yes
Lead Forensics Identity and Contact
Data
Website Tracking and
Engagement
Yes
Interaction Identity and Contact
Data
For the purpose of
sending out email
marketing
communications to
customers
Yes

All emails include an unsubscribe link. You may opt-out at any time.

Here at Redflag Alert we take your privacy seriously and will only use your personal information to contact you with regards to your enquiry. By submitting this request, you agree to receiving information from Red Flag Alert. See Privacy Policy.

Contact

Red Flag Alert
302 Chambers Business Centre
Chapel Road, Hollinwood
Oldham
Greater Manchester
OL8 4QQ
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