1. Introduction
Attara is committed to safeguarding your personal information, as your privacy is important to us.
This policy describes the types of personal information we may collect about you, the purposes for which we use the information, the circumstances in which we may share the information and the steps that we take to safeguard the information to protect your privacy.
Please ensure you read this policy carefully to understand our practices regarding your personal information that we hold.
2. Important information and who we are
Foenix Partners Limited (company number 07677978) (collectively referred to as “Foenix”, “we“, “us” or “our” in this privacy policy) is a data processor in respect of personal data provided by our clients. We have appointed a data privacy manager 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 data privacy manager using the details set out below. Contact details Our full details are: Full name of legal entity: Foenix Partners Limited Name or title of data privacy manager: Pooja Sahu Email address: contact@attara.co Postal address: 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 this privacy policy and your duty to inform us of changes We may amend this policy as and when required. If we make any changes that will affect you, we will notify you. 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.
3. Types of personal data collected from you
Personal data, or personal information, means any data 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 need to collect, store and use personal data about you (if you are an individual) or your officers and employees or partners (if you are a body corporate or a partnership respectively) (your Connected Individuals), for providing services to you, for administration purposes (including maintaining and using our contact databases) and for the prevention and detection of crime and to be compliant with our legal obligations. We may need to share your personal data with third parties worldwide (including outside the European Union), for example, other payment service providers.
For the provision of financial services to you and subject to strict compliance with all applicable laws and regulations, personal data may be collected about you indirectly from monitoring or other means (e.g. recording of telephone calls and monitoring e-mails). In these circumstances, the personal data is not accessed on a continuous or routine basis, but it may be used for compliance or security purposes.
We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:
- Identity Data includes name, job title, date of birth, passport, national identity card, driving licence.
- Contact Data includes address, email address and telephone number.
- Financial Data includes bank account and payment details.
- Transaction Data includes details about payments to and from you and other details of services you have purchased from us.
- Technical Data includes internet protocol (IP) address, 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 agree to our online terms of business.
- Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.
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.
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.
We may also need additional commercial documents if you send or receive certain high-value or highvolume transactions to comply with our anti-money laundering obligations under applicable law.
In providing the personal data of any individual (other than yourself) to us during your use of our services, you promise that you have obtained consent from such individual to disclose his/her personal data to us, as well as his/her consent to our collection, use and disclosure of such personal data, for the purposes set out in this Privacy Policy.
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 goods or services). In this case, we may have to cancel any trade and/or not provide services to you, but we will notify you if this is the case at the time.
4. Cookies
This site uses cookies – small text files that are placed on your machine to help the site provide a better user experience. In general, cookies are used to retain user preferences, store information for things like shopping carts, and provide anonymised tracking data to third party applications like Google Analytics. Cookies generally exist to make your browsing experience better. However, you may prefer to disable cookies on this site and on others. The most effective way to do this is to disable cookies in your browser. We suggest consulting the help section of your browser.
Necessary Cookies (all site visitors)
- cfduid: Is used for our CDN CloudFlare to identify individual clients behind a shared IP address and apply security settings on a per-client basis. See more information on privacy here: CloudFlare Privacy Policy.
- PHPSESSID: To identify your unique session on the website.
5. How is your personal data collected?
The personal data which we collect primarily comes from the account opening process that you submit during the course of establishing a relationship with us. We may also collect personal data about your transactions and based on the products or services you require, we may obtain additional personal data about your firm if you are registering as a corporate entity such as your credit history, from credit reporting agencies.
We use different methods to collect data from and about you, including through:
Direct interactions. You may give us your Identity, Contact and Financial Data in the context of our account opening process. We may also collect personal data from you when you:
(i) request marketing to be sent to you;
(ii) enter a competition, promotion or survey; or
(iii) give us some feedback.
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. We may also receive Technical Data about you if you visit other websites employing our cookies.
Third parties or publicly available sources. We may receive personal data about you from various third parties and public sources as set out below:
- Contact, Financial and Transaction Data from providers of technical and payment services;
- Identity and Contact Data from our credit check, identity and anti-money laundering search providers.
- Identity and Contact Data from publicly availably sources such as Companies House.
6. Third Party Access to Your Data
We don’t share your data with third-parties in a way as to reveal any of your personal information like email, name, etc. The only exceptions to that rule are for partners we have to share limited data with in order to provide the services you expect from us.
7. How Long We Retain Your 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. In some circumstances you can ask us to delete your data: see Erasure Request below for further information. In some circumstances we may 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.
8. How do 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:
- Where we need to perform the contract we are about to enter into or have entered into with you.
- 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.
- Where we need to comply with a legal or regulatory obligation.
Generally, we do not rely on consent as a legal basis for processing your personal data other than in relation to sending third party direct marketing communications to you via email. You have the right to withdraw consent to marketing at any time by contacting us.
9. Your legal rights
Under certain circumstances, you have rights under data protection laws in relation to your personal data.
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. 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.
10. Third Party Processors
Our carefully selected partners and service providers may process personal information about you on our behalf as described below:
Digital Marketing Service Providers
We periodically appoint digital marketing agents to conduct marketing activity on our behalf, such activity may result in the compliant processing of personal information.
Our appointed data processors include:
(i) Prospect Global Ltd (trading as Sopro) Reg. UK Co. 09648733. You can contact Sopro and view their privacy policy here: https://sopro.io. Sopro are registered with the ICO Reg: ZA346877 their Data Protection Officer can be emailed at: dpo@sopro.io.