1. IMPORTANT INFORMATION AND WHO WE ARE
Our sites are not intended for children and we do not knowingly collect data relating to children.
Fyio Limited is the controller and responsible for your personal data.
Full name of legal entity: Fyio Limited
Email address: email@example.com
2-10 Balham Station Road
Telephone number: 0208 675 4779
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.
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.
2. The data we collect about you
Personal data means any information about a living individual from which that person can be identified or is identifiable.
We may collect, use, store and transfer different kinds of personal data about you as set out below:
- First name, maiden name, last name, username or similar identifier, marital status, title, date of birth and gender identity.
- Billing address, email address and telephone numbers.
- Details about your transactions with us including payments to and from you and other details of products and services you have purchased from us.
- Technical data including the 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 our sites.
- Your username and password.
- Information about your interests, preferences, feedback and survey responses.
- Information about how you use our sites, products and services.
- Your preferences in receiving marketing from us, third parties (to the extent relevant) and your communication preferences.
Information stored within the fyio app
Where you are a consumer user, or business user and you are using our fyio biz service, we will host any documents that you choose to store within the fyio app on your behalf in order to enable you to use our service. We will not access those documents for any purposes.
Where you are a business user and you are using our fyio pro service, you will be a controller of any personal data that we host in the provision of our service to you. In those circumstances we will be a processor of that information on your behalf.
3. HOW IS YOUR PERSONAL DATA COLLECTED?
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:
- to ask us not to process your personal data for marketing purposes. We will inform you (before collecting your data) if we intend to use your data for such purposes or if we intend to disclose your information to any third party for such purposes;
- To ask us not to process your personal data where it is processed on the basis of legitimate interests provided that there are no compelling reasons for that processing;
- To ask us not to process your personal data for scientific or historical research purposes, where relevant, unless the processing is necessary in the public interest.
- to request from us access to personal information held about you;
- to ask for the information we hold about you to be rectified if it is inaccurate or incomplete;
- to ask for data to be erased provided that the personal data is no longer necessary for the purposes for which it was collected, you withdraw consent (if the legal basis for processing is consent), you exercise your right to object, set out below, and there are no overriding legitimate ground for processing, the data is unlawfully processed, the data needs to be erased to comply with a legal obligation or the data is children’s data and was collected in relation to an offer of information society services;
- to ask for the processing of that information to be restricted if the accuracy of that data is contested, the processing is unlawful, the personal data is no longer necessary for the purposes for which it was collected or you exercise your right to object (pending verification of whether there are legitimate grounds for processing);
- to ask for data portability if the processing is carried out by automated means and the legal basis for processing is consent or contract.
If you wish to exercise any of the rights set out above, please contact us.
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 could refuse to comply with your request in these circumstances.
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.
We try to respond to all legitimate requests within one month. Occasionally it could 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.
4. HOW WE USE YOUR PERSONAL DATA
We use different methods to collect data from and about you including through:
- Direct interactions. You may give us your data directly by filling in forms on our sites or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you register for or use our products or services, create an account on our sites, request marketing to be sent to you, enter a competition, promotion or survey or give us feedback or contact us.
- Third parties or publicly available sources. We will receive personal data about you from various third parties as set out below:
- analytics providers such as Google based outside the EU;
- advertising networks; and
- search information providers.
- We may also receive information about you from other fyio users when fyio users wish to share information stored on our sites with their contacts.
5. DISCLOSURES OF YOUR PERSONAL DATA
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.
In respect of the documents, data and information that you choose to store in the fyio app, we implement appropriate security measures to keep your documents, data and information secure, including:
- server side encryption;
- upload and download RSA 2048 bit encryption;
- separate production and staging servers;
- access to user data only through a secure API gateway; and
- 24/7 security monitoring and monthly scans of servers.
6. INTERNATIONAL TRANSFERS
We have set out below, 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.
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 our 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.
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.
|Purpose/Activity||Lawful basis for processing including legitimate interest|
|To register you as a new customer||Performance of a contract with you|
|To enable you to partake in a prize draw, competition or complete a survey||Performance of a contract with you Necessary for our legitimate interests (to study how customers use our products/services, to develop them and grow our business)|
|To administer and protect our business and our sites (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)||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) Necessary to comply with a legal obligation|
|To deliver relevant content and advertisements to you, sometimes on behalf of third parties, and measure or understand the effectiveness of the advertising we serve to you||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) Consent (where required)|
|To use data analytics to improve our sites, products/services, marketing, customer relationships and experiences||Necessary for our legitimate interests (to define types of customers for our products and services, to keep our sites updated and relevant, to develop our business and to inform our marketing strategy)|
|To form a view on what we think you may want or need or what may be of interest to you.||Necessary for our legitimate interests (to develop our products/services and grow our business)|
|To make suggestions and recommendations to you about services that may be of interest to you||Consent (where required) Necessary for our legitimate interests (to develop our products/services and grow our business)|
|To send marketing communications to you about our products and services.||Consent (where required) Necessary for our legitimate interests (to develop our products/services and grow our business)|
|To send relevant marketing communications and information to you based on your use of our products and services, which may include marketing communications sent on behalf of third parties.||Consent (where required) Necessary for our legitimate interests (to provide you with additional information about products and services that might be of interests to you)|
|To comply with our legal obligations||Necessary to comply with a legal obligation|
|To allow your documents, data and information to be shared with other fyio users where you choose to do so||Necessary for the performance of a contract|
Marketing: opting out
You can ask us to stop sending you marketing messages at any time by either:
- logging into our sites or app and checking or unchecking relevant boxes to adjust your marketing preferences;
- following the opt-out links on any marketing message sent to you; or
- by emailing firstname.lastname@example.org at any time.
7. DATA SECURITY
We may share your personal data with the parties set out below for the purposes set out in the table:
- Service providers acting as processors who provide IT and system administration, website hosting, database management, app/website development and support, email marketing management and back office and consultancy services.
- Professional advisers including lawyers, bankers, auditors and insurers who provide consultancy, banking, legal, insurance and accounting services.
- HM Revenue & Customs, regulators and other authorities who require reporting of processing activities in certain circumstances.
- Market research or customer survey providers, price comparison sites and fraud prevention services.
8. DATA RETENTION
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.
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.
9. YOUR LEGAL RIGHTS
We may transfer your personal data out of the EEA. Where we do so, 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.
- 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.
- 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 Europe and the US.
Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the EEA.