Introduction

Floe Tech Technologies plc (“Floe Tech”) is a leading software and services company that specialises in providing solutions for data integrity and control, banking integration, payments and cash management. As an essential part of our business, we collect and manage data relating to our clients, visitors (to our website or to our premises) and other contacts.

Floe Tech respects your privacy and is 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 (regardless of where you visit it from) or when you visit our premises and tell you about your privacy rights and how the law protects you.

Important information and who we are

Purpose of this privacy policy

This privacy policy aims to give you information on how Floe Tech collects and processes your personal data through you visiting our premises, your use of this website, including any data you may provide through this website if you wish to consent to updates, gain access to specific content, submit an enquiry or ask us to contact you. You may also correspond with us by email, telephone or other means, or in person, as a result of which we may collect your information.

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 policy together with any other privacy 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. This privacy policy supplements other notices and privacy policies and is not intended to override them.

Controller

The Floe Tech group is made up of a number of legal entities, details of which are set out in Schedule 1 of this policy (the “Floe Tech Group”). This privacy policy is issued on behalf of the Floe Tech Group so when we mention Floe Tech, “we”, “us” or “our” in this privacy policy, we are referring to the relevant company in the Floe Tech Group responsible for processing your data. Floe Tech Technologies plc is the controller and responsible for this website.

Floe Tech’s in-house Data Protection team are 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 Protection team using the details set out below.

Contact details

Full name of legal entity: Floe Tech Technologies plc

Email address: hello@floetech.com

Postal address: Aldermary House, 10-15 Queen Street, London, EC4N 1TX

Although our aim is to ensure that we handle any issues or complaints quickly and efficiently, you have the right to make a complaint at any time to your local data protection authority. The Information Commissioner’s Office (ICO), is the UK regulator for data protection issues (www.ico.org.uk). In the European Economic Area (“EEA”) the local data protection authorities information can be found here .

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

We keep our privacy policy under regular review. 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.

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 as follows:

Identity Data includes name, job title, username or similar identifier.

Contact Data includes company address, email address and telephone numbers.

Technical Data includes internet protocol (IP) address, your login data, geographic location, type and language and time zone setting, and other technology on the devices you use to access this website.

Profile Data includes your username and password.

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

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

Shareholder Information includes personal data of our shareholders. This may include name, address, date of birth, telephone number, email address, financial information, details or any share transfers. We will also keep records of enquiries and correspondence we may have with you. This information may have been provided to us directly or to Equiniti, our share registrars, who manage the shareholder register on our behalf. Further information pertaining to processing of shareholder details can be found on Equiniti’s website at https://equiniti.com/uk/privacy-policy/

CCTV and physical security CCTV systems are installed in some of our premises. These collect images and videos of certain entrances or exits of our premises and of certain secure areas of or equipment at our offices, and other information relating to access of our premises obtained through electronic means, such as swipe card records, or visitor logbook. If you attend our premises in person, we may also collect practical details such as arrival time, departure time and car registration details (if relevant).

We operate a separate, employment-related data protection policy which sets out the information, use and other details regarding our processing activities for employee and job applicant data. A copy of this policy is made available to all employees and upon request.

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.

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.

How is your personal data collected?

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

Direct interactions. You may give us your Identity and Contact information by corresponding with us by post, phone, email, completing a form on our website, or otherwise. This includes personal data you provide when you:

request information relating to our products and services;

create an account on our website;

subscribe to our service or publications;

request marketing to be sent to you;

information received from you as a shareholder;

give us feedback or contact us: or

if you attend our premises in person, we may also collect practical details such as arrival time, departure time and car registration details (if relevant).

Automated technologies or interactions. As you interact with our website, we will automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies, and other similar technologies. We may also receive Technical Data about you if you visit other websites employing our cookies. Please see our cookie policy for further details.

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

Technical Data from the following parties:

analytics providers such as Google based outside the UK; and

advertising networks and search information providers such as IBS Intelligence and Finextra based inside and outside the UK

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:

to provide products and services to our clients;

to provide you with information regarding our products and services and other marketing communications or news or invitations that may be of interest to you or your organisation;

to contact you for your views or a survey as part of market research;

to administer our shareholder register;

to manage and ensure the security of our premises;

generally, to administer our relationship with you and respond to your queries or feedback;

generally, to administer, improve and develop our business.

generally, to comply with our statutory and regulatory obligations;

generally, to enforce our legal rights.

Generally, we do not rely on consent as a legal basis for processing your personal data although we will get your consent before sending third party direct marketing communications to you via email or text message. You have the right to withdraw consent to marketing at any time by contacting 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. Please 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 employee in our customer support portal

(a) Identity

(b) Contact

Performance of a contract with you/your employer

To process payments for products and services we provide or purchase

(a) Manage payments, fees and charges

(b) Collect and recover money owed to us

(c) Process any payments due to you/your organisation

(a) Identity

(b) Contact

(c) Financial and bank details

(d) Transaction

(e) Marketing and Communications

(a) Performance of a contract with you/your employer

(b) Necessary for our legitimate interests (to recover

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To manage our relationship with you/your employer as our customer 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

To manage our relationship with you/your employer as our customer 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) Performance of a contract with you/your employer

(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 administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)          

(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 administer our shareholder register

(a) Identity

(b) Contact

(a) Performance of a contract with you

(b) Necessary to comply with a legal obligation

To use data analytics to improve our website, products/services, marketing, customer relationships and experiences

(a) Technical

(b) Usage

(c) CCTV and physical security

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 manage and ensure the security of our premises

Necessary to comply with a legal obligation

Marketing

We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising. We have established the following personal data control mechanisms.

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 or purchased a solution or services from us and you have not opted out of receiving that marketing.

Third-party marketing

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

Opting out

You can ask us or third parties 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 a product/service purchase, product/service experience 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 our 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 share your information to any member of our group of companies (this means our subsidiaries, our ultimate holding company and all its subsidiaries) insofar as reasonably necessary for the purposes, and on the legal bases, set out in this policy.

We use both internal computer systems and third party computer systems to hold information that you provide or that we collect. Our internal computer systems are in the UK and elsewhere including inside and outside of the EEA. The third party systems that we use include cloud-based IT platforms and providers of support or specialist products/services that may be based and/or process and/or store information in the UK or elsewhere including inside and outside of the EEA. Both our internal systems and our third party computer systems are access controlled such that only our authorised personnel are able to access the information. Our authorised personnel may be based in any of our global locations.

We may share your information with our insurers and professional advisers or other service providers insofar as reasonably necessary for the purposes of insurances, risk management, professional advice and operational necessity.

In addition to the third party systems referred to above, we engage suppliers and/or subcontractors from time to time to assist us with our business processes and practices, which may include providers of human resources services, marketing consultants, IT consultants. We may share your information with any of these suppliers and/or subcontractors as reasonably necessary for the purposes and on the legal bases set out above.

We may also be obliged to disclose information under certain laws or by order of court or other competent regulatory body or may be permitted to disclose it under applicable data protection laws.

International transfers

We share your personal data within the Floe Tech Group. This will involve transferring your data outside the UK and EEA.

Whenever we transfer your personal data out of the UK and EEA, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:

For transfers outside of the UK and EEA but within the Floe Tech Group we have Intra Group Transfer Agreements in place.

For transfers outside of the UK and EEA but not within the Floe Tech Group, we will only transfer your personal data:

to countries that have been deemed to provide an adequate level of protection for personal data.

Where we have in place specific contracts approved for use in the UK and EEA which give personal data the same protection it has in the UK. Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the UK.

As you may be aware, data protection laws vary from country to country. Our transfer of personal data to other countries outside of the UK and the EEA could result in your personal data being available to governments and/or other Supervisory Authorities under the local law.

Floe Tech Information Systems Inc (“Floe Tech”), part of the Floe Tech Group, is registered and complies with the EU-U.S. Privacy Shield Framework as set forth by the U.S. Department of Commerce regarding the collection, use, and retention of personal information transferred from the European Union (“EU”) to the United States although Floe Tech do not rely on the Privacy Shield as a lawful mechanism to transfer personal data from the EU,UK or Switzerland. For further information of the Privacy Shield please see Schedule 2.

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 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.

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.

In some circumstances you can ask us to delete your data: see your legal rights below for further information.

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.

Your legal rights

Under certain circumstances, you have rights under data protection laws in relation to your personal data.

If you wish to exercise any of your rights under data protection laws that require us to take an action, please contact us at dataprotection@Floe Techtech.com.

We may update this policy from time to time by publishing a new version on our website. You should check this page occasionally to ensure you are happy with any changes to this policy.

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 could 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 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.

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/product and the best and most secure experience that we can reasonably manage. 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 obligation means processing your personal data where it is necessary for compliance with a legal obligation that we are subject to.

THIRD PARTIES

Internal Third Parties

Other companies in the Floe Tech Group acting as joint controllers or processors and who are based in Australia, Luxembourg, and the United States and provide operational services (such as central IT, HR, finance and legal services for the Floe Tech Group), as well as services to our customers.

External Third Parties

Service providers based in the UK, EEA and United States including IT and system administration services.

Professional advisers including auditors and insurers based in UK, EEA and the United States who provide consultancy, banking, legal, insurance and accounting services.

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:

If you want us to establish the data’s accuracy.

Where our use of the data is unlawful but you do not want us to erase it.

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.

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.

SCHEDULE 1

Floe Tech Companies

Entity name

Registered office

Place and date of Incorporation

Floe Tech

Aldermary House

10-15 Queen Street

London

EC4N 1TX

UK

SCHEDULE 2

Privacy Shield

Floe Tech has certified to the U.S. Department of Commerce that it adheres to the Privacy Shield Principles.  If there is any conflict between the terms in this privacy policy and the Privacy Shield Principles, the Privacy Shield Principles shall govern.  To learn more about the Privacy Shield program, and to view our certification, please visit https://www.privacyshield.gov/.

In the context of an onward transfer, Floe Tech has responsibility for the processing of personal information it receives under the Privacy Shield and subsequently transfers to a third party acting as an agent on its behalf. Floe Tech shall remain liable under the Privacy Shield Principles if its agent processes such personal information in a manner inconsistent with the Privacy Shield Principles, unless the organization proves that it is not responsible for the event giving rise to the damage.

In compliance with the Privacy Shield Principles, Floe Tech commits to resolve complaints about collection or use of your personal information.  EU individuals with inquiries or complaints regarding our Privacy Shield policy should first contact our Data Protection team at: hello@floetech.com

Floe Tech has further committed to refer unresolved Privacy Shield complaints to JAMS Privacy Shield Program, an alternative dispute resolution provider located in the United States. If you do not receive timely acknowledgment of your complaint, or if we have not addressed your complaint to your satisfaction, please visit https://www.jamsadr.com/eu-us-privacy-shield for more information or to file a complaint.  The services of JAMS are provided at no cost to you.

Under the Privacy Shield Framework, Floe Tech is subject to the investigatory and enforcement power of the Federal Trade Commission (FTC), which has Privacy Shield investigatory and enforcement powers over Floe Tech. Under certain circumstances, individuals may be able to invoke binding arbitration to address complaints about Floe Tech’s compliance with the Privacy Shield Principles.