Key Definitions
1. In this document:
“Controller” shall have the same meaning as given under the Act and the GDPR. “Data Protection Regulations” shall refer to the Data Protection Act 2018 (“the Act”), the General Data Protection Regulation (“GDPR”) and all other similar and applicable law.
“Data Subject” shall refer to subject of the data, namely the person who the data concerns being either you or someone else as the context dictates.
“Personal Data” shall refer to all information relating to you or such other Data Subject as the context dictates, that is gathered and retained by us.
“Processor” shall have the same meaning as given under the Act and the GDPR.
“Solicited Third Party” means any third party that you have agreed to provide Personal Data to engaging them to act in the capacity of Controller.
"We," "our," or "us" refers to Forenzix Limited a duly incorporated company with the number 14074819, with registered office at 85 Great Portland Street, First Floor, London, England, W1W 7LT.
Our Position
2. In respect of Data Protection Regulations, we are both:
i. A “Controller” in respect of your Personal Data where you are the Data Subject; and
ii. A “Processor” in respect of processing the Personal Data of the Data Subject that you have provided us with, in the circumstances of a relationship between us as the Processor and you as the Controller.
Application of this Policy to Personal Data
3. In both circumstances, the terms of this privacy policy shall apply to both you and/or the Data Subject as the context dictates.
4. This policy applies to any Personal Data concerning the Data Subject obtained from you or from a Solicited Third Party, created, or acquired from other sources and outlines how we will use and store all Personal Data. It is essential to read this notice to comprehend our relationship with Personal Data and the rights associated with that Personal Data belonging to the Data Subject.
5. For context, this policy shall apply to following interactions that you may have with us:
i. use of our Website (as defined in our Terms & Conditions);
ii. use of our Web App (as defined in our Terms & Conditions);
iii. providing us with access to a data storage platform where Personal Data regarding the Data Subject is uploaded to and stored, thereby making that Personal Data available to us; and
iv. the supply of any Personal Data to a Solicited Third Party who requests us to process that data in which circumstance they are acting in the capacity of Controller and we are acting in the capacity of Processor.
Personal Data Collection
6. We will collect and use the following Personal Data regarding the Data Subject:
i. Information provided to us: This includes details such as names, addresses, email addresses, telephone numbers, financial information, credit history, employment history, health information, utility invoice information, data relating to business and other relevant information;
ii. Information generated or collected: Our website uses Google Analytics to gather statistical information on visitors, such as IP addresses, for aggregated analysis and improvement purposes.
Use of Cookies
7. Cookies are used on our website to remember certain Personal Data about users’ preferences and activities. They do not identify users personally and can be disabled through browser settings.
Information from Other Sources
8. We may also receive Personal Data from credit reference agencies, fraud prevention agencies, intermediaries, social media profiles, and public databases.
Data Usage
9. We use Personal Data for purposes such as processing and recreating involved with report generating, conducting statistical analysis, providing requested information, fulfilling agreements, identity verification, fraud prevention, and offering tailored products and services.
10. We may also use Personal Data to:
i. pursue any outstanding debts existing under an agreement that we have with you;
ii. improve our products and services; or
iii. to contact you about products and services that may be of interest to you.
Data Storage
11. We take appropriate technical and organisational measures to secure all information including Personal Data, and to protect it from unauthorised or unlawful access or use as well as accidental loss or destruction. This consists of storing all information including Personal Data on server software, that each use separate encryption measures for both data at rest and data in transit. We are happy to share the details of the servers that we use and the encryption service/measures of those with you or the Data Subject upon request along with a full list of our own security measures;
Legal Basis for Processing Personal Data
12. We process Personal Data based on:
i. consent from the Data Subject in accordance with Data Protection Regulations;
ii. fulfilment of any agreement that we have with the Data Subject or any Solicited Third Parties; and
iii. any legal obligations, protection of legal rights, and legitimate business interests.
Sharing Personal Data
13. We may disclose certain Personal Data mentioned under this policy to third parties via our collection of your Cookies, in which case we will seek your prior consent before doing so and specify exactly what Personal Data is being disclosed and how it will be appear to those third parties.
14. We may disclose certain Personal Data mentioned under this policy to third-party service providers and, in specific circumstances, to professional advisers, insurers, intermediaries, and other entities where the purpose of processing the Personal Data necessitates. Before disclosing any Personal Data to such third parties we will ensure that confidentiality as well as compliance with Data Protection Regulations is considered, and where required, your consent, or the consent of the Data Subject, has been attained.
15. We may be legally obligated to disclose any Personal Data to any authority in the circumstances of an investigation concerning the Data Subject. In which case your rights to object to this, or the rights of the Data Subject to object to this may be subject to the provisions of the Data Protection Regulations.
Data Retention
16. The retention period regarding all Personal Data will vary depending on the purpose of us retaining the Personal Data and our legal obligations as either Controller or Processor. As a standard practice we will aim to retain all Personal Data for up to five years after the relationship ends unless legal requirements mandate a longer duration or a request to terminate Personal Data is made in accordance with either this privacy policy, the Terms & Conditions, or any right under the Data Protection Regulations. However, we make no guarantee as to retention of Personal Data for any time longer than necessary to fulfil our duties under any agreements with you or Solicited Third Parties.
Your Rights
17. Your rights in relation to the Personal Data regarding you, that we keep include:
a. the right to receive information regarding the processing of your Personal Data and access to your Personal Data that we hold;
b. the right to receive some of your Personal Data in a structured format and/or request that we share that data with a third party where this is agreed to be a part of a legitimate business purpose or is technically feasible;
c. the right to request that we rectify your Personal Data if it is inaccurate or incomplete;
d. the right to withdraw your consent to, or restrict our processing of your Personal Data except in the instance where we are legally entitled or obligated to refuse your objection;
e. the right to request that we erase your Personal Data in certain circumstances, except in the circumstance that we are legally entitled or obligated to retain it; and
f. the right to withdraw your consent to the processing of your Personal Data for direct marketing purposes;
18. The responsibility lies with us to ensure the lawful use of all Personal Data made available to us in accordance with Data Protection Regulations.
Amendments to Policy and further information
19. Our privacy policy undergoes regular reviews, and any updates will be posted on this page and when appropriate, communicated to you via email. Please check back for the latest changes.
20. For inquiries regarding this policy, our data processing procedures, or rights regarding Personal Data, you can contact us at info@forenzix.co.uk or 0203 411 2931.
21. If you have any concerns about our use of your personal information, you can make a complaint to us at info@forenzix.co.uk or by calling 02034112931. You can also complain to the Information Commissioner’s Office (the ICO) if you are unhappy with how we have used your data. The ICO’s physical address is Information Commissioner’s Office, Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF. Or alternatively, contact their helpline on 0303 123 1113 or visit their website at https://www.ico.org.uk for more details.