Last updated May 1, 2018
Wagestream respects your privacy and is committed to protecting your Personal Data. We want to be transparent with you about how we collect and use your Personal Data in making available our platform, mobile application and/or website(s) (“Platform”) and tell you about your privacy rights and how the law protects you.
- Who we are and how to contact us
- Your rights relating to your Personal Data
- What Personal Data we collect
- How we use your Personal Data and why
- What happens when you do not provide necessary Personal Data?
- Personal Data from Third Party Sources
- Who we share your Personal Data with
- How we keep your Personal Data secure
- How long we store your Personal Data
- Our policy on children
- Third party links
Who we are and how to contact us
Who we are
Our address is: Stapleton House, 110 Clifton Street, London, UK, EC2A 4HT.
How to contact us
You can contact us by emailing: firstname.lastname@example.org.
Your rights relating to your Personal Data
By law you have the right to:
- Request access to your Personal Data. 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 information we hold about you corrected.
- 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 exercised your right to object to processing (see below).
- Object to processing of your Personal Data. This right exists where we are relying on a Legitimate Interest as the legal basis for our processing and there is something about your particular situation, which makes you want to object to processing on this ground.
- Request the restriction of processing of your Personal Data. This enables you to ask us to suspend the processing of Personal Data about you, for example if you want us to establish its accuracy or the reason for processing it.
- Request the transfer of your Personal Data. 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. This right only exists where we are relying on consent to process your Personal Data (“Consent Withdrawal”). If you withdraw your consent, we may not be able to provide you with access to the certain specific functionalities of our Platform. We will advise you if this is the case at the time you withdraw your consent.
How to exercise your rights
If you want to exercise any of the rights described above, please contact us using the contact details shown in “Who We Are and How to Contact Us”.
Typically, you will not have to pay a fee to access your Personal Data (or to exercise any of the other rights). However, except in relation to Consent Withdrawal, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive, or, we may 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 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.
We will reply to your complaint as soon as we can.
If you feel that your complaint has not been adequately resolved, please note that the GDPR gives you the right to contact your local data protection supervisory authority, which for the UK, is the Information Commissioner’s Office.
What Personal Data we collect
All the Personal Data we collect, both from you and from third parties about you, is outlined in the table below.
|Category of Personal Data collected||What this means|
|Identity Data||First name, surname, last name, username or similar identifier, title, and date of birth.|
|Contact Data||Your home address, email address and telephone numbers.|
|Financial Data||Your bank sort code and account number.|
|Transaction Data||Any details about payments to and from you and other details of subscriptions and services you have
purchased from us. Data in respect of your transactions with third parties.
|Behavioural Data||Inferred or assumed information relating to your behaviour and interests, based on your online activity.
This is most often collated and grouped into “segments” (e.g., there may be a segment for users, living in
London and aged under 25, who use our services twice a month).
|Technical Data||Internet protocol (IP) address, mobile device identifier, your login data, browser type and version, time
zone setting and location, browser plug-in types and versions, device type and model, operating system and
platform and other technology on the devices you use to access this Platform or use our services.
No Special Categories of Personal Data
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 we use your Personal Data and why
We will only use your Personal Data for the purposes for which we collected it as listed below, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose.
What is our “legal basis” for processing your Personal Data?
In respect of each of the purposes for which we use your Personal Data, the GDPR requires us to ensure that we have a “legal basis” for that use. Most commonly, we will rely on one of the following legal bases:
- Where it is necessary for our legitimate interests and your interests and fundamental rights do not override those interests (“Legitimate Interests”). More detail about the specific legitimate interests pursued in respect of each Purpose we use your Personal Data for is set out in the table below.
- Where we need to comply with a legal or regulatory obligation (“Compliance with Law”).
- Where we have your specific consent to carry out the processing for the Purpose in question (“Consent”).
Generally we do not rely on your Consent as a legal basis for using your Personal Data.
We have set out below, in a table format, the legal bases we rely on in respect of the relevant Purposes for which we use your Personal Data.
|Purpose||Category(ies) of Personal Data involved||Why do we do this||Our legal basis for this use of data|
|Account Creation and Transfer||
||To register you as a new user, and transfer your data to another employer, should you use our services with
different employers from time to time.
We have a legitimate interest in ensuring that your data is accurate and consistent across employers, so
that we can ensure the ongoing security and proper operation of our services, website and associated IT
services and networks.
||To keep our website, our services and associated systems operational and secure. To keep your data and
||To track issues that might be occurring on our systems.||Legitimate Interests.
It is in our legitimate interests that we are able to monitor and ensure the proper operation of our
Platforms and associated systems and services.
|Optimisation and Analytics||
||To understand and measure how users use our Platform to improve it accordingly, and report relevant
aggregated management information.
What happens when you do not provide necessary Personal Data?
Where we need to process your Personal Data either to comply with law, or to perform 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 the functionalities of the Platform).
In this case, we may have to stop you using our Platform have with us but we will notify you if this is the case at the time.
Personal Data from Third Party Sources
In addition to the Personal Data that we collect directly from you (as described in the section immediately above this one), we also collect certain of your Personal Data from third party sources. These sources are broken down in the table below, together with a description of whether they are publicly available or not.
|Third party data source||Publicly available?||Category(ies) or other types of personal data received.|
What are cookies?
We may collect information using “cookies”. Cookies are small data files stored on the hard drive of your computer or mobile device by a website. We may use both session cookies (which expire once you close your web browser) and persistent cookies (which stay on your computer or mobile device until you delete them) to provide you with a more personal and interactive experience on our Platform.
We use two broad categories of cookies:
- first party cookies, served directly by us to your computer or mobile device; and
- third party cookies, which are served by our partners or service providers on our Platform.
Cookies we use
Our Platform uses the following types of cookies for the purposes set out below:
|Type of cookie||Purpose|
|Essential Cookies||These cookies are essential to provide you with services available through our Platform and to
enable you to use some of its features. For example, they allow you to log in to secure areas of our
Platform and help the content of the pages you request to load quickly. Without these cookies, the services
that you have asked for cannot be provided, and we only use these cookies to provide you with those
|Functionality Cookies||These cookies allow our Platform to remember choices you make when you use our Platform, such as remembering
your language preferences, remembering your login details and remembering the changes you make to other
parts of our Platform which you can customise. The purpose of these cookies is to provide you with a more
personal experience and to avoid you having to re-enter your preferences every time you visit our Platform.
|Analytics and Performance Cookies||These cookies are used to collect information about traffic to our Platform and how users use
our Platform. The information gathered via these cookies does not “directly” identify any individual
visitor. However, it may render such visitors “indirectly identifiable”. This is because the information
collected is typically linked to a pseudonymous identifier associated with the device you use to access our
Platform. The information collected is aggregated and anonymous. It includes the number of visitors to our
Platform, the websites that referred them to our Platform, the pages they visited on our Platform, what time
of day they visited our Platform, whether they have visited our Platform before, and other similar
information. We use this information to help operate our Platform more efficiently, to gather broad
demographic information and to monitor the level of activity on our Platform.
[We use Google Analytics for this purpose. Google Analytics uses its own cookies. It is only used to improve
how our Platform works. You can find out more information about Google Analytics cookies here:
You can typically remove or reject cookies via your browser settings. In order to do this, follow the instructions provided by your browser (usually located within the “settings”, “help” “tools” or “edit” facility). Many browsers are set to accept cookies until you change your settings.
If you do not accept our cookies, you may experience some inconvenience in your use of our Platform. For example, we may not be able to recognise your computer or mobile device and you may need to log in every time you visit our Platform.
Further information about cookies, including how to see what cookies have been set on your computer or mobile device and how to manage and delete them, visit www.allaboutcookies.org and www.youronlinechoices.com.uk.
You can also prevent the use of Google Analytics relating to your use of our Platform by downloading and installing the browser plugin available via this link: http://tools.google.com/dlpage/gaoptout?hl=en-GB
Third party cookies
Who we share your Personal Data with
The table below describes who we share your Personal Data with, what we share and why we share it.
|Recipients||Category(ies) of Personal Data we share||Why we share it||Location(s)|
||Your employer(s) engaged Wagestream to provide the Platform and Wagestream services. We share your personal
data with your employer(s) to provide them and you with such Platform and services.
||Our service providers provide us with IT and system administration services.||
||Our third party partners facilitate communication (like e-mail, chat and phone), in order to provide you
with our services.
|Transaction Processing Partners||
||Our third party partners who process transactions on our behalf and assist with communication, in order to
provide you with our services.
||Our lawyers, bankers, consultants, auditors and insurers provide consultancy, banking, legal, insurance and
|HM Revenue & Customs, regulators and other authorities||
||Authorities may require reporting of processing activities in certain circumstances||
As you can see from the above, we share your Personal Data both with our affiliated companies within the Wagestream group and certain external third parties who are based outside the European Economic Area (“Europe”). Any processing of your Personal Data by these parties will involve an export of your Personal Data outside of Europe. We endeavour to ensure that people to whom we provide Personal Data hold it subject to appropriate safeguards and controls. Whenever we transfer your Personal Data out of Europe to countries that have not been deemed to provide an adequate level of protection for Personal Data by the European Commission, we ensure a similar degree of protection is afforded to it by implementing the following safeguards:
- We use specific contracts approved by the European Commission which give Personal Data the same protection it has in Europe. For further details, see European Commission: Model contracts for the transfer of Personal Data to third countries.
- Where we use service providers based in the U.S., we may also transfer data to them if they are part of the Privacy Shield, which requires them to provide similar protections to Personal Data shared between Europe and the U.S. For further details, see European Commission: EU-U.S. Privacy Shield.
How we keep your Personal Data secure
We have put in place appropriate security measures to prevent your Personal Data from being accidentally lost, used or accessed in an unauthorized way, altered or disclosed.
We limit access to your Personal Data to those employees and other staff who have a business need to have such access. All such people are subject to a contractual duty of confidentiality.
We have put in place procedures to deal with any actual or suspected Personal Data breach. In the event of any such breach, we have systems in place to work with applicable regulators. In addition, in certain circumstances (e.g., where we are legally required to do so) we may notify you of breaches affecting your Personal Data.
How long we store your Personal Data
We will only retain your Personal Data for so long as we reasonably need to use it for the purposes set out above in “How we use your Personal Data and why.”, unless a longer retention period is required by law (for example for regulatory purposes).
The table below shows our standard retention practices:
|Category of Personal Data||Retention period|
|Behavioural Data||90 Days from the date on which we collected or received it.|
|Contact Data||For so long as retention is necessary to fulfil the Purposes/Use for which it is used (see “How we use your Personal Data and why”).|
|Identity Data||For so long as you remain a user of our Platform.|
|Financial Data||Seven years or a shorted period of time if allowed by applicable laws and regulations, and best practice
guidance on such laws and regulations.
|Transaction Data||Seven years or a shorted period of time if allowed by applicable laws and regulations, and best practice
guidance on such laws and regulations.
|Technical Data||Three years from the date on which we collected or received it.|
Our policy on children
This Platform is not intended for children below 16 and we do not knowingly collect data relating to such children.
Third party links
WAGESTREAM LTD, 2018
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