1.Definitions and Interpretation

In this Policy the following terms shall have the following meanings:

• “Cookie” – means a small text file placed on your computer or device by Our Site when you visit certain parts of Our Site and/or when you use certain features of Our Site. Details of the Cookies used by Our Site are set out in Part 14, below;
• “Cookie Law” – means the relevant parts of the Privacy and Electronic Communications (EC Directive) Regulations 2003;

2.Information About Us

Our Site is owned and operated by Mango Pay Limited, a limited company registered in England under company number 10354495.

Address: S8 Oaklands Business Centre Hooton Road Hooton Cheshire CH66 7NZ.

VAT number: 282 9313 86.

Data Protection Officer: Owain Davies.

Email address: owain@mangopay.co.uk

Telephone number: 03300 580190.

Postal Address: S8 Oaklands Business Centre Hooton Road Hooton Cheshire CH66 7NZ.

We are regulated by HMRC.

We are a member of Professional Passport; PRISM; TEAM; FCSA.

3.What Does This Policy Cover?

This Privacy Policy applies only to your use of Our Site. Our Site may contain links to other websites. Please note that we have no control over how your data is collected, stored, or used by other websites and we advise you to check the privacy policies of any such websites before providing any data to them.

4.What is Personal Data?

Personal data is defined by the General Data Protection Regulation (EU Regulation 2016/679) (the “GDPR”) as ‘any information relating to an identifiable person who can be directly or indirectly identified in particular by reference to an identifier’.

Personal data is, in simpler terms, any information about you that enables you to be identified. Personal data covers obvious information such as your name and contact details, but it also covers less obvious information such as identification numbers, electronic location data, and other online identifiers.

5.What Are My Rights?

Under the GDPR, you have the following rights, which we will always work to uphold:

1. The right to be informed about our collection and use of your personal data. This Privacy Policy should tell you everything you need to know, but you can always contact us to find out more or to ask any questions using the details in Part 15.
2. The right to access the personal data we hold about you. Part 13 will tell you how to do this.
3. The right to have your personal data rectified if any of your personal data held by us is inaccurate or incomplete. Please contact us using the details in Part 15 to find out more.
4. The right to be forgotten, i.e. the right to ask us to delete or otherwise dispose of any of your personal data that we have. Please contact us using the details in Part 15 to find out more.
5. The right to restrict (i.e. prevent) the processing of your personal data.
6. The right to object to us using your personal data for a particular purpose or purposes.
7. The right to data portability. This means that, if you have provided personal data to us directly, we are using it with your consent or for the performance of a contract, and that data is processed using automated means, you can ask us for a copy of that personal data to re-use with another service or business in many cases.

For more information about our use of your personal data or exercising your rights as outlined above, please contact us using the details provided in Part 15.

Further information about your rights can also be obtained from the Information Commissioner’s Office or your local Citizens Advice Bureau.

If you have any cause for complaint about our use of your personal data, you have the right to lodge a complaint with the Information Commissioner’s Office.

6.What Data Do We Collect?

Depending upon your use of Our Site, we may collect some or all of the following personal and non-personal data (please also see Part 14 on our use of Cookies and similar technologies:

• Name;
• Gender;
• Address;
• Email address;
• Telephone number;
• Business name;
• Job title;
• Profession;
• Payment information;
• Information about your preferences and interests;
• Web browser type and version;
• Operating system;
• A list of URLs starting with a referring site, your activity on Our Site, and the site you exit to;
• Residential address;
• Work location;
• Title;
• IP address/location;
• Connect login and password details;
• Bank details;
• Unique tax reference number;
• Nationality;
• National Insurance Number;
• Tax codes;
• Email address and secondary email address;
• Home, mobile and work/business telephone numbers
• Delegation authority name;
• Eye colour;
• Mother’s maiden name;
• Birth town;
• Historic addresses;
• Personal income/tax returns and employment details;
• Financial details;

We may also collect, store and use the following “special categories” of more sensitive personal information:

• Information about criminal convictions and offences which you may inform us about from time to time which may be used to provide advice your duties as a director or employee, or your eligibility to act as a director of a business.
• Information about your health, including any medical condition, health and sickness records from any Sick Note, Fit Note or other note or records provided by your doctor or medical professional from time to time, in order to assist you with any accounting services or relating to state benefits which you may be claiming or entitled to claim.

7.How Do You Use My Personal Data?

Under the GDPR, we must always have a lawful basis for using personal data. This may be because the data is necessary for our performance of a contract with you, because you have consented to our use of your personal data, or because it is in our legitimate business interests to use it. Your personal data will be used for the following purposes:

• Providing and managing your Account.
• Supplying our services to you. Your personal details are required in order for us enter into a contract with you.
• Personalising and tailoring our services for you.
• Communicating with you. This may include responding to emails or calls from you.
• Supplying you with information by email or post that you have opted-in to (you may unsubscribe or opt-out at any time by selecting the unsubscribe link at the end of the mail).
• Analysing your use of Our Site and gathering feedback to enable us to continually improve Our Site and your user experience.

With your permission and/or where permitted by law, we may also use your personal data for marketing purposes, which may include contacting you by email, telephone, text message or post with information, news, and offers on services. You will not be sent any unlawful marketing or spam. We will always work to fully protect your rights and comply with our obligations under the GDPR and the Privacy and Electronic Communications (EC Directive) Regulations 2003, and you will always have the opportunity to opt-out.

Third Parties (including Partnership Invoice Finance Limited) whose content appears on Our Site may use third-party Cookies, as detailed below in Part 14. Please refer to Part 14 for more information on controlling cookies. Please note that we do not control the activities of such third parties, nor the data that they collect and use themselves, and we advise you to check the privacy policies of any such third parties.

8.How Long Will You Keep My Personal Data?

We will not keep your personal data for any longer than is necessary in light of the reason(s) for which it was first collected. Your personal data will therefore be kept for the following periods (or, where there is no fixed period, the following factors will be used to determine how long it is kept):

• We will only retain your personal information 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. Details of retention periods for different aspects of your personal information are available in our data retention policy which is available from our Group Data Protection Officer (owain@mangopay.co.uk). 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 we may anonymise your personal information so that it can no longer be associated with you, in which case we may use such information without further notice to you. Once you are no longer an employee, worker or contractor of the company we will retain and securely destroy your personal information in accordance with our data retention policy or applicable laws and regulations (where appropriate).

9.How and Where Do You Store or Transfer My Personal Data?

We will only store or transfer your personal data in the UK. This means that it will be fully protected under the GDPR.

The security of your personal data is essential to us, and to protect your data, we take a number of important measures, including the following:

• Complying with Cyber Essentials standards for data handling.

10.Do You Share My Personal Data?

We may share your personal data with other companies in our group for enquiries connected with the business of the subsidiary. This includes Mango Accountancy Services Limited.

We may sometimes contract with the following third parties to supply certain services. These may include payment processing, delivery, and marketing. In some cases, those third parties may require access to some or all of your personal data that we hold.

• Saffery Champness, Chartered Accountants; and Brabners, Lawyers for the purpose of statutory and trade body audits.

If any of your personal data is required by a third party, as described above, we will take steps to ensure that your personal data is handled safely, securely, and in accordance with your rights, our obligations, and the third party’s obligations under the law, as described above in Part 9.

If any personal data is transferred outside of the EEA, we will take suitable steps in order to ensure that your personal data is treated just as safely and securely as it would be within the UK and under the GDPR, as explained above in Part 9.

If any personal data is transferred outside of the EEA, we will take suitable steps in order to ensure that your personal data is treated just as safely and securely as it would be within the UK and under the GDPR, as explained above in Part 9.

In some limited circumstances, we may be legally required to share certain personal data, which might include yours, if we are involved in legal proceedings or complying with legal obligations, a court order, or the instructions of a government authority.

11.How Can I Control My Personal Data?

• 11.1.In addition to your rights under the GDPR, set out in Part 5, when you submit personal data via Our Site, you may be given options to restrict our use of your personal data. In particular, we aim to give you strong controls on our use of your data for direct marketing purposes (including the ability to opt-out of receiving emails from us which you may do by unsubscribing using the links provided in our emails and at the point of providing your details and by managing your Account).
• 11.2.You may also wish to sign up to one or more of the preference services operating in the UK: The Telephone Preference Service (“the TPS”), the Corporate Telephone Preference Service (“the CTPS”), and the Mailing Preference Service (“the MPS”). These may help to prevent you receiving unsolicited marketing. Please note, however, that these services will not prevent you from receiving marketing communications that you have consented to receiving.

12.Can I Withhold Information?

You may access Our Site without providing any personal data at all. However, to use all features and functions available on Our Site you may be required to submit or allow for the collection of certain data.

You may restrict our use of Cookies. For more information, see Part 14.

13.How Can I Access My Personal Data?

If you want to know what personal data we have about you, you can ask us for details of that personal data and for a copy of it (where any such personal data is held). This is known as a “subject access request”.

All subject access requests should be made in writing and sent to the email or postal addresses shown in Part 15. To make this as easy as possible for you, a Subject Access Request Form is available for you to use. You do not have to use this form, but it is the easiest way to tell us everything we need to know to respond to your request as quickly as possible.

There is not normally any charge for a subject access request. If your request is ‘manifestly unfounded or excessive’ (for example, if you make repetitive requests) a fee may be charged to cover our administrative costs in responding.

We will respond to your subject access request within 10 working days and, in any case, not more than one month of receiving it. Normally, we aim to provide a complete response, including a copy of your personal data within that time. In some cases, however, particularly if your request is more complex, more time may be required up to a maximum of three months from the date we receive your request. You will be kept fully informed of our progress.

14.How Do You Use Cookies?

Our Site may place and access certain first-party Cookies on your computer or device. First-party Cookies are those placed directly by us and are used only by us. We use Cookies to facilitate and improve your experience of Our Site and to provide and improve our services. We have carefully chosen these Cookies and have taken steps to ensure that your privacy and personal data is protected and respected at all times.

By using Our Site, you may receive certain third-party Cookies on your computer or device. Third-party Cookies are those placed by websites, services, and/or parties other than us. Third-party Cookies are not being used on Our Site at the moment. For more details, please refer to the table below. These Cookies are not integral to the functioning of Our Site and your use and experience of Our Site will not be impaired by refusing consent to them.

All Cookies used by and on Our Site are used in accordance with current Cookie Law.

Before Cookies are placed on your computer or device, you will be shown a message in a bar at the bottom of the browser requesting your consent to set those Cookies. By giving your consent to the placing of Cookies you are enabling us to provide the best possible experience and service to you. You may, if you wish, deny consent to the placing of Cookies; You will be given the opportunity to allow only first-party Cookies and block third-party Cookies.

The following first-party Cookies may be placed on your computer or device:

Cookie	Type	Duration	Description
_ga	persistent	2 years	Used to identify unique users.
_gat	session	1 min	Used to throttle the request rate.
_gid	persistent	24 hours	Used to record the user journey.

Our Site uses analytics services provided by google analytics?. Website analytics refers to a set of tools used to collect and analyse anonymous usage information, enabling us to better understand how Our Site is used. This, in turn, enables us to improve Our Site and the services offered through it.

The analytics service used by Our Site uses Cookies to gather the required information. You do not have to allow us to use these Cookies, however whilst our use of them does not pose any risk to your privacy or your safe use of Our Site, it does enable us to continually improve Our Site, making it a better and more useful experience for you.

The analytics service used by Our Site use(s) the following Cookies:

Cookie	Type	Duration	Description
_ga	persistent	2 years	Used to identify unique users.
_gat	session	1 min	Used to throttle the request rate.
_gid	persistent	24 hours	Used to record the user journey.

In addition to the controls that we provide, you can choose to enable or disable Cookies in your internet browser. Most internet browsers also enable you to choose whether you wish to disable all Cookies or only third-party Cookies. By default, most internet browsers accept Cookies, but this can be changed. For further details, please consult the help menu in your internet browser or the documentation that came with your device.

You can choose to delete Cookies on your computer or device at any time, however you may lose any information that enables you to access Our Site more quickly and efficiently including, but not limited to, login and personalisation settings.

It is recommended that you keep your internet browser and operating system up-to-date and that you consult the help and guidance provided by the developer of your internet browser and manufacturer of your computer or device if you are unsure about adjusting your privacy settings.

15.How Do I Contact You?

To contact us about anything to do with your personal data and data protection, including to make a subject access request, please use the following details (for the attention of Owain Davies):

Email address: owain@mangopay.co.uk

Telephone number: 03300 580290

Postal Address: S8 Oaklands Business Centre Hooton Road Hooton Cheshire CH66 7NZ

16.Changes to this Privacy Policy

We may change this Privacy Notice from time to time. This may be necessary, for example, if the law changes, or if we change our business in a way that affects personal data protection.

Any changes will be immediately posted on Our Site and you will be deemed to have accepted the terms of the Privacy Policy on your first use of Our Site following the alterations. We recommend that you check this page regularly to keep up-to-date.