About this policy
This policy describes how we use your personal data when you use our website (www.amlcc.co.uk) or our product. We have provided this policy to ensure that you understand what personal data we may collect and hold about you, what we may use it for and how we keep it safe. You have legal rights to access the personal data that we hold about you and to control how we use it which are also explained.
You can click on the links below to see specific information about:
Who we are and how you can contact us
We are Anti-Money Laundering Compliance Company Limited, a limited company registered in England and Wales under company number 4525430. Our registered office address is at Alma Park, Woodway Lane, Claybrooke Parva, Lutterworth, Leicestershire, LE17 5FB.
You can contact us in writing at Alma Park, Woodway Lane, Claybrooke Parva, Lutterworth, Leicestershire, LE17 5FB or by emailing Admin@amlcc.co.uk. If you would like to speak to us please call us on 01455 555 468.
Our data compliance manager
We have appointed a data compliance manager who acts as our primary point of contact for any questions or concerns you may have regarding our handling of your personal data.
You can contact our Data Compliance Manager using the contact details in the Who we are and how you can contact us section above and marking your correspondence “FAO Data Compliance Manager”.
What personal data we collect about you
- personal data that you provide to us. There are lots of ways in which you may share your personal data with us, for example, you will share your name, position and professional contact details with us when you use our product or contact us in connection with our product. You may share further personal data including your opinions with us if you complete a survey or questionnaire we send you for research purposes or if you make a complaint or support request to us.
- personal data that we receive from third parties. We may receive your personal data from your employer if it has subscribed to our product and wishes us to set up a user account for you. If we work with other businesses or use sub-contractors these parties may collect personal data about you which they will share with us. For example, we may have your name and contact details passed to us by a mutual contact that refers you to us so that we can provide you with our product or receive your details from a supervisory or membership organisation that funds your AMLCC subscription.
- personal data about your use of our website and product. This is technical information and includes details such as your IP address, your login information, browser type and version, time zone setting, browser plug-in types and versions, operating system and platform, as well as details of how you navigated to our website and where you went when you left, what pages or products you viewed or searched for, page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs), and any phone number or email address used to contact us.
What we use your personal data for
We use your personal data in the following ways:
- personal data that you provide to us is used to:
- provide you with information that you request from us
- enable you to use our product
- provide you with marketing information in accordance with your marketing preferences (see How we use your personal data for marketing)
- manage and administer our business
- review and improve our product and customer experience
- personal data that we receive from third parties is combined with the personal data that you provide to us and used for the purposes described above.
- personal data about your use of our website and/or our product is used to:
- administer our website and product and for internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes
- to improve our website and product to ensure that content is presented in the most effective manner for you and for your computer or mobile device
- to allow you to participate in interactive features of our product, when you choose to do so
- as part of our efforts to keep our website and product safe and secure
Consent and other legal grounds for processing your data
Whilst we always want you to be aware of how we are using your personal data, this does not necessarily mean that we are required to ask for your consent before we can use it. In the day to day running of our business we may use your personal data without asking for your consent because:
- we are entering into and carrying out our obligations under a contract with you
- we need to use your personal data for our own legitimate purposes (such as the administration and management of our business and the improvement of our services) and our doing so will not interfere with your privacy rights
- we are subject to legal obligations that require us to use your personal data in certain ways (such as disclosing information to HM Revenue & Customs)
The most common situation in which we will process your personal data on the grounds of consent is where we wish to send marketing communications to you. Please refer to the section on How we use your personal data for marketing to read about our marketing practices.
In exceptional circumstances we may wish to use your personal data for a different purpose to the purpose for which we originally collected your personal data. Unless this is to fulfil a legal obligation, in these circumstances we will contact you to explain how we wish to use your data and to ask for your consent.
You are not required to give consent just because we ask for it. If you do give consent you can change your mind and withdraw it at a later date.
To help you understand the legal grounds we rely on for different types of processing, we have set out an overview of the main processing activities we undertake and the relevant legal grounds below:
|Categories of personal data used||Purpose||Legal basis|
|Name, position and contact details||To respond to your enquiries regarding our product||Legitimate interest (in growing our business and developing new customer relationships) and/or contractual necessity|
|Name, position and contact details, financial information, transaction history||To enable your subscription to our product and to collect money owed to us||Contractual necessity and/or legitimate interests (to recover monies due to us)|
|Name, position and contact details, financial information, transaction history||To manage our relationship with you e.g. to keep your details up to date and notify you of any changes to our contractual documents or privacy policies||Contractual necessity and/or legitimate interests (to keep our records updated and understand how our customers use our goods and services)|
|Name, position and contact details, transaction history, details of your interests and preferences, technical data about your use of our website and product, your marketing preferences||To send you appropriate marketing communications in accordance with your marketing preferences||Consent and/or legitimate interests (to grow and develop our business)|
|Name, position and contact details, transaction history, technical data about your use of our website and product||To manage and administer our business and website and product (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)||Legitimate interests (to run our business, provide administration and IT services, ensure network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercises) and legal obligations|
|Name, position and contact details, transaction history, details of your interests and preferences, technical data about your use of our website and product, your marketing preferences||To develop and improve our website and product and our customer relationships and experience||Legitimate interests (to define types of customers for our products and services, to keep our website updated and relevant, to develop our business, to improve our products and services and to inform our marketing strategy)|
Please note that whilst we will provide data processing services in respect of personal data about your own customers or clients that you collect and process using our product, you are considered to be the data controller, and are responsible for, the personal data that you collect and process about your customers and clients. Please refer to the data processing clause in our Terms and Conditions to better understand our obligations in this regard.
Personal data you are legally obliged to provide
You are not under a legal obligation to provide us with any of your personal data but please note that if you elect not to provide us with your personal data we may be unable to allow you to use our product.
Your rights to know what personal data we hold and to control how we use it
You have a legal right to know what personal data we hold about you – this is called the right of subject access. You can exercise this right (or any of the other rights described below) by sending us a written request at any time. Please mark your letter “Data Subject Request” and send it to us by post or email using the details in the Who we are and how you can contact us section marking your request “FAO Data Compliance Manager”.
You also have rights to:
- prevent your personal data being used for marketing purposes (see How we use your personal data for marketing for further details)
- have inaccurate personal data corrected, blocked or erased
- object to decisions being made about you by automated means or to your personal data being used for profiling purposes
- restrict our use of your personal data
- require that we delete your personal data (the “right to be forgotten”)
- require that we provide you, or anyone that you nominate, with a copy of personal data you have given us in a structured electronic form such as a CSV file
You can find full details of your personal data rights on the Information Commissioner’s Office website at www.ico.org.uk.
Automated decision making and profiling
We do not use your personal data to make automated decisions or to profile you.
When we will share your personal data with others
The business partners, suppliers and sub-contractors we work with to provide you with goods or services that you have requested from us. This includes:
- FA Simms and Partners Limited
- Draytus Ltd which provides IT development and support services
- PHD in Communication Ltd t/a Verbatim which provides call answering services
- AWS which provides web hosting services
- Barclaycard which provides payment processing services
- Simpson and Co which provide chartered accountancy and audit services
- Docusoft Ltd which provides IT support services
- consumer credit reporting agencies such as Equifax
- analytics and search engine providers that assist us in the improvement and optimisation of our website and app
- any supervisory or membership body that funds your subscription to our product
- HM Revenue & Customs
We may also share your personal information with third parties on a one-off basis, for example, if:
We sell or buy any business or assets (including our own), in which case we will disclose your personal data to the prospective seller or buyer of such business or assets
We are under a duty to disclose or share your personal data in order to comply with any legal obligation, or in order to enforce or apply our terms and conditions and other agreements; or to protect the rights, property, or safety of our customers, ourselves or others. This includes exchanging information with other companies and organisations for the purposes of fraud protection and credit risk reduction.
How we keep your personal data safe
We take every care to ensure that your personal data is kept secure. The security measures we take include:
- only storing your personal data on secure cloud-based servers
- only processing payments via a specialist third party payment provider that offers a secure payment platform
- ensuring that our staff receive regular data security awareness training
- keeping paper records to a minimum and ensuring that those we do have are stored in locked filing cabinets on our office premises
- maintaining up to date firewalls and anti-virus software to minimise the risk of unauthorised access to our systems
- enforcing a strict policy on the use of mobile devices and out of office working
Please remember that you are responsible for keeping your passwords secure. If we have given you (or you have chosen) a password which enables you to access certain parts of our website or product, you are responsible for keeping this password confidential. Please do not to share your passwords with anyone.
Unfortunately, sending information via the internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of personal data sent to our website; you send us personal data at your own risk. Once we have received your personal data, we will use strict procedures and security features (some of which are described above) to try to prevent unauthorised access.
How we use your personal data for marketing
We will add your details to our marketing database if:
- you make an enquiry about or purchase a subscription for our product and do not opt out of receiving marketing communications from us
- you have told a third party that you would like them to pass us your contact details so that we can send you marketing communications
- you have expressly told us that you are happy to receive marketing communications from us
We may send you marketing communications by email.
You may ask us not to send you any marketing communications by opting out at any time, either by clicking on the unsubscribe option you will find in every marketing email from us or by contacting us at any time using the details set out in the Who we are and how you can contact us section above.
You can check and update your current marketing preferences at any time by contacting us using the details set out in the Who we are and how you can contact us section above.
We never share your personal data with third parties for marketing purposes.
When we will send your personal data to other countries
If you would like to request a full schedule of recipients outside of the EEA which may have access to your personal data please contact us using the details in the Who we are and how you can contact us section above and marking your correspondence “FAO Data Compliance Manager”.
How long we keep your personal data
We only keep your personal data for as long as we actually need it. In practice this means that we will keep:
- your name and contact details for marketing purposes until you ask us to cease sending you marketing communications or we are notified that your contact details are no longer current
- you product log in and usage data for 1 year
- complaint records for 6 years from resolution of your complaint
- support records for 1 year (for general support queries) or for the term of your AMLCC subscription (for account-specific queries)
Please note that we may anonymise your personal data or use it for statistical purposes. We keep anonymised and statistical data indefinitely but we take care to ensure that such data can no longer identify or be connected to any individual.
If you have any questions about our data retention practices please contact us using the details in the Who we are and how you can contact us section above and marking your correspondence “FAO Data Compliance Manager”.
How you can make a complaint
If you are unhappy with the way we have used your personal data please contact us to discuss this using the contact details set out in the Who we are and how you can contact us section above and marking your correspondence “FAO Data Compliance Manager”.
You are also entitled to make a complaint to the Information Commissioner’s Office which you can do by visiting www.ico.org.uk. Whilst you are not required to do so, we encourage you to contact us directly to discuss any concerns that you may have and to allow us an opportunity to address these before you contact the Information Commissioner’s Office.
How we keep this policy up to date
We will review and update this policy from time to time. This may be to reflect a change in the goods or services we offer or to our internal procedures or it may be to reflect a change in the law.
The easiest way to check for updates is by looking for the latest version of this policy on our website or you can contact us (see Who we are and how to contact us) to ask us to send you the latest version of our policy.
Each time we update our policy we will update the policy version number shown at the end of the policy and the date on which that version of the policy came into force.
This is policy version number two which came into effect on 12 April 2019.