This document refers to personal data, which is defined as information concerning any living person (a natural person who hereafter will be called the Data Subject) that is not already in the public domain.
The General Data Protection Regulation (GDPR) which is EU wide and far more extensive than its predecessor the Data Protection Act, along with the Privacy and Electronic Communications Regulations (PECR), seek to protect and enhance the rights of EU data subjects. These rights cover the safeguarding of personal data, protection against the unlawful processing of personal data and the unrestricted movement of personal data within the EU and its storage within the EEA.
The business TruNarrative Limited, based at, The Leeming Building, Vicar Lane, Leeds, LS2 7JF, which hereafter for the purposes of this Privacy Notice will be referred to as the Business, is pleased to provide the following information:
Who we are
The business provides the following services:
TruNarrative provides a unified, holistic platform for joined-up fraud, identity, KYC and AML decisioning to global businesses.
Built upon a dynamic risk engine, the latest API management capability and an orchestration layer with case management and document processing built in, TruNarrative’s technology is designed to solve some of the most important challenges of modern business.
Data goes to the heart of what we do and in all the markets in which we operate we make data protection understanding a priority for both our business and those of our clients.
We are committed to providing users of this site with the utmost security and privacy.
We aim to comply with all relevant legislation, licence terms and maintain industry standards and continually monitor our management of and our processes in providing our services to you.
We are registered with the Information Commissioner’s Office in the UK registration number ZA245377 https://ico.org.uk.
a) The Business uses the information collected from you to provide quotations, make telephone contact and to email you information concerning your enquiry.
b) For marketing purposes, the Business may use the contact details provided by you to respond to your enquiries including making telephone contact, emailing information to you which we believe may be of interest to you.
c) In you making initial contact you consent to the Business maintaining a marketing dialogue with you until you either opt out (which you can do at any stage) or we decide to desist in promoting our services. At all times, the business will work hard to be fully GDPR compliant.
d) Some personal data may be collected about you from the forms and surveys you complete, from records of our correspondence, when you visit us, from phone calls and details of your visits to our website, including but not limited to, personally identifying information like Internet Protocol (IP) addresses.
f) The Business will only collect the information needed so that it can provide you with the products and/or services it provides; the business does not sell or broker your data.
g) Telephone calls are recorded for training and security reasons; call data is retained no longer than six months unless it is required longer for legal reasons.
Further information exclusively pertaining to GDPR and employees, can be obtained from the Company Handbook.
Legal basis for processing any personal data
To meet our contractual obligations to customers and legitimate interest to respond to enquiries concerning the products and/or services provided.
Legitimate interests pursued by the business
To promote our products and/or services and to inform existing and prospective customers about the TruNarrative Financial Crime Platform, ensuring ongoing business viability through communication with clients and prospects. Communications may include direct mail, email, newsletters, telephone calls, social media and any other channels to reach those who may be interested in using the goods and/or services provided by the business.
Through agreeing to this privacy notice you are consenting to the Business processing your personal data for the purposes outlined. You can withdraw consent at any time by using the postal, email address or telephone number provided at the end of this Privacy Notice.
The Business will keep your personal information safe and secure, although our administration team will have access to your contact details so that they can manage your account.
The Business will not disclose your Personal Information unless compelled in order to meet legal obligations, regulations or valid governmental requests.
The business may also enforce its Terms and Conditions, including investigating potential violations of its Terms and Conditions to detect, prevent or mitigate fraud or security or technical issues; or to protect against imminent harm to the rights, property or safety of its staff.
The Business will process personal data for the duration of any business dealings and will continue to store only the personal data needed for eight years after any contract has expired to meet any legal obligations. After eight years all personal data will be deleted, unless basic information needs to be retained by us to meet our future obligations to you, such as erasure details.
All Data is held in the European Union. The Business does not store personal data outside the EEA.
our rights as a data subject
At any point whilst the Business is acting as a Data Controller and is in possession of, or processing your personal data, all data subjects have the following rights:
· Right of access – you have the right to request a copy of the information that we hold about you.
· Right of rectification – you have a right to correct data that we hold about you that is inaccurate or incomplete.
· Right to be forgotten – in certain circumstances you can ask for the data we hold about you to be erased from our records.
· Right to restriction of processing – where certain conditions apply you have a right to restrict the processing.
· Right of portability – you have the right to have the data we hold about you transferred to another organisation.
· Right to object – you have the right to object to certain types of processing such as direct marketing.
· Right to object to automated processing, including profiling – you also have the right not to be subject to the legal effects of automated processing or profiling.
In the event that the Business refuses your request under rights of access, we will provide you with a reason as to why, which you have the right to legally challenge.
At your request, the Business can confirm what information it holds about you and how it is processed.
You can request the following information:
· Identity and the contact details of the person or organisation that has determined how and why to process your data.
· Contact details of the data protection officer, where applicable.
· The purpose of the processing as well as the legal basis for processing.
· If the processing is based on the legitimate interests of the Business and information about these interests.
· The categories of personal data collected, stored and processed.
· Recipient(s) or categories of recipients that the data is/will be disclosed to.
· How long the data will be stored.
· Details of your rights to correct, erasure, restrict or object to such processing.
· Information about your right to withdraw consent at any time.
· How to lodge a complaint with the supervisory authority (ICO).
· Whether the provision of personal data is a statutory or contractual requirement, or a requirement necessary to enter into a contract, as well as whether you are obliged to provide the personal data and the possible consequences of failing to provide such data.
· The source of personal data if it wasn’t collected directly from you.
· Any details and information of automated decision making, such as profiling, and any meaningful information about the logic involved, as well as the significance and expected consequences of such processing.
To access what personal data is held, identification will be required
The Business will accept the following forms of ID when information on your personal data is requested: a copy of your driving licence, passport, birth certificate and a utility bill not older than three months. A minimum of one piece of photographic ID listed above and a supporting document is required. If the Business is dissatisfied with the quality, further information may be sought before personal data can be released.
All requests should be made to email@example.com by phoning +44 (0) 2038871539 or writing to us at the address below.
In the event that you wish to make a complaint about how your personal data is being processed by the Business you have the right to complain to us. If you do not get a response within 30 days you can complain to the ICO.
The details for each of these contacts are:
Jon Kent, TruNarrative Limited, The Leeming Building, Vicar Lane, Leeds LS2 7JF
Telephone +44 (0) 2038871539 or email: firstname.lastname@example.org
Wycliffe House, Water Lane, Wilmslow, SK9 5AF
Telephone +44 (0) 303 123 1113 or email: https://ico.org.uk/global/contact-us/email/
Published June 6th 2018 V1 Issue number 1001