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Revision:

1.0

Date:

1/7/2022

Introduction

Daniel Finance Ltd (“DANIEL”, “we” or “us”), recognises the importance of the protection of personal data.  Before communicating any personal data, DANIEL invites you to read this Privacy Policy carefully as it contains important information on how we use your personal data supplied to us, the security measures taken to ensure the protection of this personal data and your rights and protections available in compliance with relevant Data Protection Laws (including GDPR).

This Privacy Policy:

  • Is intended only for the Website https://www.daniel.global/ (“Website”)
  • Does not apply to other websites consulted via external links or links contained on our Website.  Such websites have their own privacy policies and we do not accept any responsibility or liability for these policies

Daniel Finance Limited is a company incorporated in England with company number 11346903, and the registered address at 71-75 Shelton Street, Covent Garden, London, England, WC2H 9JQ.

This privacy policy is not intended to cover personal data that we may process on behalf of our clients or customers. Any queries relating to such data should be directed to the relevant organisation in the first instance.

Data Controller

The Data Controller is DANIEL as defined above. We are registered with the Information Commissioner's Office (ICO) as a Data Controller, registration number ZB369471.

Our registered address is 71-75 Shelton Street, London, WC2H 9JQ, United Kingdom.

For any information regarding the processing of personal data of the Data Controller, including the list of data processors, please write to DPO@daniel.global.

Data Protection Officer

DANIEL has appointed a Data Protection Officer (DPO) to ensure we are meeting our requirements for the processing of your personal data.

The DPO has specific functions they are legally responsible for. Some of these are below:

  • To be DANIEL’s point of contact for all data protection issues
  • To ensure DANIEL complies with all relevant Data Protection laws
  • To ensure all DANIEL staff receive Data Protection training
  • To ensure all DANIEL’s systems and processes are reviewed regularly

What Information Do We Collect From You?

When visiting our Website and utilising our services, it may be necessary for us to collect and process personal data from you as follows:

  • Information provided by you at the time of registering for our service such as: name; telephone number;  email address; residential address; date of birth; nationality; bank account information, other identification details (e.g. passport) and transactional information. This information may also be input by you when reporting a problem with our Website or other service
  • Any correspondence sent to us by you
  • Technical Data such as: internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, and other technology on the devices you use to access the Website.
  • Navigation data. The computer systems of the Website collect some Personal Data that is required in the use of Internet communication protocols. This information is not collected to be associated with you, but by its very nature could, through processing and association with data held by third parties, allow you to identify yourself. This data is used to obtain anonymous statistical information on the use of the Website and to check its correct functioning
  • Marketing and Communications Data such as: your preferences for receiving marketing from us and our third parties and your communication preferences.

DANIEL does 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).

How Do We Use Your Information?

Information that we hold about you is used in the following ways:

  • The execution of a contract of which you are a party or to the execution of pre-contractual measures taken on your request (e.g. the management of your account)
  • To allow the correct delivery of the various features you requested e.g. to carry out your transaction instructions
  • To fulfil any obligations required by applicable laws, regulations or Community legislation, or satisfy requests from authorities
  • To notify you of any change to our service
  • To develop new products
  • To conduct analysis to track business performance and aid in the operation and protection of the business
  • To ascertain, exercise or defend a right in court or whenever the jurisdictional authorities exercise their jurisdictional duties;
  • To allow navigation of the Website and the provision of our services
  • To find specific requests addressed to us
  • To carry out direct marketing via e-mail for services similar to those signed by you, subject to your refusal to receive such communications, which may be expressed during registration or on subsequent occasions by contacting DPO@daniel.global
  • To carry out marketing activities such as: preparing studies, research, market statistics; send informational and promotional material relating to the activities, services and products DANIEL and our commercial partners (without any communication of personal data held by us to the aforementioned Partners)
  • Send you surveys to improve the service (“customer satisfaction”). Such communications may be made by e-mail or text message, by mail and / or the use of the telephone with operator and / or through the official pages of DANIEL on social networks
  • For statistical purposes, without being able to trace your identity

DANIEL does not typically rely on consent as a legal basis for processing your personal data although we will obtain your consent before sending direct marketing communications to you. You have the right to withdraw consent to marketing at any time by contacting us.

More than one lawful ground for processing may be used by DANIEL to process your personal data depending on the specific purpose we are using your data for. Please contact us if you need details about the specific legal ground we are relying on to process your personal data.

Who We Share Your Information With

In order for DANIEL to provide you with the requested services, we are required to collaborate with various third parties. These are partners such as technical sub-contractors, payment and delivery services, analytics providers, credit reference agencies and fraud prevention tools.  Information that may be collected about you from partners can include information which helps us to verify your identity or information relating to your payment transactions.

Your Personal Data may also be shared with:

  • Our banking partner with whom you have your online account
  • Other third parties where you ask us to, including with partners integrated with DANIEL via our API or in connection with banking and financial services
  • Subjects that typically act as data controllers, namely: i) persons, companies or professional firms that provide assistance and advice to DANIEL in accounting, administrative, legal, tax and financial matters; ii) subjects delegated to carry out technical maintenance activities; iii) credit institutions, insurance companies and brokers; iv) companies controlling, controlled and connected to DANIEL, limited to the pursuit of administrative-contracting purposes connected to the performance of organizational, administrative, financial and accounting activities
  • Persons authorised by DANIEL to process Personal Data that have committed to confidentiality or have an adequate legal obligation of confidentiality; (e.g. employees of DANIEL)
  • Subjects, bodies or authorities to whom it is mandatory to communicate your personal data in accordance with the provisions of law or orders of the authorities
  • Jurisdictional authorities in the exercise of their functions when required by the Applicable Regulations.
  • Any prospective seller or buyer should we sell or buy any business or assets

Where Is Your Personal Data Stored?

Personal Data that is collected from you is stored in servers managed by our hosting partners.  These servers are located across a number of secure data centres in the UK and EEAAny personal data will be encrypted “at rest” (in other words, on being stored).  

Staff working for on behalf of DANIEL located outside the UK or EEA may also process your personal data. Prior to your personal data being transmitted outside the UK or EEA, we will ensure that either the destination country is the subject of an EU Adequacy Decision or there are measures in place that are equal to EU standards to ensure the security of your data.

Whilst we undertake to do our best to ensure your personal data is protected, and procedures and features are in place to prevent unauthorised access, any transmission of data to our Website is at your own risk. This is because we are not able to guarantee the security of your data transmitted to our Website as the transmission of data via the Internet is not completely secure.

Data Retention

DANIEL will process and retain your personal data for the time strictly necessary to achieve the purposes indicated above. There may be times when we are subject to legislative requirement to retain your data, such as our Anti-Money Laundering obligations.  When such an obligation exists, DANIEL will ensure Compliance with these requirements.

Anti-Money Laundering and Compliance

DANIEL may as part of the processing of your personal data, make decisions by automated means, e.g. DANIEL may automatically decide that you pose a fraud or money laundering/terrorist financing risk if it is determined your behaviour is consistent with money laundering/terrorist financing or known fraudulent typologies. You have rights in relation to automated decision making and if you want to know more, please contact us at DPO@daniel.global.

If it is determined that a fraud or money laundering/terrorist financing risk is posed by you as a result of processing by us or a third party, we may refuse to provide the services you have requested, or we may cease providing existing services to you.

DANIEL is required to make all information provided to us available to law enforcement bodies and regulatory authorities in both the country of origin of the funds and the destination country of the funds.

Cookies

DANIEL collects personal data through the use of cookies. This is for the purpose of obtaining information about your general internet usage and some of these are essential for the operation of our Website.  More information on the use of cookies and related technologies is available in our Cookies Policy document.

Rights Available to Individuals

Data Protection legislation has granted you the below rights in relation to your personal data:

  • Request access to your personal data (commonly known as a "data subject access request"). This enables you to receive a copy of the personal data we hold about you.
  • Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data corrected, however, we may need to verify the accuracy of the new data you provide to us.
  • 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 successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Please be aware that we may not always be able to comply with your request of erasure for legal reasons which will you will be advised of at the time of your request.
  • Object to processing of your personal data. This is in situations where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal information for direct marketing purposes. In some cases, we may be able to show that we have compelling legitimate grounds to process your information which override your rights. Due to regulatory requirements, DANIEL has numerous obligations to process and retain certain personal information for compliance purposes, these requirements supersede any right to objection requests under applicable data protection laws. If you object to the processing of certain personal information, we may not be able to provide you with our services and it is likely we will have to terminate your account.
  • Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios: (a) if you want us to establish the data's accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it. Please be aware that any requests in relation to the restriction of the processing of your data means that we may not be able to perform the contract we have or are trying to enter into with you. In this case, we may have to cancel your use of our Services but we will notify you if this is the case at the time.
  • Request the transfer of your personal data to you or to a third party. We will provide you with your personal information in a structured, commonly used, machine-readable format, which you can then transfer to an applicable third party. Please be aware 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 at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent.  Please be aware, if you withdraw your consent, we may not be able to provide our Services to you and we will advise you of this following receipt of your request.
  • Should you wish to access any of your rights, please contact us at DPO@daniel.global

Data Subject Access Requests (DSAR)

Should you wish to request access to the personal data we hold about you, you are entitled to make a DSAR, by contacting DPO@daniel.global.  Please provide an outline of what data you are requesting, and the reason for your request.  You will not have to pay a fee, however, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, 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.

We try to respond to all DSAR 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.

Complaints

You have the right to make a complaint at any time to the Information Commissioner's Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk).  We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.

Changes to this Privacy Policy

DANIEL reserves the right to modify or simply update its content, in part or completely, due to changes in the applicable legislation. We will inform you of these changes as soon as they are introduced and they will be binding as soon as they are published on the Website. DANIEL invites you to visit this section regularly to get to know the most recent and updated.

Conflict Between English Text and Other Translations

If there is any conflict or discrepancy between the English text of this privacy policy and any translation, the English text shall prevail and supersede any other translation or any other version in any other language.

Our Contact Details

Should you wish to make any comments or requests in relation to anything in this policy, please contact DPO@daniel.global or write to the Data Protection Officer, Daniel Finance Ltd, 71-75 Shelton Street, London, WC2H 9JQ

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