Website Privacy Notice

Last updated on 19 Feb 2024.

Introduction

The Fnality Group (comprised of Fnality International Limited, Fnality Services Limited and Fnality UK Limited) (“we”, “us” or “Fnality”) respects your privacy and is committed to protecting your personal data. This privacy notice will inform you how we look after your personal data and tell you about your privacy rights. This privacy notice applies to you if:

• you visit our website at Fnality International (our “Website”) (regardless of where you visit it from);

• you are a business contact of one of Fnality team members or you are otherwise in contact with us;

• you are working for an investor or a prospective investor in Fnality; or

• you are working for one of our vendors, subcontractors or professional advisers.

Our Website is not intended for children and we do not knowingly collect data relating to children.

In summary

• We keep to a minimum the amount of information we hold about you.

• We use your data to respond to your enquiries, communicate with you and/or send you useful information.

• We delete your data when it is no longer needed.
  We apply appropriate security mechanisms to protect your personal data. We ensure any third party processors have sufficient safeguards in place.

 

1. Data Controller

• Fnality is the Data Controller in respect of your personal data.

• We have appointed a Data Protection Manager who is responsible for overseeing compliance with this privacy notice. If you have any questions about this privacy notice, including any requests to exercise your legal rights, please contact the Data Protection Manager using the details set out below.

Full name of legal entity: Fnality International Limited

Email address: data.protection@fnality.org

Postal address: C/O RSM 6th Floor, 25 Farringdon Street, London, England, EC4A 4AB

2. Third-party links

This Website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our Website, we encourage you to read the privacy policy of every website you visit.

3. Data we collect about you

Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).

It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.

If you are visiting our Website, we will collect and process the following information:

Technical Data – internet protocol (IP) address, 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 this Website, as well as information about how you use our Website. Please refer to our Cookies Policy for further details about the tracking technologies used on our Website.

If you submit the “Contact Us” form on our Website, we will collect and process the following information:

• Identity Data – your name, last name, company you work for (and the institution type) and your job title.

• Contact Data – your email address and telephone number.

• Marketing Preferences Data – your choice in relation to our newsletters.

If you work for one of our investors (including if you are a director of Fnality) or prospective investors, or you are our business partner in any other capacity, we will collect and process the following information about you:

• Identity Data – your name, last name, company you work for (and the institution type) and your job title.

• Contact Data – your email address and telephone number.

• Marketing Preferences Data – your choice in relation to our newsletters.

• Communications Data – communications received from you and your engagement with our marketing communications (if applicable).

If you work for our vendors, contractors or professional advisers, we will collect and process the following information about you:

• Identity Data – your name, last name, company you work for (and the institution type) and your job title.

• Contact Data – your email address and telephone number.

• Communications Data – communications received from you.

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.

If you fail to provide personal data

• Where we need to collect personal data by law, or under the terms of a contract we have with you (or the organisation you represent), and you fail to provide that data when requested, we may not be able to perform the contract or continue our engagements with you.

4. How is your personal data collected?

We use different methods to collect data from and about you including through:

• Direct interactions. You (or your employer) may give us your identity and contact information by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you request information about us, submit an enquiry, give us feedback or otherwise contact us.

• Automated technologies or interactions. As you interact with our Website, we will automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies, server logs and other similar technologies. Please see our Cookies Policy for further details.

• Third parties or publicly available sources. We may receive personal data about you from various third parties including:

5. How we use your personal data

We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:

• Where we need to perform the contract, we are about to enter into or have entered into with you (or the organisation you represent).

• Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.

• Where we need to comply with a legal obligation.

Generally, we do not rely on consent as a legal basis for processing your personal data. However, if you submit a “Contact Us” form on our Website and you choose to receive our newsletters, we will ask for your consent to the processing of your personal data for this purpose. You have the right to withdraw consent to marketing at any time by contacting us – see section 6 below for more details on how to opt-out from receiving our newsletters.

Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground we are relying on to process your personal data.

6. Purposes for which we will use your personal data

We have set out below a description of all the ways we plan to use your personal data.

If you are visiting our Website, we will collect and process the Technical Data about your visit to manage and improve our Website and for the purposes set out in our Cookies Policy.

If you submit the “Contact Us” form on our Website, we will collect and process your Identity Data, your Contact Data and your Marketing Preferences Data to enable us to respond to your enquiry, record your marketing preferences and send you our newsletter if you chose to receive it.

If you work for one of our investors (including if you are a director of Fnality) or prospective investors, or you are our business partner in any other capacity, we will collect and process your Identity Data, your Contact Data, your Marketing Preferences Data and your Communications Data to enable us to manage our relationship with you and to communicate with you (including to send you our newsletter, if you marketing preferences permit this). If you are representing one of our existing investors, we will use your personal data to provide you with Fnality performance and reporting information and for the purpose of management reporting.

If you are attending any events organised by us, we will process your Identity Data, Contact Data and Communications Data for the purpose of organising and managing the event. This may include data relating to your dietary preferences (if relevant to the event).

If you work for our vendors, contractors or professional advisers, we will collect and process your Identity Data, your Contact Data and your Communications Data to manage our relationship with you (and your employer) and to assess the performance of the services received by us.

We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.

If we need to use your personal data for an unrelated purpose, we will notify you and we will

explain the legal basis which allows us to do so.

Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

Marketing

We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising.

If you work for one of our investors (including if you are a director of Fnality) or prospective investors, or you are our business partner in any other capacity, we believe that you welcome news about Fnality, the progress of our project, our products and services as well as other related content. We rely on our legitimate interest to send our email newsletters to all our business partners, investors and potential investors, but only if your email address is not a private email address and you have not opted-out from our newsletters. If you no longer wish to receive our newsletters, simply click the “unsubscribe” link in our latest newsletter email, or contact us to opt-out.

If you have completed the “Contact Us” form on our Website and you chose to receive our newsletters by ticking the relevant box, the basis on which we will rely to send you our email newsletters is your consent. You can always withdraw your consent by clicking the “unsubscribe” link in our newsletter email or by contacting us.

We will not share your personal data with any third party for marketing purposes, unless we obtain your express consent to do so.

7. Data sharing and transfers

We will share your personal information with third parties only where required by law, where it is necessary in connection with the purpose for which we collected your data (see paragraph 6 above) or where we have another legitimate interest in doing so.

“Third parties” includes third-party service providers (including contractors), professional advisers and other entities within our group. For example our current CRM and marketing communications management platform is provided by HubSpot.

All our third-party service providers and other entities in the group are required to take appropriate security measures to protect your personal information in line with our policies. We do not allow our third-party service providers to use your personal data for their own purposes. We only permit them to process your personal data for specified purposes and in accordance with our instructions.

We may share your personal information with other third parties, for example in the context of the possible sale or restructuring of the business. In this situation we will, so far as possible, share anonymised data with the other parties before the transaction completes. Once the transaction is completed, we will share your personal data with the other parties if and to the extent required under the terms of the transaction.

We may also need to share your personal information with a regulator or to otherwise comply with the law. This may include making returns to HMRC, disclosures to regulators and disclosures to shareholders such as directors’ remuneration reporting requirements.

Some of our external third parties may be based outside the EEA so their processing of your personal data will involve a transfer of data outside the EEA. Whenever we transfer your personal data out of the EEA, we ensure a similar degree of protection is afforded to it by ensuring that where we use certain service providers, we use specific contracts approved by the UK GDPR which give personal data the same protection it has in EEA.

8. Data Security

We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions, and they are subject to a duty of confidentiality.

We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

9. Data retention

We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.

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, regulatory, tax, accounting or other requirements. For example:

• we will retain evidence of opt-out from newsletters for an indefinite period of time, to ensure that we do not send you any further newsletters in breach of your opt-out request;

• if you have submitted your consent to receive our newsletters via our Website, we will retain evidence of your consent for a period of 6 years from the date you withdraw your consent or your consent ceased to be valid (usually not more than 2 years from the date it was given).

In some circumstances you can ask us to delete your data: see your legal rights below for further information.

In some circumstances we will anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes, in which case we may use this information indefinitely without further notice to you.

10. Your legal rights

Under certain circumstances, by law you have the right to:

• Request access to your personal information (commonly known as a “data subject access request”). This enables you to receive a copy of the personal information we hold about you and to check that we are lawfully processing it.

• Request correction of the personal information that we hold about you. This enables you to have any incomplete or inaccurate information we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.

• Request erasure of your personal information. 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. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.

• Object to processing of your personal information 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. You also have the right to object where we are processing your personal information for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.

• Request the restriction of processing of your personal information. This enables you to ask us to suspend the processing of personal information about you, for example if you want us to establish its accuracy or the reason for processing it, or if you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.

• Request the transfer of your personal information to another party. 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 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. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.

If you wish to exercise any of the rights set out above, please contact us via email data.protection@fnality.org.

No fee usually required

You will not have to pay a fee to access your personal information (or to exercise any of the other rights). However, we may charge a reasonable fee if your request for access is clearly unfounded or excessive. Alternatively, we may refuse to comply with the request in such circumstances.

What we may need from you

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.

Time limit to respond

We try to respond to all legitimate requests within one month. Occasionally it could 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.

11. 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 (http://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.