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    1. Payper Ltd (Company Number 09780349) of 41 Florida Street, London E2 6LP, United Kingdom (Payper), provides use and access the Payper mobile Application (Application).
    2. We have adopted this Privacy Policy to ensure that we have standards in place to protect the data that we collect about individuals that is necessary and incidental to:
      1. Providing the services that we offer; and
      2. The normal day-to-day operations of our business.
    3. We publish this Privacy Policy in compliance with obligations under the Data Protection Act 1998 (Act). We aim to make it easy for our users, and the public to understand what data we collect and store, why we do so, how we receive and/or obtain that information, and the rights an individual has with respect to their data in our possession.
    1. We handle data in our own right and for and on behalf of our users, Customers and Venues.
    2. The Privacy Policy applies to all forms of information, physical and digital, whether collected or stored electronically or in hardcopy.
    3. If, at any time, an individual provides data or other information about someone other than himself or herself, the individual warrants that they have that person's consent to provide such information for the purpose specified.
    1. In the course of business it is necessary for us to collect data. This information allows us to identify who an individual is for the purposes of our business, share data when required for the use of services, contact the individual in the ordinary course of business and transact with the individual. Without limitation, the type of information we may collect is:
      1. Personal Information. We may collect personal details such as an individual’s full name, date of birth and other information that may allow us to identify who the individual is;
      2. Contact Information. We may collect information such as an individual’s email address, telephone number, third-party usernames, address and other information that allows us to contact the individual;
      3. Account Information. We may collect account information for the purposes of convenient registration and access to the Application (such as Facebook or Google profile information)
      4. Financial Information. We may collect financial information related to an individual such as any bank or credit card details and other information that allows us to transact with the individual;
      5. Statistical Information. We may collect anonymised information about an individual’s online and offline preferences, habits, movements, trends, decisions, associations, memberships, finances, purchases and other information for statistical purposes; and
      6. Information an individual sends us. We may collect any personal correspondence that an individual sends us, or that is sent to us by others about the individual’s activities, including activities with our partners.
    2. We may collect other data about an individual, which we will maintain in accordance with this Privacy Policy.
    3. We may also collect non-data about an individual such as information regarding their computer, network and browser. This may include their IP address.
    1. Most information will be collected in association with an individual’s use of the Application, our products and services, an enquiry about the Application or generally dealing with us. However we may also receive data from other sources such as advertising, an individual’s own promotions, public records, mailing lists, contractors, staff, recruitment agencies and our business partners. In particular, information is likely to be collected as follows:
      1. Registrations/Subscriptions/Transactions. When an individual registers, subscribes and/or engages in transactions using the Application or other process whereby they enter data details or grant access to information in order to receive or access something;
      2. Accounts/Memberships. When an individual submits their details to open an account and/or become a member with us;
      3. Contact/Access. When an individual contacts us in any way or an individual accesses us physically we may require them to provide us with details for us to permit them such access;
      4. Meta Data/Pixel Tags. Meta data and pixel tags enable us to track users and email messages.
    2. As there are many circumstances in which we may collect information both electronically and physically, we will endeavour to ensure that an individual is always aware of when their data is being collected.
    3. We may also collect anonymous data such as traffic, IP addresses and transaction statistics, which may be used and shared on an aggregated and anonymous basis.
    1. The data that we collect from an individual may be transferred to, and stored at, a destination outside the European Economic Area (EEA). It may also be processed by staff operating outside the EEA who work for us or for one of our suppliers. Such staff maybe engaged in, among other things, the fulfilment of your order, the processing of an individual’s payment details and the provision of support services.
    2. By submitting their personal data, an individual agrees to this transfer, storing or processing.
    1. An individual consents to us using and disclosing their personal information in any manner that could reasonably be contemplated by this Privacy Policy and our Terms and Conditions.
    2. We will retain data for the period necessary to fulfil the purposes outlined in this Privacy Policy unless a longer retention period is required or permitted by law.
    3. If an individual is a Customer, we may disclose your personal information including contact details to a Venue, but only when such disclosure is in relation to Payper Services, the Venue Services, or otherwise where you have given us permission to make the disclosure to the Venue.
    4. If an individual is a Venue, we may disclose your personal information including contact details to a Customer, but only when such disclosure is in relation to Payper Services, the Venue Services, or otherwise where you have given us permission to make the disclosure to the Customer.
    5. We may disclose your personal information to other entities or individuals to facilitate the purpose for which information was collected. Such entities and individuals include:
      1. Third party service providers for the purpose of enabling them to provide a service such as (but not limited to) IT service providers, data storage, web-hosting and server providers, debt collectors;
      2. Any third party partners or entities with whom we have a commercial relationship, and are involved in the service we provide to you;
      3. Any applicable or relevant regulator or third party for the purpose of legislative or contractual compliance and/or reporting or when we believe in good faith that disclosure is reasonably necessary to protect the property or rights of us, third parties or the public at large; or
      4. Other entities if an individual has given their express consent (electronically or written permission). Those entities and individuals will be permitted to obtain only the personal information necessary to deliver the service. Payper takes reasonable steps to ensure that these organisations and individuals are bound by confidentiality and privacy obligations in relation to the protection of their personal information.
    6. We may use an individual’s personal and/or Application usage information to:
      1. Establish, maintain and administer their account;
      2. Send them service or promotional communications, including surveys and information about security updates;
      3. Create or distribute marketing material;
      4. Conduct verifications of profiles, check credentials, monitor and report as permitted in the Terms they have agreed with us or under any applicable laws;
      5. Promote and market the Application, our services and/or the Venues registered with us; or
      6. Aggregate anonymous data in a form of analytics and disclose to Venues and/or our commercial partners, with or without monetary charge.
    7. We will not disclose or sell an individual’s data to unrelated third parties under any circumstances.
    8. Information is used to enable us to operate our business, especially as it relates to an individual. This may include:
      1. Verifying an individual’s identity;
      2. Communicating with an individual about their relationship with us;
      3. Investigating any complaints about or made by an individual, or if we have reason to suspect that an individual is in breach of any of our terms and conditions or that an individual is or has been otherwise engaged in any unlawful activity; and/or
      4. As required or permitted by any law (including the Act).
    9. There are some circumstances in which we must disclose an individual’s information:
      1. Where we reasonably believe that an individual may be engaged in fraudulent, deceptive or unlawful activity that a governmental authority should be made aware of;
      2. As required by any law (including the Act); and/or
      3. In order to sell our business or part thereof (as we may transfer data to a new owner).
    10. Where relevant, an individual consents to us posting and using any photographs, content and/or personal information they might upload on our Application or have otherwise provided consent to publish on our Application, in our marketing collateral or social media channels, which we may use in order to provide our services, the marketing of our services or for the purpose of our functions and/or activities.
    11. We will not disclose an individual’s data to any entity outside of the EEA that is in a jurisdiction that does not have a similar regime to the Act or an implemented and enforceable privacy policy similar to this Privacy Policy. We will take reasonable steps to ensure that any disclosure to an entity outside of the EEA will not be made until that entity has agreed in writing with us to safeguard data as we do.
    12. We may partner with or utilise third-party service providers (such as Gmail from Google, Inc.) to communicate with an individual and to store contact details about an individual. These service providers may be located outside the United Kingdom, including the United States of America.
    1. We may link an individual’s account with a third party (such as Facebook, Google, or Twitter) to our services to enable certain functionality, which allows us to obtain information from those accounts (including their profile picture, friends or contacts and/or other details). Permission to access this data is always asked beforehand.
    2. The information we may obtain from those services often depends on an individual’s settings or their privacy policies.
    1. We may use cookies to distinguish an individual from other users of our Application. This helps us to provide them with a good experience when they browse and also allows us to improve our Application. By continuing to browse, an individual agrees to our use of cookies.
    2. A cookie is a small file of letters and numbers that we store on an individual’s browser or the hard drive of their computer if they agree. Cookies contain information that is transferred to their computer's hard drive. An individual can block cookies by activating the setting on their browser that allows them to refuse the setting of all or some cookies. However, if an individual uses their browser settings to block all cookies (including essential cookies) they may not be able to access all or parts of our Application.
    3. We use the following cookies:
      1. Strictly necessary cookies. These are cookies that are required for the operation of the Application. They include, for example, cookies that enable an individual to log in and log out of secure areas of the Application or make use of payment services. Temporary settings also allow data to be stored for each session.
      2. Analytical/performance cookies. They allow us to recognise and count the number of visitors and to see how visitors move around the Application when they are using it. This helps us to improve the way the Application works, for example, by ensuring that users are finding what they are looking for easily.
      3. Functionality cookies. These are used to recognise an individual when they return to the Application. This enables us to personalise our content for them, greet them by name and remember their preferences (for example, their choice of language or region).
      4. Targeting cookies. These cookies record an individual’s visit to the Application, the pages they have visited and the links they have followed. We will use this information to make the Application more relevant to their interests. We may also share this information with third parties for this purpose.
    4. Please note that third parties (including, for example, advertising networks and providers of external services like web traffic analysis services) may also use cookies, over which we have no control. These cookies are likely to be analytical/performance cookies or targeting cookies.
    5. If you are unclear about the types or function of the cookies we use, please contact us for more information.
    1. An individual may opt to not have us collect their data. This may prevent us from offering them some or all of our services and may terminate their access to some or all of the services they access with or through us. They will be aware of this when:
      1. Opt In. Where relevant, the individual will have the right to choose to have information collected and/or receive information from us; or
      2. Opt Out. Where relevant, the individual will have the right to choose to exclude himself or herself from some or all collection of information and/or receiving information from us.
    2. If an individual believes that they have received information from us that they did not opt in or out to receive, they should contact us on the details below.
    1. We will take all reasonable precautions to protect an individual’s data from unauthorised access. This includes appropriately securing our physical facilities and electronic networks.
    2. The security of online transactions and the security of communications sent by electronic means or by post cannot be guaranteed. Each individual that provides information to us via the internet or by post does so at their own risk. We cannot accept responsibility for misuse or loss of, or unauthorised access to, data where the security of information is not within our control.
    3. We are not responsible for the privacy or security practices of any third party (including third parties that we are permitted to disclose an individual’s data to in accordance with this policy or any applicable laws). The collection and use of an individual’s information by such third parties may be subject to separate privacy and security policies.
    4. If an individual suspects any misuse or loss of, or unauthorised access to, their data, they should let us know immediately.
    5. We are not liable for any loss, damage or claim arising out of another person’s use of the data where we were authorised to provide that person with the data.
    1. The Act gives an individual the right to request from us the data that we have about him/her. He/she may review, edit, correct or delete personal information he/she submits to us at any time. He/she just needs to log into their account to do this.
    2. If an individual cannot update his or her own information, we will correct any errors in the data we hold about an individual within 7 days of receiving email notice from them about those errors.
    3. It is an individual’s responsibility to provide us with accurate and truthful data. We cannot be liable for any information that is provided to us that is incorrect.
    4. We may charge an individual a reasonable fee (£10-£100) for our costs incurred in meeting any of their requests to disclose the data we hold about them.
    5. Access to an individual’s personal information may be denied on certain grounds including, for example: it is unlawful; it may have an unreasonable impact upon the privacy of other individuals; or their request is frivolous or vexatious. If we deny them access we will provide our reason for doing so at the time of their request.
    1. If an individual has a complaint about our handling of their data, they should address their complaint in writing to the details below.
    2. If we have a dispute regarding an individual’s data, we both must first attempt to resolve the issue directly between us.
    3. If we become aware of any unauthorised access to an individual’s data we will inform them at the earliest practical opportunity once we have established what was accessed and how it was accessed.
    1. If we decide to change this Privacy Policy, we will post the changes on our Application and/or at our website www.payper.io. It is an individual’s responsibility to refer back to this Privacy Policy to review any amendments. An individual’s continued use of this site and/or the Application after any change in this Privacy Policy will constitute their acceptance of such change.
    2. We may do things in addition to what is stated in this Privacy Policy to comply with the Act and nothing in this Privacy Policy shall deem us to have not complied with the Act.
    1. All correspondene with regards to privacy should be addressed to:

      Payper Ltd
      41 Florida Street

      Email: support@clouderapp.com

      All such enquiries or complaints will be taken seriously and will be handled as soon as reasonably practicable.