Introduction

Farillio Limited respects your privacy and is committed to protecting your personal data. This privacy policy will inform you as to how we look after your personal data when you visit our website and use our products and services (regardless of where you visit it from) and tell you about your privacy rights and how the law protects you.

Important information and who we are

Purpose of this privacy policy

This privacy policy aims to give you information on how Farillio Limited collects and processes your personal data through your use of this website, including any data you may provide through this website, when you sign up to our newsletter, purchase products or services or take part in a competition.

This website is not intended for children and we do not knowingly collect data relating to children.

It is important that you read this privacy policy together with any other privacy policy or fair processing notice/policy we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. This privacy policy supplements the other notices and is not intended to override them.

About Us

Farillio Limited is the controller and responsible for your personal data (collectively referred to as “Farillio”, “we”, “us” or “our” in this privacy policy).

We have appointed a data privacy manager who is responsible for overseeing questions in relation to this privacy policy. If you have any questions about this privacy policy, including any requests to exercise your legal rights (see section 9 below), please contact the data privacy manager using the details set out below.

Contact details

Full name of legal entity: Farillio Limited

Name: Merlie Calvert

Email address: merlie@farill.io

Postal address: Farillio Limited, 128 City Road, London EC1V 2NX

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 the privacy policy and your duty to inform us of changes

This privacy policy is subject to changes and updates. We will post any changes on this page. 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.

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.

The 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).

We may collect, use, store and transfer different kinds of personal data about you which we have grouped together follows:

• Identity Data includes name (including first, middle and surnames), title, gender, age, date of birth, nationality, personal descriptions and photographs.
• Contact Data includes addresses (including work, office and billing addresses), email addresses and telephone numbers (including mobile and landlines).
• Financial Data includes bank account and payment card details (however, we will usually ask you to pay through our third-party payment provider and will not collect this Financial Data ourselves).
• Transaction Data includes details about payments to and from you and other details of products and services you have purchased via our website.
• KYC Data (KYC means Know-Your-Client) includes dates of birth and residential addresses. (We use a third-party provider to run KYC checks where they are necessary in relation to any interactions that you may request with our partner law firms. This is the only time that we run KYC checks and collect KYC Data.)
• Technical Data includes 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, type of mobile device you use, and other technology on the devices you use to access this website.
• Profile Data includes your username (which is usually your e-mail address) and password, purchases or orders made, your interests, preferences, feedback and survey responses.
• Usage Data includes information about how you use our website, products and services. This can include information about your visit to our website, including the full Uniform Resource Locators (URL) clickstream to and through our website, resources, products and services 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 methods used to browse away from the page.
• Marketing and Communications Data includes your preferences in receiving marketing from us and your communication preferences.
• Customer Service Data includes interactions with us via our website, over the phone, on social media or otherwise.

We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data may be derived from your personal data but is not considered personal data in law as this data does not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy policy.

We do not actively 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 actively 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 our Subscription Partner’s contract and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into (for example, to provide products or services). In this case, we may have to cancel a product or service but we will notify the relevant Farillio account holder if this is the case at the time.

How is your personal data collected?

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

• Direct interactions. You may give us your Identity, Contact and Financial Data by filling in forms or by corresponding with us by post, phone, email, on our website or otherwise. This includes personal data you provide when you:
  • apply for our products or services;
  • create an account on our website;
  • subscribe to our service or publications;
  • request marketing to be sent to you;
  • enter a competition, promotion or survey; or
  • give us some feedback.
• Automated technologies or interactions. As you interact with our website, we may 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 cookie policy /pages/cookie-policy for further details.
• Third parties or publicly available sources. We may receive personal data about you from various third parties and public sources as set out below:
  • Identity and Contact data from our Subscription Partners.
  • Technical Data from analytics providers such as Google based outside the EU.
  • Contact, Financial and Transaction Data from providers of technical, payment and delivery services, such as Stripe Inc., based outside the EU.
  • Identity and Contact Data from publicly availably sources such as Companies House.
  • We may receive Transaction Data from our expert partners.
  • KYC Information from anti-money laundering search providers (which include checks with credit reference agencies, Register of Deaths, the Electoral Register and telephone databases).

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 (” Contract Reason”).

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 (” Legitimate Interests Reason”). Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give you the best service/product and the best and most secure experience We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us (using the details set out at the beginning of this privacy policy).

Where we need to comply with a legal or regulatory obligation that we are subject to (” Legal Obligations Reason”).

Generally we do not rely on consent as a legal basis for processing your personal data other than in relation to sending third party direct marketing communications to you via email or text message (” Consent Reason” ). You have the right to withdraw consent to marketing at any time by contacting us or by using the opt-out/unsubscribe link in any email which we send to you.

Purposes for which we will use your personal data

We have set out below, in a table format, a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.

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 (using the details set out at the beginning of this privacy policy) if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below:

Purpose/Activity	Lawful basis for processing including basis of legitimate interest
To register a customer as a new customer (including to contact those who have started the sign up process but not completed it).	(a) Contract Reason.(b) Legitimate Interests Reason (because of a contract we have entered or are about to enter into with a customer in order to fulfil that contract, which is in our and their legitimate interests).
To carry out our obligations to a customer under our contract with them, including to provide them with products and services which they request from us.	(a) Contract Reason.(b) Legitimate Interests Reason (because of a contract we have entered into with a customer in order to fulfil that contract, which is in our and their legitimate interests).
To process and deliver a customer’s order including:(a) Manage payments, fees and charges(b) Collect and recover money owed to us	(a) Contract Reason.(b) Legitimate Interests Reason (because of a contract we have entered into with a customer in order to fulfil that contract, which is in our and their legitimate interests and in order to recover debts due to us).
To carry out our obligations to a Subscription Partner under our contract with them, including information to assist them with verifying your access to our site this includes your email address, details relating to your usage, email address, business sector and type of business.	(a) Contract Reason.(b) Legitimate Interests Reason (because of a contract we have entered into with the Subscription partner in order to fulfil that contract, which is in our and their legitimate interests).
To manage our relationship with a customer which will include:(a) Notifying a customer about changes to our terms or privacy policy(b) Asking a customer to leave a review or take a survey	(a) Contract Reason(b) Legal Obligations Reason.(c) Legitimate Interests Reason (to keep our records updated and to study how customers use our products/services)
To allow a customer to participate in interactive features of our website.	(a) Contract Reason(b) Legitimate Interests Reason (because of a contract we have entered into with a customer in order to fulfil that contract, which is in our and their legitimate interests).
To fulfil a customer’s request to share a document or folder with a third party or family member nominated by the customer.	(a) Contract Reason. (b) Legitimate Interests Reason (in order to fulfil a request made by a user, which is in our and their legitimate interests).
Where a customer requests this, to put them in touch with our expert partners.	(a) Contract Reason(b) Legitimate Interests Reason (because of a contract we have entered into with a customer in order to fulfil that contract, which is in our and their legitimate interests).
To carry out anti-money laundering checks on behalf of our expert partners, prior to a customer receiving advice from them.	(a) Contract Reason(b) Legitimate Interests Reason (because of a contract we have entered into with a customer in order to fulfil that contract, which is in our and their legitimate interests)
To provide customer service and support.	(a) Contract Reason(b) Legitimate Interests Reason (because of a contract we have entered into with a customer in order to fulfil that contract, which is in our and their legitimate interests and to ensure that we give the best customer service to our customers)
To enable a customer to take part in a prize draw, competition or complete a survey	(a) Contract Reason.(b) Legitimate Interests Reason (to study how customers use our products/services, to develop them and grow our business).
To administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)	(a) Legitimate Interests Reason (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise)(b) Legal Obligations Reason.
To monitor the use of our website.	Legitimate Interests Reason (to ensure that our website is being used in accordance with our acceptable use policy)
To deliver relevant website content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you	Legitimate Interests Reason (to study how customers use our products/services, to develop them, to grow our business and to inform our marketing strategy)
To use data analytics to improve our website, products/services, marketing, customer relationships and experiences	Legitimate Interests Reason (to define types of customers for our products and services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy)
To make suggestions and recommendations to our customers about goods or services that may be of interest to them	(a) Legitimate Interests Reason (to develop our products/services and grow our business)(b) Consent Reason.

Marketing

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

Promotional offers from us

We may use your Identity, Contact, Technical, Usage and Profile Data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which products, services and offers may be relevant for you (we call this marketing).

You will receive marketing communications from us if you have signed up to our mailing list and consented to receive marketing, or if you have requested information from us or purchased products or services from us, or if you provided us with your details when you entered a competition or registered for a promotion and, in each case, you have not opted out of receiving that marketing.

Third-party marketing

We will get your express opt-in consent before we share your personal data with any third party for marketing purposes.

Opting out/Unsubscribing

You can ask us or third parties to stop sending you marketing messages at any time by following the opt-out/unsubscribe links on any marketing message sent to you or by contacting us (using the details at the beginning of this privacy policy) at any time.

Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of a product/service purchase, product/service experience or other transactions.

Cookies

You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of this website may become inaccessible or not function properly. For more information about the cookies we use, please see our Cookies Policy /pages/cookie-policy.

Change of purpose

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 by contact us (using the details at the beginning of this privacy policy)

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.

Disclosures of your personal data

We may have to share your personal data with the parties set out below for the purposes set out in the table in section 4 above.

• External Third Parties such as:
  • Our expert partners acting as controllers based in the United Kingdom who provide advice to our customers;
  • Service providers acting as processors based worldwide who provide IT and system administration services and software which enables us to have features such as live chat.
  • Cloud service providers acting as processers based within the EU who provide cloud services.
  • Professional advisers acting as processors or joint controllers including lawyers, bankers, auditors and insurers based in the United Kingdom who provide consultancy, banking, legal, insurance and accounting services.
  • HM Revenue & Customs, regulators and other authorities acting as processors or joint controllers based in the United Kingdom who require reporting of processing activities in certain circumstances.
  • Anti-money laundering search providers acting as processors based in the United Kingdom who provide anti-money laundering search services (and who themselves may disclose data to credit reference agencies).
  • Email marketing platforms (such as Mailchimp) acting as processors based in the USA who provide email marketing solutions and services.
  • Fraud prevention agencies, law enforcement and credit reference agencies acting as controllers based in the United Kingdom for the prevention and detection of fraud.
• Third parties to whom we may choose to sell, transfer, or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy policy.

We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.

International transfers

Some of our external third parties are based outside the European Economic Area ( 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 at least one of the following safeguards is implemented:

• We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data by the European Commission; or
• Where we use certain service providers, we may use specific contracts approved by the European Commission which give personal data the same protection it has in Europe.

Please contact us (using the details at the beginning of this privacy policy) if you want further information on the specific mechanism used by us when transferring your personal data out of the EEA.

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.

Data retention

For how long will you use my personal data?

We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.

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 requirements.

By law we have to keep basic information about our customers (including Contact, Identity, Financial, Transaction, KYC, Profile and Customer Service Data) for seven years after they cease being customers for tax purposes.

We keep Technical and Usage Data for 12 months from the date of collection.

We keep Marketing and Communications for 12 months after you opt out/unsubscribe for marketing communications.

In some circumstances you can ask us to delete your data: please see section 9 below for further information.

In some circumstances we may 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.

Your legal rights

Under certain circumstances, you have rights under data protection laws in relation to your personal data. These rights enable you to:

• 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 and to check that we are lawfully processing it.
• Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data 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 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. 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 data 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 data 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 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.
• Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. 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 (using the details at the beginning of this privacy policy). Please note that exercise some of these rights by you may affect our ability to provide you with access (or continued access) to our website, products and services.

No fee usually required

You will not have to pay a fee to access your personal data (or to exercise any of the other rights). 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.

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 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.