Version 1.0 | Last updated: 20 October 2022
Previse Limited (“Previse”, “we” and “us”, and “our”) is committed to protecting your privacy and wants you to be familiar with how we collect, use and disclose your information. This privacy statement (the “Privacy Statement”) covers how we use personal data as a controller as described in further detail below and also describes your legal rights with respect to your personal data.
Information about us and our role
Previse Limited is a company registered in England and Wales with number 09117429 with its registered address at 2 Underwood Row, London, N1 7LQ. We are the controller responsible for the processing of personal data described in this Privacy Statement under the Data Protection Legislation and other applicable law.
If you wish to contact us about this Privacy Statement or Previse’s Applications and Services or for any enquiries about how we use personal data, please contact us at email@example.com.
The personal data we process as a controller
Purposes for processing
We will use and process personal data lawfully, fairly and in a transparent manner.
We will collect and use personal data solely for the specified and legitimate purposes stated in this Privacy Statement:
To send you marketing communications including:
information from us about goods and services which may be of interest to your company or the company you work for;
updates about new or improved functionality of Previse’s Applications and Services and services offered under it; and
events, promotions or competitions being offered by us.
We may provide these communications in various ways, including via email, postal mail, social media platforms, and text or direct messages.
If you are a corporate subscriber, we will do this because it is in our legitimate interests to process personal data in this way provided that such interests are not overridden by your interests, fundamental rights, or freedoms. In particular, we may process your personal data in reliance on a legitimate interest in the effective and lawful operation of our businesses, maintenance of our client relationships, continued relevancy of client and prospective client communications. You are entitled to object to us contacting you or to amend your communication preferences by contacting us at firstname.lastname@example.org.
If you are an individual subscriber, we will process personal data in this way where you have consented to receive these marketing communications from us. You are entitled at any time to withdraw your consent to receiving these marketing communications from us at any time.
If you subsequently decide that you do not want to receive marketing communications from us, please click the “unsubscribe” link provided in our marketing messages. Objecting to receiving marketing communications will not affect our use of the personal data prior to you objecting but it will mean that we will not be able to contact you about the offers we may run and other services we may be able to offer to you in the future. Objecting to receiving marketing communications will not affect our ability to send non-marketing messages to you as well (such as transactional messages relating to your account or your use of Previse’s Applications or Services).
To contact you, if we receive a request to contact you or to send you any requested information. We will use the personal data in this way because it is in our legitimate interests to use personal data to communicate with you, to respond to your request and develop the relationship between us.
It may also be necessary for us to:
use personal data to perform an agreement with you, where we would be unable to provide those services without that information (for example, if a particular service or information is to be provided to you, we would be unable to provide that service or information unless we were able to use personal data for that reason); or
use personal data to comply with a legal obligation relating to how we manage our business or our relationship with you.
We will let you know where you must provide us with personal data in order to perform an agreement or to comply with a legal obligation. You can choose not to enter any such personal data into Previse’s Applications and Services. However, if you choose not provide us with personal data in circumstances where we require it, we will be unable respond to enquiries, engage in further communications with you and/or make Previse’s Applications and Services available to you in circumstances where the personal data is required to do that.
We collect or otherwise obtain information relating to you in a variety of ways. Such information may include personal data, i.e., information that alone or in combination with other information identifies or can be reasonably linked to you as an individual.
The information we may gather about you includes:
Information you provide. You may submit this personal data by filling in forms on our websites or by corresponding with us by post, phone, email or otherwise when you submit a request for our products or services, make a business or press enquiry, subscribe to our publications, request marketing material to be sent to you, give us feedback, make a general employment enquiry or apply for a specific job or otherwise contact us. This information could include:
identity data (such as your first name, last name, date of birth, gender, title and the company you work for);
contact data (such as your postal address, email address or telephone number);
profile data (such as your product interests, the subject of your enquiry and any personal information contained in the message section of your enquiry, feedback and survey responses);
marketing and communications data (such as your preferences in receiving marketing from us or your communication preferences); or
application data (such as contact data of any referees, personal information included on your CV/resume such as employment history, education history, citizenship status and immigration status, directorships and other business dealings).
Information collected when you engage with Previse electronically/online. Previse may also collect information about you via:
Email or newsletter subscriptions: Previse’s marketing emails to our business contacts may use pixel tags, web beacons, and/or HTML-formatted email messages that track and report back to Previse the actions recipients take in response to our emails (e.g., whether a message has been opened or read, and which links have been followed).
Website or social media activity: Previse may, through various tools and technologies, collect information about you when you follow, post comments on, or otherwise interact with us on https://previ.se, https://instantpay.co and any other website that is published by us, Previse’s social media channels, or Previse’s advertising or marketing posts on other websites or platforms.
Please note that websites and social media sites hosted by a third party other than Previse may also collect information about you. You should review those third parties’ privacy statements to understand how and when they will collect and use your data.
Information Collected From Other Sources. In addition to the data collection described above, we may also obtain personal data from third parties (e.g., data brokers), and from publicly available sources. We may combine the information that we collect (as described above) with information from these additional sources. We will use the information only for the purposes described in this Privacy Statement.
Information We Do Not Seek. We generally do not seek information that may be considered “special” or “sensitive” personal data (e.g., government-issued identification numbers or information related to your racial or ethnic origin, political opinions, religious or other beliefs, health, criminal background, or trade union membership) for marketing purposes, and we ask that you do not provide such information.
Sharing of personal data with third parties
We will share personal data with the following third parties:
our or any of our Affiliates’ accountants, insurers, auditors and managers;
our or any of our Affiliates’ legal advisers and representatives for the purposes of establishing, exercising and defending our legal rights and obligations and otherwise taking legal advice;
our or any of our Affiliates’ service providers (including, without limitation, email delivery services) and sub-contractors;
potential purchasers of and/or successors in title to member(s) of the Previse Group and their Affiliates and representatives in connection with a sale, acquisition, reorganisation or other disposition of all or part of Previse Group’s business or assets, or the insolvency, bankruptcy or receivership of a member of the Previse Group;
third party service providers for the purpose of fraud protection and credit risk reduction such as industry associations (such as CIFAS) and their members and any agents, delegates, nominees, attorneys, trustees or custodians acting on our or any of our Affiliate’s behalf;
to those third parties where we are required to do so by law or court order or in response to reasonable enquiries from or as a result of cooperating with any governmental, banking, taxation, supervisory, industry association (such as CIFAS) or other similar body or by the rules of any stock exchange; or
to law enforcement and fraud prevention agency.
Previse does not sell your personal data to non-affiliated third parties (including for their own direct marketing purposes) without your consent. In addition, Previse has not sold your personal data to non-affiliated third parties in the last 12 months. If you are entitled to any disclosure rights in your jurisdiction regarding our sale of your personal data to non-affiliated third parties or our disclosure of your personal data to third parties for their own direct marketing purposes, this disclosure satisfies those requirements. If you still wish to learn more about our compliance with this requirement, please contact us using the information provided in the “Contact Information” section below.
Records of personal data
We will keep a record of the personal data for the purposes described in this Privacy Statement. We will keep a copy of personal data held for the specific purpose for which it was provided, until this has come to an end and we no longer need to comply with a legal obligation that requires us to retain personal data. We will delete our copy of personal data 24 months after the termination of the business relationship or after a longer period after the end of the purposes explained in the preceding sentence, although we may retain a record of the existence of the relationship, to the extent that and for so long as we are required to do so by law. For example, if you have contacted us to ask for the processing of your personal data to be erased, we will retain a record of your request in order to ensure that we comply with your wishes.
International personal data transfers
We store and process personal data:
in the UK and the European Economic Area (“EEA”) if you are located in the UK or in the EEA; and
in the UK, the EEA and/or the United States of America (“US”) if you are located in the US.
Depending on your applicable jurisdiction, including if your personal data is subject to the GDPR, you may have certain rights with respect to your personal data. Such rights may include the right to:
request access to that personal data;
receive a copy of that personal data which Previse holds about you in a structured commonly used format so that you can share it with others;
where that personal data is inaccurate or incomplete, ask for personal data to be rectified or completed;
request the transfer of that personal data to another party;
ask for that personal data be erased;
object to us processing that personal data by asking for the processing of that personal data to be restricted or stopped. For example, if Previse uses personal data for marketing purposes;
withdraw the consent that you have given us to process your personal data (where we process your personal data on the basis of your consent); and
make a complaint to the applicable data protection supervisory authority about the manner in which Previse processes personal data, such as the UK Information Commissioner’s Office.
Please contact email@example.com for additional information, or if these rights apply to you based on your jurisdiction, to exercise these rights. When you contact us to exercise the above rights, we may ask for further information from you, to confirm your identity and, if applicable, the jurisdiction to which you are subject. You may also be able to access and update the information you have provided to us via your weblink.
If you have any questions, comments or concerns about this Privacy Statement, you may contact us at firstname.lastname@example.org.
We have implemented appropriate technical and organizational measures on our servers, which are designed to protect personal data from accidental or unlawful destruction, loss, alteration, unauthorized disclosure of, or access to, personal data transmitted, stored or otherwise processed.
You should keep in mind that internet transmissions (including emails) are never completely secure or error-free. As such, you should take steps to protect yourself, especially online and take special care in deciding what information you send to us via e-mail or other transmissions.
Whilst we may take any information provided by you into account, only we will determine the content of any related public statements and any required notices to the affected data subjects and/or the relevant supervisory authorities in connection with a personal data breach in relation to the personal data.
Links to other websites
Definitions and interpretation
In this Privacy Statement:
“Data Protection Legislation” means data protection and/or privacy laws, including, where applicable, European Data Protection Laws;
“European Data Protection Laws” means the GDPR and the Privacy and Electronic Communications Directive 2002/58/EC, as implemented into and supplemented by domestic legislation of each EU Member State and in the UK (such as by the Data Protection Act 2018 and the Privacy and Electronic Communications (EC Directive) Regulations 2003 in the UK) and as amended, replaced or superseded from time to time;
“GDPR” means the EU General Data Protection Regulation 2016/679;
“Previse Group” means us and each of our affiliates;
“Previse’s Applications and Services” means the portals and tools associated with opening, running and managing your InstantPay, InstantAdvance or other account as well as other third party tools provided by Previse at https://instantpay.co, https://instantview.co, https://instantadvance.co, https://previ.se, https://previse.co, https://previsedigital.com and any sub-domains or other domain through which Previse provides such service or other applications, services and tools (including application forms for our products);
“Privacy Statement” has the meaning described in Clause 1.1 above;
The terms, “Commission”, “controller”, “data subject”, “Member State”, “personal data”, “personal data breach”, “processor”, “processing” and “supervisory authority” will have the same meaning as in the GDPR (even if the GDPR does not apply to the applicable data) as implemented and/or supplemented by domestic data protection laws (such as by the Data Protection Act 2018 in the UK), and their cognate terms will be construed accordingly.
Unless a contrary indication appears, any reference to:
the “Privacy Statement” or other agreement is a reference to the Privacy Statement or that agreement as amended, novated, restated, supplemented, extended or replaced;
the singular will include the plural and vice versa;
a “Clause” is a reference to a Clause to these terms and conditions;
the word “including” (and its derivations) must be construed as being for illustration or emphasis only and not as limiting the generality of any preceding words;
the word “other” must not be construed as being limited by the context in which it appears or the words that precede it where a wider construction is possible;
any “person” includes any assignee, transferee, successor-in-title, delegate or appointee of that person (but, in the case of you or us, only permitted assignees or transferees). It also includes any individual, company or other body corporate, any state or state agency or any unincorporated body, association, trust, joint venture, consortium or partnership whether or not having separate legal personality);
a “regulation” includes any regulation, rule, official directive, request or guideline (whether or not having the force of law) of any governmental, intergovernmental or supranational body, agency, department or of any regulatory, self-regulatory or other authority or organisation;
a provision of law is a reference to that provision as amended or re-enacted;
a time of day is a reference to local time in London, United Kingdom; and
clause headings are for ease of reference only.