Privacy Policy

1. Privacy Policy Introduction

Your privacy and trust are important to us and this Privacy Policy (“Policy”) provides important information about how Keen Thinking Limited, CRN: 04012805 and its associated Group Companies (“we” or “us”) handle personal information. This Policy applies to personal information which we process in the course of doing business including information processed through https://www.simplicityinbusiness.co.uk/ the Gems platform and the services and finance we provide (collectively, our “Services”).

Keen Thinking Limited works closely with the following companies, which have common shareholders with Keen Thinking Limited:

1. Simplicity Contracting Limited (CRN: 12404271) which Keen Thinking engages to carry out payroll services for recruitment agencies;
2. Simplicity CIS Limited (CRN: 12404365) which Keen Thinking engages to carry out services to pay contractors in the construction industry;
3. Simplicity PEO Limited (CRN: 12404543) which Keen Thinking engages where recruitment agents require staff to be jointly employed;
4. Simplicity Accounting Services Limited (CRN: 12404354) which Keen Thinking engage to assist with the administration of payment to limited company contractors; and
5. Recruitment Staffing Solutions LLP (RN: OC352156), of which Keen Thinking is a member and through which some customers of the Group engage agency workers.
6. Infinity Skills LLP (RN: OC416534), of which Keen Thinking is a member and through which some customers of the Group engage agency workers.

For the purpose of this Policy, each of the entities are together referred to as the Group and individually as a Group Company.

Please read this Policy carefully and contact us if you have any questions about our privacy practices or your personal information choices.

It is important that you check back often for updates to this Policy. If we make changes that we consider to be important, we will let you know by placing a notice on our website and/or contacting you using other methods such as email.

This Policy was last updated on 03/11/2020.

2. Purpose of the processing, legal basis, duration and retention periods

We may process personal information about you in different ways depending on our relationship with you.

• You are a current or historical customer or a current or historical employee of a current or historical customer of our Services

We will collect and store personal information including names, contact details and email addresses of our customers and those employees of our customers who are involved in engaging us so that we can provide our Services and finance in accordance with our contract with you. We may also be required to keep certain information such as your proof of identity for legal and regulatory reasons. We will also retain that information and any information relating to the contract(s) between us for a period of up to seven years following completion or termination of the contract(s) between us so that we can review our performance if any complaints or issues arise after completion of the contract(s).

We may also collect and store personal information about employees, agency workers (both permanent and temporary) and candidates of the customer for whom we are providing Services. This information may include names, contact details, email addresses, CVs, salaries and/or other details relating to your employment. We are processing this information on behalf of the recruitment agency which is our customer in order to provide them with the Services. You should, therefore, contact the recruitment agent for further information about how we process your information on their behalf.

We may also collect and store personal information about customers of our customers together with employees and candidates of our customer’s customers. This information may include names, contact details, email addresses, CVs, salaries and/or other details relating to your employment. We are processing this information on behalf of the recruitment agent, who has engaged our Services. You should, therefore, contact the recruitment agency which has been engaged by your employer (or prospective employer) for further information about how we process your information on their behalf.

Unless you request us not to do so, we may also contact you and those employees of the customer who are involved in engaging us on an individual basis, with pro-active advice on finance and recruitment, or more general service-related announcements. This contact may be made by e-mail or by telephone. We will only do this if we believe that you would reasonably expect us to contact you in this way. We will not send you general marketing information in your personal capacity as part of a group e-mailing campaign unless you have consented to be contacted in this way. If you have consented to be contacted in this way, the opt-in period will be three years from the date that you opt-in and, if we have not heard from you in respect of opting out before the end of this period, we will contact you towards the end of this period to see if you want to opt in to continue to receive marketing material.

• You are a current or historical customer or a current or historical employee of a current or historical customer using our GEMS Software (“Global Employment Management System”) services

Customers who use GEMS should understand that GEMS enables our customers and our customers’ employees to control what information is entered into the platform and we will process that information in accordance with the agreement between us and our customers.  Where we are providing a hosted solution and/or providing support services, we are storing information and may sometimes have incidental access to data that is located in the cloud or on our customer’s system. This data may contain information about our customers, an employee of our customers, customers of our customers, an employee of our customers’ customers, partners or suppliers. We are processing this information on behalf of our customers in order to provide them with the Services and we will do so in accordance with our customer’s instructions. Our customer is the controller of your information and we are acting only as the processor. If we are storing information in this way it is because it is in our legitimate interest to do so in order to perform the Services with our customer.

We will collect and store personal information including names, contact details billing details and email addresses of our customers and those employees of the customer who are involved in the purchase of GEMS from us for use on a server. As part of our order process for GEMS, we collect and retain email correspondence, notes recording telephone conversations, generate quotes by email and retain records of order data, quotes, invoices and documents relating to requests for Services. This is so that we can provide our Services in accordance with our contract with you. We will retain that information and any information relating to the contract between us for a period of up to [seven] years following completion or termination of the contract(s) between us so that we can review our performance if any complaints or issues arise after completion or termination of the contract.

We collect information related to the transactions in respect of GEMS and accept payment via bank transfer and debit and credit card checkout cleared either via Direct Debit, over the telephone or through PayPal.

Unless you request us not to do so, we may also contact those employees of our customers who are involved in engaging us on an individual basis, with pro-active advice on recruitment, or more general service-related announcements. This contact may be made by postal mail, e-mail, social media or by telephone. We will only do this if we believe that it is in our legitimate interests to keep you informed of our products and services and if we believe that you would reasonably expect us to contact you in this way. We will not send you general marketing information as part of a group e-mailing campaign unless you have consented to be contacted in this way. If you have consented to be contacted in this way, the opt-in period will be three years from the date that you opt-in and, if we have not heard from you in respect of opting out before the end of this period, we will contact you towards the end of this period to see if you want to opt in to continue to receive marketing material.

• You are a current or historical customer or a current or historical employee of a current or historical customer using our support services

We will collect and store personal information including names, email addresses, website URL’s, usernames and contact details of end-users who contact us for support. If an end-user engages with us via telephone, our support wiki, online videos or online live chat or sends to us comments, log files, screenshots, exports of customer email or personal information about their clients, suppliers, employees or other contacts as part of their request for support, then we will store that information as part of our records in relation to the support services which we provide. We may also process and store personal information, such as names, e-mail addresses, when running test cases for end-users. We are processing this personal data because it is in our legitimate interests to do so in order to perform the Services to our customers.

We will retain information relating to the support services which we provide for a period of three years so that we can review our performance, improve the Services and respond to any complaints or issues that arise. We remove information and data sent to us as part of our support services within 12 months of a case being resolved and delete the support ticket history every two years.

• You are a supplier or an employee of a supplier to us

We will collect and store personal information including contact details of our suppliers and those employees of the supplier who are involved in the delivery of the contract so that we can receive your goods or services in accordance with our contract with you. We will also retain that information and any information relating to the contract(s) between us for a period of [seven] years following completion or termination of the contract(s) between us so that we can review your performance if any complaints or issues arise after completion or termination of the contract(s).

We may also contact you about new business opportunities for us to work together with you and to keep you informed of our activities. We are processing your personal information in this way because it is in our legitimate interests to expand our business and explore new business opportunities with you. We will only do this if we believe that you would reasonably expect us to contact you in this way and that such processing does not have an impact on you in a way that would make this processing unfair.

We will not send you general marketing information in your personal capacity as part of a group e-mailing campaign unless you have consented to be contacted in this way. If you have consented to be contacted in this way, the opt-in period will be three years from the date that you opt-in and, if we have not heard from you in respect of opting out before the end of this period, we will contact you towards the end of this period to see if you want to opt in to continue to receive marketing material.

• You are a third party with whom we are in contact during the delivery of services to our customers or the possible delivery of services to prospective customers

We will collect and store personal information including contact details of third parties with whom we are in contact during the delivery of Services to our customers or discussions relating to Services to prospective customers. We may receive that information from you, a customer, a supplier, an introducer or otherwise as a result of an interaction between you and our supplier or customers. We process that information because it is in our legitimate interests to do so in order for us to be able to perform our contracts for our customers or pitch for work from prospective customers. We believe that you would reasonably expect us to process your personal information in this way and that such processing does not an impact on you in a way that would make this processing unfair.

Where your personal information is kept as part of a file relating to the performance of a contract with one of our customers, we will also retain that information and any information relating to that contract for a period of up to seven years following completion or termination of that contract(s). This is so that we can review the file if any complaints or issues arise after completion or termination of the contract. Where your information is stored in our contacts database, email archive or other records but is not kept in a customer or supplier file, we carry out a review of our records every three years when we consider whether or not we still have a legitimate interest to keep your contact information. Where we consider that we no longer have a legitimate interest to keep your contact information we will delete it.

We may also contact you about new business opportunities for us to work together with you and to keep you informed of our activities. We are processing your personal information in this way because it is our legitimate interests to expand our business and explore new business opportunities with you. We will only do this if we believe that you would reasonably expect us to contact you in this way and that such processing does not have an impact on you in a way that would make this processing unfair.

We will not send you general marketing information in your personal capacity as part of a group e-mailing campaign unless you have consented to be contacted in this way. If you have consented to be contacted in this way, the opt-in period will be three years from the date that you opt-in and, if we have not heard from you in respect of opting out before the end of this period, we will contact you towards the end of this period to see if you want to opt in to continue to receive marketing material.

• You are: (a) a prospective customer or an employee of a prospective customer; or (b) a prospective supplier or an employee of a prospective supplier

We will collect, store and use personal information including names, email addresses and contact details of people who we might do business with as a supplier or a customer for the purpose of expanding our business and exploring new business opportunities. We may collect this information from you, when you contact us (including through this website) or from a mutual contact. We also purchase data of entities and/or businesses that are known or believed to be forming a limited company for the purpose of incorporating a recruitment agency business. We enhance that data with information we can desk research from published sources, such as:

• Personal contact details
• The sector and nature of the contract you will be recruiting for i.e. permanent or temporary
• Stage that you are in setting up your business

We will only collect contact information from your website or another third party website if we have identified you specifically as someone who may be interested in receiving a Service from us or delivering goods or services to us. For example, we may send you information that we think will be useful in setting up and growing your recruitment business. We may contact you about new business opportunities for us to work together with you and to keep you informed of our activities.

We are processing your personal information in this way because it is in our legitimate interests to expand our business and explore new business opportunities with you. We believe that you would reasonably expect us to process your personal information in this way and that such processing does not have an impact on you in a way that would make this processing unfair.

Where your information is stored in our contacts database but is not kept in a customer or supplier file, we carry out a review of our contacts database every six months when we consider whether or not we still have a legitimate interest to keep your contact information. Where we consider that we no longer have a legitimate interest to keep your contact information we will delete it.

We will not send you general marketing information in your personal capacity as part of a group e-mailing campaign unless you have consented to be contacted in this way. If you have consented to be contacted in this way, the opt-in period will be three years from the date that you opt-in and, if we have not heard from you in respect of opting out before the end of this period, we will contact you towards the end of this period to see if you want to opt in to continue to receive marketing material.

• You are an employee, former employee or a relative of either

Employees should refer to the Employee Privacy Notice for further information about our privacy policy in respect of employees.

Where an employee has provided us with personal information about a spouse, civil partner or other family members/friend (perhaps in relation to private medical insurance or other benefits or as an emergency contact), it is the employee’s responsibility to inform that person that the employee has provided us with their details and that we will be processing it as an emergency contact or in connection with the relevant benefit and/or policy in accordance with this privacy policy.

• You are a prospective employee or a referee of a prospective employee

If we have received your details in response to a recruitment initiative, we will store the personal information that either you, your recruitment agent or another third party has provided us with. We process that information because it is in our legitimate interests to do so in order for us to be able to make an informed decision about whether to interview you and, ultimately, recruit you. We believe that you would reasonably expect us to process your personal information in this way and that such processing does not impact you in a way that would make this processing unfair. Where your personal information is kept as part of a file relating to prospective employees of the Group, we will retain that information and any information relating to that matter. This is so that we can review the file if any complaints or issues arise after the recruitment process. The length of time that we keep prospective employee files is usually six months after the conclusion of the relevant recruitment process.

Unless you request us not to do so, we may also contact those individuals who are referred to in any information you provide us with, for example, referees, this contact may be made by telephone, e-mail or post. We will only do this if we have your express permission to contact them in this way.

Where you have provided us with personal information about a referee or a previous employer, it is your responsibility to inform that person that you have provided us with their details and that we will be processing it in connection with your employment application. You should also give them our contact details (below) should they wish to discuss this with us.

• We have received your information from a third party

If we have received your personal information from a third party, for example, your employer or recruitment agency, that third party will normally be the controller in relation to that personal information and we will be processing it on their behalf. You should, therefore, contact that third party to review their privacy policy.

• Your relationship with us is not covered by any of the above

We may hold your contact details and personal information as a result of an interaction between you and one of our employees or prospective employees. This interaction could be as a result of business development and/or business networking. We are processing your personal information in this way because it is in our legitimate interests to retain a record of our employees’ engagement with third parties. We believe that you would reasonably expect us to process your personal information in this way and that such processing does not impact on you in a way that would make this processing unfair. We carry out a review of our contacts database every two years when we consider whether or not we still have a legitimate interest to keep your contact information. Where we consider that we no longer have a legitimate interest to keep your contact information we will delete it safely.

3.        Where you provide us with personal information about another person

If you give us personal information about another person, you must ensure that:

(a)        you are legally entitled to give us that information;

(b)       the disclosure is in accordance with any applicable data protection or privacy laws; and

(c)        such other person has also read this privacy policy.

4. Personal information we hold and where we collect it

The information we collect about you depends on the products and services you use and how you purchase those products and services. It includes (but isn’t limited to):

• Your name, address, e-mail address and other contact details
• Information we receive about your visit to our Website including the full Uniform Resource Locators (URLs) clickstream to, through and from our website (including date and time), products, services or businesses 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), methods used to browse away from the page
• Internet Protocol (IP) address used to connect your computer to the Internet, your login information, browser type and version, time zone setting, browser plug-in types and versions, operating system and platform
• Financial details, including bank and credit card details to process payments only
• Your communications with us, including data you have provided to us by filling in forms on our website, or by corresponding with us by phone, email or otherwise. It includes information you provide when you register to use our site, subscribe to our service, use our service, enter a competition, promotion or survey (where available), and when you report a problem with our site as well as notes, recordings of phone/video calls and physical letters you send to us.
• CVs, salaries and/or other details relating to the employment of candidates, employees and agency workers of recruitment agencies for whom we provide finance and Services

We will collect the information from you directly:

• where you purchase our products and services directly from us through our website, our sales partners or otherwise;
• where we contract with you for the supply of your goods and/or services;
• where we liaise with and/or engage you for recruitment purposes; and
• where you contact us to make an enquiry.

We also purchase data of entities and/or businesses that are known or believed to be forming a limited company for the purpose of incorporating a recruitment agency business.

We may also process sensitive information, for example, relating to your health, religious belief or sexual preference. Such sensitive information will only be processed where that information is relevant to the goods or services we are providing or receiving from you.

Some of our services involve data and document storage as an integral part of the product or solution offering. We may also receive personal information as an incidental part of providing our support services. Documents and data received by us or stored by us on behalf of customers may contain personal or business information, for example in relation to job application forms, business and personal tax forms, payroll and financial data and any other documentation in respect of our customers, their employees, their customers and suppliers or other third parties.

Any information stored by us on behalf of our customers is controlled and managed by our customers. Our access to this information is limited to the Group personnel who require access in order to provide our Services or for any other critical business reason.

We may be required to use and retain personal information for other legal and compliance reasons, such as the prevention, detection, or investigation of a crime; loss prevention; or fraud.

When someone visits our website, we use a third-party service, Google Analytics, to collect standard internet log information and details of visitor behaviour patterns. We do this to find out things such as the number of visitors to the various parts of the site. This information is only processed by us in a way which does not identify anyone. We do not make any attempt to find out the identities of those visiting our website. If we do want to collect personally identifiable information through our website, we will be upfront about this. We will make it clear when we collect personal information and will explain what we intend to do with it. ]The Group and our third-party providers set and use cookies and similar technologies to store and manage user preferences, deliver targeted advertising, enable content, and gather analytic and usage data. For further information, please see clause 5 below together our Cookie Policy.

5. Cookies

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 and other similar technologies.

We use cookies to monitor site visitors and to distinguish you from other users of our website so we can better understand how our visitors use the website. This helps us to provide you with a good experience when you browse our sites, and also allows us to improve our website. The software will save a cookie to your computer’s hard drive to track and monitor your engagement and usage of the website. A cookie is a small piece of data that a website asks your browser to store on your computer or mobile device. The cookie allows the website to “remember” your actions or preferences over time.

Most Internet browsers support cookies; however, users can set their browsers to decline certain types of cookies or specific cookies. Users are advised that if they wish to deny the use and saving of cookies from this website on to their computer’s hard drive, they should take all necessary steps within their web browser’s security settings to block all cookies from our website.

Please see our Cookie Policy for further details.

6. When we share personal information

The Group shares or discloses personal information when necessary to provide Services or conduct our business operations as described below. When we share personal information, we do so in accordance with data privacy and security requirements. We do not sell any personal information to third parties. We may occasionally share non-personal, anonymised, and statistical data with third parties. Below are the parties with whom we may share personal information and why.

Within the Group: Our business is supported by a variety of people who are part of the Keen Thinking’s teams and functions, including those who are part of other companies that comprise Group as set out in Section 1. Personal information will be made available to other members of the Group if necessary for the provision of Services, account administration, sales and marketing, customer and technical support, and business and product development, for instance. All of our employees within the Group and any contractors are required to follow our data privacy and security policies when handling personal information.

Our business partners: We work with and/or partner with third parties to deliver Services, provide sales and other administrative services or to host events, conferences and/or seminars. As part of these arrangements, you may be a customer of the Group and our business partners. As such, we and our business partners may collect information about you. The Group will handle personal information in accordance with this Policy, and we encourage you to review the privacy policies of our business partners to learn more about how they collect, use, and share personal information.

Third-party providers: You may choose to integrate our Services with other third party websites or use GEMS to enable access to the website content of, correspond with, and purchase products and services from, third parties via their websites or integrate them with your third party email provider or cloud storage provider to add new functionality or change the behaviour of the Services. Doing so may give those third parties access to your account with us and any information about you like your name and email address, and any content you choose to use in connection with those third parties’ websites. Third-party provider’s policies and procedures are not controlled by us, and this privacy policy does not cover how third-party providers use your information. We do not endorse or approve any third-party website nor the content of any of the third-party website made available via the Services. We encourage you to review the privacy policy of third parties before connecting to or using their applications or services to learn more about their privacy and information handling practices.

Our third-party service providers: We partner with and are supported by service providers around the world. Personal information will be made available to these parties only when necessary to fulfil the services they provide to us, including (without limitation) software, system, and platform support, payment providers, direct marketing services, cloud hosting services, advertising, data analytics and order fulfilment and delivery. Our third-party service providers are not permitted to share or use the personal information we make available to them for any other purpose than to provide services to us.

Other third parties: We will share personal information when we believe it is required or in our legitimate interests to do so, such as:

• to comply with legal obligations and respond to requests from government agencies, including law enforcement and other public authorities;
• in the event of a merger, sale, restructure, acquisition, joint venture, assignment, transfer, or other disposition of all or any portion of our business, assets, or stock (including in connection with any bankruptcy or similar proceedings);
• where it is a condition of entering into the contract with us, we may share your details with credit reference agencies for the purpose of assessing your credit score;
• to protect our rights, users, systems, and Services.

7. Where we store and process personal information

We take steps to ensure that the information we collect is processed according to this Policy and the requirements of applicable law wherever the data is located.

We store information in hard copy files, which are stored in our offices and/or in archived storage space in the UK. We also store information in electronic files using a cloud hosting service, through the provider AWS (Amazon Web Services), located in Ireland. We also store information on servers within the European Union hosted by AWS (Amazon Web Services) located in the Ireland and Mitcheldean. We collaborate with third parties such as cloud hosting services, suppliers, and technology support to serve the needs of our business, workforce, and clients. We take appropriate steps to ensure that personal information is processed, secured, and transferred according to applicable law. In some cases, we may need to disclose or transfer your personal information within the Group or to third parties in areas outside of your home country.

8. International transfers to third parties

GEMS, AWS (Amazon Web Services), Google and other third parties described in this privacy policy, which provide services to us under contract, are based in other countries that may not have equivalent privacy and data protection laws to the county in which you reside. When we share information of customers outside of the United Kingdom and the EEA, we ensure that the third parties make use of the EU–US Privacy Shield Frameworks, European Commission approved standard contractual data protection clauses, binding corporate rules for transfers to data processors, or other appropriate legal mechanisms to safeguard the transfer.

9. How we secure personal information

Keen Thinking Limited is committed to ensuring that your information is secure. To prevent unauthorised access or disclosure we have put in place robust physical, electronic and managerial procedures to safeguard and secure the information we process.

However, when you use our Services in connection with third-party services, we are not able to control the security measures applied by those third parties and it is the end user’s responsibility to determine appropriate security measures for the processing of their data in an environment where our services are used in conjunction with other third-party services provided.

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.

If at any point you become aware of a security incident or you have reason to suspect that your data may have been compromised, please forward the communication to us or report the incident by email to partnersupport@simplicityinbusiness.co.uk

10. How long we keep personal information

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.

When we no longer need personal information, or when you request us to delete your information, where this is legal, we will securely delete or destroy it. See section “Purpose of the processing, legal basis, duration and retention periods” for further information on our retention periods.

11. Your legal rights

We respect your right to access and control your information, and we will respond to requests for information and, where applicable, will correct, amend, or delete your personal information.

Access to personal information: You have the right 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. If you request access to your personal information, we will gladly comply, subject to any relevant legal requirements and exemptions, including identity verification procedures. Before providing data to you, we will ask for proof of identity and sufficient information about your interaction with us so that we can locate any relevant data.

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 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

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.

Correction of your data: You have the right to request that we correct or amend your personal information if it is inaccurate or requires updating. You also have the right to request that we complete your personal information on our records if the information we hold is incomplete.

Withdrawal of consent: If we are processing your personal information on the basis that you have given your consent to us processing that personal information, you have a right to withdraw your consent at any time by emailing partnersupport@simplicityinbusiness.co.uk

Marketing preferences: To opt-out of email marketing, you can use the unsubscribe link found in the email communication you receive from us or you can email partnersupport@simplicityinbusiness.co.uk

Filing a complaint: If you are not satisfied with how the Group manages your personal data, you have the right to make a complaint to the Information Commissioner’s Office (https://ico.org.uk).

12. 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 let us know by email at partnersupport@simplicityinbusiness.co.uk

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.

13. 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, 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 with you (for example, to provide you with our Services). In this case, we may have to cancel a Service you have with us but we will notify you if this is the case at the time.

14. Third-party links

Our website has 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 notice of every website you visit.

15. Children’s privacy

Our Services are not directed to children under 13. If you learn that a child under 13 has provided us with personal information without consent, please contact us.

16. How to contact us

Please contact us with any requests related to your personal information.

We understand that you may have questions or concerns about this Policy or our privacy practices or may wish to file a complaint. Please feel free to contact us in one of the following ways:

Email:

partnersupport@simplicityinbusiness.co.uk

Address:

Attn: Simplicity

The Aspen Building, Vantage Point Business Village, Mitcheldean, Gloucestershire GL17 0DD

Telephone:

01594 372111