1. Overview

AforeUK obtains Personal Data about you from various sources to provide our Services and to manage our Site. “You” may be a visitor to our website, a user of one or more of our Services (“User” or “AforeUK User”). If you are a User which is defined as browsing our website, AforeUK will generally not collect your Personal Data directly from you. For example, we collect Personal Data that you submit to us via online forms and surveys, and when you contact us by email.

A AforeUK User is a customer that has registered their contact details within our website which will include name, address, telephone and email address along with other information.

2. Personal data we collect

a. Personal data that we collect about you.

Any information that relates to an identified or identifiable individual. The Personal Data that you provide directly to us through our Site and Services will be apparent from the context in which you provide the data. In particular:

• When you register for a AforeUK account we collect your full name, email address, and account log-in credentials.
• When you fill-in our online form to contact our customer service team, we collect your full name, work email, country, and anything else you tell us about yourself, business, needs and other information.

When you respond to AforeUK emails or surveys we collect your email address, name and any other information you choose to include in the body of your email or responses. If you contact us by phone, we will collect the phone number you use to call AforeUK. If you contact us by phone as a AforeUK User, we may collect additional information in order to verify your identity.

• If you are a AforeUK User, you will provide your contact details, such as name, postal address, telephone number, and email address. As part of your business relationship with us, we may also receive further information about you, such as your date of birth and government identifiers associated with you and your organisation (such as your tax number, or Employer Identification Number, Company Registration Number and Vat Registration Number).

When we conduct fraud monitoring, prevention, detection, and financial compliance activities or provide such services to our Users, we will receive Personal Data from you (and your device) and about you through our Service merchant service providers, identity verification services, and publicly available sources (e.g., name, address, phone number, country), as necessary to confirm your identity and prevent fraud. Our fraud monitoring, detection and prevention services may collect Personal Data about you and use technology to help us assess the risk associated with an attempted transaction.

You may also choose to submit information to us via other methods, including: (i) in response to marketing or other communications, (ii) through social media or online forums, (iii) through participation in an offer, program or promotion, (iv) in connection with an actual or potential business relationship with us, or (v) by giving us your business card or contact details at trade shows or other events.

b. Information that we collect automatically on our Site.

Our Site uses cookies and other technologies to function effectively. These technologies record information about your use of our Site, including:

• Browser and device data, such as IP address, device type, operating system and Internet browser type, screen resolution, operating system name and version, device manufacturer and model, language, plug-ins, add-ons and the language version you are using;
• Usage data, such as time spent on the Site, pages visited, links clicked and language preferences.
• Cookies are used within AforeUK to provide uninterrupted use of our Service. No cookies are used to track, monitor or gather any information to be used as marketing or advertisement data.

3. How we use personal data

a. Our services.

We rely upon a number of legal grounds to ensure that our use of your Personal Data is compliant with applicable law. We use Personal Data to facilitate the business relationships we have with our Users, to comply with our financial regulatory and other legal obligations, and to pursue our legitimate business interests. We also use Personal Data to complete payment transactions and to our Users.

b. Marketing and events-related communications.

We will not send you email marketing communications about AforeUK services. We may invite you to participate in events or surveys to gauge our services on a professional level or to advise of a change or addition to our service. If we collect your business contact details through our participation at trade shows or other events, we may use the information to follow-up with you regarding an event, send you information that you have requested on our services and, with your permission, contact you further.

c. Advertising.

There are no paid advertising campaigns by a AforeUK User. When you visit our Site, we will not use Personal Data collected from you and your device to target advertisements for AforeUK Services to you on our Site.

We do not use, share, rent or sell the Personal Data of our AforeUK Users' or Site visitors for interest-based advertising.

4. How we disclose personal data

AforeUK does not sell or rent Personal Data to marketers or unaffiliated third parties. We share your Personal Data with trusted entities, as outlined below.

a. AforeUK.

We share Personal Data with other AforeUK entities in order to provide our Services, and for internal administration purposes.

b. Service Providers.

We share Personal Data with a limited number of our service providers. We have service providers that provide services on our behalf, such as identity verification services, website hosting, data analysis, information technology and related infrastructure, customer service, email delivery, and auditing services. These service providers may need to access Personal Data to perform their services. We authorise such service providers to use or disclose the Personal Data only as necessary to perform services on our behalf or comply with legal requirements. We require such service providers to contractually commit to protect the security and confidentiality of Personal Data they process on our behalf. Our service providers are predominantly located in the United Kingdom.

c. Business partners.

We share Personal Data with third party business partners when this is necessary to provide our Services to our Users. Examples of third parties to whom we may disclose Personal Data for this purpose are banks and payment method providers (such as credit card networks).

d. Corporate transactions.

In the event that we enter into, or intend to enter into, a transaction that alters the structure of our business, such as a reorganisation, merger, sale, joint venture, assignment, transfer, change of control, or other disposition of all or any portion of our business, assets or stock, we may share Personal Data with third parties in connection with such transaction. Any other entity which buys us or part of our business will have the right to continue to use your Personal Data, but only in the manner set out in this Privacy Policy unless you agree otherwise.

e. Compliance and harm prevention.

We share Personal Data as we believe necessary: (i) to comply with applicable law, or payment method rules; (ii) to enforce our contractual rights; (iii) to protect the rights, privacy, safety and property of AforeUK, you or others; and (iv) to respond to requests from courts, law enforcement agencies, regulatory agencies, and other public and government authorities, which may include authorities outside your country of residence.

5. Your rights and choices

You have choices regarding our use and disclosure of your Personal Data:

a. Opting out of receiving electronic communications from us.

There's nothing to opt-out of. We will only send you important administrative messages either directly to your email for account related matters, or through the Service Announcements page where all users are notified of relevant Service information. You will never receive marketing material from us.

b. How you can see or change your account Personal Data.

If You would like to review, correct, or update Personal Data that You have previously disclosed to us, You may do so by signing in to your AforeUK account.

c. Your data protection rights.

Depending on your location and subject to applicable law, you may have the following rights with regard to the Personal Data we control about you:

• The right to request confirmation of whether AforeUK processes Personal Data relating to you, and if so, to request a copy of that Personal Data;
• The right to request that AforeUK rectifies or updates your Personal Data that is inaccurate, incomplete or outdated;
• The right to request that AforeUK erase your Personal Data in certain circumstances provided by law;
• The right to request that AforeUK restrict the use of your Personal Data in certain circumstances, such as while AforeUK considers another request that you have submitted (including a request that AforeUK make an update to your Personal Data); and
• The right to request that we export to another company, where technically feasible, your Personal Data that we hold in order to provide Services to you.

Where the processing of your Personal Data is based on your previously given consent, you have the right to withdraw your consent at any time. You may also have the right to object to the processing of your Personal Data on grounds relating to your particular situation.

d. Process for exercising data protection rights.

In order to exercise your data protection rights, you may contact AforeUK. We take each request seriously. We will comply with your request to the extent required by applicable law. We will not be able to respond to a request if we no longer hold your Personal Data. If you feel that you have not received a satisfactory response from us, you may consult with the data protection authority in your country.

For your protection, we may need to verify your identity before responding to your request, such as verifying that the email address from which you send the request matches your email address that we have on file. If we no longer need to process Personal Data about you in order to provide our Services or our Site, we will not maintain, acquire or process additional information in order to identify you for the purpose of responding to your request.

6. Security and retention

We make reasonable efforts to ensure a level of security appropriate to the risk associated with the processing of Personal Data. We maintain organisational, technical and administrative measures designed to protect Personal Data within our organisation against unauthorised access, destruction, loss, alteration or misuse. Your Personal Data is only accessible to a limited number of personnel who need access to the information to perform their duties. Unfortunately, no data transmission or storage system can be guaranteed to be 100% secure. If you have reason to believe that your interaction with us is no longer secure (for example, if you feel that the security of your account has been compromised), please contact us immediately.

We retain your Personal Data as long as we are providing the Services to you. We retain Personal Data after we cease providing Services directly or indirectly to you, to the extent necessary to comply with our legal and regulatory obligations, and for the purpose of fraud monitoring, detection and prevention. We also retain Personal Data to comply with our tax, accounting, and financial reporting obligations, where we are required to retain the data by our contractual commitments to our financial partners, and where data retention is mandated by the payment methods that we support. Where we retain data, we do so in accordance with any limitation periods and records retention obligations that are imposed by applicable law.

7. International data transfers

We are a UK business. Personal Data will be stored and processed in the UK or where we engage service providers. We may transfer Personal Data that we maintain about you to recipients in countries other than the country in which the Personal Data was originally collected, including to the United States, typically for card payment transactions. Those countries may have data protection rules that are different from those of your country. However, we will take measures to ensure that any such transfers comply with applicable data protection laws and that your Personal Data remains protected to the standards described in this Privacy Policy. In certain circumstances, courts, law enforcement agencies, regulatory agencies or security authorities in those other countries may be entitled to access your Personal Data.

8. Use by minors

The Services are not directed to individuals under the age of eighteen (18), and we request that they not provide Personal Data through the Services.

9. Updates to this privacy policy and notifications

We may change this Privacy Policy from time to time to reflect new services, changes in our Personal Data practices or relevant laws. The “Last updated” legend at the top of this Privacy Policy indicates when this Privacy Policy was last revised. Any changes are effective when we post the revised Privacy Policy on the Services. We may provide you with disclosures and alerts regarding the Privacy Policy or Personal Data collected by posting them on our website and, if you are a AforeUK User, by contacting you through your AforeUK Dashboard, email address and/or the physical address listed in your AforeUK account.

10. Links to other websites

The Services may provide the ability to connect to other websites. These websites may operate independently from us and may have their own privacy notices or policies, which we strongly suggest you review. If any linked website is not owned or controlled by us, we are not responsible for its content, any use of the website or the privacy practices of the operator of the website.