Last updated: January 2020
Introduction and General Terms
Pay360 by Capita is committed to protecting your personal information when you are using our services. This Privacy Notice relates to our use of your personal information when we contact you or you make contact with us in relation to one of our products or services.
In order to provide you with the full range of services, we sometimes need to collect information about you. This Privacy Notice explains the following:
- What information we may collect about you;
- How we will use information we collect about you;
- When we may use your details to contact you;
- Whether we will disclose your details to anyone else.
We are committed to safeguarding your personal information. Whenever you provide such information, we are legally obliged to use your information in line with all applicable laws concerning the protection of personal information, these laws are referred to collectively in this Privacy Notice as "data protection laws".
Who are we
Pay360 by Capita is part of the Capita Software Division which along with other Divisions forms part of the wider Capita plc Group. We provide the latest payments, fraud and optimisation technology to help global private and public sector markets increase revenue and improve customer experience. When we refer to ‘’we’’, ‘’our’’ or "Pay360" we are referring to Pay360 by Capita.
What information we collect
In order to provide you with services and communications suited to your needs, we require information about you. Typically, we collect this information directly from you as you use, request information, or enquire about our services, we may also obtain this information via vetted third-party suppliers and publicly available sources.
For the purposes mentioned in our Privacy Notice(s), we collect the following groups of information of you:
- Your basic identification and contact details
This may include your name, company, address, telephone number, email address and other information that you provide us.
- Information about your customer relationship with us
This may include information about your previous purchases of our products and services, your billing information, information about Pay360 by Capita events you have participated in, and feedback you have given us.
Occasionally we may process personal information that hasn’t been collected directly from you. All personal information is obtained from verified sources and will only be processed if a suitable legal basis has been established. We use the following sources:
- Affiliate/Partner Programs
- Open sources such as your company website or a publicly available website e.g. LinkedIn, Facebook, Twitter etc.
- Third party data suppliers
How we use your personal information
We use your information in a manner which is consistent with the original purpose of collection. Specifically, we may use your data for the following purposes:
- Customer visit - whereby we may contact you regards to items discussed or similar products and solutions you have expressed an interest in.
- Event attendance or registration (Including webinars) in order to contact you about the event itself and/or possibly future events and/or to obtain feedback. When registering for event we may ask you for special category data, such as dietary requirements, in order to meet your needs at the event(s).
- General enquiry or feedback where you may contacted us via telephone, email or other channels requesting information about products and services and we may use the data captured to help improve services or assist in finding a resolution to your enquiry.
- Marketing subscription where you would have signed up via a web form or other data capture point. This information will be processed in accordance to that stated at the point of capture.
- Customer portal registration where we may use your data to send important updates, event information, direct marketing and other useful information that will help you get the most out of the products and services available to you.
- Product Purchase where we may have obtained your data following the signing of a contract. We may use this data to contact you about product updates, financial queries, renewals and other useful information that will help you get the most out of our products and services.
- Sales Enquiry where you may have contacted us via telephone, email or other channels requesting information about products and services we have to offer or we have contacted you and you have expressed an interest. You can unsubscribe anytime or customise your preferences (See Section 9. How can I amend my preferences?)
- Third Party data purchase where we may occasionally obtain your data from verified data supplier. We will only process data if a suitable legal basis has been established and will adhere to Capita Group Policy at all times.
Bases for processing personal data
We will only collect and use your personal information in accordance with data protection legislation. Our legal basis for processing your personal information are as follows:
- Consent – Where necessary we may collect and process your personal information if you have given your consent for us to do so, for example, we will only send you certain marketing emails and process any sensitive information about you if we have your consent.
- Legitimate Interests – We collect and use your personal information for our legitimate business purposes of communicating with you, to help with your enquiries and fulfilling your requests for services. We have completed a comprehensive assessment and implemented measures to ensure our interests do not affect your right to privacy.
If you believe the communications you received from us are of a marketing nature, you have the right to stop unsubscribe at any time. To do this either use the unsubscribe link provided within the original email or alternatively, send an email to firstname.lastname@example.org
Please note this will not affect our ability to communicate with you in support of a service or product.
How long we keep your information for
We will hold your personal information on our systems for as long as is necessary to maintain our relationship. Unless you choose to withdraw your personal details before this time, your personal data will be held in accordance with Capita Group policy. A periodic review will be carried out to ensure all information held remains relevant.
Who might your information be shared with
We will keep your information within Pay360 by Capita and the Capita Group and will only share it outside the Capita Group where you have requested it or given your consent. We may share your information across the Capita group and its commercial subsidiaries, where this is necessary to provide you with a service you have requested. Where we use third party suppliers, we will only share your information with them to ensure a Data Subjects rights are adhered to and should you wish to object to this processing please follow the process detailed below.
What information might be shared within the Capita Group
Information relating to your basic identification, contact details and Information about your customer relationship with us may be shared for the purposes of Sales and Marketing.
Sending data outside the EEA
We may transfer personal information to countries outside of the European Economic Area ("EEA"), which may not have the same data protection laws as those of the UK. Where we transfer personal information to countries outside of the EEA, we will take appropriate steps to ensure the personal information is afforded the same level of protection as described in our Privacy Notice(s). We rely on adequacy decisions or any adequate data transfer mechanisms adopted by the European Commission or a supervisory authority for transfers outside of the EEA.
Under data protection laws you have a number of rights in relation to your personal information. In relation to certain rights, we may ask you for information to confirm your identity and, where applicable, to help us to search for your personal information. Except in rare cases, we will respond to you within 30 days after we have received this information or, where no such information is required, after we have received your request. This section explains what they are and how you can use them, if you wish.
Accessing your personal information
You have the right to request a copy of the personal information that we hold about you. This is known as a Subject Access Request. If you wish to request a copy of your personal information please address requests to email@example.com
Correcting and updating your personal information
The accuracy of your information is important to us. If you change your name or address/email address, or you discover that any of the other information we hold is inaccurate or out of date, please contact us using firstname.lastname@example.org
Erasing your personal information or restricting its processing
You may ask for your personal information to be removed from our systems. Unless there is a reason that the law allows us to use your personal information for longer, we will make reasonable efforts to comply with your request. You may also ask us to restrict processing your personal information in the following situations:
- Where you believe we have unlawfully used your personal information and you choose not to elect for your information to be erased;
- Whilst we are verifying the accuracy of the information following a contest of accuracy;
- You objected to us processing your personal information and we are considering whether our legitimate grounds override your decision;
- You have objected to its use and our investigation is pending or you require us to keep it in connection with legal proceedings.
In these situations, we may only store your personal information and not further process whilst the restriction is in place. Unless we have your consent or are legally permitted to do so, for example to protect the rights of another individual or company or in connection with legal proceedings.
If you wish to exercise any of these rights please address your request to email@example.com. We will endeavor to complete your request as swiftly and diligently as possible.
Right to lodge a complaint
You have the right to complain to the Information Commissioners Office (ICO) if you are concerned about the way we have processed your personal information. They can be contacted via:
Information Commissioner's Office
Tel: 01625 545 700
If we wish to use your personal data for a new purpose, not covered by our Privacy Notice(s), we will provide you with a new notice explaining this new use prior to commencing the processing and setting out the relevant purposes and processing conditions. Where necessary, we will seek your prior consent to the new processing.
Changes to our Privacy Notice
This Privacy Notice may be updated from time to time so you may wish to check it each time you submit personal information to us. The date of the most recent revisions will appear on this page. If material changes are made to our Privacy Notice(s), for instance affecting how we would like to use your personal information, we will provide a more prominent notice (including email notification of the changes to the notice).
If you have any questions or comments regarding the content of this Privacy Notice, please contact us at firstname.lastname@example.org
The Data Protection Officer
Pay360, Capita Plc
65 Gresham Street