Privacy Notice

Please read this privacy notice (“Privacy Notice”) carefully as it describes our collection, use, disclosure, retention and protection of your personal information. The Privacy Notice applies to any website, application or service which references this Privacy Notice. Where you provide us with your personal information in any of the ways described in section 2 below, you agree that we may collect, store and use it:

(a) in order to perform our contractual obligations to you;

(b) based on our legitimate interests for processing (i.e. for internal administrative purposes, data analytics and benchmarking (see section 3 below for more information), general marketing, direct marketing, e-mail marketing, maintaining automated back-up systems or for the detection or prevention of crime); or

(c) based on your consent, which you may withdraw at any time, as described in this Privacy Notice.

1. Who we are

This Privacy Notice applies to all products, applications and services offered by Amp Communications Ltd (a company incorporated in England with company registration number 5992075 and whose registered office address is 8 Domingo Street, London EC1Y 0TA).

2. How we collect information

We will collect and process the following data about you:

• Information you give us: This is information about you that you give us by filling in forms on our site or by corresponding with us by phone, email or otherwise. The information you give us may include your name, address, email address, job title, phone number and financial information

• Information we collect from your use of our site: With regard to each of your visits to our site we will automatically collect the following information:

– technical information, such as the Internet Protocol (IP) address used to connect your device to the Internet, whereabouts you connected to our service, your Internet Service Provider (ISP), and what type of device you are using to access our service; and
– personal information you disclose when using our live chat on our website

• Information we collect throughout our relationship: This is information relating to the provision of our products and services

• Information we collect when you call us: If you call us we will automatically collect the following information:

– the phone number used to call us
– any personal data disclosed on the call
– a recording of all inbound and outbound calls

• Information we receive from other sources: We are working closely with other organisations, including:

– marketing list providers
– social media
– business partners, subsidiaries, suppliers and sub-contractors

• Providing us with your details online: This is information you may choose to provide us with using the https://www.amp-london.com page on our site. It includes your name, telephone number and email address. Please let us know if any of this information changes so we can keep our records up to date.

Providing us information about others

If you provide us with personal information about someone else, you are responsible for ensuring that you comply with any obligation and consent obligations under applicable data protection laws in relation to such disclosure. In so far as required by applicable data protection laws, you must ensure that you have provided the required notices and have obtained the individual’s explicit consent to provide us with the information and that you explain to them how we collect, use, disclose and retain their personal information or direct them to read our Privacy Notice.

3. How we use your information

To the extent permissible under applicable law, we use your information to:

• provide any information and services that you have requested or any products or services that you have ordered;
• compare information for accuracy and to verify it with third parties;
• provide, maintain, protect and improve any applications, products, services and information that you have requested from us;
• manage and administer your use of applications, products and services you have asked us to provide;
• manage our relationship with you (for example, customer services and support activities);
• monitor, measure, improve and protect our content, website, applications and services and provide an enhanced, personal, user experience for you;
• undertake internal testing of our website, applications, systems and services to test and improve their security, provision and performance, in which case, we would pseudonymise any information used for such purposes, and ensure it is only displayed at aggregated levels which will not be linked back to you or any living individual;
• provide you with any information that we are required to send you to comply with our regulatory or legal obligations;
• detect, prevent, investigate or remediate, crime, illegal or prohibited activities or to otherwise protect our legal rights (including liaison with regulators and law enforcement agencies for these purposes);
• contact you to see if you would like to take part in our customer research (for example, feedback on your use of our applications, products and services);
• to monitor, carry out statistical analysis and benchmarking, provided that in such circumstances it is on an aggregated basis which will not be linked back to you or any living individual;
• deliver targeted advertising, marketing (including in-product messaging) or information to you which may be useful to you, based on your use of our applications and services;
• deliver joint content and services with third parties with whom you have a separate relationship (for example, social media providers); and
• provide you with location – based services (for example, advertising and other personalised content), where we collect geo-location data.

4. How long do we keep hold of your information?

We will keep information about you for a maximum of 7 years after the end of our relationship with you unless obligations to our regulators require otherwise or we are required to remove such records from our records.

5. Sharing your information

We may share your information with:

• business partners, subsidiaries, suppliers and sub-contractors for the performance of any contract we enter with you
• third parties used to facilitate payment transactions, for example clearing houses, clearing systems, financial institutions and transaction beneficiaries;
• third parties where you have a relationship with that third party and you have consented to us sending information (for example social media sites or other third party application providers);
• credit reference and fraud prevention agencies;
• regulators to meet Amp Communications Ltd legal and regulatory obligations;
• law enforcement agencies so that they may detect or prevent crime or prosecute offenders;
• any third party in the context of actual or threatened legal proceedings, provided we can do so lawfully (for example in response to a court order);
• any third party in order to meet our legal and regulatory obligations, including statutory or regulatory reporting or the detection or prevention of unlawful acts;
• our own professional advisors and auditors for the purpose of seeking professional advice or to meet our audit responsibilities;
• in the event that we sell or buy any business or assets, in which case we will disclose your personal data to the prospective seller or buyer of such business or assets;
• if we are acquired by a third party, in which case personal data held by it about its customers will be one of the transferred assets; and
• Government departments where reporting is mandatory under applicable law.

We may share non-personally identifiable information about the use of our website, applications, products or services publicly or with third parties but this will not include information that can be used to identify you.

6. Your information and your rights

If you are based within the EEA or within another jurisdiction having similar data protection laws, in certain circumstances you have the following rights:

• the right to be told how we use your information and obtain access to your information;
• the right to have your information rectified or erased or place restrictions on processing your information;
• the right to object to the processing of your information e.g. for direct marketing purposes or where the processing is based on our legitimate interests;
• the right to have any information you provided to us on an automated basis returned to you in a structured, commonly used and machine-readable format, or sent directly to another company, where technically feasible (“data portability”);
• where the processing of your information is based on your consent, the right to withdraw that consent subject to legal or contractual restrictions;
• the right to object to any decisions based on the automated processing of your personal data, including profiling; and
• the right to lodge a complaint with the supervisory authority responsible for data protection matters (e.g. in the UK, the Information Commissioner’s Office).

If you request a copy of your information you may be required to pay a statutory fee.

If we hold any information about you which is incorrect or if there are any changes to your details, please let us know by so that we can keep our records accurate and up to date.

If you withdraw your consent to the use of your personal information for purposes set out in our Privacy Notice, we may not be able to provide you with access to all or parts of our website, applications, and services.

7. Changes to this Privacy Notice

We may change this Privacy Notice from time to time. However we will not reduce your rights under this Privacy Notice. We will always update this Privacy Notice on our website, so please try to read it when you visit the website (the ‘last updated’ reference tells you when we last updated this Privacy Notice).

8. Security and storage of information

We will keep your information secure by taking appropriate technical and organisational measures against its unauthorised or unlawful processing and against its accidental loss, destruction or damage. We will do our best to protect your personal information but we cannot guarantee the security of your information which is transmitted to our website, applications or services or to other website, applications and services via an internet or similar connection. If we have given you (or you have chosen) a password to access certain areas of our websites, applications or services please keep this password safe – we will not share this password with anyone.

If you believe your account has been compromised, please contact us at privacy@amp-london.com

We may transfer your data outside the European Economic Area (“EEA”). We will only do so if adequate protection measures are in place in compliance with data protection legislation. We use the following protection measures:

• transferring to Commission approved countries
• using Commission approved model contractual clauses
• requiring companies we transfer data to in USA to be signed up to certification e.g. Privacy Shield for US

Once we have received your information, we will use strict procedures and security features to try to prevent unauthorised access. More information is available by contacting us.

9. Other sites and social media

If you follow a link from our website, application or service to another site or service, this Privacy Notice will no longer apply. We are not responsible for the information handling practices of third party sites or services and we encourage you to read the privacy notices appearing on those sites or services.

Our websites, applications or services may enable you to share information with social media sites, or use social media sites to create your account or to connect your social media account. Those social media sites may automatically provide us with access to certain personal information retained by them about you (for example any content you have viewed). You should be able to manage your privacy settings from within your own third party social media account(s) to manage what personal information you enable us to access from that account.

10. Further information

If you have any queries about how we treat your information, the contents of this Privacy Notice, your rights under local law, how to update your records or how to obtain a copy of the information that we hold about you, please write to our Data Protection Officer, Nada Hinic, at Amp Communications Ltd, 8 Domingo Street, London EC1Y 0TA, or send an email to privacy@amp-london.com.