Privacy Notice

About this Notice

Underpinned Ltd (“we” or “us”) take the privacy of your information very seriously. This Privacy Notice is designed to tell you about our practices regarding the collection, use and disclosure of personal information which may be collected in person from you, obtained via our websites or collected through other means such as by an online form, email, or telephone communication.

This notice applies to personal information provided by our contacts, users and customers whose data we process. In this notice “you” refers to any individual whose personal data we hold or process. This notice is governed by the EU General Data Protection Regulation (the “GDPR”).

Please note that this notice will be updated when our Service is launched.

Personal data we collect and how we process this data

Below we have set out the categories of data we collect, the legal basis we rely on to process the data and how we process the data:

Data Retention

Our current data retention policy is to delete or destroy (to the extent we are able to) personal data after the following periods:

For any category of personal data not specifically defined in this notice, and unless otherwise specified by applicable law, the required retention period for any personal data will be deemed to be 7 years from the date of receipt by us of that data. The retention periods stated in this notice can be prolonged or shortened as may be required (for example, in the event that legal proceedings apply to the data or if there is an on-going investigation into the data).

Sharing your information

We may disclose information to third parties in the following circumstances:

 

If we do supply your personal information to a third party we will take steps to ensure that your privacy rights are protected and that third party complies with the terms of this notice.

Security

We will take all reasonable steps to ensure that appropriate technical and organisational measures are carried out in order to safeguard the information we collect from you and protect against unlawful access and accidental loss or damage.

Your privacy rights

With respect to your personal data, you have the right to:

 

All requests or notifications in respect of your above rights may be sent to us in writing at the contact details listed below. We will endeavour to comply with such requests as soon as possible but in any event we will comply within one month of receipt (unless a longer period of time to respond is reasonable by virtue of the complexity or number of your requests).

If personal data we hold about you is subject to a breach or unauthorised disclosure or access, we will report this to the Information Commissioner’s Office (ICO) and/or our data protection manager.

If a breach is likely to result in a risk to your data rights and freedoms, we will notify you as soon as possible.

Transferring your information outside Europe

We will not transfer your personal data in a systematic way outside of the European Economic Area (“EEA”) but there may be circumstances in which certain personal information is transferred outside of the EEA, in particular:

If we transfer your information outside of the EEA, and the third country or international organisation in question has not been deemed by the EU Commission to have adequate data protection laws, we will provide appropriate safeguards and we will be responsible for ensuring your privacy rights continue to be protected as outlined in this notice.

Contact us

If at any time you would like to contact us with your views about our privacy practices, or with any enquiry or complaint relating to your personal information or how it is handled, you can do so by us using the details below:

 

Address:

WeWork, Provost and East,

145 City Road,

EC1V 9NR

UK

Email:              info@underpinned.co

Complaints

If we are unable to resolve any issues you may have or you would like to make a further complaint, you can contact the Information Commissioner’s Office by visiting http://www.ico.org.uk/ for further assistance.

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