Privacy policy

General

We are JustFA Technology Limited (referred to as “we” or “us” or “our”). Our registered address is 22 Dartmouth Street, London, England, SW1H 9BP and registration number is 09878264. Our website is justfa.uk (the “Website”).

We are committed to protecting and respecting your privacy, we are the data controller.

These terms of use of the Website (“Website Terms”) and privacy policy apply to actual clients and anyone simply browsing our Website (either one referred to as “you” or “your”).

Should we ask you to provide certain information by which you can be identified when using the Website, then you can be assured that it will only be used in accordance with this Privacy Policy.

Please read this policy carefully as it sets out the basis on which we collect any personal information from you when you use our Website and how we use it. If you browse and use the Website, you are agreeing to comply with and be bound by these Website Terms and our Privacy Policy.

We promise to respect any personal data you share with us, or that we get from other organisations and keep it safe. We aim to be clear when we collect your data and not do anything you would not reasonably expect.

We may change this Privacy Policy from time to time by updating this page. You should check this page from time to time to ensure you are happy with any changes.

If you have any questions about this Privacy Policy or our data protection procedures, please contact us at dataprotection@justfa.uk or at 22 Dartmouth Street, London, England, SW1H 9BP.

What information we collect

Upon receipt of your consent we may collect the following information:

• name and title;
• contact information including your corporate or private email address and your phone number;
• address including postcode of your company;
• device information, if you use the Website (i.e. your IP address); and
• we may retain copies of any correspondence you send us, details of your registration history and any materials you post on the Website.

You can browse this Website as a guest without giving us any information, and we will not know who you are. However, even if you are a guest, please bear in mind that we may:

• record the areas of the Website which you visit and at what times;
• record information about your activities in using the Website;
• collect information your IP address; and
• store data that you submit to us via email.

How the law protects you

Your privacy is protected by our Privacy Policy and by law.

Data Protection law provides that we are allowed to use personal information only if we have a proper reason to do so. This includes sharing it outside our group of companies. The law says we must have one or more of these reasons:

• to fulfil a contract we have with you;
• when it is our legal duty;
• when it is in our legitimate interest; or
• when you consent to it.

A legitimate interest is when we have a business or commercial reason to use your information. But even then, it must not unfairly go against what is right and best for you.

What we do with the information we collect

Below are the lists of all the ways that we may use your personal information and which of the reasons we rely on to do so. This is also where we tell you what our legitimate interests are.

The ways that we (or third party data processors, agents and subcontractors acting on our behalf, where relevant) may use your personal information are:

• to analyse site usage and improve our services;
• to deliver to you any administrative notices, alerts and communications relevant to your use of the services;
• to contact you from time to time to inform you about new features, to troubleshoot problems, and to protect you against fraud or other criminal activity;
• for customer service purposes;
• for regulatory and legal reasons (e.g. anti money laundering);
• for independent audit purposes;
• for any other purposes in relation to our contractual relationship with you;
• for internal record keeping;
• to use the information to improve our products and services;
• to periodically send promotional messages about new products, special offers or other information which we think you may find interesting using the contact information which has been provided to us;
• to use your information to contact you for market research purposes; and
• to use the information to customise the Website according to your interests.

We may use your personal information by relying on the following reasons: your consent, contractual necessity, compliance with legal obligations, legitimate interests (including direct marketing, sharing personal data within a group of companies for internal administration, ensuring network and information security).

How long we keep your personal information for

We will keep your personal information for only as long as necessary for any of the following purposes:

• to respond to any questions or complaints;
• to show that we treated you fairly; or
• to maintain records according to rules that apply to us.

How we keep your personal information secure

We are committed to ensuring that your information is secure. In order to prevent unauthorised access or disclosure, we have put in place physical, electronic and managerial procedures to safeguard and secure the information we collect.

We carry out regular audits of who has access to data so that we can ensure that your information is only accessed by trained staff.

Sophisticated encryption

When you use the Website, data is transferred from your device to us. We use advanced encryption technology to keep your data secure.

Limited access

Only dedicated personnel has access to your personal details.

Fraud

We have robust fraud screening processes to mitigate and detect fraud.

Some of our suppliers may run their operations outside the European Economic Area (EEA). Although they may not be subject to same data protection laws as companies based in the UK, we will take steps to make sure they provide an adequate level of protection in accordance with UK data protection law. By submitting your personal information to us you agree to this transfer, storing or processing at a location outside the EEA.

We will only send your data outside of the EEA:

• to follow your instructions;
• to comply with a legal duty; or
• to work with our agents and advisers who we use to help run your accounts and services.

There may be links on our website to other websites which are not within our control. Once you have left our Website, we cannot be responsible for the content of other websites or for the protection and privacy of any information which you provide on these websites. Please note that these websites have their own privacy policies and website terms and conditions.

Who else we share your information with

We may disclose your personal information to our shareholder and Associated Companies and their employees, contractors and professional advisors (including legal, consulting, accounting, auditing, technology experts etc.) (together with any of our associates or third parties performing services on our behalf) for any of the above purposes. For the purposes of this Privacy Policy, “Associated Company” means the company over which for the time being our shareholder has control (directly or indirectly) within the meaning of Section 840 of The Income and Corporation Taxes Act 1988.

We may share your personal information with companies and other third parties performing services on our behalf who will only use the information to provide that service.

We will not share your data for marketing purposes unless you have actively consented to this. However, in some circumstances we may need to share your details with a third party for processing.

In some circumstances, we may have to disclose your personal information by law, because a court or the police or other law enforcement agency has asked us for it. This applies in particular to your personal data we may have to disclose as part of our “know your customer” and anti-money laundering process. If requested we may need to supply your information to the regulatory bodies or legal advisors. Apart from that, we will not sell or disclose your data to any third party other than as set out in this Privacy Policy.

Marketing, Newsletter and Notices

We will provide you with our newsletter, information on our services and/or other marketing-related notices via email (together “Notices”), if you have provided your prior consent.

If you decide at any time that you no longer wish to receive the Notices, please unsubscribe using the relevant link provided in the individual Notices. We will always give you an opportunity to unsubscribe from receiving any Notices.

Your Rights

You may request details of personal information which we hold about you. If you would like a copy of the information held on you please contact us by email at dataprotection@justfa.uk. Any access request is free, however, any additional copies may be subject to a reasonable administrative charge.

If you think any information we have about you is incorrect or incomplete, please email us at dataprotection@justfa.uk and we will correct, delete or update any information as soon as possible.

By sending an email message to us at dataprotection@justfa.uk you may inform us that you would like to enforce any of the following rights:

• right to prevent direct marketing;
• right to prevent further processing of personal data (“restriction”) when there is a dispute as to accuracy, when an objection to processing has been verified, when processing is unlawful and you object to erasure, or when the data is no longer required by us but you require it for establishment, exercise or defence of a legal claim;
• right to erase personal data (“right to be forgotten”) when processing is no longer necessary, consent is withdrawn, legitimate interests no longer apply, processing is unlawful, or erasure is required by law and we must take reasonable steps to inform other controllers of it has made such data public;
• right to prevent automated decision-making and profiling;
• right to require that the data provided by you for processing with your consent or under contract be provided in a commonly used and machine-readable form and transmitted to another controller (“data portability”).

How to withdraw your consent

You can withdraw your consent at any time by emailing to dataprotection@justfa.uk.

If you withdraw your consent, we may not be able to provide certain products or services to you. If this is so, we will tell you.

How to complain

Please let us know if you are unhappy with how we have used your personal information. You can contact us at dataprotection@justfa.uk.

If you are not satisfied with the response you receive from us for any reason then you also have the right to complain to the Information Commissioner’s Office. Find out on their website how to do so via https://ico.org.uk/.

Updated: 14 June 2022