Terms and Conditions & Privacy Notice

Introduction

This is the privacy policy (“Policy”) of Faben Digital Limited (Company No. 08754913), a private company registered in the United Kingdom with its main place of business at 20-22 Wenlock Street, London, N1 7GU (“we”, “us”, or “our”).

Our data protection officer’s details are:

We may collect and process personal information, being any information relating to any person who engages or corresponds with us (whether directly, via our website, www.faben.uk, (“Website”), via email, or otherwise) and/or who engages with us to provide digital marketing and related services (“Services”). Such persons include, for example, visitors to our Website, clients, suppliers, business contacts, contractors, and/or employees of ours (“Data Subject”, also referred to as “you”, “your”, or “yours”).

The personal information we may collect and process includes, for example, that relating to your identity, contact details, address, date of birth or demographic (“Personal Information”) which you give us, when necessary, to allow you to visit and use our Website, and/or to engage with us and/or for us to provide the Services to you.

We take the privacy of your Personal Information seriously and we are committed to its protection. We will only process Personal Information in accordance with applicable data protection legislation, including the General Data Protection Regulation (EU 2016/679) (“GDPR“) which includes the retained EU law version of GDPR as it forms part of the law of the United Kingdom, and any other applicable data protection legislation and/or regulation, (“Data Protection Laws”) and in a way that is:

• • – lawful;
  • – transparent;
  • – used to serve a legitimate purpose;
  • – limited to collect what is relevant to achieve that purpose;
  • – accurate; and/or
  • – secure.

This Policy sets out how we will collect and process your Personal Information when you visit our Website, engage with us, and/or use our Services.

By visiting our Website, engaging with us, using our Services, and/or by you submitting any Information to us, you consent to our collection of Information as set out in this Policy.

Collecting your Information

In addition to collecting your Personal Information, we may also collect information of a more sensitive nature, for example, that relating to your finances, medical details, vaccine status, criminal records, biometric data (e.g. fingerprints) and/or employment history (“Sensitive Personal Information”) (collectively, “Information”). If you object to us collecting such Information, you must inform our data protection officer immediately in writing (by email).

How do we collect your Information?

You do not have to supply any Information to us, but you understand that you may only be able to access and benefit from the use of our Website, engage with us, and/or use our Services if and only once you have supplied certain Information to us.

We may collect your Information that you, as the Data Subject supply to us, and/or which is supplied by your (i) nominated third party agent, or by (ii) a regulator, or (iii) which you supply to us directly when you visit our Website, engage with us, and/or use our Services.

You warrant to us that you when you supply Information, or any other third-party data, to us, you do so lawfully and with all necessary consents.

Children

We do not engage with children (persons under the age of 18), whether via our Website, or directly. We accordingly do not collect Information from children.

Processing of Information

We may process your Information from time to time. “Process” is the term used to describe any operation or set of operations performed on Information or sets of Information, whether or not by automated means, such as collection, recording, organisation, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction.; If you object to us Processing any Information, you must inform our data protection officer immediately in writing (by email).

Why do we Process Information?

We only Process Information if it is necessary to achieve a specific and genuine purpose. 

• • – communicate with you;
  • – deliver our Services to you;
  • – interact with your account on our Website;
  • – fulfil any contractual duties we have towards you;
  • – oversee and improve our Services and our Services delivery;
  • – market our future products and Services to you;
  • – co-operate with authorities during a law enforcement inquiry;
  • – enable legal proceedings;
  • – realise our rights; and/or
  • – to protect others.

How do we Process Information?

We only Process information in accordance with Data Protection Laws, and if, for example, where there is a legitimate purpose.

• • – you (or a competent person where the Data Subject is a child under the age of 18 years) have consented to the Processing of the Information;
  • – the Processing is necessary to allow us to perform our Services;
  • – the Processing is necessary to enable us to engage with you;
  • – the Processing is necessary to enable us to fulfil our obligations to you;
  • – to comply with a legal obligation;
  • – the Processing protects your legitimate or vital interests; 
  • – the Processing is necessary to protect our or the third party’s legitimate or vital interests (we shall provide you with details of any such legitimate or vital interests); and/or
  • – the Processing is necessary to prevent a crime being committed or being aided and abetted.

In general, in order to meet the legitimate purposes, we will Process your Information where it is necessary to enter into a contract with you or in order to carry out a legal obligation.

Lawful bases applicable to Sensitive Personal Information

Apart from the legitimate purposes outlined above where we Process your Information, there are additional conditions which apply to Sensitive Personal Information. 

• – where you (or a competent person where the Data Subject is a child under the age of 18 years) have consented to the Processing of the Sensitive Personal Information;
  – for a lawful purpose (e.g. necessary for employment, social security and/or social protection);
  – the Processing protects your legitimate or vital interests; and/or
  – the Processing is necessary to protect our or the third party’s legitimate or vital interests (we shall provide you with details of any such legitimate or vital interests).
  – the Processing is for a substantial public interest or for public health (including as necessary, for example, for scientific research; historical research, statistical purposes); and/or
  – the Processing is necessary for medical or social care reasons.

How do we Process Information outside of the United Kingdom?

We may Process Information on servers situated outside of United Kingdom, or outside of the country where such Information was collected, in accordance with Data Protection Laws.

Sharing your Information

We will not share with or sell your Information to any third party without your written consent. There are exceptions.

• • – where it is shared or sold to a third party which is not affiliated to us, such information is for our required purposes, under our specific instruction, and not for their purposes, and in terms of a formal legal agreement with that third party;
  • – such Information has been anonymised – this means that we have deleted any identifiers in the Information linking the information to you and such Information accordingly cannot be used, manipulated, or linked, using any reasonably foreseeable methods, to identify you; and/or
  • – that third party is affiliated with us (for example, if the third party is a related entity, or our service provider such as our auditors, accountants, and/or lawyers.

How long to we keep your Information

We will only keep your Information for as long as it is necessary to achieve a specific and legitimate purpose as referred to above and/or to comply with the law, and/or to comply with a request from you.

We will destroy, delete, or anonymise any of your Information in our possession once it is no longer necessary for us to retain it.

Obligation to Notify

You must ensure that your Information supplied to us it is correct and up-to-date at all times. If you discover that the Information supplied in inaccurate or outdated, you must immediately inform us of this so that we can correct it.

Third Party Links

Our Website may contain third party links to other websites or platforms. 

You are responsible for complying with the terms and conditions of any third-party website or platform linked on our Website.

You indemnify us against any loss or damage that may occur from you visiting any third-party links on our Website, including loss or damage related to security, privacy policies, and/or content.

Third Party Processors

Our carefully selected partners and service providers may process personal information about you on our behalf as described below:

Digital Marketing Service Providers

We periodically appoint digital marketing agents to conduct marketing activity on our behalf, such activity may result in the compliant Processing of your Information. See our appointed data processors:

(i) Prospect Global Ltd (trading as Sopro) Reg. UK Co. 09648733. You can contact Sopro and view their privacy policy here: http://sopro.io. Sopro is registered with the ICO Reg: ZA346877 their Data Protection Officer can be emailed at: dpo@sopro.io.

Keeping your Information Secure

We will implement technological and organisational measures to protect and keep secure the confidentiality and integrity of your Information. We will identify and prevent all reasonably foreseeable internal and external risks to your Information, so as to maintain appropriate safeguards against such risks.

We will regularly re-evaluate the effectiveness of such safeguards and measures in place, especially in response to any new risks to personal information identified.

Data Breach

We have proper procedures in place to deal with any data breach. Any data breach shall be reported and dealt with in accordance with the Data Protection Laws. We will notify you and the relevant regulator as soon as reasonably possible in writing should there be any data breach, or should there be reasonable grounds to suspect that a data breach has occurred or is likely to occur.

Cookies

We may track and store information gathered from your Website visits, including the IP address of your device, the date and time of your Website visit, and which pages you have visited successfully (“Cookies”). We use Cookies in order to for us to recognise you during your subsequent Website visits, to customise our Services offering and/or engagement with you. 

You may change your device settings to deny Cookies; however, this may prevent you from accessing the Website and/or Services and/or from the benefit of customised Services offerings and/or engagements.

Your Rights

As a Data Subject, under the Data Protection Laws, you have certain rights relating to your Information. 

These rights include, for example:

• • – transparency about how your we use your Information and if it has been accessed by an unauthorised person;
  • – access the Information that we hold about you;
  • – ask us to rectify/correct/update inaccurate Information and to update incomplete Information;
  • – request us to correct, destroy or erase your Information in certain circumstances;
  • – object to or restrict our processing of your Information; 
  • – request the transfer of your Information to you or to a third party in a machine-readable format;
  • – object to decisions being made, under certain circumstances, by automated-decision-making processes;
  • – object at any time to the Processing of your Information for direct marketing purposes; 
  • – withdraw your consent, at any time where you have consented to us Processing your Information;
  • – to lodge a complaint against us with the relevant regulatory body; and
  • – institute civil proceedings in relation to your Information.

For further information on these rights refer to the Guidance from the UK Information Commissioner’s office (ICO) on your rights under the General Data Protection Regulations https://ico.org.uk/for-organisations/guide-to-data-protection/guide-to-the-general-data-protection-regulation-gdpr/individual-rights/

Changes to this Policy

This Policy was published on our Website on 13th June 2022

We may change this Policy from time to time and we will take all reasonable steps to notify all Data Subjects of such amendments, including the publication of such amendments on our Website.

It is therefore your responsibility to check our Website regularly for any amendments made to this Policy.

Governing Law

This Policy shall be governed by and interpreted in accordance with English law.