Privacy notice

Last updated: 14 July 2023

This privacy notice (“Privacy Notice”) sets out how Pactio Technologies Limited (“Pactio”, “us”, “our” and “we”) collects and processes your personal data.

Your privacy is a priority for us at Pactio, and we are committed to protecting your personal data. We process your personal data when you access https://pactio.io and its sub-domains (the “Website”), use our associated software services (the “Services”), or have other business interactions with our team.

We recommend reading this Privacy Notice in full to understand how we use your personal data. If you prefer, you can skip to specific sections using the table of contents below.

Table of contents

1. Important information & who we are

2. Your legal rights

3. Data we collect about you

4. How we collect your personal data

5. How we use your personal data

6. What we do with your personal data

7. How we protect your personal data

8. How we share your personal data

9. How long we keep your personal data

10. Third-party links

11. Children’s privacy

1. Important information & who we are

Controller

This Privacy Notice applies to personal data which Pactio processes as a controller when you visit our Website, use our Services, or interact with us. "Personal data" refers to any information about an individual from which that person can be identified (excluding anonymised data).

We may also process certain personal data on behalf of an organisation (a “Subscriber”) using our Services. In this context, Pactio acts as a processor, and the Subscriber is the controller.

Questions about how such data is processed should be directed to the Subscriber.

Changes to this Privacy Notice

We keep this Privacy Notice under regular review. Changes will be posted on the Website and dated accordingly. Significant changes may be highlighted separately.

You may request historical versions by emailing dataprotection@pactio.io.

Your duty to inform us of changes

Please let us know if your personal data changes during your relationship with us.

Other privacy notices

Additional privacy notices may apply in specific cases. This Privacy Notice supplements those notices.

Contact details

Email: dataprotection@pactio.io

You have the right to lodge a complaint with the Information Commissioner’s Office (ICO) (www.ico.org.uk), though we encourage you to contact us first.

EU data subjects

For EU data subjects, our representative is Rickert Rechtsanwaltsgesellschaft mbH.
Contact them by emailing art-27-rep-pactio@rickert.law or writing to:
Rickert Rechtsanwaltsgesellschaft mbH (Pactio), Colmantstraße 15, 53115 Bonn, Germany.

2. Your legal rights

You have rights regarding your personal data, including:

• Requesting access, correction, or erasure of your data

• Restricting or objecting to processing

• Requesting data transfer

• Withdrawing consent where processing relies on consent

Requests are generally handled within one month. We may require identity verification for security purposes.

3. Data we collect about you

We may collect:

• Identity data (e.g., full name, date of birth, employment details)

• Contact data (e.g., email, telephone number)

• Marketing and communications data (e.g., preferences)

• Profile data (e.g., user ID, password, feedback)

• Technical data (e.g., IP address, browser type)

• Transactional data (e.g., details of transactions and actions on our platform)

• Usage data (e.g., how you interact with our Website and Services)

We do not ordinarily collect special categories of personal data or data about criminal convictions.

4. How we collect your personal data

We collect data through:

• Direct interactions (e.g., account creation, feedback)

• Automated technologies (e.g., cookies – see our Cookie Notice)

• Third parties and publicly available sources (e.g., Subscribers, business contacts)

5. How we use your personal data

We use your data only when legally permitted, primarily based on:

• Legitimate interests (e.g., operating and improving our Services)

• Compliance with legal obligations

We obtain your consent separately for direct marketing communications.

6. What we do with your personal data

We process your data for purposes such as:

If we change the purpose for using your data, we will explain the basis to you.

Marketing

We may use your data for marketing where permitted. You can opt out at any time.

7. How we protect your personal data

We implement technical and organisational measures to safeguard your data. Only those with a business need-to-know have access.

Procedures are in place to handle potential breaches.

8. How we share your personal data

We may share data with:

• Service providers (e.g., IT services)

• Professional advisers (e.g., legal, insurance)

• Regulators and authorities (e.g., HMRC)

When sharing, we ensure appropriate safeguards and obligations are in place.

International transfers

Where data is transferred outside the UK/EEA (e.g., to the USA), we use appropriate safeguards like Standard Contractual Clauses.

9. How long we keep your personal data

We retain your data only as long as necessary for the purposes outlined, considering factors like:

• The amount and sensitivity of the data

• The risk of harm

• Legal, regulatory, and tax requirements

10. Third-party links

Our Website may contain links to third-party websites. We are not responsible for their privacy practices. Please review their privacy notices before providing any personal data.

11. Children’s privacy

Our Website and Services are intended for adults (18+).
We do not knowingly collect data from children under 18. If you believe we have, please contact us.

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