Privacy Policy

Please read this privacy policy carefully as it contains important information on how TreasurySpring Limited and the TreasurySpring group of companies (“TreasurySpring”, “we”, “us”, or “our”) collect, store, use and share your personal information in connection with your use of our website. It also explains your rights in relation to your personal data and how to contact us or a relevant regulator in the event you have a complaint.

TreasurySpring respects your privacy and is committed to protecting your personal data. We are the controller of personal data obtained via our website, meaning we are the organisation legally responsible for deciding how and for what purposes it is used.

What this policy applies to
This privacy policy relates to your use of our website only.

Throughout our website we may link to other websites owned and operated by certain trusted third parties. Those third party websites may also gather information about you in accordance with their own separate privacy policies. For privacy information relating to those third party websites, please consult their privacy policies as appropriate.

Personal data we collect
The personal data we collect about you depends on the particular activities carried out through our website. We currently collect and use personal data in the normal course of business, for example:

• you may provide us with your name, address and contact information, including email address, telephone number and company details submitted via our website or by email;
• your account details, such as username and login details; and
• when you visit our website, we collect information about how you use our website and technology systems.

How your personal data is collected
We collect personal data from you:

• directly, when you enter or send us information, such as when you register with us, contact us (including via email), send us feedback or request a product demo; and
• indirectly, such as your browsing activity while on our website; we will usually collect information indirectly by using cookies and other analytical technologies to help us improve your experience – please read our Cookies Policy to find out more.

How we use your personal data
We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:

• where you have given consent;
• where we need to perform the contract we are about to enter into or have entered into with you;
• where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests; and
• where we need to comply with a legal or regulatory obligation.

How and why we use your personal data – in more detail
We may use your personal information for the following purposes:

• to provide our services and respond to your enquiries;
• to administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data);
• to use data analytics to improve our website, products/services, marketing, client relationships and experiences; and
• for business development purposes.

Sharing your personal information
We may share your personal data with third parties we use to help us run our business, for example our administrators, website hosts and website analytics providers.

We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.

We or the third parties mentioned above occasionally also share personal data with:

• our and their external auditors, for example, in relation to the audit of our or their accounts, in which case the recipient of the information will be bound by confidentiality obligations;
• our and their professional advisors (such as lawyers and other advisors), in which case the recipient of the information will be bound by confidentiality obligations;
• law enforcement agencies, courts, tribunals and regulatory bodies to comply with legal and regulatory obligations; and
• other parties that have or may acquire control or ownership of our business (and our or their professional advisers) in connection with a significant corporate transaction or restructuring, including a merger, acquisition, asset sale, initial public offering or in the event of our insolvency – usually, information will be anonymised but this may not always be possible. The recipient of any of your personal data will be bound by confidentiality obligations.

It is sometimes necessary for us to transfer your personal data to countries outside the UK. Whenever we transfer your personal data out of the UK, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:

• we will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data;
• where we use certain service providers, we may use specific contracts approved for use in the UK which give personal data the same protection it has in the UK.

If you would like more information about who we share our data with and why, please contact us using the details set out under “Contact us” below.

Data security
We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.

We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

Data retention
We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.

To determine the appropriate retention period for personal data, we consider the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements.

Changes to this privacy policy
We may change this privacy policy from time to time. When we make significant changes we will take steps to inform you via our website.

This version was last updated on 21 April 2022.

Your data protection rights
Under certain circumstances, you have rights under data protection laws in relation to your personal data, as set out below:

• Your right of access – You have the right to ask us for copies of your personal information.
• Your right to rectification – You have the right to ask us to rectify personal information you think is inaccurate. You also have the right to ask us to complete information you think is incomplete.
• Your right to erasure – You have the right to ask us to erase your personal information in certain circumstances.
• Your right to restriction of processing – You have the right to ask us to restrict the processing of your personal information in certain circumstances.
• Your right to object to processing – You have the the right to object to the processing of your personal information in certain circumstances.
• Your right to data portability – You have the right to ask that we transfer the personal information you gave us to another organisation, or to you, in certain circumstances.

You are not required to pay any charge for exercising your rights. If you make a request, we will respond to you within one month.

Please contact us using the details set out under “Contact us” below if you wish to make a request.

Contact us
If you have any questions about this privacy policy or our privacy practices, please contact us by post, email or telephone using the contact details shown below:

Address: 84 Eccleston Square, London SW1V 1PX for the attention of Head of Legal

Email: legal@treasuryspring.com

Telephone: +44 (0)20 3948 1405

You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK regulator for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.

Do you need extra help?
If you would like this notice in another format (for example: audio, large print, braille) please contact us (see ‘Contact us’ above).