Last Updated 1st of August, 2019
1. Background Introduction and Contact:
Note, as used herein “Our Company”, “FixYourName”, “FixYourName.com”, “Us” or “We”, shall mean and/or refer Net Tech Dynamics, Inc. (dba: FixYourName), and other brands and companies within, or of Net Tech Dynamics, Inc., including but not limited to FixYourName.com. Group Companies shall mean and/or refer to; without limitations to FixYourName.com, parent companies, subsidiaries (if any), Social Media web presence(if any), etc. “Our Products”, or “Our Services” shall mean and/or refer to services, products and/or platforms offer directly from, or via Net Tech Dynamics, Inc. (dba: FixYourName).
2.2 Personal Data:
As Used herein, “Personal Data” shall mean data or information which may relate to any identified or identifiable natural person’s data, or from that data and other information which is in the possession of, or may likely come into the possession of Our Company, such as a name, an identification number, location data, an online identifier, or to one, or more factors specific to the social identity, economic, cultural, or physical, of You as a natural person.
2.3 What Personal Data May We Collect:
2.3 A FixYourName may store, process, and collect, Personal Data collected from You via Your use of Our Website, Service, Product and/or where You have given Your consent. This is in part as many of the Services offered by Us, require Us to obtain Personal Data about You in order to perform the Services We are to provide.
2.3 B This Personal Data that You provide to Us, may include contact details, copies of identification documentation provided by You or derived from publicly accessible databases, Your government identification number, as well as information relating to Your device(s), or internet service (such as an IP address and a MAC number). Note, the nature of the Services You are requesting will determine the kind of Personal Data We may ask for.
2.3 C As FixYourName may operate within the European Economic Area (“EEA”), FixYourName shall process, collect, and store Your personal information via the accordance of the provisions of the General Data Protection Regulation (“GDPR”) and Data Protection Act (“DPA”).
2.3 D Additionally note, We may collect information You provide Us during the onboarding process, or signup process, which may be a completed, incomplete, or abandoned process—data/information. We collect, use, store, and transfer Your Personal Data, which may include; without limitations for individuals or corporate Customer (by way of a non-exhaustive list) the following:
- Description of Your business, the applicable entity(ies).
- Full legal name of all ultimate beneficial owners (UBO’s), legal representatives, and directors of the applicable entity(ies).
- Mobile phone number of UBO(s), and/or for applicable individuals.
- Passport number, or any government issued ID number
- Date of birth (“DOB”)
- Full legal name (including former name, and names in local language)
- The applicable entitu(ies) registration/incorporation information
- Proof of residency
- Additional documentation or personal data at the sole discretion of FixYourName.
- Proof of identity (e.g. p government-issued ID, Passport, or driver’s license)
- Incorporation/registration Information
- Address of Residency
- Contact information of executive management, owners, UBOs, and principals
- Wealth Source (WS)
- Selfie photo(s)
- Address (principal place of business and/or other known physical locations)
- Proof of legal existence (if applicable)
- Email address personal and/or corporate
- Corporate legal name (including in local language)
- Percentage of ownership for UBOs/Individuals/Trusts/Corporate owners
- Proof of identity (e.g., government-issued ID, passport, or driver’s license) for significant individual beneficial owner of the institutional customer/entity.
- Personal Data for each entity’s significant beneficial owner of the institutional customer/entity.
3. Information We Obtain from Other Sources:
FixYourName may work with third-parties, including other group companies, Our Customers, and data providers as required by applicable law & regulations for the purposes of Anti-Money Laundering (AML) and Know-Your -Customer (KYC), and this may include accessing the electoral roll and reviewing credit histories.
Please read FixYourName complete policy on cookies, for such see Cookies page located at the bottom/footer of Our WebPages: www.FixYourName.com. Should you have difficulty accessing the Cookies content, email us at InfoGB@FixYourName.com and we shall provide said content, per your request.
5. Anonymised Data:
In addition to Personal Data described categories, FixYourName may also process further anonymised data and information that is and/or may not be processed by reference to a specific individual.
6. Collection and Transfer of Data Outside the EEA:
As noted, FixYourName may collect Personal Data from Users/Customers located in the EEA in order to facilitate Our Services. As such DT request explicit consent for the transfer of Personal Data from the EEA to outside of the area. If a User /Customer is an individual located in the EEA and decline to consent to such transfer, said individual will no longer be able to Use Our Services. In such event, User shall not use Our Services or visit Our Website.
7. How We May Use Your Personal Data:
FixYourName shall Use Personal Data in order to communicate with administer(s) and User, in order to possibly improve, deliver, and personalize the Service We may offer. FixYourName may additionally generate generic data (GGD) out of any Personal Data We Use and collect, and Use said data for Our proprietary purposes or to facilitate with third party services and/or independent contractors. We may additionally Use said data to communicate with Customers in relation, to other Services and/or products offered by, or via FixYourName and Group Companies, and/or its partners. We do not share Your Personal Data with third parties (other than partners, third-parties, or independent contractors in connection with their Services to, or via FixYourName) except where You have given Your consent and further detailed below.
We may share Your Personal Data with third parties:
- If We think that sharing it is necessary to enforce the Terms;
- In order to allow You to access and Use the provided functionality by Our Products/Services;
- In order to assess Your application or applicability for Our Products/Services, where applicable;
- To conduct required analysis in order to detect malicious data and understand how this may affect IT systems;
- To understand feedback on Our Products/Services and to help provide more information on the Use of those Services and Products in an efficient and timely manner;
- To communicate with Customer as to providing information, Services or information about Services or about Our Company, Website(s), Group Companies and/or Our Products;
- In order to comply with and in order to assess compliance with applicable jurisdictional regulations laws and rules, as well as internal policies and procedures;
- For the maintenance and administration of databases storing Personal Data;
- To third parties who provide Services to FixYourName(such as, independent contractors or agents, administration or technical Services;
- To market Our Products to You, which herein will be done with Your consent;
- In connection with the sale or transfer of Our business or any part thereof;
- We may share Your Personal Data within Group Companies for the purposes described above;
- In order to perform its contractual obligations with Customers, third parties and agents;
- We have obtained Your , or Your repetitive’s, or agent’s consent;
- We have regulatory and/or legal obligations that We are to discharge;
- If We deem necessary in order to establish, exercise or defend Our legal rights or for the purpose of legal Disputes, claims, controversies and/or legal proceedings;
- The Use of Your Personal Data as described is necessary for Our legitimate business interests, such as, but not limited to allowing Us to efficiently and effectively administer and/or manage the operation of Our business;
- In order to maintaining compliance with internal policies and procedures;
- In order to monitoring the use of Our trademarked and/or copyrighted materials;
- In order to enabling greater access to information on Our Products/Services;
- In order to offer up-to-date security solutions for mobile devices and IT systems;
- In order obtaining further knowledge of current threats to network security, with regard to the possibility of updating Our security solutions and provide these to the market; and
- In order to best implemented global standards in order to better prevent terrorist financing, money laundering and circumventing trade and economic sanctions, as well as Our implementation of U.S.A. regulatory requirements, which may require Us to undertake Due-Diligence(DD) on Our Customers. This may include, without limitations, the use of third-party data and Service Providers which We will cross-reference with Your personal information in order to conduct DD processing.
FixYourName may additionally share Your Personal Data outside of Our Group Companies, purposes may also include the following:
- With third party contractors and agents to the purposes of providing Services to Us (for example, professional advisors, Our accountants, IT and communications providers, Servicers, Payment Processors, and debt collectors, etc. ). These third parties will be subject to appropriate data protection obligations;
- With Our business partners. As an example this may include Our partners from whom You or Your company or Your organization purchased/have used Our Product(s). Personal Data will only be transferred to a Business Partner(s) who is contractually obliged to comply with appropriate data protection obligations, and the relevant privacy and confidentiality legislation(s);
- To the extent required by applicable jurisdictional law(s), as an example, if We are under a jurisdictional duty to disclose Your Personal Data in order to lawfully comply with any legal obligation (including, without limitations, in order to comply with tax reporting requirements, be it civil or criminal, and disclosures to regulators), or to exercise, establish, or defend its legal rights;
- If we sell, transfer, or relinquish Our business or any applicable assets, in which case We may need to disclose Your Personal Data to the prospective buyer(s)/inherit new owner(s), for due diligence purposes; and
- If We are acquired by a third party, in which case the Personal Data held by Us about You will be disclosed to the third party buyer(s), for the purpose of DD, and marketable asset evaluations, but not limited to such.
8. International Transfers of Personal Data:
- Our’s is a international brand and business. As such, Our operations and business are spread around the world. As a result, We transfer and collect Personal Data on a global basis. The result is, We may transfer Your Personal Data to locations outside of Your home
- Where We transfer Your Personal Data to another country outside the EEA, We shall ensure that it is protected and transferred in a manner consistent with legal requirements. In relation to data being transferred outside of Europe, this may be done in one of the following ways:
- The recipient may have signed up to a contract based on the model contractual clauses (“MCC”) approved by the European Commission, obliging them to protect Your Personal Data;
- The country that We send the data to may be approved by the European Commission as offering an adequate level of protection for Personal Data, such as the United States;
- Where the recipient is located in the United States, it might be a certified member of the EU-US Privacy Shield scheme; or
- In other circumstances the law, may permit Us to otherwise transfer Your Personal Data outside Europe.
9. Storing of Personal Data:
9.1 The Personal Data that We may collect from Customers and Website visitors/Users may be transferred to, and stored at, a destination(s) outside of the EU. It may also be processed by staff operating outside of the EU who may perform work for FixYourName and/or for one of Our suppliers, independent contractors, partners and/or Service Providers. By submitting Your personal data, You acknowledge, understand and agree to this processing, transfers, and storing; without applicable limitations. The information You provide to Us is stored on Our and/or third party cloud servers and/or networks.
9.2 There are extensive controls in place to maintain the security of Our information and information systems. Customer digital-files are protected with safeguards according to the sensitivity of the relevant information. Appropriate controls (such as high restricted access) are in placed on Our computer systems. Physical access to areas where Personal Data is gathered, processed or stored is limited to authorized personal only.
9.3 As a condition of employment, Our employees are required to follow all applicable laws and regulations, including in relation to Data Protection law. Unauthorised Use or disclosure of confidential client information by a company employee/personal is prohibited and may result in disciplinary measures or immediate termination.
10. How Long We May Keep Your Personal Data:
10.1 The length of time We will retain Your Personal Data, may vary and may be determined by the following criteria(s):
- The multi-purpose for which We are Using it – We will keep the data for as long as it is necessary for that correlating and/or sub-correlating purpose(s); and
- The legal obligations – regulation and/or jurisdictional laws that may collectively set a minimum or maximum period(s), for which We must keep Your Personal Data.
11. Access, Corrections, and Deletions of Your Personal Data:
11.1 Customers have the right to obtain a copy of their Personal Data upon duly verified request and ascertain whether the information We hold about said Customer is up-to-date and accurate. If any of the Personal Data is deemed inaccurate, Customer may request to update Your information. Customer may also request to delete their Personal Data, with the exceptions of, in the case(s) We reference herein, the use of Personal Data and in regards to the deletion request provisions —In certain circumstances, such as proprietary compliance procedures, jurisdictional compliance with law(s), or other legal purposes, or remedies. For data deletion, access, or correction requests, please contact InfoGB@FixYourName.com. Please include a subject line of “DATA INQUIRY”.
11.2 Note in responding to such “Data Inquiry” data access, correction, or deletion request, We will duly verify the requesting party’s identity in order to best ensure he, she, or authorized personnel of “It”, with the case of a corporate entity, is legally entitled to make such request. Although in the future We aim to respond to these requests free of charge, We reserve the right to charge You a reasonable fee for such request, as third party Services may be involved; thus a certain cost may be applied to Us.
12. Marketing and Communications:
13. Designated Contact Representative(s):
Our Company’s registered office and/or Website may be contacted using the contact information located in the “Contact Us” web page of Our Website.