Finity
Privacy Policy2025-01-13T13:26:46+00:00

Privacy Policy

We take your privacy seriously. Read our policy below.

Last updated: January 2025

This notice applies across all websites that we own and operate and all services we provide.

When we say ‘personal data’ we mean identifiable information about you, like your name, email, address, telephone number, bank account details, support queries and so on. If you can’t be personally identified (for example, when personal data has been aggregated and anonymised) then this notice doesn’t apply.

Check out our terms of use for more information on how we treat your other data.

We may need to update this notice from time to time. Where a change is significant, we’ll make sure we let you know – usually by sending you an email. You can read the whole notice below.

Who are ‘we’?

When we refer to ‘we’ (or ‘our’ or ‘us’), that means Finity Management Limited (trading as ‘Finity’) and any of its wholly owned subsidiaries or brands. Our headquarters are in the United Kingdom (UK), but we have a workforce operating from other parts of the world.

We provide recruitment back office solutions. If you want to find out more about what we do, see the ‘About us’ section of our website.

For European Union (EU) data protection purposes, when we act as a controller in relation to your personal data, Finity Management Limited (company number 15557668) are the representative in the EU.

Our data protection principles

At Finity, we pride ourselves on operating with transparency, integrity and security. Our approach to data protection is built around three key principles, which sit at the heart of our approach to your personal data.

More information is available in the subsequent sections, but this means we will be open and honest about how we process your data, working with you to keep accurate records and ensuring we take the appropriate steps to safeguard your personal data.

The data we collect about you2025-01-03T23:41:10+00:00

We may collect, use, store and transfer different kinds of personal data about you that we have grouped together as follows:

  • Identity Data includes first name, last name, username or similar identifier, title, date of birth and gender. This could include photographs of forms of identification and proof of address.
  • Contact Data includes billing address, email address and telephone numbers.
  • Financial Data (which may include bank account details).
  • Transaction Data includes details about payments to and from you and other details of products and services you have purchased from us.
  • Technical Data includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, and other technology on the devices you use to access this website.
  • Profile Data includes your username and password, your transactions, your user preferences, feedback and survey responses.
  • Usage Data includes information about how you use our website, products and services.
  • Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.
  • Rewards Data includes information about rewards you have collected with us and details of redemption of rewards.

We may also collect personal data about you from publicly available sources for the purposes of completing our anti-money laundering and know-your-customer (KYC) checks.

We also collect, use and share Aggregated Data (such as statistical or demographic data) for any purpose. Aggregated Data could be derived from your personal data, but is not considered personal data in law, as this data will not directly or indirectly reveal your identity.

We do not collect any special categories of personal data about you (such as details about your race or ethnicity, religious or philosophical beliefs, sexual orientation, political opinions, trade union membership, information about your health, and genetic and biometric data). Nor do we collect any information about criminal convictions and offences.

How we collect your data2025-01-03T23:43:37+00:00

When visiting our website or using our services, we sometimes need to collect personal data. How this is collected can be generally classified as follows:

  • Information you provide to us directly: when visiting or using some aspects of our website and/or services we might ask you to give personal data. As an example, we ask for your contact information when you sign up for a free trial, join us on social media, partake in training, contact us with queries or use our technical support service. If you do not want to provide us with personal data, you do not have to, but it might mean you cannot use certain parts of our website or services.
  • Information we collect automatically: we sometimes collect certain information about you automatically when visiting our website or using our services. As an example, we may need to collect your IP address and device type (desktop, mobile and so on). We also collect information when you navigate through our website and services, including what pages you looked at and what links you clicked on. This information is useful for us as it helps us get a better understanding of how users are utilising our website and services so that we can continue to provide the best experience possible (e.g., by personalising the content you see). Some of this information will be collected via cookies or similar tracking technologies. More information regarding the types of cookies we use, why, and how you can control them is available upon request.
  • Information we get from third parties: most of the information we collect should be obtained directly from you. Occasionally we will need to collect personal data about you from other sources beyond our own website and services, such as publicly available materials or via trusted third parties. Any information gathered from these sources is simply to supplement the personal data we already hold about you, in order to better inform, personalise and improve our services.

Where your personal data is not collected, there is a risk that we may not be able to provide to you some or all of our services; this includes – but is not limited to – certain functionality in our systems or website features being unavailable.

Lawful basis for processing2025-01-03T17:57:28+00:00

Where your personal data is collected, this will only be processed:

  • Contractual obligation – Where processing is necessary to comply with our obligations arising out of a contract, for example, taking payment.
  • Legitimate Interest– Where we use legitimate interests, we will record our decision on making this decision. We rely on legitimate interest where processing of the data we hold on about you does not, in our opinion, affect your rights or freedoms and is proportionate to our interests e.g. obtaining your feedback on our service.
  • Consent– We will seek to obtain your consent to process your personal data outside our contractual obligations (see above) unless we have identified a Legitimate Interest (see above).

If we do not have an existing relationship with you, but you believe that Finity may be holding your personal data (for example an existing customer has entered this into our website or services), then you will need to contact that Finity customer regarding your personal data; including – but not limited to – your rights to access, update, amend or delete your personal data.

How your data may be used2025-01-03T17:58:17+00:00

We may use your personal data to operate our website and any other services you have requested; this includes our ability to manage the relationship with you. We also use your personal data for other purposes, which may include the following:

  • Communicating with you: share information you have requested from us, operating notifications (e.g. security alerts), marketing communications you have signed up to receive and so on;
  • Supporting you: assistance with support queries, technical issue resolution (both with our website and services);
  • Improving our website and services: tracking usage to optimise the experience;
  • Protecting you: ensuring data integrity and no malicious activity;
How your data may be shared2025-01-03T17:59:08+00:00

There may be occasions where we need to share your personal data with third parties. We will only disclose your personal data to:

  • third party service providers and/or partners that assist and enable Finity to use the personal data – for example, technical support resolution, KYC service providers, rewards providers, or a payment provider;
  • regulators, law enforcement bodies, government agencies, courts or other third parties where we think it might be necessary to comply with applicable laws or regulations, or to exercise, establish or defend our legal rights. Where possible and appropriate, we will notify you of this type of disclosure;
  • other people or entities where we have your prior consent.

We may also share personal data with third parties to whom we may choose to sell, transfer or merge parts of our business or assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy notice.

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.

Data transfer (outside your country of residence)

When your data gets shared, this may be distributed to, and processed in, countries other than the country in which you reside. For example, payment processing by a third-party software provider.

Please know that where personal data needs to be distributed to a third-party outside of your country of residence, we have in place safeguards (e.g. encryption) to ensure this data remains protected.

If you are in the European Economic Area (EEA), for the avoidance of doubt, the above means that from time-to-time, data may be distributed to a country outside of the EEA. However, measures have been taken to identify – in advance of any such distribution of your data – to ensure that those non-EEA countries have sufficient protection in place. Where third parties are involved, appropriate additional steps have been taken to preserve the integrity of your personal data, i.e., by entering into the European Commission’s Standard Contractual Clauses with these companies. If you have any queries or require any clarifications, please do reach out to the Finity team using the details listed on the ‘Contact’ page of the website (see final section of this document).

Data security

Security is one of our Board’s top priorities, especially with individual’s personal data. At Finity, we are dedicated to protecting your personal data and have appropriate technical and internal measures in place to make sure that happens. This includes Finity being ISO27001 certified since 2023.

All information you provide to us via email, or our website is stored on our secure servers. Where we have given you (or where you have chosen) a password which enables you to access certain parts of our website, you are responsible for keeping this password confidential. We ask you not to share a password with anyone. When you enter sensitive information (such as bank account information) on our order forms, we process this through a secure third-party platform. We follow generally accepted standards to protect the personal data submitted to us, both during transmission and once we receive it. No method of transmission over the Internet, or method of electronic storage, is 100% secure, however. Therefore, we cannot guarantee its absolute security.

Some payments made to us are processed by GoCardless, which conforms to the highest level of security – please see here for more details. GoCardless has been audited by a PCI-certified auditor and is certified to PCI Service Provider Level 1. This is the most stringent level of certification available in the payments industry.

We use recognised and accredited third parties to perform regular penetration tests of our platform and internal networks across our offices. Any output is reviewed and prioritised with high importance.

Third party security

Like many businesses, we use certain third‑parties to support the services we provide to our users. We constantly review the security and suitability of any third parties as part of our ongoing processes. 

Staff training

Our employees are required to undertake cybersecurity awareness training and also acknowledge that they will be compliant with internal security processes across hardware and software. These are reviewed and updated regularly.

Retention policy

By law we must keep basic information about our customers (including Contact, Identity, Financial and Transaction Data) for three years after they cease being customers. Otherwise, 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 more than six years 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.

Details of retention periods for different aspects of your personal data are available in our retention policy which you can request from us by contacting us at the details below.

In some circumstances you can ask us to delete your data: see your legal rights below for further information.

Know your rights

At Finity, we believe that your personal data ultimately belongs to you, and that you have certain rights relating to it. When it comes to marketing communications, you can ask us not to send you these at any time – just follow the opt-out link included in all marketing communications from us, or send us a request to info@finity.co.uk to unsubscribe.

You have further rights under data protection laws in relation to your personal data (though please note that your rights may be limited under certain circumstances). For example, you may have the right to:

  • Request access to your personal data (commonly known as a “data subject access request”). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
  • Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
  • Request erasure of your personal data. This enables you to ask us to delete personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons, which will be notified to you, if applicable, at the time of your request.
  • Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
  • Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios:
    • If you want us to establish the data’s accuracy.
    • Where our use of the data is unlawful, but you do not want us to erase it.
    • Where you need us to hold the data even if we no longer require it, as you need it to establish, exercise or defend legal claims.
    • You have objected to our use of your data, but we need to verify whether we have overriding legitimate grounds to use it.
  • Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use, or where we used the information to perform a contract with you.
  • Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.

If you wish to exercise any of the rights set out above, please contact us using the details provided in this notice.

You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we could refuse to comply with your request in these circumstances.

We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

We try to respond to all legitimate requests within one month. Occasionally it could take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.

Cookies

You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of this website may become inaccessible or not function properly.

What is a cookie?

A ‘cookie’ is a type of data file that is stored on your device when you visit a website or perform actions while visiting a website. A cookie file contains information that is transferred to your device’s memory which is recalled when you revisit our site, or when you perform certain actions on your device. Where we refer to a cookie in this policy, this incorporates similar tracking technologies.

Necessary Cookies

When you first visit our website, we only use necessary cookies. This means that additional cookies (called “Optional Cookies” in this policy) won’t be used unless you agree to accept/enable all cookies or select your own cookie preferences.

Optional Cookies

Optional cookies are used for analytical, performance, advanced functionality and advertising purposes. More information is set out in this policy. Optional cookies help us improve our website and we believe accepting all optional cookies provides you with the best user experience.

Cookies can be “First Party”, i.e. set by us, or “Third Party”, i.e. placed on your device by another organisation when you visit our website. Third-party cookies may be placed on your device by an organisation providing a service to us or by our business partners, so that they can advertise products and services to you on our website and elsewhere on the internet. Because of how cookies work, our website cannot access third-party cookies stored from other websites; nor can other organisations access the data in the cookies we use on our website.

Changing your preferences

You can select to accept/enable some or all of the optional cookies either within the settings of your own device or by selecting the option provided on our website.

How long will cookies stay on my device?

The length of time a cookie will stay on your computer or mobile device depends on whether it is a “persistent” or “session” cookie. Session cookies should expire when you stop browsing. Persistent cookies stay on your device until they expire after a set period or are deleted. For each of the cookies used on our website we have set out the duration in the tables below.

Cookie List

A cookie is a small piece of data (text file) that a website – when visited by a user – asks your browser to store on your device in order to remember information about you, such as your language preference or login information. Those cookies are set by us and called first-party cookies. We also use third-party cookies – which are cookies from a domain different than the domain of the website you are visiting – for our advertising and marketing efforts.

More specifically, we use cookies and other tracking technologies for the following purposes:

Strictly Necessary Cookies

These cookies are necessary for the website to function and cannot be switched off in our systems. They are usually only set in response to actions made by you which amount to a request for services, such as setting your privacy preferences, logging in or filling in forms. You can set your browser to block or alert you about these cookies, but some parts of the site will not then work. These cookies do not store any personally identifiable information.

Cookie Sub-group Cookies Cookies Used
finity.co.uk finity First party
support.finity.co.uk intercom-id, intercom-session, intercom-device-id First party
hubspot.com __hs_opt_out First party
vimeo.com player, vuid Third party
cloudflare.com __cf_bm Third party
recaptcha.net _grecaptcha, rc::a, rc::f Third party

 

Performance Cookies

These cookies allow us to count visits and traffic sources so we can measure and improve the performance of our site. They help us to know which pages are the most and least popular and see how visitors move around the site. All information these cookies collect is aggregated and therefore anonymous. If you do not allow these cookies we will not know when you have visited our site and will not be able to monitor its performance.

Cookie Sub-group Cookies Cookies Used
Hotjar _hjSession, _hjCookieTest, _hjLocalStorageTest, _hjSessionStorageTest, _hjTLDTest First party
Google Analytics _ga_#, _ga First party
Google AdSense _gcl_au First party
HubSpot __ptq.gif Third party

 

Functional Cookies

These cookies enable the website to provide enhanced functionality and personalisation. They may be set by us or by third party providers whose services we have added to our pages. If you do not allow these cookies then some or all of these services may not function properly.

Cookie Sub-group Cookies Cookies Used
HubSpot _cfruid, _cfuvid, _cf_bm First party
Connected third-party services

Third party privacy notices will apply in respect of integrated services which collect data, namely:

Third-party links

This website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements or their handling of your data. When you leave our website, we encourage you to read the privacy notice of the websites you visit.

Contacting the Finity team

We are always happy to hear from you.

If you would like to know what personal data we may hold about you, or should you have any general enquiries, feedback or would like to discuss our website and/or services in more detail, then do reach out to the Finity team.

Our preferred communication method is via email. This helps us ensure your message is always assigned to the right people. You can reach us on info@finity.co.uk.

You also have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk) (and to the EDPS supervisory for European complaints).

We would, however, appreciate the chance to deal with your concerns before you approach the ICO (or EDPS), so please contact us in the first instance.

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