iiPay Privacy & Terms

This Privacy Policy sets out how we, Integrated International Payroll Limited (iiPay), collect, store and use information about you when you use or interact with our website, iipay.flywheelstaging.com (our website) and where we otherwise obtain or collect information about you.

This section summarises how we obtain, store and use information about you. It is intended to provide a very general overview only. It is not complete in and of itself and it must be read in conjunction with the corresponding full sections of this Privacy Policy.

• Data Controller: Integrated International Payroll Limited and Integrated International Payroll LLC (we also act as a “Data Processor” on behalf of our clients when we provide them with payroll services)
• How we collect or obtain information about you:
  • when you provide it to us (e.g. by contacting us or by completing online contact forms)
  • from your use of our website, using cookies, and
  • from third parties (e.g. our clients, in order to provide payroll services).
• Information we collect: name, contact details, IP address, information from cookies, information about your computer or device (e.g. device and browser type), information about how you use our website (e.g. which pages you have viewed), the time when you view them and what you clicked on, the geographical location from which you accessed our website (based on your IP address), company name or business name (if applicable), job title, email address and home country.
• How we use your information: for administrative and business purposes (particularly to contact you, to improve our business and website, to fulfil our contractual obligations, to advertise our services, to analyse your use of our website, and in connection with our legal rights and obligations.
• Disclosure of your information to third parties: only to the extent necessary to run our business, to our service providers, and where required by law or to enforce our legal rights.
• Do we sell your information to third parties (other than in the course of a business sale or purchase or similar event)? No.
• How long we retain your information: for no longer than necessary, taking into account any legal obligations we have (e.g. to maintain records for tax purposes), any other legal basis we have for using your information (e.g. your consent, performance of a contract with you or our legitimate interests as a business). For specific retention periods in relation to certain information which we collect from you, please see the main section below entitled How long we retain your information.
• How we secure your information: using appropriate technical and organisational measures such as storing your information on secure servers, encrypting transfers of data to or from our servers using Secure Sockets Layer (SSL) technology, only granting access to your information where necessary and encryption of your personal data.
• Use of cookies: we use cookies on our website including necessary, preferences, statistics and marketing cookies. For more information, please refer to our Cookie Declaration.
• Transfers of your information outside the European Economic Area: in certain circumstances (including those set out later in this Privacy Policy) we transfer your information outside of the European Economic Area. Where we do so, we will ensure appropriate safeguards are in place, including:
  • an adequacy decision by the European Commission – this is permitted under Article 45(1) of the General Data Protection Regulation
  • Standard Contractual Clauses (SCCs) – approved by the European Commission and the UK Information Commissioner – this is permitted under Article 46(2)(c) of the General Data Protection Regulation and Article 46(2)(d) of the General Data Protection Regulation, and
• Use of automated decision making and profiling: we do not use automated decision making. We use profiling on our website. We do not consider that this has any legal effect on you or significantly affects you.
• Your rights in relation to your information
  • to access your information and to receive information about its use
  • to have your information corrected and/or completed
  • to have your information deleted
  • to restrict the use of your information
  • to receive your information in a portable format
  • to object to the use of your information
  • to withdraw your consent (where we are relying on your consent) to the use of your information
  • to complain to a supervisory authority
• Sensitive personal information: we do not knowingly or intentionally collect what is commonly referred to as “sensitive personal information” in the course of your use or interaction with our website or otherwise. We might however be supplied with “sensitive personal information” by our clients, in order to properly fulfil our contractual obligations in relation to the provision of payroll services. For more information, please see the main section below entitled Sensitive Personal Information.

We are Integrated International Payroll Limited (company registration number: 04920388) of Festival House, Jessop Avenue, 2nd Floor, Cheltenham, GL50 3SH, United Kingdom and Integrated International Payroll LLC of 12700 Park Central Suite 1910 Dallas, Texas 75251, United States. You can contact us by writing to:

Integrated International Payroll Limited
2nd Floor, Festival House
Jessop Avenue
Cheltenham
GL50 3SH
United Kingdom

or sending an email to TheDataController@iiPay.com.
If you have any questions about this Privacy Policy, please contact us.
Integrated International Payroll Limited is the representative of Integrated International Payroll LLC for the purpose of Article 27 of the General Data Protection Regulation (Representatives of controllers or processors not established in the Union).

We collect and use information about you in accordance with this section and the section entitled Disclosure and additional uses of your information.

4.1 Web server log information

We use a third-party hosting provider to host our website. Our website server may automatically log the IP address you use to access our website as well as other information about your visit such as the pages accessed, information requested, the date and time of the request, the source of your access to our website (e.g. the website or URL (link) which referred you to our website), and your browser version and operating system.

Our server is located in the United States and, accordingly, your information is transferred outside the European Economic Area (EEA). For further information and information on the safeguards used, please see the section of this privacy policy entitled Transfers of your information outside the European Economic Area.

4.2 Use of website server log information for IT security purposes

Our third-party hosting provider collect(s) and store(s) server logs to ensure network and IT security and so that the server and website remain uncompromised. This includes analysing log files to help identify and prevent unauthorised access to our network, the distribution of malicious code, denial of services attacks and other cyber-attacks, by detecting unusual or suspicious activity.

Unless our third-party hosting provider are investigating suspicious or potentially criminal activity, we do not make, nor do we allow our hosting provider to make, any attempt to identify you from the information collected via server logs.

Legal basis for processing: compliance with a legal obligation to which we are subject (Article 6(1)(c) of the General Data Protection Regulation).

Legal obligation: we have a legal obligation to implement appropriate technical and organisational measures to ensure a level of security appropriate to the risk of our processing of information about individuals. Recording access to our website using server log files is such a measure.

Legal basis for processing: our and a third party’s legitimate interest (Article 6(1)(f) of the General Data Protection Regulation).

Legitimate interests: we and our third-party hosting provider have a legitimate interest in using your information for the purposes of ensuring network and information security.

4.3 Use of website server log information to analyse website use and improve our website

We use the information collected by our website server logs to analyse how our website users interact with our website and its features. For example, we analyse the numbers of visits and unique visitors we receive, the time and date of the visit, the location of the visit and the operating system and browser used.

We use the information gathered from the analysis of this information to improve our website. For example, we use the information gathered to change the information, content and structure of our website and individual pages based according to what users are engaging most with and the duration of time spent on particular pages on our website.

Legal basis for processing: our legitimate interests (Article 6(1)(f) of the General Data Protection Regulation).

Legitimate interest: improving our website for our website users and getting to know our website users’ preferences so our website can better meet their needs and desires.

4.4 Cookies

Cookies are data files which are sent from a website to a browser to record information about users for various purposes.

We use cookies on our website, including necessary, preferences, statistics and marketing cookies cookies. For further information on how we use cookies, please see our Cookie Declaration.

You can, at any time, change or withdraw your consent from the Cookie Declaration on our website.

We collect and use information from individuals who contact us in accordance with this section and the section entitled Disclosure and additional uses of your information.

5.1 Email

When you send an email to us we collect your email address and any other information you provide in that email (such as your name, telephone number, the contents of that email and the information contained in any signature block in your email).

Legal basis for processing: our legitimate interests (Article 6(1)(f) of the General Data Protection Regulation).

Legitimate interest(s): responding to enquiries and messages we receive, taking steps to enter into contracts or managing and administering our contracts with customers, and keeping records of correspondence.

5.2 Transfer and storage of your information

We use a third-party email provider to store emails you send us.

Emails you send us will be stored within the European Economic Area on third-party email provider’s servers, located in the United Kingdom.

5.3 Contact form

When you contact us using our contact form, we collect your name, company name or business name (if applicable), contact details, job title, home country and number of countries within which your company operates. We also collect any other information you provide to us when you complete the contract form, including information such as number of international employees and services we provide that you are interested in.

If you do not provide the mandatory information required by our contact form, you will not be able to submit the contact form and we will not receive your enquiry.

Legal basis for processing: our legitimate interests (Article 6(1)(f) of the General Data Protection Regulation).

Legitimate interest(s): responding to enquiries and messages we receive, taking steps to enter into contracts or managing and administering our contracts with customers, and keeping records of correspondence.

5.4 Transfer and storage of your information

We use a third party service provider in relation to our contact forms. Messages you send us via our contact form will be stored inside and outside the European Economic Areas on their servers, located in Ireland and United States.

For further information about the safeguards used when your information is transferred outside the European economic Area, see the section of this privacy policy below entitled Transfer of your information outside the European Economic Area.

5.5 Phone

When you contact us by phone, we will collect your phone number and any information provided to us during your conversation with us.

We do not record phone calls.

Legal basis for processing: our legitimate interests (Article 6(1)(f) of the General Data Protection Regulation).
Legitimate interest(s): responding to enquiries and messages we receive, taking steps to enter into contracts or managing and administering our contracts with customers, and keeping records of correspondence.

5.6 Transfer and storage of your information

Information about your call, such as your phone number and the date and time of your call, is processed by our third-party telephone service provider.

Information about your phone call will be stored by our third-party telephone service provider within and outside of European Economic Area, including United States, Germany and Netherlands.

For further information about the safeguards used when your information is transferred outside the European economic Area, see the section of this privacy policy below entitled Transfer of your information outside the European Economic Area.

5.7 Post

If you contact us by post, we will collect any information you provide to us in any postal communications you send us.

Legal basis for processing: our legitimate interests (Article 6(1)(f) of the General Data Protection Regulation).
Legitimate interest(s): responding to enquiries and messages we receive, taking steps to enter into contracts or managing and administering our contracts with customers, and keeping records of correspondence.

We collect and use information from individuals who interact with particular features of our website in accordance with this section and the section entitled Disclosure and additional uses of your information.

6.1 E-Newsletter

When you sign up for our e-newsletter on our website or opt to receive news from us by subscribing to our blog (through submitting your email address), we collect your email address.

Legal basis for processing: your consent (Article 6(1)(a) of the General Data Protection Regulation).
Consent: you give your consent to us sending you our e-newsletter by signing up to receive it using the steps described above.

6.2 Transfer and storage of your information

We use a third-party service to send out our e-newsletter and administer our mailing list.

Information you submit to subscribe for our e-newsletter will be stored within and outside of European Economic Area third party servers, located in Ireland and United States.

For further information about the safeguards used when your information is transferred outside the European economic Area, see the section of this privacy policy below entitled Transfer of your information outside the European Economic Area.

6.3 Use of web beacons in emails

We use technologies such as web beacons (small graphic files) in the emails we send to allow us to assess the level of engagement our emails receive by measuring information such as the delivery rates, open rates and click through rates which our emails achieve.

Legal basis for processing: our legitimate interests (Article 6(1)(f) of the General Data Protection Regulation).
Legitimate interest(s): reviewing and analysing our email communications and getting to know our email recipients’ preferences so our emails can better meet their needs and desires.

This section sets out how we obtain or collect information about you from third parties.

7.1 Information received from third parties

We do receive information about you from third parties. The third parties from which we receive information about you will generally include our clients (in order to properly fulfil our contractual obligations in relation to the provision of payroll services), affiliates or business partners.

It is also possible that third parties with whom we have had no prior contact may provide us with information about you.

Information we obtain from third parties will generally be your name and contact details, but will include any additional information about you, including sensitive personal information which they provide us (sensitive personal information is generally only provided in relation to employees of our clients, in order to properly fulfil our contractual obligations in relation to the provision of payroll services, in which case we act as a Data Processor).

Legal basis for processing: consent (Article 6(1)(a) of the General Data Protection Regulation).
Consent: in some circumstances, you may have asked a third party to share information about you with us (usually where the purpose of sharing that information is not related to the performance of a contract or services by us to you, or related to our legitimate interests), in those circumstances, we will process your information on the basis of your consent.

Legal basis for processing: our legitimate interests (Article 6(1)(f) of the General Data Protection Regulation).
Legitimate interests: where a third party has shared information about you with us, we may process that information as necessary for the purposes of our legitimate interests in carrying out our contracts with our customers, administering and managing our business, and protecting and enforcing our legal rights.

For example, we would have a legitimate interest in processing your information to perform our obligations under a sub-contract with the third party, where the third party has the main contract with you. Our legitimate interest is the performance of our obligations under our sub-contract.

Similarly, third parties may pass on information about you to us if you have infringed or potentially infringed any of our legal rights. In this case, we will have a legitimate interest in processing that information to investigate and pursue any such potential infringement.

7.2 Where we receive information about you in error

If we receive information about you from a third party in error and/or we do not have a legal basis for processing that information, we will delete your information.

7.3 Information obtained by us from third parties

In certain circumstances (for example, to verify the information we hold about you or obtain missing information we require to provide you with a service) we will obtain information about you from certain publicly accessible sources, both EU and non-EU, such as the electoral register, Companies House, online customer databases, business directories, media publications, social media and websites (including your own website if you have one).

Legal basis for processing: our legitimate interests (Article 6(1)(f) of the General Data Protection Regulation).
Legitimate interests: in certain circumstances, we will have a legitimate interest in obtaining information about you from public and private sources as necessary for the purposes of our legitimate interests in carrying out our contracts with our customers, administering and managing our business, and protecting and enforcing our legal rights.

For example, if you have infringed or we suspect that you have infringed any of our legal rights, we will have a legitimate interest in obtaining and processing information about you from such sources in order to investigate and pursue any suspected or potential infringement.

For example, we would obtain and/or verify your email address from your website or from a directory where you ask us to send you information by email but we do not possess the information or we need to confirm that we have recorded your email address correctly.

Legal basis for processing: consent (Article 6(1)(a) of the General Data Protection Regulation).

Consent: we may obtain information from third parties, such as data brokers, where you have consented to them sharing information with us, e.g. by ticking a box stating that you would like your information to be shared with us.

We use profiling on our website. We do not consider that this has any legal effect on you or significantly affects you. You can at any time change or withdraw your consent from the Cookie Declaration on our website.

You can find out more about our use of cookies in our Cookie Declaration.

8.1 Profiling

Profiling is any form of automated processing of your information to evaluate personal aspects about you, in particular to analyse or predict things like your personal preferences, interests or location.

8.2 Use of profiling for web analytics

Our web analytics services use and collects information such as your location (based on your IP address) and your behaviour (based on cookies) when you access our website (such as the pages you visit and what you click on).

Logic involved: by automatically analysing and categorising information such as the location (based on IP address) as well as the behaviour and devices of visitors to our website (using cookies), we are able to gain a better understanding of what our website visitors want (in terms of the content of our website), how to improve our website and how to advertise and market our services to them.

Significant and envisaged consequences: cookies will be used to track and store information about your behaviour and device on our website and your location will be analysed based on your IP address. We may target advertisements based on the level of interest we receive from certain visitors and their behaviour on our website.

Legal basis for processing: our legitimate interests (Article 6(1)(f) of the General Data Protection Regulation).

Legitimate interest: improving our website for our website users, getting to know our website users’ preferences so our website can better meet their needs and desires and to ensure any advertising we conduct is directed at the most suitable recipients.

8.3 Use of profiling in marketing emails

We use web beacons in our marketing emails to analyse who opens our emails and what actions they take (for example, what they click on).

Logic involved: by analysing how our email recipients respond to our marketing emails, we are able to improve the content and effectiveness of our emails and gauge who is most interested.

Significance and envisaged consequences: your behaviour when you open our emails will be tracked using small gif files (web beacons), including, i.e. open rates and click through rates.

Legal basis for processing: our legitimate interests (Article 6(1)(f) of the General Data Protection Regulation).
Legitimate interest(s): reviewing and analysing our email communications and getting to know our email recipients’ preferences so our emails can better meet their needs and desires.

How to object: if you wish to object, please contact us.

This section sets out the circumstances in which will disclose information about you to third parties and any additional purposes for which we use your information.

9.1 Disclosure of your information to service providers

We use a number of third parties to provide us with services which are necessary to run our business or to assist us with running our business and who process your information on our behalf. These include the following:

• Telephone provider(s)
• Email provider(s)
• IT service provider(s)
• Web developer(s), and
• Hosting provider(s).

Our third-party service providers are located in the United Kingdom, Ireland, Germany, Netherlands and United States.

Your information will be shared with these service providers where necessary to provide you with our services or taking steps at your request prior to providing you with our services, or in course of accessing our website.

We do not display the identities of all of our service providers publicly by name for security and commercial reasons. If you would like further information about the identities of our service providers, however, please contact us directly (please refer to section entitled Our details) and we will provide you with such information where you have a legitimate reason for requesting it (where we have shared your information with such service providers, for example).

Legal basis for processing: legitimate interests (Article 6(1)(f) of the General Data Protection Regulation).
Legitimate interest relied on: we will share your information with such third parties where it is necessary to perform contracts with our customers, and in order to allow us to run and manage our business efficiently.

9.2 Disclosure of your information to other third parties

We disclose your information to other third parties in specific circumstances, as set out below.

Providing information to third parties such as Google Inc. Google collects information through our use of Google Analytics on our website. Google uses this information for a number of purposes, such as improving its Google Analytics service. Information is shared with Google on an aggregated and pseudonymised basis. To find out more about what information Google collects, how it uses this information and how to control the information sent to Google, please see the following page: https://www.google.com/policies/privacy/partners/.

Legal basis for processing: our legitimate interests (Article 6(1)(f) of the General Data Protection Regulation).
Legitimate interest(s): meeting our contractual obligations to Google under our Google Analytics Terms of Service (https://www.google.com/analytics/terms/us.html)

You can opt out of Google Analytics by installing the browser plugin here:  https://tools.google.com/dlpage/gaoptout

9.3 Transfer and storage of your information

Information collected by Google Analytics is stored outside the European Economic Area on Google’s servers in the United States.

For further information about the safeguards used when your information is transferred outside the European Economic Area, see the section of this privacy policy below entitled Transfers of your information outside the European Economic Area.

Sharing your information with third parties, which are either related to or associated with the running of our business, where it is necessary for us to do so. These third parties include our accountants, advisors, affiliates, business partners, independent contractors and insurers. Further information on each of these third parties is set out below.

Legal basis for processing: our legitimate interests (Article 6(1)(f) of the General Data Protection Regulation).
Legitimate interest: running and managing our business efficiently.

9.4 Auditors

We share information with our auditors for financial and other audit purposes. Our auditors are located in United Kingdom and United States.

9.5 Advisors

Occasionally, we obtain advice from advisors, such as accountants, financial advisors, lawyers and public relations professionals. We will share your information with these third parties only where it is necessary to enable these third parties to be able to provide us with the relevant advice.

Our advisors are located in United Kingdom and United States.

9.6 Affiliates

Affiliates are individuals or entities we work with to promote our business by various means, including by advertising our services on their website, for example, Affiliates will share information with us and we will share information with them where you have expressed an interest in our services.

Our affiliates are located in United Kingdom and United States.

9.7 Business partners (including In Country Partners)

Business partners (including In Country Partners) are businesses we work with which provide goods and services which are complementary to our own or which allow us to provide services which we could not provide on our own. We share information with our business partners (including In Country Partners) where you have requested services which they provide whether independently from, or in connection with our own services.

Our business partners (including In Country Partners) are located within and outside of European Economic Area.

9.8 Independent contractors

Occasionally, we use independent contractors in our business. Your information will be shared with independent contractors only where it is necessary for them to perform the function we have hired them to perform in relation to our business, and they will be subject to strict security and confidentiality requirements.

Our independent contractors are located in European Union and United States.

9.9 Insurers

We will share your information with our insurers where it is necessary to do so, for example in relation to a claim or potential claim we receive or make or under our general disclosure obligations under our insurance contract with them.

Our insurers are located in United Kingdom and United States.

Sharing your information within our business’ group of companies for internal administrative purposes, including client, customer and employee information.

Legal basis for processing: our legitimate interests (Article 6(1)(f) of the General Data Protection Regulation).

Legitimate interest: where it is necessary to perform contracts with our customers, obtaining relevant advice, running and managing our business effectively.

We do not display the identities of all of the other third parties we may share information with by name for security and commercial reasons. If you would like further information about the identities of such third parties, however, please contact us directly (please refer to section entitled Our details) and we will provide you with such information where you have a legitimate reason for requesting it (where we have shared your information with such third parties, for example).

We may also share your information with a prospective or actual purchaser or seller in the context of a business or asset sale or acquisition by us, a merger or similar business combination event, whether actual or potential. This will generally relate to negotiations or due diligence exercises. Information will only be shared prior to any sale to the extent necessary, and will always be subject to security and confidentiality obligations.

Legal basis for processing: legitimate interests (Article 6(1)(f) of the General Data Protection Regulation).
Legitimate interest(s): sharing your information with a prospective purchaser, seller or similar person in order to allow such a transaction to take place.

9.10 Disclosure and use of your information for legal reasons

Indicating possible criminal acts or threats to public security to a competent authority

If we suspect that criminal or potential criminal conduct has been occurred, we will in certain circumstances need to contact an appropriate authority, such as the police. This could be the case, for instance, if we suspect that fraud or a cyber-crime has been committed or if we receive threats or malicious communications towards us or third parties.

We will generally only need to process your information for this purpose if you were involved or affected by such an incident in some way.

Legal basis for processing: our legitimate interests (Article 6(1)(f) of the General Data Protection Regulation).
Legitimate interests: preventing crime or suspected criminal activity (such as fraud).

9.11 In connection with the enforcement or potential enforcement our legal rights

We will use your information in connection with the enforcement or potential enforcement of our legal rights, including, for example, sharing information with debt collection agencies if you do not pay amounts owed to us when you are contractually obliged to do so. Our legal rights may be contractual (where we have entered into a contract with you or your employer) or non-contractual (such as legal rights that we have under copyright law).

Legal basis for processing: our legitimate interests (Article 6(1)(f) of the General Data Protection Regulation).
Legitimate interest: enforcing our legal rights and taking steps to enforce our legal rights.

9.12 In connection with a legal or potential legal dispute or proceedings

We may need to use your information if we are involved in a dispute with you or a third party for example, either to resolve the dispute or as part of any mediation, arbitration or court resolution or similar process.

Legal basis for processing: our legitimate interests (Article 6(1)(f) of the General Data Protection Regulation).
Legitimate interest(s): resolving disputes and potential disputes.

9.13 For ongoing compliance with laws, regulations and other legal requirements

We will use and process your information in order to comply with legal obligations to which we are subject. For example, we may need to disclose your information pursuant to a court order or subpoena if we receive one or to National Crime Agency in connection with suspected or potential money laundering matters.

Legal basis for processing: compliance with a legal obligation (Article 6(1)(c) of the General Data Protection Regulation).

Legal obligation(s): legal obligations to disclose information under UK or EU law (or another EU member state country’s laws to which we are subject).

Legal basis for processing: our legitimate interests (Article 6(1)(f) of the General Data Protection Regulation).

Legitimate interest: where the legal obligations are not under UK or EU law (or another EU member state country’s laws to which we are subject), we have a legitimate interest in complying with these obligations.

This section sets out how long we retain your information. We have set out specific retention periods where possible. Where that has not been possible, we have set out the criteria we use to determine the retention period.

10.1 Retention periods

Server log information: 7 days.

Correspondence and enquiries: when you make an enquiry or correspond with us for any reason, whether by email, via our contact form or by phone, we will retain your information for as long as it takes to respond to and resolve your enquiry, and for:

• Maximum 7 years from the date the information is collected
• Maximum 7 years from the date of the performance of the contract
• 7 years for VAT records from the performance of the contract, and
• 6 months for the contacts that have not made any engagement with our outreach under normal circumstances.

E-Newsletter: we retain the information you used to sign up for our e-newsletter for as long as you remain subscribed (i.e. you do not unsubscribe) or if we decide to cancel our e-newsletter service, whichever comes earlier. When you unsubscribe, we retain your information on an “unsubscribe list” to ensure we don’t accidentally send you any further newsletters.

Any other categories of data: personal data, including sensitive personal information provided to us by our clients will be retained for the duration of the contract. On the completion of the contract:

• if we act as a “Data Processor” of any information, we will delete or return that information at our customer’s instruction; or
• if we act as a “Data Controller” of that information, we will keep it for no longer than necessary, as dictated by relevant statutes of limitation.

Please refer to our Cookie Declaration for the information about the retention of cookies.

10.2 Criteria for determining retention periods

In any other circumstances, we will retain your information for no longer than necessary, and as dictated by relevant statutes of limitation.

We take appropriate technical and organisational measures to secure your information and to protect it against unauthorised or unlawful use and accidental loss or destruction, including:

• only sharing and providing access to your information to the minimum extent necessary, subject to confidentiality restrictions where appropriate, and on an anonymised basis wherever possible;
• using secure servers to store your information;
• verifying the identity of any individual who requests access to information prior to granting them access to information;
• using Secure Sockets Layer (SSL) software to encrypt any information you submit to us via any forms on our website; and
• only transferring your information via closed system or encrypted data transfers.

11.1 Transmission of information to us by email

Transmission of information over the internet is not entirely secure, and if you submit any information to us over the internet (whether by email, via our website or any other means), you do so entirely at your own risk.

We cannot be responsible for any costs, expenses, loss of profits, harm or reputation, damages, liabilities or any other form of loss or damage suffered by you as a result of your decision to transmit information to us by such means.

Your information will be stored in the following European Economic Area (EEA) countries: United Kingdom, Ireland, Netherlands and Germany.

Where required, your information will be transferred and stored outside the European Economic Area (EEA) in the circumstances set out below. We will also transfer your information outside the EEA or to an international organisation in order to comply with legal obligations to which we are subject (compliance with a court order, for example). Where we are required to do so, we will ensure appropriate safeguards and protections are in place.

12.1 Server log information

Information collected when you visit our website is transferred outside of the EEA and stored on the servers of our third party hosting company.

Country of storage: United States. This country is not subject to an adequacy decision by the European Commission.

Safeguard(s) used: Our third party contact form provider has self-certified its compliance with the EU-U.S. Privacy Shield however Privacy Shield is no longer a valid mechanism for data transfers from the EU but still serves as a blueprint towards meeting GDPR obligations. Standard Contractual Clauses (SCCs) also used as the valid mechanism to lawfully transfer personal data.

12.2 Contact form

Information you submit to us via our contact form is transferred outside the EEA and stored on our third party contact form provider’s servers.

Country of storage: United States. This country is not subject to an adequacy decision by the European Commission.

Safeguard(s) used: Our third party contact form provider has self-certified its compliance with the EU-U.S. Privacy Shield however Privacy Shield is no longer a valid mechanism for data transfers from the EU but still serves as a blueprint towards meeting GDPR obligations. Standard Contractual Clauses (SCCs) also used as the valid mechanism to lawfully transfer personal data.

12.3 E-Newsletter

Information you submit to us when you sign up for our e-newsletter is transferred outside the EEA and stored on our third party mailing list provider’s server.

Country of storage: United States. This country is not subject to an adequacy decision by the European Commission.

Safeguard(s) used: Our third party contact form provider has self-certified its compliance with the EU-U.S. Privacy Shield however Privacy Shield is no longer a valid mechanism for data transfers from the EU but still serves as a blueprint towards meeting GDPR obligations. Standard Contractual Clauses (SCCs) also used as the valid mechanism to lawfully transfer personal data.

12.3 Google Analytics

Information collected by Google Analytics  is transferred outside of EEA and stored on Google’s servers. You can access Google’s privacy policy here: https://www.google.com/policies/privacy.

Country of storage: United States. This country is not subject to an adequacy decision by the European Commission.

Safeguard(s) used: Our third party contact form provider has self-certified its compliance with the EU-U.S. Privacy Shield however Privacy Shield is no longer a valid mechanism for data transfers from the EU but still serves as a blueprint towards meeting GDPR obligations. Standard Contractual Clauses (SCCs) also used as the valid mechanism to lawfully transfer personal data.

12.4 Service providers

We use a number of third parties to provide us with services which are necessary to run our business or to assist us with running our business and who process your information for us on your behalf. These include the following:

• Telephone provider(s)
• Email provider(s)
• IT service provider(s)
• Web developer(s)
• In Country Partners, and
• Hosting provider(s).

Information shared with service providers may be transferred outside the EEA and stored on third party servers.

Country of storage: Our third-party service providers are located in the United Kingdom, Ireland, Germany, Netherlands and United States.

In relation to In Country Providers, these could be anywhere in the world and may not be subject to an adequacy decision by the European Commission.

United States are not subject to an adequacy decision by the European Commission.

Safeguard(s) used: Where information is transferred to United States, our third party contact form provider has self-certified its compliance with the EU-U.S. Privacy Shield however Privacy Shield is no longer a valid mechanism for data transfers from the EU but still serves as a blueprint towards meeting GDPR obligations. Standard Contractual Clauses (SCCs) also used as the valid mechanism to lawfully transfer personal data.

Subject to certain limitations on certain rights, you have the following rights in relation to your information, which you can exercise by writing to: Integrated International Payroll Limited, 2^nd Floor, Festival House, Jessop Avenue, Cheltenham, GL50 3SH, United Kingdom or sending an email to TheDataController@iiPay.com:

• to request access to your information and information related to our use of processing of your information;
• to request the correction or deletion of your information;
• to request that we restrict our use of your information;
• to receive information which you have provided to us in a structured, commonly used and machine-readable format (e.g. a CSV file) and the right to have that information transferred to another data controller (including a third party data controller);
• to object to the processing of your information for certain purposes (for further information, see section below entitled Your right to object to the processing of your information for certain purposes); and
• to withdraw your consent to our use of your information at any time where we rely on your consent to use or process that information. Please note that if you withdraw your consent, this will not affect the lawfulness of our use and processing of your information on the basis of your consent before the point in time when you withdraw your consent.

In accordance with Article 77 of the General Data Protection Regulation, you also have the right to lodge a complaint with a supervisory authority, in particular the Member State of your habitual residence, place of work or of an alleged infringement of the General Data Protection Regulation.

For the purpose of the UK, the supervisory authority is the Information Commissioner’s Office (ICO), the contact details of which are available here: https://ico.org.uk/global/contact-us/.

12.5 Further information on your rights in relation to your personal data as an individual

The above rights are provided in summary form only and certain limitations apply to many of these rights. For further information about your rights in relation to your information, including any limitations which apply, please visit the following pages on the ICO’s website:

• https://ico.org.uk/for-organisations/guide-to-the-general-data-protection-regulation-gdpr/individual-rights/; and
• https://ico.org.uk/for-the-public/is-my-information-being-handled-correctly/

You can also find out further information about your rights, as well as information on any limitations which apply to those rights, by reading the underlying legislation contained in Articles 12 to 22 and 34 of the General Data Protection Regulation, which is available here: http://ec.europa.eu/justice/data-protection/reform/files/regulation_oj_en.pdf.

12.6 Verifying your identity where you request access to your information

Where you request access to your information, we are required by law to use all reasonable measures to verify your identity before doing so.

These measures are designed to protect your information and to reduce the risk of identity fraud, identity theft or general unauthorised access to your information.

How we verify your identity

Where we possess appropriate information about you on file, we will attempt to verify your identity using that information.

If it is not possible to identify you from such information, or if we have insufficient information about you, we may require original or certified copies of certain documentation in order to be able to verify your identity before we are able to provide you with access to your information.

We will be able to confirm the precise information we require to verify your identity in your specific circumstances if and when you make such a request.

You have the following rights in relation to your information, which you may exercise in the same way as you may exercise by writing to Integrated International Payroll Limited, 2^nd Floor, Festival House, Jessop Avenue, Cheltenham, GL50 3SH, United Kingdom or sending an email to TheDataController@iiPay.com:

• To object to us using or processing your information where we use or process it in order to carry out a task in the public interest or for our legitimate interests, based on any of these purpose; and
• To object to us using or processing your information for direct marketing purposes (including any profiling we engage in that is related to such direct marketing).

You may also exercise your right to object to us using or processing your information for direct marketing purposes by:

• clicking the unsubscribe link contained at the bottom of any marketing email we send to you and following the instructions which appear in your browser following your clicking on that link;
• sending an email to info@iipay.com, asking that we stop sending you marketing communications or by including the words “OPT OUT”.

For more information on how to object to our use of information collected from cookies and similar technologies, please refer to our cookies policy.

“Sensitive personal information” is information about an individual that reveals their racial or ethnic origin, political opinions, religious or philosophical beliefs, or trade union membership, genetic information, biometric information for the purpose of uniquely identifying an individual, information concerning health or information concerning a natural person’s sex life or sexual orientation.

As it applies to web server log information, e-mail, contact form, phone, post or e-newsletter, we do not knowingly or intentionally collect sensitive personal information from individuals, and you must not submit sensitive personal information to us.

If, however, you inadvertently or intentionally transmit sensitive personal information to us, you will be considered to have manifestly made that information public to us under Article 9(2)(e) of the General Data Protection Regulation. Where we have identified that sensitive personal information has been provided, we will use and process your sensitive personal information for the purpose of deleting it.

14.1 iiPay clients and their employees

Information we obtain from our clients will generally be limited to that necessary to fulfil our obligations in relation to the provision of payroll services, however in some cases, such information may include sensitive personal information. As information requirements to facilitate payroll processing will vary greatly from country to country, in all cases, use of such information will be only for the purpose of iiPay’s provision of payroll services.

Legal basis for processing: our legitimate interests (Article 6(1)(f) of the General Data Protection Regulation).

Legitimate interest: where a client has passed on information about you to us (such as information necessary to fulfil our obligations in relation to the provision of payroll services, including sensitive personal information, in which case we act as a Data Processor) in order for us to provide services to the client, we will process your information in order to perform a contract with the client.

We update and amend our Privacy Policy from time to time.

15.1 Minor changes to our Privacy Policy

Where we make minor changes to our Privacy Policy, we will update our Privacy Policy with a new effective date stated at the beginning of it. Our processing of your information will be governed by the practices set out in that new version of the Privacy policy from its effective date onwards.

15.2 Major changes to our Privacy policy or the purposes for which we process your information

Where we make major changes to our Privacy Policy or intended to use your information for a new purpose or a different purpose than the purposes for which we originally collected it, we will notify you by email (where possible) or by posting a notice on our website.

We will provide you with the information about the changes in question and the purpose and any other relevant information before we use your information for that new purpose.

Wherever required, we will obtain your prior consent before using your information for a purpose that is different from the purpose for which we originally collected it.