Privacy policy
Legal Information
Borderless Payroll ("we," "us," or "our") is committed to protecting the privacy and security of your personal information. This Privacy Policy explains how we collect, use, disclose, and protect your data when you use our recruitment and hiring services. We comply with the General Data Protection Regulation (GDPR) and other relevant data protection laws applicable in the United Kingdom.
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Borderless (UK)
4th Floor, 18 St Cross Street,
London, England, EC1N 8UN
Represented by Raymond Reed
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Contact details: info@borderlesspayroll.com
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DATA PROTECTION PRINCIPLES
We will comply with data protection laws. This means that the personal information we hold about you must be:
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Used lawfully, fairly and transparently.
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Collected only for valid purposes that we have clearly explained to you and not used in any way that is incompatible with those purposes.
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Relevant to the purposes we have told you about and limited only to those purposes.
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Accurate and kept up to date.
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Kept only as long as necessary for the purposes we have told you about.
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Kept securely.
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Information we collect
Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).
We may collect, use, store and transfer different kinds of personal data about you, which we have grouped together as follows:
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Identity Data includes first name, maiden name, last name, username or similar identifier, marital status, title, date of birth and gender
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Socio-demographic includes details about your work or profession, nationality and any immigration information, including Biometric Residence Permits, share codes and European Settlement Status or Pre-Settlement Status
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Contact Data email address, telephone numbers, address details
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Documentary data includes details about you that are stored in documents in different formats or copies. This includes identity documentation such as passport and proof of address
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Transaction Data includes details about payments from you and other details of services you have purchased from us
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Contract Details about the services we provide to you and services you provide to your clients
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Usage Data includes data about how you use our services
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Financial payments made or received by you and your company, your bank details, credit card information
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Open data and public records include details about you that are in public records and information about you that is openly available on the internet
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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 our website and portal
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Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties, your communication preferences, information you provide to us in emails, letters and over the phone
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Calls may be recorded for training and quality purposes.
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Where we must gather special categories of personal data, we will only do so when we have a lawful basis
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How we will use your personal information
We will only use your personal information when the law allows us to. Most commonly, we will use your personal information in the following circumstances:
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Where we need to perform the contract we are about to enter into or have entered into with you
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Where it is necessary for our legitimate interests
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Where we need to comply with our legal obligations
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Where you have consented to it
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A legitimate interest is when we have a business or commercial reason to use your information. But even then, it must not unfairly go against what is right and best for you. If we rely on our legitimate interest, we will tell you what that is.
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Below is a list of all the ways in which we may use your data and the basis upon which we rely. We have also specified what our legitimate interests are if we rely on this basis.
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Purpose/Activity
1. To register you as a new client
2. To conduct identity and any other necessary Anti-Money Laundering (“AML”) checks on you
3. To deliver our services
4. To make and manage payments due to us by you
5. To manage fees, charges and interest due on your accounts
6. To collect and recover money that is owed to us
7. To develop new ways to meet your needs
8. To develop and carry out marketing activities
9. To study how you use our services
10. To provide advice or guidance about our services
11. To improve our service offering
12. To respond and deal with complaints
13. To contact you within 12 months of you terminating or failing to use our services with offers and proposed services for you to re-engage with us.
14. To develop and manage our business and services
15. To test new service offerings
16. To manage how we work with other companies that provide services to us and our clients
17. To make recommendations and suggestions to you about services that may be of interest to you, including communicating to you about services that our supplier companies provide and those of our external business partners.
18. To analyse any data we hold on you to understand your interests and preferences.
19. To detect, investigate, report, and seek to prevent financial crime
20. To manage risk for us and our clients
21. To obey laws and regulations that apply to us
22. To run our business efficiently and properly to protect our business
23. To send your contact details to external business partners who offer services that may be relevant to you
Marketing
We may use your personal information to tell you about relevant products and services that we think may be of interest to you. We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising.
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We can only use your personal information to send you marketing messages if we have either your consent (which we will ask for via an opt-in or soft opt-in) or legitimate interest. A legitimate interest is when we have a business or commercial reason to use your information, taking into consideration your interests. A soft opt-in query is a specific type of consent that applies when we have previously provided services to you, and we are marketing other related services.
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Marketing and Third Parties
If you have consented to receive marketing emails, you can withdraw this at any time. In certain circumstances we may share your personal data with third parties for client satisfaction reviews. If we are relying on our legitimate interests to send you marketing or client satisfaction reviews, you can object. We will only provide third parties with the information they need to know to perform their specific services.
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You can ask us or third parties to stop sending you marketing messages at any time by logging into the website and checking or unchecking relevant boxes to adjust your marketing preferences or by following the opt-out links on any marketing message sent to you, or by contacting us at any time. You can also email the marketing team directly: marketing@borderlesspayroll.com
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Change of purpose
We will only use your personal data for the purposes for which we collected it unless we reasonably consider that we need to use it for another reason, and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.
If we need to use your personal data for an unrelated purpose, we will notify you and explain the legal basis for doing so.
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Please note that we may process your personal data without your knowledge or consent in compliance with the above rules where this is required or permitted by law.
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Who do we share your personal data with?
We may have to share your personal data with the third parties set out below for the purposes set out in the table above (“How we will use your personal information”)
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Companies within the Borderless Payroll group of companies as part of our regular reporting activities on company performance, for system maintenance support and hosting of data, and when you request to receive services or information about any of our other entities in our Group
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Supplier companies and specific employer of record providers that we partner with
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Internal staff who help support and administer our services
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Companies House, HMRC, regulators and other authorities
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Our auditors and external business professionals and lawyers conducting our FCSA annual review
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Fraud prevention agencies
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Credit reference agencies
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Organisations that introduce you to us
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Organisations that we introduce you to
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Companies you ask us to share your data with
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Any party that we have partnered with to offer you services you may be interested in
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If you choose a service package which offers insurance, we may pass your personal or business details on the insurance broker, insurer or reinsurer
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Our insurance broker and insurers if you make a claim or we notify them in respect of a claim or potential claim concerning you
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Third parties to whom we may choose to sell, transfer, or merge parts of our business or our 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
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Third-party service providers (including contractors and designated agents). The following activities are carried out by third-party service providers: employer of record service provision, IT and marketing services including use of cookies and trackers, accounting services and use of accounting software
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We require all third parties to respect the security of your personal data and 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 it for specified purposes and in accordance with our instructions.
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How long will you use my personal data?
We will only retain your personal data for as long as necessary to fulfil the purposes for which we collected it, including satisfying any legal, accounting, insurance, contractual, or reporting requirements.
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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 requirements.
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In some circumstances, we may anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes in which case we may use this information indefinitely without further notice to you.
Your legal rights
Under certain circumstances, you have rights under data protection laws in relation to your personal information:
Access to your personal information
You are entitled to make a data subject access request to receive a copy of the personal data we hold about you. We may need to verify your identity before we provide this.
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Please note that 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 may refuse to comply with your request in these circumstances.
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Request correction of personal information
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.
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Request the erasure of your personal information
This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your 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.
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Object to processing of your personal data
This is where we are relying on a legitimate interest (or those of a third party), and something about your particular situation makes you want to object to processing on this ground as you feel it impacts your fundamental rights and freedoms. You also have the right to object when we are processing your data for direct marketing purposes. In some cases, we may demonstrate that we have legitimate grounds to process your information, which overrides your rights and freedoms.
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Request restriction of processing your personal data
This enables you to ask us to suspend the processing of your data in the following scenarios: (a) if you want us to establish the data's accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) 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; or (d) you have objected to our use of your data but we need to verify whether we have to override legitimate grounds to use it.
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Request transfer of your personal data
We will provide to you, or a third party you have chosen, your data in a 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.
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Right to withdraw consent
You have a right to withdraw your consent at any time. 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 services to you. We will advise you if this is the case when you withdraw your consent.
We try to respond to all legitimate requests within one month. Occasionally, it may take us longer than a month if your request is particularly complex or you have made several requests. In this case, we will notify you and keep you updated.
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DATA TEAM
We have appointed a Data Team to oversee compliance with this privacy notice. If you have any questions about this privacy notice or how we handle your personal information, please contact the Data Team by emailing data@borderlesspayroll.com. You 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.
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CHANGES TO THIS PRIVACY NOTICE
We reserve the right to update this privacy notice at any time and will provide you with a new one when we make any substantial updates. We may also notify you in other ways from time to time about the processing of your personal information.
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Contact us
For inquiries or requests, please contact us.