Privacy Policy
Data Collection
my-iWallet undertakes to collect Your Data by means
that are:
- fair;
- legal; and
- transparent.
If you visit my-iWallet's web-site,
your web-browser automatically discloses, and my-iWallet's web-server
automatically logs, the following information: the date and time,
the IP address from which you issued the request, the type of browser
and operating system you are using, the URL of any page that referred
you to the page, the URL you requested, and whether your request
was successful. This data may or may not be sufficient to identify
you.
Any additional data that you provide, e.g. in a web-form,
may also be logged. This data may or may not be sufficient to
identify you.
Any additional data that your web-browser automatically
provides may also be logged. This will be the case,
for example, if your browser has previously been requested
to store data on your computer in 'cookies' and
submits them each time you request a web-page within a particular
domain (such as my-iWallet.com). This data may or may not
be sufficient to identify you.
If you disclose personal data to my-iWallet in conjunction
with an identifier such as your name or your credit-card details,
my-iWallet will collect Your Data. Moreover, any data that
becomes available to my-iWallet through any of the means
described in the preceding paragraphs may be able to be associated
with that identifier, and hence become Your Data.
Subject to the qualifications immediately below, my-iWallet undertakes
to collect Your Data from you and not from other
parties. This undertaking is qualified as follows:
- where my-iWallet reasonably considers that the protection of
its financial interests requires that it gather YourData from other
sources, or from additional sources. This applies in particular
where my-iWallet has a lending exposure to you, and seeks information
about your creditworthiness;
- where my-iWallet reasonably considers that its capability to
deliver quality services to you will be materially enhanced by
gathering YourData from other sources. This applies in particular
to consumer profile data.
Where my-iWallet collects Your Data from
sources other than you, it undertakes:
- to do so only by legal means;
- to do so only with your Consent; and
- to declare to you what sources it uses, and under what circumstances.
my-iWallet undertakes to declare the purpose
of collection in a manner which is clear and meaningful,
and to avoid vague, highly inclusive statements such as 'to support
our operations'.
Data Security
my-iWallet undertakes to store Your
Data in a manner that ensures security against unauthorised access,
alteration or deletion, at a level commensurate with its sensitivity.
my-iWallet undertakes to store Your Data only in jurisdictions where
data protections are at least equivalent to those required under
the OECD Guidelines.
my-iWallet undertakes to transmit Your Data in
a manner that ensures security against unauthorised access, alteration
or deletion, at a level commensurate with its sensitivity.
my-iWallet undertakes to implement appropriate measures
to ensure security of Your Data against inappropriate behaviour by
my-iWallet's staff-members and contractors. These include:
- training for staff in relation to privacy;
- access control, to limit access to Your Data to those staff and
contractors who have legitimate reasons to access it;
- particularly in the case of sensitive data, audit trails of accesses,
including the identities of staff and contractors accessing the
data;
- reminders to staff and contractors from time to time about the
importance of data privacy, and the consequences of inappropriate
behaviour;
- declaration of appropriately strong sanctions that are to be
applied in the event of inappropriate behaviour
- clear communication of policies and sanctions; and
- processes to audit, to investigate and to impose sanctions.
Data Use
Use refers to the application of Your Data by any
part of my-iWallet, or any staff-member or contractor of my-iWallet
in the course of their work.
my-iWallet undertakes to use Your Data only for:
- the purposes for which it was collected;
- such other purposes as are subsequently agreed between
my-iWallet and You;
- such additional purposes as may be required by law.
In these circumstances, my-iWallet will take any reasonable steps
available to it to communicate to You that the use has occurred,
unless it is precluded from doing so by law; and
- such additional purposes as are authorised by law (in
particular to protect my-iWallet's interests, e.g. if it believes
on reasonable grounds that You have failed to fulfil your undertakings
to my-iWallet or have committed a breach of the criminal law).
my-iWallet undertakes to use YourData only if it
has demonstrable relevance to the particular use
to which it is being put.
my-iWallet undertakes to use YourData in such a manner as to take
into account the possibility that it is not of sufficient
quality for the purpose, e.g. because it is inaccurate,
out-of-date, incomplete, or out-of-context.
Data Disclosure
Disclosure refers to making YourData available to
any party other than my-iWallet and You. The term disclosure may
include many different conditions of data transfer, including selling,
renting, trading, sharing and giving.
my-iWallet undertakes to disclose Your Data only under the following
circumstances:
- in the course of business being conducted between You
and my-iWallet, where disclosure is necessary to a
contractor, such as a transport company. Where Your Data is disclosed
in this way, my-iWallet undertakes to exercise control over
my-iWallet's contractors to ensure that their actions are compliant
with these Terms;
- in other circumstances that are directly implied by the
purpose agreed between You and my-iWallet at the time
of data collection or subsequently. Where Your Data is disclosed
in this way, my-iWallet undertakes to exercise control over
my-iWallet's contractors to ensure that their actions are compliant
with these Terms;
- with your consent, or at your request;
- where required by law, such as a provision of
a statute, or a court order such as a search warrant or sub poena.
In these circumstances, my-iWallet will take any reasonable steps
available to it to communicate to You that the disclosure has occurred,
unless it is precluded from doing so by law;
- where permitted by law (e.g. the reporting of
suspected breach of the criminal law to a law enforcement agency;
and in an emergency, where my-iWallet believes on reasonable
grounds that the disclosure of YourData will materially assist
in the protection of the life of health of some person), provided
that my-iWallet will apply due diligence to ensure that the exercise
of the permission is justifiable.
In all cases, my-iWallet undertakes to disclose
only such of Your Data as is necessary in the particular circumstances.
Data Retention and Destruction
Subject to the qualifications immediately below,
my-iWallet undertakes:
- to retain Your Data only as long as is consistent
with its purpose; and
- to destroy Your Data when its purpose has expired,
and to do so in such a manner that Your Data is not subsequently
capable of being recovered.
This undertaking is qualified as follows:
- Your Data may be retained in my-iWallet's logs, backups
and audit trails within short-term retention cycles
that are devised to protect the company's operations. In such
cases, Your Data will be destroyed in accordance with those cycles;
- Your Data may be retained beyond the expiry of its purpose if
that is required by law, such as a provision of
a statute, or a court order such as a search warrant or sub poena,
or a warning by a law enforcement agency that delivery of a court
order is imminent. In these circumstances, my-iWallet:
- will take any reasonable steps available to it to communicate
to You that Your Data is being retained, unless it is precluded
from doing so by law; and
- will only retain Your Data while that provision is current,
and will then destroy Your Data;
- Your Data may be retained beyond the expiry of its purpose if
it is authorised by law (in particular to protect
my-iWallet's interests, e.g. if it believes on reasonable grounds
that You have failed to fulfil your undertakings to my-iWallet
or have committed a breach of the criminal law). In these circumstances,
my-iWallet will only retain Your Data while that situation is
current, and will then destroy Your Data.
Access by You to Your Personal Data
my-iWallet undertakes to provide you with access to
Your Data, subject to only such conditions and processes as are reasonable
in the circumstances. In particular, my-iWallet undertakes to enable
access:
- conveniently;
- without unreasonable delay; and
- without cost.
my-iWallet undertakes to establish and operate identity
authentication protections for access to Your Data that
are appropriate to its sensitivity, but practical. This may involve
some inconvenience; for example, relatively straightforward procedures
may be involved in order to provide you with access through a channel
that you have previously registered with my-iWallet (such as
a particular email-address), but may impose more onerous procedures
if you wish to use some other channel.
In the event that you dispute some aspect of Your Data, my-iWallet
undertakes to take reasonable steps in relation to the amendment,
supplementation or deletion of Your Data.
You undertake:
- not to seek access for frivolous purposes, or unreasonably frequently;
- to accept that deletion of some data may not be consistent with
the provision of particular services by my-iWallet to you.
Information about Data-Handling Practices
my-iWallet undertakes to make information available
to you about the manner in which my-iWallet handles your data:
- in general terms, in a readily accessible manner; and
- in more specific terms, on request.
Where Your Data is disclosed to a contractor, my-iWallet
undertakes to make information available to you on request about
the manner in which my-iWallet's contractors handle your data.
my-iWallet undertakes to ensure that the information provided is
meaningful, and addresses your concerns.
You undertake:
- not to seek such information for frivolous purposes, or unreasonably
frequently; and
- to accept that the disclosure of excessive detail may harm the
security of Your Data and my-iWallet's business processes, and
may harm my-iWallet's commercial interests.
Handling of Enquiries, General Concerns and Complaints
If you have enquiries, general concerns, or complaints
about these Terms, or about my-iWallet's behaviour in relation
to these Terms, you undertake:
- to communicate them in the first instance:
- to my-iWallet only;
- in sufficient detail;
- through a channel made available by my-iWallet for that purpose;
my-iWallet undertakes:
- to provide one or more channels for communications to
my-iWallet, which are convenient to users;
- to promptly provide acknowledgement of the receipt
of communications, including the provision of a copy of the communication,
the date and time it was registered, and my-iWallet's reference-code
for the communication;
- to promptly provide a response to the communication,
in an appropriate and meaningful manner.
You further undertake to not pursue my-iWallet
through any Regulator or the media:
- until and unless my-iWallet has had a reasonable
opportunity to respond to the initial communication; and
- while my-iWallet and you remain are conducting
a meaningful dialogue about the matter.
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