DocuLink Express Ltd is committed to protecting and respecting your privacy. We want you to understand how we collect and use information about you.

The privacy notice describes to you:

• who we are
• what personal data we collect and store about you, and how we collect it
• why we collect personal data and what we do with it
• the categories of third parties with whom we share your personal data
• how we retain your information and keep it secure
• your rights and how to exercise them
• how to contact us

1.  Who we are

For the purposes of data protection law, the “controller” is DocuLink Express Ltd, a company incorporated and registered in England and Wales under company number 11350343 and having its registered office address at Kemp House, 160 City Road, London, EC1V 2NX, United Kingdom (from now on referred to as “DocuLink”, or as “we” and related words such as “us” and “our”). Our registered VAT number is GB 308107531

As controller we are responsible for, and control the processing of, your personal data.

2.  The information we collect from you - 

In the course of our business we collect the following personal data when you provide it to us:

• personal details, such as name and title, username, date of birth
• contact data, such as address, billing details, e-mail address, telephone and mobile numbers and any other personal information you provide
• transaction data, such as details about payments to and from you, details of services you have purchased from us and credit referencing results
• usage data, such as information about how you use your ID pass
• marketing data, such as your preferences in receiving marketing and

 We do not knowingly collect “sensitive” personal data. Sensitive data is data to which more stringent processing conditions apply, and comprises data concerning your racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership, health, sex life or sexual orientation, and genetic data and/or biometric data. We also do not collect information about criminal convictions or offences. 

3.  How we collect personal data - 

We obtain personal data directly from you when you interact with us, for example when you:

• open an account
• request information
• email us
• phone our accounts and customer services teams (since your call may be recorded for training, fraud prevention and investigation purposes)
• enter a competition or take part in a survey
• give us feedback

4.  How we use your personal data Introduction - 

We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:

• to allow you to open an account
• to enable us to perform a service for you
• if it is necessary for our legitimate interests (or those of a third party) and these are not overridden by your own rights and interests
• where we need to comply with a legal or regulatory

Lawful processing - 

In order to process personal data, we must have a lawful reason. We always ensure that this is the case, and we set out our lawful bases below. We will use your personal data only for the purposes for which we collected it, unless we fairly consider that we need it for another reason that is compatible with the original purpose.

Contractual Necessity

As our customer or potential customer we will process your personal data for the following purposes, on the legal basis that it is necessary for us to provide our services to you:

• to enable us to carry out our services
• to identify you
• to respond to your inquiries
• to allow you to open an account
• to the extent necessary to provide you with information you have requested in relation to our services before you decide to use them
• to provide our services, including contacting you about your service
• to carry out billing and administration activities, including refunds and credits

Whenever we process your personal data for these purposes, we ensure that your interests, rights and freedoms are carefully considered.

Compliance with laws

We may process your personal data in order to comply with applicable laws, for example, if we are required to co-operate with a criminal investigation.

Consent

You have the right to withdraw consent to receive information from us at any time and can do so by contacting us at any time. 

5.  Sharing your personal data (disclosure to third parties) - 

We may provide your personal data to the following recipients for the purposes set out in this notice:

• other service providers, including airlines and ground handlers, e-mail and mail service providers and technical and support partners, such as the companies who host our website and who provide technical support and back-up services
• law enforcement agencies, government or public agencies or officials, regulators, including UK Border Force, CAA, the Police, HMRC and any other person or entity that has the appropriate legal authority where we are legally required or permitted to do so, to respond to investigations, claims, or to protect our rights, interests, privacy, property or safety
• any other parties, where we have your specific consent to do

6.  Provision of personal data - 

To provide services for you, we will need some or all of the personal data described above so that we can perform that service or the steps that lead up to it. If we do not receive the data, the service could not be performed.

7.  How long we retain personal data for - 

We carefully consider the personal data that we store, and we will not keep your information in a form that identifies you for longer than is necessary for the purposes set out in this notice or as required by applicable law. In some instances, we are required to hold data for minimum periods: for example, UK tax law currently specifies a six-year period for retention of some of your personal data.

8.  Transfers of personal data outside the EEA - 

We may transfer your personal information to a location outside of the European Economic Area if we consider it necessary or desirable for the purposes set out in this notice. In such cases, we will safeguard your privacy rights and transfers will only be made to recipients with adequate safeguards in place for the protection of personal data.

9.  How we keep your personal data secure - 

DocuLink has security measures in place designed to prevent data loss, to preserve data integrity, and to regulate access to the data. Only authorised DocuLink employees and third parties processing data on our behalf have access to your personal data. All DocuLink employees who have access to your personal data are required to adhere to the DocuLink Express Ltd Privacy Notice that we have in place contractual safeguards with our third-party data processors to ensure that your personal data is processed only as instructed by DocuLink.

10.   Your information rights - 

You have the following rights under data protection law:

• right to be informed about the collection and use of your personal data
• right of access to your personal data, and the right to request a copy of the information that we hold about you
• right to have inaccurate personal data that we process about you rectified if you believe it to be out of date or incorrect
• the right of erasure and in certain circumstances the right to “be forgotten”
• the right to object to, or restrict processing of personal data concerning you for direct marketing and in certain other situations, to our continued processing of your personal data