Introduction

Palsar Capital Limited, henceforth referred to as “We” “Our” “Us” provides an affiliate programme to promote our clients on whose behalf We administer and manage the affiliate program. In this policy “affiliate” “you” and “your” refers to the individual entity that has agreed to promote the brands we provide marketing services for, in accordance with this Privacy Policy.

This Privacy Policy is designed to help you understand how we collect, use and safeguard your information.

This privacy policy should be read in conjunction with the Affiliate Programmes Terms and Conditions. By entering into any kind of contract with Palsar Capital Limited, you agree to the contents of this privacy policy. If you do not agree with any section of this privacy policy, you should not attempt to use our service.

Data Controller

The Data Controller is Palsar Capital Limited t/a Raven of Glassworks, 1 Back Turner Street, Manchester, M4 1FR

All queries in regards to this privacy policy should be addressed to the Data Protection Officer at the above address, who can also be contacted directly at compliance@raventrack.com

Personal Information

We collect and process the following data from (and about) you:

• Your name, company name, address and contact details, including email address and telephone number;
• Payment details including Electronic transfer address, and payment method owner.
• A record of any correspondence between You and Us.

Personal information is collected for the following purposes

• To administer the opening, management, and maintenance of accounts.
• To enable Palsar Capital Limited to build an accurate profile of our client base and carry out statistical analysis.
• To contact you for purposes including (but not limited to) sales reports, training, provision of promotional resources, newsletters, and other correspondence.
• To monitor affiliate activity to ensure your compliance with the terms and conditions of the Active Wins Affiliates Affiliate Programme.
• To monitor and process payments in relationship to your involvement in this Affiliate Programme.
• All telephone calls to and from Palsar Capital Limited office(s) may be recorded for training and security purposes.

We implement effective processes to identify, manage, monitor and report risks and internal control mechanisms. These controls include secure systems and networks, and clear processes for privilege access rights. All data is stored securely.

Legal Basis for Processing

Our lawful basis for processing personal data include:

• To fulfil a contract we have with you.
• When it is our legal duty to do so.
• When it is in our legitimate interest.
• When you consent to it.

Who we share your personal information with

We may disclose your personal data to:

• Palsar Capital Limited employees
• contractors working with Palsar Capital Limited
• regulators, and other legal authorities
• the brands that you are promoting
• auditors
• payment providers
• fraud prevention and compliance services
• potential purchasers or investors
• companies that you ask us to share your data with

All processing of information will be governed by the appropriate data protection laws.

Marketing

We will not send promotional or direct marketing, inclusive of email, SMS, or automated calls, without first obtaining your specific consent.

The consent requires a positive Opt-In either in electronic format, verbally or in writing. The consent will be clear and specific, granular, separate from other Terms and Conditions, name any third parties relying on the consent, and be easily withdrawable.

Data Transfers outside the EEA

We will not transfer Personal Data to recipients in Third Party countries that are outside of the EEA, or are not currently recognised by EU law as having an adequate level of legal protection for the rights and freedoms of data subjects unless:

• The Processor is certified under the EU-U.S. Privacy Shield Framework.
• The existence of any other specifically approved safeguard for data transfers (as recognised under EU Data Protection Laws) and/or a European Commission finding of adequacy can be demonstrated.

Data Retention

You may request that your Personal Data be anonymised in the following circumstances:

• Where the Personal Data is no longer necessary in relation to the purpose for which it was originally collected/processed.
• When you withdraw consent, if consent is being used as the Legal Basis for Processing.
• If you object to the Processing and there is no overriding Legitimate Interest or Legal Obligation to continue the Processing.
• The Personal Data was unlawfully processed.
• The Personal Data has to be erased to comply with a legal obligation.

We will only retain data for the necessary time to complete the task that the data was collected for, or to meet our legal obligations.

Subject Access Request (SAR)

You are entitled to a file a Subject Access Request (SAR) to obtain a copy of the personal information which we hold about you. If you wish to receive a copy of this information, please contact your account manager, or the DPO directly, and allow up to thirty calendar days for the information to be collated and provided to you. Please note that your identity will need to be confirmed in order to complete a SAR, which may include the disclosure of other personally identifiable documentation in order to prove your identity (such as a passport scan, or valid proof of address) before commencing with the process.

Cookies

By using the Raven website, you consent to our use of ‘cookies’. A cookie is a small piece of information sent by a web server to a web browser, which enables the server to collect information from the browser. We use cookies and the information gained from them to analyse site usage, with this information used accordingly to improve our content and site layout and to remember your onsite preferences.

If you prefer, you can disable cookies in your web browser. The ‘help’ menu on the menu bar of most browsers will have a functionality to disable cookies.

Automated Decision Making and Profiling

Palsar Capital Limited do not use any automated systems in order to make decisions regarding your account which have any legal effect on You.

Right to Lodge a complaint

Please let us know if you are unhappy with how we have used your personal information in writing to the Data Protection Officer, who will be able to assist further with your complaint or concern. You also have the right to complain to the Information Commissioner’s Office.

Privacy Policy Status

This Privacy Policy is kept under continued review by Palsar Capital Limited and can be amended by Us at any time, and without notice to you. Whenever a change is made to the privacy policy which will affect your rights as a data subject, or change the intended processing purposes, then you will be notified directly and asked to agree to the new privacy policy. If you disagree with the changes made to the privacy policy, you retain the right to withdraw consent for future processing, as stated in the introduction to this policy.

This version of the Privacy Policy is effective as of September 20th 2018.