We are committed to safeguarding the privacy of our clients and our website visitors; this policy sets out how we will treat your personal information.
Last updated 1st October 2019
This notice applies across all websites that we own and operate and all services we provide, including our online and mobile accounting and financial services products, and any other apps or services we may offer (for example, events or training). For the purpose of this notice, we’ll just call them our ‘services’.
When we say ‘personal data’ we mean identifiable information about you, like your name, email, address, telephone number, bank account details, payment information, support queries and so on. If you can’t be identified (for example, when personal data has been aggregated and anonymised) then this notice doesn’t apply.
We may need to update this notice from time to time. Where a change is significant, we’ll make sure we let you know – usually by sending you an email.
Here is a summary of some of the key changes we made on 1st October 2019:
Navigation: We split the privacy notice into clear and defined sections so that it’s more user-friendly and easier to navigate to the information you need.
Paternoster Consulting Ltd: We clarified who we are, and where we are headquartered.
Principles: We’re using the update to our privacy notice as an opportunity to introduce the key principles that guide our approach to data protection – namely: Transparency, Enablement, Security and Stewardship. They’re at the heart of everything we do relating to personal data.
Collection and Use: We’ve provided more information about the ways we collect personal data about you, who we collect that data from, and how we intend to use it.
Sharing: We’ve been more prescriptive about who we share your personal data with, which includes third party service providers and partners, regulators, an actual or potential buyer or where required by law.
Security: We’ve restated our commitment to protecting your personal data using appropriate technical and organisational measures.
Data Subject Rights: We’ve set out in more detail all rights individuals have in relation to their personal data and how those rights can be exercised.
Who are ‘we’?
When we refer to ‘we’ (or ‘our’ or ‘us’), that means Paternoster Consulting Ltd and any business divisions operating under their own trading style. The registered office address of Paternoster Consulting Ltd is Ground Floor, Wilson House, Woodsy Close, Cardiff Gate Business Park, Cardiff, CF23 8RW, United Kingdom. We provide Programme and Project Management services, accountancy and bookkeeping services and an easy-to-use global online platform for small businesses through our partner, Xero. For European Union data protection purposes, when we act as a controller in relation to your personal data, Paternoster Consulting Ltd (company number 07803142) is our controlling representative in the European Union.
Our principles of data protection
Our approach to data protection is built around four key principles. They’re at the heart of everything we do relating to personal data.
Transparency: We take a human approach to how we process personal data by being open, honest and transparent.
Enablement: We enable connections and efficient use of personal data to empower productivity and growth.
Security: We champion industry leading approaches to securing the personal data entrusted to us.
Stewardship: We accept the responsibility that comes with processing personal data.
How we collect your data
When you visit our websites or use our services, we collect personal data. The ways we collect it can be broadly categorised into the following:
Information you provide to us directly: When you visit or use some parts of our websites and/or services we might ask you to provide personal data to us. For example, we ask for your contact information when you sign up for a free trial, respond to a job application or an email offer, join us on social media, take part in training and events, contact us with questions or request support. If you don’t want to provide us with personal data, you don’t have to, but it might mean you can’t use some parts of our websites or services.
Information we collect automatically: We collect some information about you automatically when you visit our websites or use our services, like your IP address and device type. We also collect information when you navigate through our websites and services, including what pages you looked at and what links you clicked on. This information is useful for us as it helps us get a better understanding of how you’re using our websites and services so that we can continue to provide the best experience possible (e.g., by personalising the content you see). Some of this information is collected using cookies and similar tracking technologies. If you want to find out more about the types of cookies we use, why, and how you can control them, take a look at our cookie notice.
Information we get from third parties: The majority of information we collect, we collect directly from you. Sometimes we might collect personal data about you from other sources, such as publicly available materials or trusted third parties like our marketing and research partners. We use this information to supplement the personal data we already hold about you, in order to better inform, personalise and improve our services, and to validate the personal data you provide. Where we collect personal data, we’ll only process it:
to perform a contract with you, or
where we have legitimate interests to process the personal data and they’re not overridden by your rights, or
in accordance with a legal obligation, or
where we have your consent.
If we don’t collect your personal data, we may be unable to provide you with all our services, and some functions and features on our websites may not be available to you.
How we use your data
First and foremost, we use your personal data to operate our websites and provide you with any services you’ve requested, and to manage our relationship with you. We also use your personal data for other purposes, which may include the following:
To communicate with you. This may include:
providing you with information you’ve requested from us (like training or education materials) or information we are required to send to you
operational communications, like changes to our websites and services, security updates, or assistance with using our websites and services
asking you for feedback or to take part in any research we are conducting (which we may engage a third party to assist with).
To support you. This may include:
assisting with the resolution of technical support issues or other issues relating to the websites or services, whether by email, in-app support or otherwise.
To enhance our websites and services and develop new ones. For example, by tracking and monitoring your use of websites and services so we can keep improving, or by carrying out technical analysis of our websites and services so that we can optimise your user experience and provide you with more efficient tools.
To market to you: In addition to sending you marketing communications, we may also use your personal data to display targeted advertising to you online – through our own websites and services or through third party websites and their platforms.
We will only disclose your personal data to:
third party service providers and partners who assist and enable us to use the personal data to, for example, support delivery of or provide functionality on the website or services, or to market or promote our goods and services to you
regulators, law enforcement bodies, government agencies, courts or other third parties where we think it’s necessary to comply with applicable laws or regulations, or to exercise, establish or defend our legal rights. Where possible and appropriate, we will notify you of this type of disclosure
an actual or potential buyer (and its agents and advisers) in connection with an actual or proposed purchase, merger or acquisition of any part of our business
other people where we have your consent.
International Data Transfers
When we share data, it may be transferred to, and processed in, countries other than the country you live in – such as to the United States, where Xero’s data hosting provider’s servers are located. For individuals in the European Economic Area (EEA), this means that your data may be transferred outside of the EEA. Where your personal data is transferred outside the EEA, it will only be transferred to countries that have been identified as providing adequate protection for EEA data, or to a third party where we or our trading partners have approved transfer mechanisms in place to protect your personal data. For further information, please contact us using the details set out in the Contact us section below.
Security is a priority for us when it comes to your personal data. We’re committed to protecting your personal data and have appropriate technical and organisational measures in place to make sure that happens.
The length of time we keep your personal data depends on what it is and whether we have an ongoing business need to retain it (for example, to provide you with a service you’ve requested or to comply with applicable legal, tax or accounting requirements). We’ll retain your personal data for as long as we have a relationship with you and for a period of time afterwards where we have an ongoing business need to retain it, in accordance with our data retention policies and practices. Following that period, we’ll make sure it’s deleted.
It’s your personal data and you have certain rights relating to it. When it comes to marketing communications, you can ask us not to send you these at any time – just send your request to email@example.com. You also have rights to:
know what personal data we hold about you, and to make sure it’s correct and up to date
request a copy of your personal data, or ask us to restrict processing your personal data or delete it
object to our continued processing of your personal data
You can exercise these rights at any time by sending an email to firstname.lastname@example.org.
If you’re not happy with how we are processing your personal data, please let us know by sending an email to email@example.com. We will review and investigate your complaint and get back to you within a reasonable time frame. You can also complain to your local data protection authority. They will be able to advise you how to submit a complaint.
How to contact us
We’re always keen to hear from you. If you’re curious about what personal data we hold about you or you have a question or feedback for us on this notice, our websites or services, please get in touch. We prefer to communicate with you by email – this ensures that you’re put in contact with the right person and in accordance with any regulatory time frames.
Please contact us by email at firstname.lastname@example.org OR email@example.com OR by post to the registered office address of Paternoster Consulting Ltd, Ground Floor, Wilson House, Woodsy Close, Cardiff Gate Business Park, Cardiff, CF23 8RW, United Kingdom.