Privacy and Cookie Notice (the “notice”)

LAST UPDATED 25 November 2021

Document Control
Title: Customer Privacy and Cookie notice
Author: Playroll Legal
Version Date: March 2023
For all questions and queries in relation to this notice, contact legal@playroll.com

Playroll Limited (“Playroll”) is a company incorporated in the United Kingdom. Playroll is a specialist in global payroll and related services and has established a network of international companies through which it provides these services.

In this notice, we may refer to Playroll as “us”, “our” or “we”. Any references to “you” or “your” are references to (i) either a client of Playroll; or (ii) a user of our website (www.playroll.com), who has either filled in a form providing us with data about themselves or who has not identified themselves on our website, as the context may require.

Privacy Notice

1. Introduction and Purpose of this Notice

1.1 This notice explains how we collect and protect data. It sets out the type of data that is collected, why it is collected, what will be done with it, and what your rights are in respect of your information. It also sets out how the law protects you and your privacy rights.
1.2 This notice is important because we take the protection of your information seriously. It is designed in accordance with the EU General Data Protection Regulation (“GDPR”) and other applicable privacy and data protection laws.
1.3 In terms of applicable privacy laws, this notice may also apply in respect of other third parties, acting on our behalf when providing either you or ourselves with services necessary for giving effect to our agreements with you.

2. What is Personal Information?

‘Personal information’ means any information that is recognised as such in terms of the General Data Protection Regulation 2016/679 and includes any information which identifies you. ‘Personal data’ means any information relating to an identified or identifiable natural person. An identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.

3. What information do we collect?

3.1 When you use our website, we may collect and store the following information and Personal Information:
3.1.1 your personal or entity name, and entity email address
3.1.2 correspondence via the website and information relating to transactional activity via the website; and
3.1.3 website connection information, statistics on page views, traffic to and from the website, IP address and standard web log information.

3.2 If you are a client, we may collect and store some or all of the following information about you: company name, company registration number, bank details, vat/tax identification numbers, registered and billing address, and contact details of authorized contact person.

4. When will we use your personal information?

4.1 In order to make the information that we gather useful, we will process the information. “Process” refers to how we collect, use, store, make available, destroy, update, disclose, or otherwise deal with your personal information.

4.2 We are committed to protecting your personal information and only using it for very specific purposes.

4.3 In general, we will only process your personal information if we need it to provide a service to you. For example, if you have entered into an agreement with us, in order for us to fulfil our contractual obligations to you, comply with obligations imposed by law; or to protect your legitimate interests, your personal information may be processed by us.

4.4 We will retain and evaluate information on your recent visits to our website and how you move around different sections of our website for analytics purposes to understand how people use our website so that we can make it more intuitive.

4.5 In addition, we may process your information where lawful purposes require it:
4.5.1 if the processing is needed to create, use or protect a right or obligation in law;
4.5.2 if the processing is for statistical or research purposes, and all legal conditions are met; ·
4.5.3 if the special personal information was made public by you; or ·
4.5.4 if the processing is required by law.

5. What legal basis do we have to process your information?

We have a legal basis to process information where:
5.1 You have given us consent to process your data. Such consent must always be freely given, specific, informed and unambiguous,

5.2 There is a contract in place between us and we need to process information to execute our obligations under the contract.

5.3 We are be obliged to process or store your information in order to comply with our obligations under various laws.

5.4 Processing is necessary for the purpose of legitimate interests.

6. Where is your data processed and stored?

We transfer your data through Amazon Web Services.

7. Transfers to third countries and safeguards we have in place

7.1 The nature of the service provided by us means that we operate globally. This means that your personal information may be shared with our network of companies in other countries and processed in those countries under relevant privacy rules.

7.2 Nevertheless, we will only transfer your personal information in certain circumstances. This would include:
7.2.1 where your personal information will be adequately protected in that third party (either by law or agreement with the third-party recipient); ·
7.2.2 where the transfer is necessary to enter into, or perform, under a contract with you or a contract with a third-party that is in your interest; or
7.2.3 where you have consented to the transfer.

7.3 This transfer will happen within the requirements and safeguards of applicable laws or privacy rules that bind us.

7.4 Where possible, the party processing your personal information in another country will apply the same level of protection as available by law in your country, or if the other country’s laws provide better protection, the other country’s laws may be agreed to and applied.

7.5 We will also ensure that if a third country’s data protection laws are not equivalent to acceptable standards, steps will be taken to adopt supplementary measures.

7.6 We will re-evaluate the privacy laws of these third countries from time to time.

8. Marketing
We may use your personal information to send you information about products and services that we think may be appropriate for you. In all cases, you can request that we stop sending marketing communications to you by emailing legal@playroll.com.

9. What are your data protection rights?

It is important to us that you are aware of all of your data protection rights. You are entitled to the following:
9.1 The right to access – you have the right to request copies of your personal data from us. We may charge you a small fee for this service.

9.2 The right to rectification – you have the right to request that we correct any information you believe is inaccurate. You also have the right to request that we complete any information you believe is incomplete.

9.3 The right to erasure – you have the right to request that we erase your personal data, under certain conditions. This also means that you may withdraw any consent that you have provided in respect of your personal data.

9.4 The right to restrict processing – you have the right to request that we restrict the processing of your personal data, under certain conditions.

9.5 The right to object to processing – you have the right to object to our processing of your personal data, under certain conditions.

9.6 The right to data portability – you have the right to request that we transfer the data that we have collected to another organisation, or directly to you, under certain conditions.

To exercise your rights in respect of any of the above, including to opt out of any disclosure of your personal data, you can email us at legal@playroll.com.

10. For how long will we hold your information?

10.1 We will only keep your personal information for as long as:
10.1.1 the law requires us to do so;
10.1.2 a contract between us requires us to keep it;
10.1.3 you have consented to our keeping it; or
10.1.4 we require it for a lawful business purpose, to achieve any purpose set out in this notice, or for statistical and/or research purposes.

10.2 Once these time periods have expired, we will take steps to delete your data.

10.3 In specific, please note the following:
10.3.1 If you leave a comment, the comment and its metadata are retained indefinitely. This is so we can recognise and approve any follow-up comments automatically instead of holding them in a moderation queue.

10.3.2 For users that register on our website, we also store the personal information provided in the user profile. Website administrators can also see and edit that information.

11. Changes to this Notice
We may change this notice from time to time if required by law or as a result of changes to our business practices. The latest version of the notice will be displayed on our website.

12. Responsible Party
Playroll is the responsible party in respect of the information we collect about you. It is responsible for determining why and how your personal information will be used. Playroll’s data privacy officer can be contacted at legal@playroll.com.

13. Links to other Websites

13.1 Our website may contain links to third party websites. You should be aware that these third-party websites may collect data about you, use cookies, embed additional third-party tracking, and monitor your interaction with that embedded content.

13.2 Our privacy policy applies only to our website, so if you click on a link to another website, you make sure that you are comfortable with the terms of that website.

14. Complaints

14.1 You have a right to file a complaint regarding any infringement of personal information with either us or a supervisory authority with jurisdiction.

14.2 As we are registered in the United Kingdom and Wales, please take note of the contact information for the Information Commissioner’s Office:
icocasework@ico.org.uk
Telephone: 0303 123 1113
Textphone: 01625 545860
Wycliffe House Water Lane
Wilmslow
Cheshire
SK9 5AF
Email: casework@ico.org.uk
14.3 Any complaint to the Information Commissioner is without prejudice to your right to seek redress through the courts.

Cookie Notice

A cookie is a small data file that we store on your browser or the hard drive of your computer if you agree to accept our cookies. Cookies contain information that is transferred to your computer’s hard drive. It helps us “remember” user behavior even where we do not know the identity of the user.

1. Categories of Cookies that we use on our website
Origin What this refers to Use Duration
First Party Cookies These refer to cookies placed directly on your devices by our website. These cookies allow us to collect analytics, data, remember language settings or perform other useful functions that enhance user experience. Session cookies: These are temporary cookies that expire once a user’s session ends or the browser is closed.
Persistent cookies: These remain on a user’s device for a longer period until they are manually erased by the user or until their expiration date lapses.
Third-party cookies: These refer to cookies placed on your devices by a third-party service integrated into our website (e.g., analytics). Third-party cookies are created by domains separate/different from the website (or domain) that the user is visiting. These cookies are usually used for online advertising, cross-site tracking; and are accessible on any website that loads the third party’s server code Persistent cookies: See above

2. What is the purpose of the cookies that we have on our website?
Strictly necessary cookies These are required for the proper operation of our website.
Analytical/performance cookies These allow us to recognise and count the number of visitors and to see how visitors move around our website when they are using it. This helps us to improve the way our website works.
Functionality cookies These recognise a user returning to our website. This enables us to personalise our content for you and remember your preferences.
Targeting/Advertising cookies. These record your visit to our website, the pages you have visited and the links you have followed. We use this information to make our website and the advertising displayed on it more relevant to your interests. We may also share this information with third parties for this purpose.

3. How can you control the information from the cookies we gather from you?
All browsers allow users to refuse to accept cookies and to remove current cookies. The methods for doing so vary between different browsers and versions. You can block cookies on our website, but it may have a negative impact upon the experience you have with our website.

4. Additional information about cookies and how we use them

4.1 Cookies cannot be used to distribute viruses onto a device.

4.2 If you disable cookies, previous cookies collected will not be deleted, but no new cookies will be created.

4.3 If you leave a comment on our website, you may opt in to saving your name, email address, and website in cookies. These are for your convenience so that you do not have to fill in your details again when you leave another comment. These cookies will last for one year.

4.4 If you visit our login page, we will set a temporary cookie to determine if your browser accepts cookies. This cookie contains no personal data and is discarded when you close your browser.

4.5 When you log in, we will also set up several cookies to save your login information and your screen display choices. Login cookies last for two days, and screen options cookies last for a year. If you select “Remember Me”, Your login will continue for thirty days. If you log out of Your account, the login cookies will be removed.

4.6 We have third-party platforms integrated into our website. These include Google Tag Manager, Log Rocket, Rollbar, Hubspot, Kiflo and Zendesk. You are advised to consider the cookie policies of these platforms.