Privacy Policy

This privacy policy applies between you, the User of this Website, and Loopline Ltd, the owner and provider of this Website. Loopline Ltd takes the privacy of your information very seriously. This privacy policy applies to our use of any and all Data collected by us or provided by you in relation to your use of the Website.

Please read this privacy policy carefully.

Definitions and interpretation

1. In this privacy policy, the following definitions are used:

Collectively all information that you submit to Loopline Ltd via the Website. This definition incorporates, where applicable, the definitions provided in the Data Protection Laws;

Any applicable law relating to the processing of personal Data, including but not limited to the GDPR, and any national implementing and supplementary laws, regulations and secondary legislation;

The UK General Data Protection Regulation;

Loopline Ltd, a company incorporated in England and Wales with registered number 13691289 whose registered office is at 86-90 Paul Street, London, EC2A 4NE;

Any third party that accesses the Website and is not either (i) employed by Loopline Ltd and acting in the course of their employment or (ii) engaged as a consultant or otherwise providing services to Loopline Ltd and accessing the Website in connection with the provision of such services; and

The website that you are currently using, www.loopline.org.uk , and any sub-domains of this site unless expressly excluded by their own terms and conditions.

2. In this privacy policy, unless the context requires a different interpretation:

  • the singular includes the plural and vice versa;
  • references to sub-clauses, clauses, schedules or appendices are to sub-clauses, clauses, schedules or appendices of this privacy policy;
  • a reference to a person includes firms, companies, government entities, trusts and partnerships;
  • “including” is understood to mean “including without limitation”;
  • reference to any statutory provision includes any modification or amendment of it;
  • the headings and sub-headings do not form part of this privacy policy.

Scope of this privacy policy

3. This privacy policy applies only to the actions of Loopline Ltd and Users with respect to this Website. It does not
extend to any websites that can be accessed from this Website including, but not limited to, any links we may provide
to social media websites.

4. For purposes of the applicable Data Protection Laws, Loopline Ltd is the “data controller”. This means that Loopline
Ltd determines the purposes for which, and the manner in which, your Data is processed. 

Data collected

5. We may collect the following Data, which includes personal Data, from you: contact Information such as email addresses and telephone numbers; in each case, in accordance with this privacy policy.

How we collect Data

6. We collect Data in the following ways:

  • data is given to us by you; and
  • when you elect to receive marketing communications from us

in each case, in accordance with this privacy policy.

Data that is collected automatically

7. To the extent that you access the Website, we will collect your Data automatically, for example:

  • We automatically collect some information about your visit to the Website. This information helps us to make
    improvements to Website content and navigation, and includes your IP address, the date, times and frequency with which you access the Website and the way you use and interact with its content.

Our use of Data

8. Any or all of the above Data may be required by us from time to time in order to provide you with the best possible
service and experience when using our Website. Specifically, Data may be used by us for the following reasons:

  • internal record keeping;
  • improvement of our products / services;
  • transmission by email of marketing materials that may be of interest to you;
  • contact for market research purposes which may be done using email, telephone, fax or mail. Such information
    may be used to customise or update the Website;

in each case, in accordance with this privacy policy.

9. We may use your Data for the above purposes if we deem it necessary to do so for our legitimate interests. If you are not satisfied with this, you have the right to object in certain circumstances (see the section headed “Your rights”
below).

10. For the delivery of direct marketing to you via e-mail, we’ll need your consent, whether via an opt-in or soft-opt-in:

  • soft opt-in consent is a specific type of consent which applies when you have previously engaged with us (for
    example, you contact us to ask us for more details about a particular product/service, and we are marketing similar products/services). Under “soft opt-in” consent, we will take your consent as given unless you opt-out
  • for other types of e-marketing, we are required to obtain your explicit consent; that is, you need to take positive
    and affirmative action when consenting by, for example, checking a tick box that we’ll provide.
  • for other types of e-marketing, we are required to obtain your explicit consent; that is, you need to take positive
    and affirmative action when consenting by, for example, checking a tick box that we’ll provide.

Who we share Data with

11. We may share your Data with the following groups of people for the following reasons:

  • any of our group companies or affiliates – to ensure the proper administration of your website and business;
  • our employees, agents and/or professional advisors – to obtain advice from professional advisers;
  • third party service providers who provide services to us which require the processing of personal data – to help
    third party service providers in receipt of any shared data to perform functions on our behalf to help ensure the
    website runs smoothly;
  • relevant authorities – to facilitate the detection of crime or the collection of taxes or duties;
  • in each case, in accordance with this privacy policy.

Keeping Data secure

12. We will use technical and organisational measures to safeguard your Data, for example:

  • access to your account is controlled by a password and a user name that is unique to you.
  • we store your Data on secure servers.

13. Technical and organisational measures include measures to deal with any suspected data breach. If you suspect any
misuse or loss or unauthorised access to your Data, please let us know immediately by contacting us via this e-mail
address: privacy@loopline.org.uk.

14. If you want detailed information from Get Safe Online on how to protect your information and your computers and
devices against fraud, identity theft, viruses and many other online problems, please visit www.getsafeonline.org. Get
Safe Online is supported by HM Government and leading businesses

Data retention

15. Unless a longer retention period is required or permitted by law, we will only hold your Data on our systems for the
period necessary to fulfil the purposes outlined in this privacy policy or until you request that the Data be deleted.

16. Even if we delete your Data, it may persist on backup or archival media for legal, tax or regulatory purposes.

Your rights

17. You have the following rights in relation to your Data:

  • Right to access – the right to request (i) copies of the information we hold about you at any time, or (ii) that we
    modify, update or delete such information. If we provide you with access to the information we hold about you,
    we will not charge you for this, unless your request is “manifestly unfounded or excessive.” Where we are legally
    permitted to do so, we may refuse your request. If we refuse your request, we will tell you the reasons why.
  • Right to correct – the right to have your Data rectified if it is inaccurate or incomplete.
  • Right to erase – the right to request that we delete or remove your Data from our systems.
  • Right to restrict our use of your Data – the right to “block” us from using your Data or limit the way in which
    we can use it.
  • Right to data portability – the right to request that we move, copy or transfer your Data.
  • Right to object – the right to object to our use of your Data including where we use it for our legitimate interests.

18. To make enquiries, exercise any of your rights set out above, or withdraw your consent to the processing of your Data
(where consent is our legal basis for processing your Data), please contact us via this e-mail address: privacy@loopline.
org.uk.

19. If you are not satisfied with the way a complaint you make in relation to your Data is handled by us, you may be able
to refer your complaint to the relevant data protection authority. For the UK, this is the Information Commissioner’s
Office (ICO). The ICO’s contact details can be found on their website at https://ico.org.uk/.

20. It is important that the Data we hold about you is accurate and current. Please keep us informed if your Data changes
during the period for which we hold it. 

Transfers outside the United Kingdom and European Economic Area

21. Data which we collect from you may be stored and processed in and transferred to countries outside of the UK and
European Economic Area (EEA). For example, this could occur if our servers are located in a country outside the UK
or EEA or one of our service providers is situated in a country outside the UK or EEA. 

22. We will only transfer Data outside the UK or EEA where it is compliant with data protection legislation and the means
of transfer provides adequate safeguards in relation to your data, eg by way of data transfer agreement, incorporating
the current standard contractual clauses adopted by the European Commission.

23. To ensure that your Data receives an adequate level of protection, we have put in place appropriate safeguards and
procedures with the third parties we share your Data with. This ensures your Data is treated by those third parties in a
way that is consistent with the Data Protection Laws. 

Links to other websites

24. This Website may, from time to time, provide links to other websites. We have no control over such websites and are
not responsible for the content of these websites. This privacy policy does not extend to your use of such websites. You
are advised to read the privacy policy or statement of other websites prior to using them.

Changes of business ownership and control

25. Loopline Ltd may, from time to time, expand or reduce our business and this may involve the sale and/or the transfer
of control of all or part of Loopline Ltd. Data provided by Users will, where it is relevant to any part of our business so
transferred, be transferred along with that part and the new owner or newly controlling party will, under the terms of
this privacy policy, be permitted to use the Data for the purposes for which it was originally supplied to us.

26. We may also disclose Data to a prospective purchaser of our business or any part of it.

27. In the above instances, we will take steps with the aim of ensuring your privacy is protected.

General

28. You may not transfer any of your rights under this privacy policy to any other person. We may transfer our rights
under this privacy policy where we reasonably believe your rights will not be affected.

29. If any court or competent authority finds that any provision of this privacy policy (or part of any provision) is invalid,
illegal or unenforceable, that provision or part-provision will, to the extent required, be deemed to be deleted, and the
validity and enforceability of the other provisions of this privacy policy will not be affected.

30. Unless otherwise agreed, no delay, act or omission by a party in exercising any right or remedy will be deemed a
waiver of that, or any other, right or remedy.

31. This Agreement will be governed by and interpreted according to the law of England and Wales. All disputes arising
under the Agreement will be subject to the exclusive jurisdiction of the English and Welsh courts.

Changes to this privacy policy

32. Loopline Ltd reserves the right to change this privacy policy as we may deem necessary from time to time or as may be required by law. Any changes will be immediately posted on the Website and you are deemed to have accepted the terms of the privacy policy on your first use of the Website following the alterations.

You may contact Loopline Ltd by email at privacy@loopline.org.uk.

Attribution

33. This privacy policy was created using a document from Rocket Lawyer (https://www.rocketlawyer.com/gb/en).
This privacy policy was created on 14 August 2022.

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Post-Brexit: data protection
Card processor sends sensitive data to wrong address
24 August 2022

Worldline SA subsidiary Payone GmbH has been accused of breaching data protection rules after it sent sensitive employee payroll information to the wrong address by accident. The Worldline Group holdS a 60% stake in the Frankfurt based company who have a small UK market presence.

In June 2021, one of Payone GmbH’s ex UK employees (the data subject) received a “potential data breach notification” from the firm advising him that his salary, National Insurance data, nationality (Special Category Data) was amongst various bits of information sent to an incorrect home address.

This included personal information such as the former employees name, age and address.  It also included details such as the date of birth and the amount of annual work bonus he received in his bank account amongst other identifiable data.

Payone GmbH confirmed that this document was sent out in error following an employee making a mistake when re-entering data processed by their third-party payroll provider.  The error arose when the employee was fulfilling an Article 15 GDPR request. The error was spotted by the data subject when he noticed in an email version of the document that the postal address was incorrect. An attempt to notify Payone GmbH of the error went in vain as the document was already irretrievably despatched.

The data subject was alarmed with the incident which exposed him to the possibility of fraudulent activity, amidst reasonable fears his data could end up on the dark web and used by criminals.  Habitually resident in the UK he complained to the Information Commissioner’s Office (ICO) in June 2021. He similarly raised the concern in Germany via The Hessian Commissioner for Data Protection and Freedom of Information (HBDI).

The ICO reprimanded Payone GmbH for the error in their final decision letter.
Similarly, the HBDI cited a violation of Article 5(f) of the General Data Protection Regulation (GDPR) relating to integrity and confidentiality.

The ICO stated in their July 2021 findings that Payone GmbH, “should take steps to ensure that all personal data records are accurate and up to date. Holding inaccurate information, such as addresses, does increase the risk of personal data breaches and poses risks to the security of information”.

The HBDI confirmed in their October 2021 findings that Payone GmbH had taken remedial action. They concluded that a monetary fine would not be imposed on Payone GmbH as they had taken technical and organisational steps in response to the data breach. Data subjects could now request their data in an autonomous portal.

The GDPR, which came into effect in 2018, gave the Information Commissioner’s Office greater powers to tackle data breaches. The new ‘UK GDPR’ charts its own course after Brexit whilst seeking to maintain EU GDPR adequacy.  In extreme scenarios, organisations face penalties of up to £20m or 4 per cent of their global worldwide turnover, whichever is more.

In the years prior to GDPR, the ICO fines were capped at £500,000.

The data subject said: “I am just glad I spotted it; they were going to resend the document again to another wrong address. Prior to Brexit the process would have been commenced via the ICO who in turn would liaise with the HBDI on the data subjects’ behalf; but I found myself communicating with both authorities separately which was an additional step but in the end was surprisingly
effective. Unfortunately, Payone GmbH again sent my incorrect address to the
Workers Pension Trust in January 2022, and documents yet again went to the wrong address. In my opinion they have not learned from the first time and my complaint is sitting with the ICO yet again”.

The former employee is pursuing a remedy under Article 82 UK GDPR via
the Court’s of England & Wales.

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