BACKGROUND
- Your employer (“Employer”) wishes tomaketheEmployeeBenefitavailableto
- The expression “Employee Benefit” means a benefit whereby eligible employees may, through the Hastee App (“Hastee App”), request that they receive part of their accrued salary or wages for immediate payment (a “Withdrawal”)rather than at the next scheduled pay day, in accordance with the terms of use for the Hastee mobile application (“Hastee App”) which can be accessed via the Hastee App (“App User Terms”). It also covers the provision of advice pertaining to personal finance that your Employer has requested we provide as part of our performance of the ClientContract (the “Financial Education Series”).
- Your Employer has engaged us under a separate contract (the “Client Contract”) to make the Employee Benefit available to you. You may access the Employee Benefit via the Hastee App.
- In providing services to your Employer under the Client Contract which enable us to make the Employee Benefit available to you, we will receive Personal Data about you. We respect your privacy, and we want to be transparent with you about what personal data we collect and why. This policy (“Privacy Policy”) explains the personal data wecollect from you, either directly or indirectly, and how we will use Personal data is any information that can be usedto identify you or that we can link to you (“Personal Data”).
WHO WE ARE
In this Privacy Policy the terms “we”, “us”, or “Hastee” are each intended as a reference to Hastee Technologies HR Ltd and/or any other entity within the Hastee group with whom your Employer signed a Client Contract and together withwhom Hastee Technologies HR Ltd may be a joint controller of your Personal Data. Details of these Hastee groupcompanies and their registration details are found at the end of this Privacy Policy.
WHAT DOES THIS PRIVACY POLICY COVER?
This Privacy Policy explains how we process your personal data through your use of the Hastee App or our website (together, the “Hastee Technology”) or which your Employer might provide to us in relation to our provision of the services to them (“Services”) which enable you to access the Employee Benefit.
It also sets out the choices you can make about the Personal Data we collect and the legal rights you have in relation toyour Personal Data.
This Policy is broken down into a number of sections which explain:
- Who We Are & The Types of Personal Data We Process
- Minors
- The Legal Bases and Purposes for Using Personal Data
- How We May Share Your Personal Data
- Our Use of Cookies and Other Similar Technology
- Data Storage and Transfer
- Keeping Your Personal Data Secure
- Retention of Your Personal Data
- Third Party Links
- Your Rights and Choices
- Changes to Our Privacy Policy and Your Duties to Notify Us of Changes
- How To Contact Us
If you are:
- a shareholder, an employee or supplier of Hastee or are otherwise engaged in working for us or applying to work for us; or
- a visitor to our website who has not registered an account on the Hastee App pursuant to a Client Contract between Hastee and your Employer, a separate privacy policy or data processing agreement applies to information instead and you will be notified of the relevant policy that applies to you.
Important Information regarding Employers and Organisations
This Privacy Policy is not a substitute for any privacy notice that i) your Employer is required to provide to its employees, contractors, staff, affiliates, workers, volunteers, associates, members or other end users. All questions about the policies,data collection policies and fair processing notices of a) your Employer (“Employer Policies”) relating to your Personal Data and administrative user access rights should be directed to your employer. Hastee is not liable for: i) your Employer’compliance with their obligations as a Controller and if you have any concerns over the processing of your Personal Data bythem you should contact them directly as appropriate.
THE TYPES OF PERSONAL DATA WE PROCESS
We collect information from you when:
- You interactwiththeHastee
- You request information about our Hastee
- Your Employer providesyourPersonalDataandinformationto
- You sign-in or visit our Hastee Technology or use the services and functionality available through that Hastee Technology – including:
- to register your interest in receiving bespoke financial education content
- to register your interest in the Hastee App
- to apply to create a Hastee Account
- when you use the Hastee App
- You use a social media service, for example, our Facebook page or YouTube
- You sign up for e-mails, mobile messages, social media, or other communications or notifications from
- You enter a contest or sweepstakes, respond to one of our surveys, or participate in a focus
- You provide us with comments, suggestions, or other
All the Personal Data we collect: i) from you directly via the Hastee App; ii) from your Employer iii) from the Hastee Technology iv) from any third-party providers of bespoke financial education content is set out in Table 1 below. We maycollect, use, store and transfer different kinds of Personal Data as follows:
| SECTION | CATEGORY OF PERSONAL DATACOLLECTED | SOURCE | DESCRIPTION |
| 1 | Personal Data provided by your Employer to Hastee to enable the Employee Benefit to be made available to you. | ||
| Identity Data | Your Employer | Title; first name; last name; payroll or worker identification number; and (but only where requiredby your Employer) your date of birth and/or national insurance number. | |
| Contact Data | Email address | ||
| Financial Data | Your pay or salary information including: -whether you are a salaried orcontingent worker -if salaried, the amount of your salary -if a contingent worker, your rate (hourly or daily) |
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| Employment Data | For Registered Users who are contingent workers(where payment of wages or fees is contingentupon work performed for or services provided to the Employer), once work has been approved byyour Employer: -rota, time and attendance data; -job ID*; -location / venue*; and -approved start and end information / check-in time and check-out time*. *only if your Employer has provided this tous. For all Registered Users: -dates of termination of employment or engagement; -any other information provided by or on behalf of your Employer which is necessaryfor Hastee to provide the Services to your Employer, such as your national insurance number. |
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| 2 | Personal Data that you voluntarily give us by:
• registering to use and creating a user account on the Hastee App (“User Account”); • registering to use and (if your application with Contis is successful) to create aHastee Account; • registering to receive bespoke financial education content (please note: though you may provide this via our third-party provider of financial education services, Hastee is the controller of any such personal data and that service provider the dataprocessor); • making a request, via the Hastee Technology, for payment of a Withdrawal to you by Hastee on your Employer’s behalf (“Withdrawal Request”); • corresponding with us by email, telephone call or other means; • requesting an invitation code from our website; • sharing via the Hastee App social media function; • entering into any competition, promotion or survey; or • reporting a problem with the Hastee App. |
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| Identity Data | You | Hastee App log-in details: username (or similar identifier); password; and (but only in limited situations where required by your Employer todeliver the Employee Benefit to you) your date ofbirth and/or national insurance number.
If you chose to receive bespoke financial education content: first name; last name; username (whichwould be your email address) and password. Additionally, but |
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| only if you choose to provide it to receive financial education tailored to your specific individual circumstances: date of birth. | |||
| Contact Data | Email address; mobile number; residential address | ||
| Financial Data | Bank account number, sort code or other account or card details (cardholder name and card number)into or onto which payment of a Withdrawal would be made to you.
If you opt in to receive bespoke financial education content and choose to provide this personal data: salary/wage; any sources of additional income oruse of financial products. |
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| Employment Data | Employer name. | ||
| Marketing and Communications Data | Your preferences in receiving marketing from us,our third parties, and your communicationpreferences by opting to manage your preferences through a link at the bottom of any email we sendyou. | ||
| Location Data | If you opt in to receive bespoke financial education content and choose to provide this personal data: postcode. | ||
| 3 | Personal Data that the Hastee Technology collects: i) about you and your deviceautomatically each time you use the Hastee Technology, including by the use of cookies and other similar technologies; and ii) about Withdrawal transactions made on the Hastee App. For more information on our cookie policy please see the “How we use cookies and other technologies” section below. | ||
| Identity Data | Hastee (by Hastee Technology) | One-time unique registration code
Records of future log-ins to your User Account once you have become a Registered User Login credentials (username and password) |
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| Transaction Data | Transaction and usage information including details of Withdrawal payments made to you by Hastee on behalf of your Employer, via the Hastee App, andany charges associated with such payments (“Charges”). | ||
| Device Data | Mobile device type and model, mobile device identifier, mobile network information, operating system and platform and other technology on the devices you use to access the Hastee Technology, internet protocol (“IP”) address used to connectyour computer to the internet, your login information, browser type and version, time zone setting and location, browser and browser plug-in types and versions | ||
| Usage Data | Information about your visit, including the fullUniform Resource Locators (“URL”) clickstream to, through and from the Hastee Technology (including date and time); the pages you viewed; page response times, download errors, length of visitsto certain pages, page
interaction information (such as scrolling, clicks, and |
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| mouse-overs), and methods used to browse away from the page. | |||
| Location Data | We use GPS technology on your device todetermine your current location to support the time and attendance functionality of the Hastee App (youwill confirm the activation of the collection of suchlocation data via a pop up in the Hastee App). Pleasenote that you can withdraw your consent to your location data being used for this purpose by changing the settings in the Hastee App. | ||
| Camera Data | Data collected from your device’s camera where the camera is used as part of the “check in” and“check out” functionality of the Hastee App (forexample to collect QR code data). | ||
| Aggregate Data | Statistical or demographic data which may bederived from your Personal Data, and which, once in aggregated form, does not directly or indirectlyreveal your identity. E.g., We may aggregate yourUsage Data to calculate the percentage of users using a specific feature of the Hastee Technology. However, if we combine or connect Aggregated Data with your Personal Data so that it can directly or indirectly identify you, we treat the combined data as Personal Data which will be used inaccordance with this Privacy Policy. | ||
Sensitive Data
In some jurisdictions, Personal Data that is considered “sensitive personal data” (or “special categories of data”) under applicable laws may be subject to more stringent protection and limitations on use than other Personal Data. What is considered sensitive Personal Data varies from country to country, but generally includes information relating to a person’s sexual orientation, racial or ethnic origin, alleged or actual criminal offence, physical or mental health or condition, tradeunion membership, political opinions, religious belief or genetic data. It is our intent that information collected will not includeany Personal Data that would be considered sensitive Personal Data under the applicable laws of any jurisdiction.
MINORS
The Hastee Technology is not intended for children below 16 and we do not knowingly collect Personal Data relating to such children. In the event that such data is provided to us, we reserve the right in our absolute discretion to delete it.
THE LEGAL BASES AND PURPOSES FOR OUR USING PERSONAL DATA
We will only use your Personal Data where the law allows us to do so and for the purposes for which we collected it as listedin Table 2, unless we reasonably consider that we need to use it for another reason and that reason is compatible with theoriginal purpose.
If we need to use your Personal Data for an unrelated purpose, we will update this Privacy Policy and we will explain thelegal basis which allows us to do so.
LEGAL BASIS
We process your information based on the following legal bases:
Pursuant to contract
- Where the provision of your Personal Data is necessary for us to perform a contract we have entered into with you –namely, to comply with our obligations to you under our Hastee App User Terms and for you to have access to theEmployee Benefit and the full functionality of the Hastee
Legitimate interest
- Where it is necessary for our interests in conducting and managing our business to give you the best product and most secure experience.
- To send you direct marketing communications by email or You can unsubscribe from such communications in advance of receiving any by emailing gdpr@hastee.com or at any time by clicking the link in the email itself.
We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your Personal Data for our legitimate interests. More detail about the specific legitimate interestspursued in respect of each purpose we use your Personal Data for is set out in the table below.
Compliance with Law
- Where we need to comply with a legal or regulatory
Consent
- Where we have your specific, freely given, informed and unambiguous consent to carry out the processing for thepurpose in
- On the basis of consent we may share your information with non-affiliated third parties, for example, for them todevelop or provide you with their own products or market to you, where they have the requisite legal permissionsto do We will get your express opt-in consent before we share your personal data with any third party formarketing purposes.
We have set out in Table 2, the legal bases relied on in respect of the relevant Purposes for which we use your PersonalData.
TABLE 2: PURPOSE AND LEGAL BASIS FOR PROCESSING PERSONAL DATA
| TYPE OFPERSONAL DATA | PURPOSE FOR COLLECTING | LAWFUL BASIS FOR PROCESSING |
| Identity Data Contact Data Financial Data Employment Data Location Data Camera Data |
Account creation and use To create your User Account on the App. To provide details and retain records of your Withdrawal transactions. To provide you with bespoke financial education content if this is something you opt to receive. To allow us to share your personal data with our third-party provider ofbespoke financial educationso that they can register auser account for you anddeliver content tailored to your individual circumstances. |
Pursuant to contract:To fulfil our obligations to you under theHastee App User Terms (which you agreed to as part of the process of creating your UserAccount) and enable you to take advantageof the Employee Benefit. To enable Hastee to invite you to use andinstall the Hastee App and register you as anew Registered User, to log back in should youhave forgotten your password or find yourself locked out for other reasons; to submitWithdrawal Requests and receive payments ofWithdrawals (including via the Hastee App) on the basis of the Employment and FinancialData provided and, where used by you to checkin/out of work, the Location Data and CameraData. To notify you about any changes to the Charges for the payment of Withdrawals to you. To allow third-party providers to provide toyou, on our behalf, bespoke financial education services tailored to your individual circumstances. In such situation, Hastee isthe controller of your personal data and suchthird- party provider the processor. Legitimate Interest: To keep transaction records of Withdrawal payments made to you via the Hastee Technology and Charges associated withthem so that this data can be provided to your Employer by us at the end of each payroll period so that we may seekreimbursement from them in respect of the same. The provision of Services to your Employer(our client) under the Client Contract which enable them to provide the Employee Benefit to you. The effective and efficient management ofour business, including the ability to recover sums owing to us by your Employer(s) inrelation to the payment of Withdrawals to you and Charges in relation to them. Ensuring that your data is accurate so that we can ensure the functionality of the HasteeApp and security of your Personal Data. |
| Identity Data Contact Data Marketing and Communication Data |
Relationship ManagementTo manage our relationship with you and deliver content.To provide customer support to you regarding your User Account and Withdrawal Payments or to investigate any complaint or query. | Pursuant to contract: to fulfil our obligations: • to you under the Hastee App User Terms and to advise you if the Employee Benefit or the Chargesin respect of it are changing in anyway; and • to your Employer under the terms of the Client Contract between usand them. Legitimate Interests: of keeping records updated and analysing how customers useour products/ services). To enable you to participate in a prize draw, competition or complete a survey. |
| Marketing and Communication Data | Marketing communication information Such as details of your preferences for receiving marketing from us and our third parties and your communicationpreferences (if applicable). To make recommendations to you about which goodsor services Hastee group companies provide thatmay be of interest to you; via email, text, in-app notifications and/or push notifications. |
Legitimate Interests: it is in our legitimate interest to provide you with information that is relevant to you, where you have signed up fora User Account. You will be provided with the opportunity to unsubscribe from such communications by clicking on a link in the email itself or, in advance, by emailing gdpr@hastee.com. Further details as to howto manage your preferences are set out in this Privacy Policy. Consent: On the basis of consent we mayshare your information with non-affiliated third parties, for example, for them to developtheir own products or market to you, where they have the requisite legal permissions to do so. |
| Identity Data Contact Data Employment Data Financial Data Device Data |
Important Notices,Educative Materials, Benefits and TransactionalE-mailTo fulfil our obligations to your Employer under the Client Contract. | Contract: We will send to your email addressnon- commercial electronic email messages with important information about: us; the Hastee Technology; the Employee Benefit; or advice pertaining to personal finance that your Employer has requested we provide to you as part of our performance of the Client Contract(the “Financial Education Series”). Please notethat any opt-out you have made in relation to promotional content (including the receipt of pushnotifications and/or in-Hastee App notifications)will not apply to these Transactional Emails, theFinancial Education Series or to anycommunications which we are required to send you pursuant to the performance of our obligations to your Employer under the Client Contract. |
| Identity Data Contact Data Employment Data Financial Data Device Data |
Fraud PreventionTo keep the Hastee Technology operational and secure. To keep your Personal Data and identity secure. |
Legitimate Interests: We have a legitimate interest in ensuring the ongoing security and proper operation of our services, website and associated IT services and networks. Pursuant to contract: To fulfil our obligations to you under the Hastee App User Terms and to your Employer under the Client Contract. |
| Identity Data Contact Data Transactional Data Device Data Usage Data Aggregated Data |
Optimisation and AnalyticsTo understand andmeasure how users use our Hastee Technology andto use this data to improve it. | Legitimate Interests: •To ensure content is presented in the most effective manner for your device and the proper operation and improvement ofthe Hastee Technology. It is in ourlegitimate interest to better understand how to deliver our services to ourcustomers and prospective customers,such as though finding efficiencies andnew opportunities. To allow for participation in interactive features of the Hastee Technology when youchoose to do so. •To develop our products/ Services and grow our business, though understanding app usage and how to improve the service and/or Hastee Technology. |
| Device Data Identity Data Contact Data Transactional Data Financial Data Employment Data |
TroubleshootingTo track issues that might be adversely affecting the operation of the Hastee Technology. |
Legitimate interests:
To help you in the event you have a problem with your User Account, the Hastee App orthe submission of a Withdrawal Request orreceipt of a payment of a Withdrawal. |
| Device Data Identity Data Contact Data Employment Data |
Changes to our App, the App User Terms, Employee Benefit and Privacy Policy. | Legal Obligations: To notify you of changesto the Hastee App, the App User Terms, thisPrivacy Policy, the Services delivered to yourEmployer or any change to the Charges foraccessing the Employee Benefit. |
HOW WE MAY SHARE YOUR PERSONAL DATA
| RECIPIENTS | CATEGORIES OF PERSONAL DATA SHARED | REASON SHARED |
| Your Employer(s) | Transaction Data Identity Data |
We share, with your Employer, at the end of each payroll period, details of the consolidated Withdrawalsyou have received from us on your Employer’s behalfand any associated Charges during that payroll period (using your first name, last name and payroll orworker identification number to identify you) to enable your Employer to make the appropriate deductions from your pay at the end of each pay period. |
| Service Providers | Identity Data Contact Data Financial Data Employment Data Transaction Data Device Data Aggregate Data Usage Data |
So that survey, hosting, analytics, search engine and other technical assistance providers can assist us inthe improvement and optimisation of the Hastee Technology and the provision of Services to your Employer.
Survey companies are only permitted to use your Personal Data to request a review from you in thecontext of your use of the Hastee App. They may notuse it for any other purpose. Our IT service providers provide us with software development, business analyst and system administration services. So that third-party providers of bespoke financial education may provide you with content tailored toyour individual circumstances. Such financial education providers are only permitted to use yourPersonal Data for this purpose and not for any other purpose. Specifically – they may not use it to market or sell products or services to you. |
| Communication Partners | Contact Data | Our third-party partners provide live chat and facilitate communication (like email, chat and phone),in order to provide you with the full functionality of theHastee App.
They may ask for your email and Employer name to provide assistance to you. |
| Transaction Processing Partners | Identity Data Contact Data FinancialData Transaction Data |
So that these third-party partners may process transactions on our behalf. |
| Professional advisers | Identity Data Contact Data Transaction Data Financial Data Device Data Usage Data |
To our lawyers, bankers, consultants, auditors and providers of banking, legal, insurance andaccountancy services if such disclosure is reasonably required to comply with any legal obligation; to enforceany contract entered into with you or your Employer; toprotect the rights, property or safety of Hastee or ourcustomers (including by exchanging information with other organisations for the purposes of fraud protection). |
| Hastee Group Companies | Identity Data Contact Data FinancialData Transaction Data Employment Data Usage Data Device Data Aggregate Data Location Data Camera Data |
We may share your information with our corporate affiliates and associates (e.g., parent company, sistercompanies, associated trust entities, subsidiaries, joint ventures, or other companies under common control). We have a legitimate business interest toshare data with our group as it allows us to better understand the performance of our Services and how to offer and improve our product offerings across the group. It also assists us with finding operational efficiencies(such as financial efficiencies though sharing IT infrastructure), making use of group level software solutions and improving our technological offerings which form an integral part of our Service. |
| Purchaser of Hastee and/or any member of the Hastee Group | Identity Data Contact Data Financial Data Transaction Data Employment Data Usage Data Device Data Aggregate Data Location Data Camera Data |
Any entity which purchases all or part of Hasteeand/or any member of the Hastee Group, upon completion of which transaction, Personal Data heldby Hastee about its Registered Users will be one of the transferred assets (whether transferred via abusiness or share sale). We will also shareinformation at the negotiation stage or in a bidding process, as applicable.
We may retain a copy of that information. |
| Law Enforcement Agencies | Identity Data Contact Data Financial Data Transaction Data Employment Data Usage Data Device Data Aggregate Data Location Data |
On the basis of the compliance with a legal obligationfor example if we are required to disclose information pursuant to regulatory, employment, taxation, criminal, terrorist financing and money laundering law requirements. |
| Legal, civil or business affairs | Identity Data Contact Data Financial Data Transaction Data Employment Data Usage Data Device Data Aggregate Data Location Data |
We may disclose information when we believe disclosureis appropriate to comply with the law, to enforce or apply applicable terms and conditions and other agreements, or to protect our rights, property or safety or the rights,property or safety of our affiliates, users, or third parties.For example, we may disclose information in response tosubpoenas, arbitration proceedings, warrants, or court orders, or in connection with any legal process, or to comply with relevant laws. We may also shareinformation in order to establish or exercise our rights, todefend against a legal claim, to investigate, prevent, or take action regarding possible illegal activities,suspected fraud, safety of person or property, or aviolation of our policies. |
OUR USE OF COOKIES AND OTHER SIMILAR TECHNOLOGIES
What are cookies?
We may collect information using “cookies”. Cookies are small data files stored on the hard drive of your computer or mobiledevice by a website. We use them to distinguish you from other users of the Hastee Technology and to remember yourpreferences. This helps us to provide you with a good experience when you use the Hastee Technology and also allows us toimprove it. We may use both session cookies (which expire once you close your web browser) and persistent cookies (whichstay on your computer or mobile device until you delete them) to provide you with a more personal and interactive experience.
Categories of cookies
The Hastee Technology uses two broad categories of cookies:
- First party cookies, served directly by us to your computer or mobile device; and
- Third party cookies, which are served by our partners orservice
Type & purposes of cookie use
The Hastee Technology uses the following types of cookies for the purposes set out below:
- Essential cookies: to provide you with services available through the Hastee Technology to enable you to use some ofits For example, they allow you to log in to secure areas of the Hastee Technology and help the content of the pages you request to load quickly. Without these cookies, the services that you have asked for cannot beprovided, and we only use these cookies to provide you with those services.
- Functional cookies: to allow the Hastee Technology to remember choices you make when you use the Hastee Technology, such as remembering your language preferences, login details and any aspects of the Hastee Technology which you can customise. The purpose of these cookies is to provide you with a more personalexperience and to avoid you having to re-enter your preferences every time you visit the Hastee
- Analytics and performance cookies: to collect information about traffic to the Hastee Technology and how it is The information gathered via these cookies does not “directly” identify any individual user. However, it mayrender such visitors “indirectly identifiable”. This is because the information collected is typically linked to a pseudonymous identifier associated with the device you use to access the Hastee Technology. The information collected is aggregated and anonymous. It includes the number of visitors to the Hastee Technology, the websites that referred them, the pages they visited, what time of day they visited it, whether they have visited the HasteeTechnology before, and other similar information. We use this information to help operate the Hastee Technology more efficiently, to gather broad demographic information and to monitor the level of activity on the Hastee Technology.
- We use Google Analytics for this purpose. Google Analytics uses its own It is only used to improve how the Hastee Technology works. You can find out more information about Google Analytics cookies here: https://developers.google.com/analytics/devguides/collection/analyticsjs/cookie-usage
- You can find out more about how Google protects your data here: google.com/analytics/learn/privacy.html
- Targeting Cookies: these will collect information about your browsing habits and allow us to deliver content andfunctionality that best suits you and your interests while you are browsing our site and other sites on the
- Social Media Cookies: these cookies are set by a range of social media services that we have added to the site toenable you to share our content with your friends and They are capable of tracking your browser across other sites and building up a profile of your interests. This may impact the content and messages you see on otherwebsites you visit.
Disabling cookies
You can typically remove or reject cookies via your browser settings. In order to do this, follow the instructions provided byyour browser (usually located within the “settings”, “help” “tools” or “edit” facility). Many browsers are set to accept cookies until you change your settings.
If you do not accept our cookies, you may experience some inconvenience in your use of the Hastee Technology. Forexample, we may not be able to recognise your computer or mobile device and you may need to log in every time you visit the Hastee Technology.
Further information about cookies, including how to see what cookies have been set on your computer or mobile device and howto manage and delete them, visit www.allaboutcookies.org and www.youronlinechoices.com.uk.
You can also prevent the use of Google Analytics relating to your use of the Hastee Technology by downloading and installing the browser plugin available via this link: http://tools.google.com/dlpage/gaoptout?hl=en-GB
Mobile Privacy
Although you do not have to provide your location information to us to use our Hastee Technology, your Employer may require a postcode or geolocation as part of its provision of the Employee Benefit to you and we therefore require it toenable our Hastee App to function to deliver the Services to your Employer. For example, where your Employer requires youto check in and check out of a work or job location to prove your physical presence or the time at which you started / endedyour work. If you request that we confirm your location or IP address, we may use your geolocation information to do so. Our Hastee Technology may also tell us the region of the world in which you are located when you use the Hastee Technology. If you have questions about location and notification privacy, please contact your mobile service provider or the manufacturer of your device to learn how to adjust your settings.
DATA STORAGE AND TRANSFER
For the purposes of this section the following definitions apply:
European Data Protection Laws means any and all applicable laws relating to the processing of personal data and privacy applicable in the EEA, including applicable guidance and codes of practice issued by the European Commission orany other supervisory authority and including, to the extent applicable, the GDPR.
GDPR means Regulation (EU) 2016/679 of the European Parliament and the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data and any legislationthat amends, re-enacts, replaces or supplements it.
UK Data Protection Laws means any and all applicable laws relating to the processing of personal data and privacy applicable in the UK, including applicable guidance and codes of practice issued by the UK Information Commissioner orany other supervisory authority and including, to the extent applicable, the Data Protection Act 2018 and any nationallegislation that amends, re-enacts, replaces or supplements the GDPR in the United Kingdom as a consequence of thewithdrawal of the United Kingdom from the European Union and the domestic data protection laws.
The Personal Data that we obtain about you is stored on third party servers. We process such Personal Data on serverslocated both within the United Kingdom and outside the United Kingdom, in the European Economic Area. In connection with any transfers of your Personal Data, we endeavour to ensure that the entities or people to whom we provide Personal Datahold it subject to appropriate safeguards and controls. Whenever we transfer your Personal Data:
- out of the United Kingdom to countries that have not been deemed to provide an adequate level of protection for Personal Data by the United Kingdom, we will ensure a similar degree of protection is afforded to it by implementing the following safeguards:
- Transfers of Personal Data will only take place where the organization receiving the PersonalData has provided us with adequate safeguards and subject to a written agreement, in line withthe requirements of UK Data Protection Laws applicable to processors and Personal Data transfers. We will use specific contracts approved by the UK Government to give Personal Datathe same protection as it has in the United
- out of Europe to countries that have not been deemed to provide an adequate level of protection forPersonal Data by the European Commission, we will ensure a similar degree of protection is afforded to it by implementing the following safeguards:
- Transfers of Personal Data will only take place where the organization receiving the PersonalData has provided us with adequate safeguards and subject to a written agreement, in line withthe requirements of European Data Protection Laws applicable to processors and Personal Data We use specific contracts approved by the European Commission, which give Personal Data the same protection it has in Europe. For further details, see European Commission: Modelcontracts for the transfer of Personal Data to third countries.
KEEPING YOUR PERSONAL DATA SECURE
The transmission of information by the internet is not completely secure. Although we will endeavour to protect your Personal Data, we cannot guarantee the security of your data transmitted via the Hastee App; any transmission is at yourown risk. Once we have received your information, we will use security features to try to prevent unauthorised access.
We have put in place appropriate security measures to prevent your Personal Data from being accidentally lost, used oraccessed in an unauthorised way, altered or disclosed. We limit access to your Personal Data to those employees and other staff who have a business need to have such access.
RETENTION OF YOUR PERSONAL DATA
We will retain your Personal Data for so long as we reasonably need to use it for the purposes set out above unless alonger retention period is required by law (e.g. for tax, regulatory or future potential claims purposes). We will retain your information for as long as necessary for the purposes described in this Privacy Policy and in accordance with the following principles:
- For the duration required pursuant to a legal obligation;
- For the period required by applicable law and regulations, for the activities relating to the service; or
- For the duration of legal proceedings and the related limitation periods, for processing activities necessaryto protect against legal liability and enforce our
THIRD PARTY LINKS
The Hastee Technology may, from time to time, contain links to and from the websites of our partner networks, advertisers and affiliates and other third-party websites, plug-ins and applications. Please note that these websites and any servicesthat may be accessible through them have their own privacy policies and that we do not accept any responsibility or liability for these policies or for any personal data that may be collected through these websites or services, such as Contact and Location Data. Please check these policies before you submit any personal data to these websites or use these services.When you leave the Hastee Technology, we encourage you to read the privacy policy of every site you visit.
WHAT CHOICES AND RIGHTS YOU HAVE REGARDING YOUR PERSONAL DATA
If your Personal Data was collected by another party under their privacy policy, we may have to refer you to that party in order to exercise the choices regarding your Personal Data. If your data was collected by us under this Privacy Policy, you can make the following choices regarding your Personal Data. In order to exercise any of these rights, you can contact usby using the contact information provided at the end of this Privacy Policy.
It is important to note that Hastee is designed to collect and manage Personal Data collected in the course of your employment or relationship with your Employer. Some information we hold about you is processed on behalf of yourEmployer on their instructions. Where this is the case we will either ask that you contact them directly or we will contactthem for instructions in relation to any request you make for that data and they may either respond to you directly or ask us to respond on their behalf. In such circumstances, it will be your Employer’s obligation to comply with the request.
- Access to Your Personal Data: You may request access to your Personal Data by contacting us using the contact information provided at the end of this Privacy Policy. If permitted, and required by law, we will grant you reasonableaccess to the data that we have about
- Changes to Your Personal Data: We rely on you to update and correct your Personal Note that we may keep historical Personal Data in our backup files as permitted by law. If our services do not permit you to update or correctcertain Personal Data, please contact us by using the contact information provided at the end of this Privacy Policy.
- Deletion of Your Personal Data: Typically, we retain your Personal Data for the period necessary to fulfil the purposes outlined in this Privacy Policy, unless a longer retention period is required or permitted by You may,however, request information about how long we keep a specific type of Personal Data, or request that we delete yourPersonal Data by contacting us using the contact information provided at the end of this Privacy Policy. If permitted by law, we may grant a request to delete Personal Data, but you should note that in many situations we are required to keep your Personal Data to comply with our legal obligations, resolve disputes, enforce our agreements, or foranother one of our business purposes. If we grant your request to delete your Personal Data, you should note that inmany situations we may no longer be able to provide you with access to the functionality and services of the HasteeTechnology.
- Objection to Certain Processing: You may object to our use of your Personal Data by contacting us using the contact information provided at the end of this Privacy Policy.
- Marketing: When we send you promotional emails, push notifications and/or in-app notifications (“Promotional Content”) based on your consent or as permitted by applicable laws, you have the right tounsubscribe or amend your in-app preferences You also have the ability to unsubscribe to Promotional Content by following the unsubscribe instructions in e-mails. Please allow us up to 10 business days to implement your request to unsubscribe. Note that even if you decide to opt out of receivingPromotional Content, we may still send you service-related communications.
- Important Notices and Transactional E-mails: From time to time we may send to your email address non-commercial electronic email messages with important information about us, the Hastee Technology and/or the Employee Benefit (“Transactional Emails”); or advice pertaining to personal finance that your Employerhas requested we provide as part of our performance of the Client Contract (the “Financial Education Series”). Please note that even if you decide not to receive Promotional Content, will still send you Transactional Emails and the Financial Education Series.
- Financial Education Series: You also have the ability to unsubscribe from the Financial Education Series by following the unsubscribe instructions in e-mails. Please allow us up to 10 business days to implement yourrequest to Note that even if you decide to opt out of receiving the Financial Education Series, we may still send you Transactional Emails.
- Mobile: We may distribute text messages to your mobile You may opt out of receiving text via the textsyou receive.
- Revocation of Consent: Where we rely on consent as our lawful basis for processing, if you revoke your consent forthe processing of your Personal Data, then we may no longer be able to provide you with access to the functionality andservices of the Hastee Technology. In some cases, we may limit or deny your request to revoke consent if the lawpermits or requires us to do so, or if we are unable to adequately verify your You may revoke consent to processing (where such processing is based upon consent) by contacting us using the contact information providedat the end of this Privacy Policy.
If you would like to exercise any of the rights described above, please contact us by emailing: gdpr@hastee.com.
We may need to request specific information from you to help us confirm your identity and verify your right to access yourPersonal Data (or to exercise any of your other rights). This is a security measure to ensure that Personal Data is notdisclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relationto your request to speed up our response. We try to respond to all legitimate requests within one month. Occasionally it maytake us longer than a month if your request is particularly complex or in the event you have made a number of requests, inwhich case, we will notify you and keep you updated.
If you feel that your complaint has not been adequately resolved, please note that you have the right to contact the Information Commissioner’s Office (“ICO”), the UK supervisory authority for data protection issues. Please see https://ico.org.uk/make-a-complaint/ for information on how to do this.
CHANGES TO THE PRIVACY POLICY AND YOUR DUTY TO NOTIFY US OF CHANGES
We may change this Privacy Policy and our information collection, use, and sharing practices over time. To the extent that our Privacy Policy changes in a material way, we will notify you of such changes in accordance with applicable dataprotection law requirements.
HASTEE GROUP COMPANIES
- Hastee Technologies HR Ltd, a company incorporated in England with company number 14155527 and of registered office C/O Legalinx Ltd. 3 Floor, 207 Regent Street, London W1B 3HH.
- Hastee HR Ltd, a company incorporated in England with company number 14152229, of registered office, C/O Legalinx Ltd. 3 Floor, 207 Regent Street, London W1B 3HH.
- Hastee Europe L.U., a company registered in Spain with NIF B-67.374.504 at Plaça Pau Vila n.º 1, 2 A, Barcelona, Spain.
HOW TO CONTACT US
- Our address for all queries in relation to this policy is: Hastee, Plaça Pau Vila º 1, 2 A, Barcelona, Spain.
You can contact us with any questions, comments and requests regarding this Privacy Policy or your Personal Data by emailing: gdpr@hastee.com.
The contact details of our Data Protection Officer are: email: dpo@hastee.com; phone: 07866 564702.
