PRIVACY POLICY
The purpose of this Privacy Policy is for you to understand how we collect and use your information, your privacy rights, and what information we are required to keep. In compliance with applicable Data Privacy regulations, you may contact us with any privacy related questions you may have.
For the operation of the CloudPay Now App, CloudPay acts as the Controller for any Cookies on the App and any analytical data that comes from the usage of those Cookies. For any personal data pertaining to payroll, CloudPay remains the Processor of this data, with your employer remaining the Controller of this data. Consequently, all your data rights over this data should be dealt with through your employer.
INTRO
Since we are a subscription-only service that is limited and not available to everybody, we collect information in a particular manner, where transparency is key to our business. Information that we gather is mostly Personal Information (PI), and it refers to information that can be associated with you and/or identify you. It does not include information that has been aggregated, de-identified, or anonymized so it does not identify you.
This policy applies whenever you access and use CloudPay Now.
PERSONAL INFORMATION WE COLLECT on CloudPay Now
The information CloudPay collects includes:
  • Contact data – name, address, mobile number and email address.
  • Personal employment records –this may include all or some of the following information: position, employment history, date of birth, and may include special categories of information relevant to the employment application like medical conditions, information necessary to make payments to you, and any other information you provide.
  • Usage data – how you interact with CloudPay Now. 
    • HOW WE COLLECT YOUR PERSONAL DATA
    The personal data we process is voluntarily obtained directly from you and from your employer, who provide personal information regarding you as an employee so that we can provide our payroll services, and CloudPay Now. More specifically, our sources and methods are:
  • From CloudPay Now where you may enter personal information
  • From your employer’s data, shared for the purpose of providing the CloudPay Now service to you
    • For information collected via Cookies, CloudPay is using technology that many other websites and apps employ, small data files stored on your computer’s hard drive, to collect information (“Cookies”). If your browser is set to accept Cookies, then your browser adds the text in a small file. CloudPay does not use Cookies to read any other information on your computer’s hard drive. You may refuse to accept Cookies by activating the setting on your browser which allows you to refuse the setting of Cookies. However, if you select this setting you may be unable to access certain parts of our Website. Unless you have adjusted your browser setting so that it will refuse Cookies, our system will issue Cookies when you log on to our Website. Please note that any third-party sites which are linked via our web site may also use Cookies and CloudPay has no control over those.
    For web usage data, CloudPay uses web beacons, or transparent GIF files, provided by our service provider to report activity on our site. The beacons help us manage our online advertising and measure its effectiveness. These files enable our service provider to recognize a Cookie on your web browser, which in turn enables us to learn which communications are most effective. Either CloudPay or our services providers place the Cookie. The information that CloudPay collects by means of these technologies is anonymous and is not personally identifiable unless you have chosen to identify yourself through a form on the website.
    HOW WE USE YOUR PERSONAL INFORMATION
    CloudPay uses personal information provided to us only for the purpose it was provided. Those purposes include:
  • (i) To process payroll on behalf of our customers and carry out obligations arising from an agreement entered into between your employer and CloudPay. (This will include using your data to ensure that the total amount of successful Pay Now’s you have received is reflected in the calculation of your earnings for each Payment Period and deducted from the overall amount that you have earned in that Payment Period. By using CloudPay Now for a Pay Now request, you authorise us to share that information with your employer);
  • (ii) To provide you with cash payments against your earned salary through our CloudPay Now solution;
  • (iii) To notify you about changes to our payroll solution;
  • (iv) For business development, customer relations and contract management;
  • (v) To allow you to participate in interactive features of our service when you choose to do so;
  • (vi) To carry out legal and regulatory obligations such as anti-money laundering checks;
  • (vii) We will monitor the number of Pay Now’s you have made during each Payment Period.
    • For information collected via Cookies, CloudPay uses that information to authenticate your access to various areas of our websites, and tailor its content to your preferences. Cookies also help us analyse web traffic in general. You can set your browser to refuse cookies, or to warn you before a cookie is placed.
    We may use and share information in a de-identified form that does not allow an individual or customer to be identified, primarily to enhance your use of CloudPay Now and for benchmarking purposes.
    We do not sell personal information to any third parties.
    LEGAL BASIS FOR PROCESSING YOUR INFORMATION
    Under the General Data Protection Regulation (GDPR) the lawful bases for processing your personal data are:
  • (i) To perform a contract we have entered into, or are about to enter into,
  • (ii) Where the processing of your data is necessary for our legitimate interests (or those of a third party and your interests and fundamental rights do not override those interests),
  • (iii) Where we need to comply with a legal or regulatory obligation.
    • Our legitimate interests include: 
  • Providing you with the ability to request cash payments from your earnings,
  • Processing payrolls on behalf of our customers
  • Customer relations
  • Supplier management
  • Product development
  • Operational management
  • Legal obligations including compliance with anti-money laundering regulations
    • Please note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data.
    YOUR RIGHTS UNDER GDPR
    You have the following rights regarding your information subject to certain exemptions. Please note that any rights relating to the personal data within your payroll, are to be directed to your employer as the Controller of this data. You can:
  • Request access to your personal data (commonly known as a “data subject access request”)
  • Request correction of the personal data
  • Request erasure of your personal data.
  • Object to processing of your personal
  • Request restriction of processing of your personal data.
  • Request the transfer of your personal data to you or to a third party.
  • Withdraw consent at any time where CloudPay is relying on consent to process your personal data.
    • To exercise any of these rights relating to the information that you have given directly to us within CloudPay Now, please email your request to us at dpo@cloudpay.net. We may need to verify your identity or to take other steps to respond to your request but we will provide an initial response to such requests within one calendar month.
    COMPLAINTS
    You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk). We would appreciate the chance to deal with your concerns through our own complaints procedure which is in line with best practices before you approach the ICO. This may also enable any issues to be dealt with and resolved more quickly.
    Complaints should be sent to dpo@cloudpay.net..
    Nothing in this privacy policy shall limit the ability of the individual to assert their rights in accordance with applicable privacy laws or other legislation in the country where the processing takes place.
    INTERNATIONAL TRANSFERS
    We may need to share your personal data within the CloudPay group of companies and third parties located inside and outside the European Economic Area (EEA). When we do, we ensure there is a similar degree of protection in managing your information by ensuring one of the following safeguards is in place when applicable:
  • (i) A determination by the European Commission that the country where the data is being sent has been deemed to provide an adequate level of protection for personal data by the European Commission.
  • (ii) Standard contractual conditions approved by the European Commission which give personal data the same protection it has in the EEA are in place with third parties to whom we transfer data, or
    • (iii) A suitable framework recognized by the relevant authorities or courts as providing an adequate level of protection for personal data.
    DATA SECURITY
    CloudPay maintains a comprehensive information security program that contains industry standard technical and physical safeguards designed to prevent unauthorized access to personal information.
    We limit access to personal information to those persons and authorized service providers who have a specific business purpose for maintaining and processing such information. Our employees and other third party providers who have been granted physical access to personal information are made aware of their responsibilities to protect the confidentiality, and integrity of that information and receive relevant training and instruction.
    HOW LONG IS YOUR DATA HELD?
    We will only keep your personal data for as long as necessary to fulfil the purposes we collected it for. This includes statutory retention periods and the CloudPay records management policy. Payroll information is held on behalf of customers and in accordance with their instructions.
    CHANGES TO DATA
    It is important that the personal data we hold about you is accurate and current. you should direct your request to your employer to ensure your personal data maintained by CloudPay is accurate and current as our customers generally have administrative rights to make these changes.
    CONTACT
    CloudPay’s legal department and Data Protection Officer are responsible for overseeing questions in relation to this privacy policy and any requests to exercise your legal rights.
    If you have any queries about this privacy policy, CloudPay’s legal department can be contacted at legal@cloudpay.net or at: CloudPay UK, Kingsgate House, Newbury Road, Andover, Hampshire, SP10 4DU, United Kingdom.
    Last modification to this privacy policy: October 2020.