Introduction
Welcome to the CPRA's privacy policy.
CPRA respects your privacy and is committed to protecting your personal data. This privacy policy will inform you as to how we look after your personal data and about your privacy rights and how the law protects you.
This privacy policy aims to give you information on how CPRA collects and processes your personal data through your use of our website https://www.cpragroup.com/ (‘the Site’) including any data you may provide through the Site or when we provide you or your organisation with our services as described on the Site (‘the Services’).
This Site is not intended for children and we do not knowingly collect data relating to children.
CPRA Group Limited is the controller and responsible for your personal data (collectively referred to as CPRA, "we", "us" or "our" in this privacy policy).
We have appointed a data privacy manager who is responsible for overseeing questions in relation to this privacy policy. If you have any questions about this privacy policy, including any requests to exercise your legal rights, please contact the data privacy manager using the details set out below
If you have any questions about this privacy policy or our privacy practices, please contact our data privacy manager in the following ways:
Email address: info@cpragroup.com
You have the right to make a complaint at any time to the Information Commissioner's Office (ICO), the UK regulator for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.
We keep our privacy policy under regular review. This version was last updated in November 2023.
It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.
The Site may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our Site, we encourage you to read the privacy policy of every website you visit.
Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).
We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:
We do not collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health, and genetic and biometric data). Nor do we collect any information about criminal convictions and offences.
Where we need to collect personal data by law, or under the terms of a contract we have with you or with the organisation you represent, and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you or your organisation with the Services). In this case, we may have to cancel a service you have with us but we will notify you if this is the case at the time.
We use different methods to collect data from and about you including through:
We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:
We have set out below, in a table format, a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.
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. Please contact us if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below.
| Purpose/Activity | Type of data | Lawful basis for processing including basis of legitimate interest |
|---|---|---|
To register you or your organisation as a new customer | (a) Identity | Performance of a contract with you or your organisation |
Anti Money Laundering checks and onboarding you or your organisation as a customer | Anti Money Laundering | Performance of a contract with you or your organisation |
To process and deliver you or your organisation’s request for the Services including: | (a) Identity | (a) Performance of a contract with you or your organisation |
To manage our relationship with you or your organisation which will include: | (a) Identity | (a) Performance of a contract with you or your organisation |
To administer and protect our business and this Site (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data) | (a) Identity | (a) Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise) |
To deliver relevant Site content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you | (a) Identity | Necessary for our legitimate interests (to study how customers use the Services, to develop them, to grow our business and to inform our marketing strategy) |
To make suggestions and recommendations to you about goods or services that may be of interest to you or your organisation | (a) Identity | Necessary for our legitimate interests (to develop the Services and grow our business) |
We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising.
You can ask us or third parties to stop sending you marketing messages at any time by following the opt-out links on any marketing message sent to you or by emailing info@cpragroup.com
You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of this Site may become inaccessible or not function properly. For more information about the cookies we use, please see COOKIE POLICY
We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.
If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.
Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.
We may share your personal data with the parties set out below for the purposes set out in the table above.
We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.
*Further information about our affiliated entities can be provided on request by emailing info@cpragroup.com.
Occasionally the external third parties that we rely on are based outside the UK so their processing of your personal data may involve a transfer of data outside the UK.
Whenever we transfer your personal data out of the UK, we ensure a similar degree of protection is afforded by ensuring at least one of the following safeguards is implemented:
We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data.
Where we use certain service providers, we may use specific contracts approved by the UK which give personal data the same protection it has in the UK.
Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the UK.
How long will you use my personal data for?
We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.
To determine the appropriate retention period for personal data, we consider the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements.
By law we have to keep basic information about our customers (including Contact and Identity) for six years after they cease being customers for tax purposes.
Under certain circumstances, you have rights under data protection laws in relation to your personal data. Please see below to find out more about these rights:
If you wish to exercise any of the rights set out below, please contact our data privacy manager by emailing: info@cpragroup.com
You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we could refuse to comply with your request in these circumstances.
We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.
We try to respond to all legitimate requests within one month. Occasionally it could take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.
Request access to your personal data (commonly known as a "data subject access request"). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios:
Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain of the Services to you. We will advise you if this is the case at the time you withdraw your consent.
