1. Who we are
1.1 De La Rue International Limited, a company registered in England and Wales with company registration number 00720284, whose registered address is at De La Rue House, Jays Close, Viables, Basingstoke, Hampshire RG22 4BS (De La Rue) is the controller and is responsible for your personal data.
1.2 De La Rue respects your right to privacy and will process personal information you provide only in accordance with the General Data Protection Regulation, Data Protection Act 2018, the Privacy and Electronic Communications (EC Directive) Regulations 2003 and other applicable privacy laws.
2. The information collected and how it is used
2.1 We will only use your personal data when the law allows us to do so.
2.2 We have listed below the types of personal data about you which we may collect, use, store and transfer, the purpose for which we are collecting it, and the lawful basis for processing relating to each type of personal data.
|Personal Data||Type of Data||Purpose||Lawful basis for processing|
To install the app and register you as a new app user
To manage our relationship with you
Performance of a contract with you
Necessary to comply with legal obligations (to inform you of any changes to our Terms & Conditions or this policy)
||Usage Data||To track user engagement||Necessary for our legitimate interest (marketing)|
2.3 We do not collect any special category personal data about you (such as details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health, or genetic and biometric data). Nor do we collect any information about criminal convictions and offences.
2.4 We collect the Identity Data and the Profile Data when you register an account for the App. We collect the Usage Data when you use the App.
2.5 We do not use any cookies.
3. Third-party use of information
3.1 De La Rue may disclose your personal data to any of its group companies but will not otherwise disclose, sell or rent your personal information to any third party unless you have consented to this. If you do consent but later change your mind, you may contact De La Rue (at firstname.lastname@example.org) to ask for any such activity to stop.
3.3 De La Rue may disclose your personal information where required to do so by applicable law, by a governmental body or by a law enforcement agency.
4. International transfers
4.1 We use Amazon Web Services to host the App in the UK.
4.2 We will not transfer your personal data out of the UK, unless we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:
- transferring your personal data to countries that have been deemed to provide an adequate level of protection for personal data; or
- entering into standard contractual clauses that have been approved for use in the UK and which give personal data the same protection it has in the UK.
5.1 Whilst De La Rue takes appropriate technical and organisational measures to safeguard the personal information that you provide, no transmission over the Internet can ever be guaranteed secure. Consequently, please note that the security of any personal information that you transfer over the Internet to De La Rue cannot be guaranteed.
5.2 De La Rue has put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so or where it is otherwise prudent to do so.
6. Data retention
6.1 De La Rue 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. De La Rue 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.
6.2 To determine the appropriate retention period for personal data, De La Rue considers 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.
7. Your rights
7.1 You have the right to:
- request access to the personal data that we hold about you;
- request correction of the personal data that we hold about you;
- request erasure of the personal data that we hold about you (where there is no good reason for us continuing to process it);
- object to processing of your personal data (where we are relying on a legitimate interest to process the data);
- request the transfer of your personal data to you or to a third party (where your personal data is in an automated form and used by us for the purposes of a contract); and
- request that we suspend processing of your personal data if:
- you want us to establish the data's accuracy;
- our use of the data is unlawful but you do not want us to erase it;
- you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or
- you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it
If you wish to exercise any of the rights set out above, please contact us at email@example.com.
You also 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 we request that you please contact us in the first instance.