Last Updated: August 28, 2024
This policy applies to the PhilanthPro group of companies including:
- PhilanthPro Solutions Limited ("PhilanthPro UK"), a company registered in England and Wales (number 15610619) whose registered office is located at 10th Floor 240 Blackfriars Road, London, England, SE1 8NW;
- PhilanthPro Solutions Inc., PhilanthPro UK's parent company and a company registered in Canada with corporation number 1475858-7 and whose registered office is located at 333 Bay Street, Suite 2400, Toronto ON, M5H 2T6, Canada ("PhilanthPro Canada"); and
- PhilanthPro Solutions LLC, another group company registered in the United States with corporation number 7580586 and whose agent's address is located at 251 Little Falls Drive - Wilmington DE 19808, United States ("PhilanthPro US").
PhilanthPro UK, PhilanthPro Canada and PhilanthPro US together are "PhilanthPro".
PhilanthPro 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 when you visit our website philanthpro.com (regardless of where you visit it from) and tell you about your privacy rights and how the law protects you.
Purpose of this privacy policy
This privacy policy aims to give you information on how PhilanthPro collects and processes your personal data through your use of this website, including any data you may provide through this website when you make an enquiry or application for funding.
This website is not intended for children, and we do not knowingly collect data relating to children.
Controller
If you are based in:
- the UK, PhilanthPro UK is the controller and is responsible for your personal data;
- Canada, PhilanthPro Canada is the controller and is responsible for your personal data; and
- the United States, PhilanthPro US is the controller and is responsible for your personal data.
We are 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 us using the details set out below.
Contact details
If you are based in the UK and have any questions about this privacy policy or our privacy practices, please contact us in the following ways:
Full name of legal entity: PhilanthPro Solutions Limited
Email address: info@philanthpro.com
Postal address: c/o 10th Floor, 240 Blackfriars Road, London, England SE1 8NW (ref: PhilanthPro)
If you are based in Canada and have any questions about this privacy policy or our privacy practices, please contact us in the following ways:
Full name of legal entity: PhilanthPro Solutions Inc.
Email address: info@philanthpro.com
Postal address: 333 Bay Street, Suite 2400, Toronto ON, M5H 2T6, Canada
If you are based in the United States and have any questions about this privacy policy or our privacy practices, please contact us in the following ways:
Full name of legal entity: PhilanthPro Solutions LLC
Email address: info@philanthpro.com
Postal address: 251 Little Falls Drive - Wilmington DE 19808, United States
If you are based in the UK, 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). You may have other similar rights if you are based in Canada or the United States/ We would, however, appreciate the chance to deal with your concerns before you approach any regulator so please contact us in the first instance.
Changes to the privacy policy and your duty to inform us of changes
We keep our privacy policy under regular review.
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.
Third-party links
This website 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 website, we encourage you to read the privacy policy of every website you visit.
The data we collect about you
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:
- Identity Data: includes first name, maiden name, last name, username or similar identifier, marital status, title, date of birth and gender.
- Contact Data: includes email address, mail address and telephone numbers.
- Financial Data: includes bank account, financial accounts and salary information.
- Technical Data: includes internet protocol (IP) address, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, and other technology on the devices you use to access this website.
- Usage Data: includes information about how you use our website and services.
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) unless these are disclosed to us by you as being relevant to a particular enquiry or application. Nor do we collect any information about criminal convictions and offences unless these are disclosed to us by you.
Where we need to collect personal data by law or otherwise and you fail to provide that data when requested, we may not be able provide you with funding. In this case, we may be unable to progress matters further.
How is your personal data collected?
We use different methods to collect data from and about you including through direct interactions.
You may give us your Identity, Contact and Financial Data by filling in forms on our website or otherwise or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:
- Create an account with use to use our services and tools and throughout our provision of the services and your use of our tools;
- request information to be sent to you; and
- give us feedback or contact us.
How we use your personal data
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:
- To review the information you provide us when you set up your account and to provide our services and tools to you.
- Where we need to perform the contract we are about to enter into or have entered into with you.
- Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
- Where we need to comply with a legal obligation.
Please refer to the Glossary for the definition of Lawful Basis to find out more about the types of lawful basis that we will rely on to process your personal data.
Sharing of Data
Generally, we do not rely on consent as a legal basis for processing your personal data although we will get your consent before sending third party direct marketing communications to you via email. You have the right to withdraw consent to marketing at any time by contacting us.
We will never share SMS messages with Third Parties.
Purposes for which we will use your personal data
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 as a new user | (a) Identity | Performance of a contract with you |
To manage our relationship with you which will include: | (a) Identity | (a) Performance of a contract with you |
To administer and protect our business and this website (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 use data analytics to improve our website, products/services, marketing, customer relationships and experiences | (a) Technical | Necessary for our legitimate interests (to define types of customers for our products and services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy) |
Third-party marketing
We will get your express opt-in consent before we share your personal data with any third party for marketing purposes.
Cookies
We do not currently use any cookies other than functional cookies required to ensure the functionality of our website. We do not use any alternative cookies.
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 website may become inaccessible or not function properly.
Change of purpose
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.
Disclosures of your personal data
We may share your personal data with our officers and employees and the External Third Parties as set out in the Glossary 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.
International transfers
If you are based in the UK, your personal data is stored in the UK and we do not transfer your personal data outside the UK. Some personal data will however be visible on our platform by PhilanthPro Canada in Canada and PhilanthPro US in the United States to ensure the seamless provision of our services to you.
Data security
We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.
We have 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.
Data retention
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. As a matter of policy, we do not retain information on our systems for more than six years, but 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.
1. Your legal rights
Under certain circumstances, you have rights under data protection laws in relation to your personal data. Please see the glossary below to find out more about these rights:
- Request access to your personal data.
- Request correction of your personal data.
- Request erasure of your personal data.
- Object to processing of your personal data.
- Request restriction of processing your personal data.
- Request transfer of your personal data.
- Right to withdraw consent.
If you wish to exercise any of the rights set out above, please contact us.
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.
What we may need from you
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.
Time limit to respond
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.
Glossary
The follows are each a Lawful Basis for processing personal data:
Legitimate Interest means the interest of our company in conducting and managing the company to enable us to give you the best service and the best and most secure experience. 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. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us.
Performance of Contract means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.
Comply with a legal obligation means processing your personal data where it is necessary for compliance with a legal obligation that we are subject to.
The following are External Third Parties who we may share your personal data with:
- Professional advisers acting as processors or joint controllers including lawyers, bankers, auditors and insurers who provide consultancy, banking, legal, insurance and accounting services.
- Customs authorities, regulators and other authorities acting as processors or joint controllers who require reporting of processing activities in certain circumstances.
Your legal rights
You have the right to:
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:
- If you want us to establish the data's accuracy.
- Where our use of the data is unlawful but you do not want us to erase it.
- Where 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.
- You have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
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 products or services to you. We will advise you if this is the case at the time you withdraw your consent.