The Pay Index Privacy Policy

Effective 14th January 2022. You can find the previous version of our Privacy Policy below.

Contents:

1. HOW INFORMATION IS PROVIDED TO US

2. INFORMATION WE COLLECT ABOUT YOU

3. INFORMATION WE RECEIVE FROM OTHER SOURCES

4. HOW WE USE YOUR INFORMATION AND JUSTIFICATION OF USE

5. WHERE WE STORE YOUR PERSONAL INFORMATION

6. DISCLOSURE OF YOUR INFORMATION

7. HOW LONG WE RETAIN YOUR PERSONAL DATA

8. YOUR RIGHTS

9. COOKIES

10. THIRD PARTY WEBSITES

11. CHANGES TO THIS POLICY

12. CONTACT

Information About Us

The Pay Index Limited is registered in England and Wales, having its registered office address at c/o Haines Watts (Berkhamsted) Ltd at 4 Claridge Court Lower Kings Road, Berkhamsted, Hertfordshire HP4 2AF, UK (“our”, “us” or “we” or “The Pay Index”).

What Does This Policy Cover?

Protecting your data, privacy and personal information is very important to The Pay Index. This Privacy Policy (“Policy“) relates to services provided through our website at https://thepayindex.com, our subsidiary website https://propella.uk and our subsidiary websites https://inspo.uk and https://inspo.online

This Privacy Policy applies to the personal data of:

any web user accessing our website;

individuals registering an account with us and providing personal data through the use of our service; [and]

any representative of a business or institution using our services provided to business or institutional users]]

(our “Website” and “Subsidiary Website") or using any of the services offered via the Website, such as The Pay Index widget on a client or partner website

Definitions

“End User” means any individuals using our services to access compensation data, products and services.

“Controller” means a person or company that decide the purposes for which personal data is used and how it is processed.

“Client” means any business user accessing our data services.

“Partner” means a third party that hosts The Pay Index widget on their website.

“Personal Data” means any information that identifies or relates to a particular individual and also includes information referred to as “personally identifiable information” or “personal information” under applicable data privacy laws, rules, or regulations (collectively the “Data Protection Laws”).

“Client Microsite” is a self-contained collection of webpages built specifically for a client. These typically contain a login portal, and access to specific tools for the user to gain access to. They might also contain other learning documentation and videos.

“Student” (“Student”) means any user that is at school, college or already studying in university or higher education.

“Brand Ambassador” (“Ambassador”) means a person acting on behalf of The Pay Index as its representative and interacts with other University Students.

“Website” means a set of related web pages located under a single domain name namely www.thepayindex.com, our subsidiary website https://propella.uk and our subsidiary websites https://inspo.uk and https://inspo.online

For the purpose of the General Data Protection Regulation (the “GDPR”)

Website and Client Microsite/s Users

For all respective occasions above we ensure that we comply with existing Data Protection Laws.

Our Client Microsite/s and Website Users is only for those aged 13 or over (Year 9 plus)

Our Client Microsite/s and Website is only intended for use by persons aged at least 13 years of age. DO NOT USE THE PAY INDEX IF YOU ARE NOT AT LEAST 13 YEARS OF AGE.

How to contact us

If you wish to access an older version of our Privacy Policy, please click here or alternatively please contact us

dpo@thepayindex.com

This policy (together with our Terms and Conditions and any other documents referred to therein), sets out the basis on which any Personal Data we collect from you, or that you provide to us, will be processed by The Pay Index.

Please read this privacy policy carefully to understand the types of information we collect from you, how we use that information, the circumstances under which we will share it with third parties, and your rights in relation to the personal data you provide to us.

1. HOW INFORMATION IS PROVIDED TO US

You will be asked to provide us with your information when you:

fill in forms on our Website, Subsidiary Website Propella.uk, Subsidiary Websites inspo.uk and inspo.online, Client Microsite/s, or correspond with us by phone, email or otherwise;
register to use our Client Microsite/s (creating a The Pay Index account or Propella.uk account or inspo.uk or inspo.online account);
report a problem with our Client Microsite/s; or
complete any surveys we ask you to fill in (although you do not have to respond to these if you do not want to).

Where you enter any details relating to a third party, you must have obtained clear permission from the individuals whose data you provide us with before sharing that data with us.

For the avoidance of any doubt, any reference in this Privacy Policy to your data shall include data about other individuals that you have provided us with.

2. INFORMATION WE COLLECT ABOUT YOU

The Pay Index acting as a Data Controller or as a separate Data Controller with our Client

In respect of all End Users, with regard to each of your visits to our Website, Subsidiary Website Propella.uk, Subsidiary Websites inspo.uk, inspo.online or use of The Pay Index’s Client Microsite/s, we may automatically collect the following information:

device-specific information, such as your hardware model, operating system version, unique device identifiers, and mobile network information;
technical information about your computer, including where available, your IP address, operating system and browser type, for system administration and analytical purposes; and
details of your visits to our Website or Subsidiary Website Propella.uk or Subsidiary Websites inspo.uk, inspo.online including the full Uniform Resource Locators (URL) clickstream to, through and from our Website (including date and time), length of visits to certain pages, and page interaction information (such as scrolling, clicks, and mouse-overs), details of whether you are using the Website, Subsidiary Website Propella.uk, Subsidiary Websites inspo.uk, inspo.online or Client Microsite/s.

The Pay Index acting as a Data Controller

In respect of End Users of The Pay Index’s Client Microsite/s we collect the following types of information and The Pay Index acts as a Data Controller of such Personal Data which is captured as encrypted. Such Personal Data may include but is not limited to:

Contact information such as names, telephone number and email addresses;
Gender;
Location;
Level of Education;
University;
Course;
Graduation Year;
Company Name;
Company Headcount;
Company Annual Revenue;
Industry;
Sub-industry;
Function;
Sub-function;
Specialism;
Skills;
Geographical scope;
Structural level;
Scope of responsibility;
Job Title;
Working arrangement;
Office Location;
Start Date;
Tenure;
Currency;
Last annual base salary;
Last annual bonus;
Equity;
Current Day rate and Days of work
Course;
Primary Major;
Graduation Year;
University;
Year Group;
School/College Name;
First and Last Name;
Postcode;
Free School Meals;
Sexual Orientation;
Disability;
Age;
Date of Birth;
[any information which you provide in any free text field provided for completion on our Websites or in the course of the provision of any of our Services.]

We also create, collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data could be derived from your personal data but is not considered personal data in law as this data will not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. 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 in accordance with this privacy policy.

Certain types of particularly sensitive personal data known as “special categories of personal data” are given additional protection under data protection laws. We current process the following types of special categories of personal data:

Ethnicity

We invite End Users accessing our services to provide information about their ethnicity. The provision of this data is optional, and you will be able to access our services without providing this data. However, if you do choose to provide information about your ethnicity, this data will be used and stored in accordance with this policy.

3. INFORMATION WE RECEIVE FROM OTHER SOURCES

When using our Platform, we will be in contact with third parties who may provide us with certain information about you in order to enable your use of the Platform:

Social networks connected to the services. If you provide your social network account credentials to us via the bio field or otherwise sign into the Platform, Website or Subsidiary Website Propella.uk or Subsidiary Websites inspo.uk or inspo.online through a third-party site or service, you understand some content and/or information in those accounts may be transmitted into your Account with us.
Partners. If you sign up to access The Pay Index through a third party partner website, The Pay Index and/or our partner may indicate that certain data will be shared with that third party.

4. HOW WE USE YOUR INFORMATION AND JUSTIFICATION OF USE

Use of personal information under data protection laws must be justified under one of a number of legal “grounds” and we are required to set out the ground we rely on in respect of each type of personal data which we use, as described in the privacy policy.

The following legal bases apply to our routine use of your personal data:

Contract performance: where the use of your information is necessary to enter into or perform a contract with you;
Legal obligation: where we need to use your information to comply with legal obligations;
Legitimate interests: where we use your information for one of more legitimate business purposes having appropriate regard to your rights and freedoms; and

4.A Purposes for the use of your Personal Data:

In respect of the use of the Platform, The Pay Index uses information held about you (and information about others that you have provided us with) in the following ways:

Types of Personal Data collected	Purpose for the use of Personal Data	Lawful Basis
School and College students (Year Groups 9 - FE Level 2)
Gender; Year Group; School/College Name; First and Last Name; Postcode; Age; Email Address; Password	To enable students to engage with The Pay Index platform	Contract performance Legitimate interest (to ensure the database is accurate and up to date and communicate with users).
	To send monthly product communications and re-engagement communications for inactive accounts as part of the Platform	Legitimate interest (to ensure the database is accurate and up to date and communicate with users).
	To administer and improve the Platform and for internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes in a pseudonymised manner. To ensure the content on our Platform is presented in the most effective manner for you and your computer or mobile device	Contract performance, legitimate interest (to improve the Platform and report internally on usage and gain insight on user basis at a statistical level).
	To enable the Client to analyse School and College Student engagement data.	Contract performance, legitimate interests (to allow the Client to assess how the platform is being engaged with).
University Students
Email Address; Contact Number; Password; First Name; Gender; Location; Highest level of education; Course; Primary Major; Graduation Year; University; Password The Pay Index or Clients may request additional Personal Data to be processed for use of the Platform.	To enable students to engage with The Pay Index platform.	Contract performance, consent (to the extent you provide any sensitive personal data in any free text box, you are consenting to the processing of such sensitive personal data).
	To send monthly product communications and re-engagement communications for inactive accounts as part of the Platform	Legitimate interest (to ensure the database is accurate and up to date and communicate with users).
	To administer and improve the Platform and for internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes in a pseudonymised manner. To ensure the content on our Platform is presented in the most effective manner for you and your computer or mobile device	Contract performance, legitimate interest (to improve the Platform and report internally on usage and gain insight on user basis at a statistical level).
	To enable the Client/s to analyse University Student engagement data.	Contract performance, legitimate interests (to allow the Client to assess how the platform is being engaged with).
Ethnicity	To collate statistical data	Monitoring equality of opportunity.
Professionals/Executives, Alumni & Business School Students
Gender; Location; First Name; Contact Number; Email address; Level of Education; University; Course; Graduation Year; Company Name; Company Headcount; Company Annual Revenue; Industry; Sub-industry; Function; Sub-function; Specialism; Skills; Geographical scope; Structural level; Scope of responsibility; What is your Actual Job Title?; What is your working arrangement?; Where is the office in which your role is based?; When did you start your current role?; How many total years of work experience do you have?; Currency; Last annual base salary; Last annual bonus; Equity; Current Day rate and Days of work The Pay Index may request additional Personal Data to be processed for use of the Platform.	To enable Professionals, University Alumni and Business School Students to engage with The Pay Index platform.	Contract performance, consent (you have the right to opt out at anytime by contacting The Pay Index). Legitimate interest (to ensure the database is accurate and up to date and communicate with users).
	To send monthly product communications and re-engagement communications for inactive accounts as part of the Platform	Legitimate interest (to ensure the database is accurate and up to date and communicate with users).
	To administer and improve the Platform and for internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes in a pseudonymised manner. To ensure the content on our Platform is presented in the most effective manner for you and your computer or mobile device	Contract performance, legitimate interest (to improve the Platform and report internally on usage and gain insight on user basis at a statistical level).
	To enable the Client/s to analyse Professional, Alumni & Business School Student engagement data.	Contract performance, legitimate interests (to allow the Client to assess how the platform is being engaged with).
Ethnicity	To collate statistical data	Monitoring equality of opportunity.
Parents/Carers/Guardians
First Name; Last Name; Contact Number; Gender; Location; Email Address; Child's age The Pay Index may request additional Personal Data to be processed for use of the Platform.	To enable parents/carers/guardians to engage with the Platform	Contract performance, consent (you have the right to opt out at anytime by contacting The Pay Index). Legitimate interest (to ensure the database is accurate and up to date and communicate with users).
	To send monthly product communications and re-engagement communications for inactive accounts as part of the Platform	Legitimate interest (to ensure the database is accurate and up to date and communicate with users).
	To administer and improve the Platform and for internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes in a pseudonymised manner. To ensure the content on our Platform is presented in the most effective manner for you and your computer or mobile device	Contract performance, legitimate interest (to improve the Platform and report internally on usage and gain insight on user basis at a statistical level).
Ethnicity	To collate statistical data	Monitoring equality of opportunity.

With your permission and/or where permitted by law, we may also use your personal data for marketing purposes, which may include contacting you with information, news, and offers on our services. We will always work to fully protect your rights and comply with our obligations under the Data Protection Legislation and the Privacy and Electronic Communications (EC Directive) Regulations 2003, and you will always have the opportunity to opt-out. We will always obtain your express opt-in consent before sharing your personal data with third parties for marketing purposes and you will be able to opt-out at any time by following the opt-out links on any marketing message sent to you. You have the right to withdraw consent to marketing at any time by contacting us.

We do not use your personal data in any automated decision making and/or automated profiling. We will only use your personal data for the purpose(s) for which it was originally collected unless we reasonably believe that another purpose is compatible with that or those original purpose(s) and need to use your personal data for that purpose. If we do use your personal data in this way and you wish us to explain how the new purpose is compatible with the original, please contact us.

5. WHERE WE STORE YOUR PERSONAL INFORMATION

Your Personal Data is maintained, processed and stored by us in the UK. Your Personal Data may be accessed from outside of the UK by our service providers and these countries may not offer an equivalent level of protection for personal data.

Your passwords are stored on The Pay Index’s servers in encrypted form. We do not disclose your account details to anyone except when legally required to do so. It is your responsibility to keep your password secure. Unfortunately, the transmission of information via the internet is not completely secure. Although The Pay Index will do its best to protect your personal data, we cannot guarantee the security of your data transmitted to our Website or Client Microsite/s, any transmission is at your own risk. Once we have received your information, we will use strict procedures and security features to try to prevent any unauthorised access.

6. DISCLOSURE OF YOUR INFORMATION

We may also disclose your personal information to third parties in the following circumstances:

Purpose of disclosure and third party(s) to which disclosure might be made	Use Justification
The Pay Index may share certain Personal Data with Clients and Partners where necessary for the provision of our services. Such Personal Data may include: Personal Data submitted in the creation of a The Pay Index account (such as name, email, etc)	Contract performance, legitimate interest (to allow our service providers to provide the necessary services).
If The Pay Index or substantially all of its assets are acquired by a third party, personal information about our Clients will be one of the transferred assets.	Legitimate interest (to sell our Company or assets), Consent (for sensitive personal data).
If we are under a duty to disclose or share your personal data in order to comply with any legal obligation or to protect the rights, property, or safety of The Pay Index, our Clients, or others. This includes exchanging information with other companies and organisations for the purposes of fraud protection.	Legal obligation.
We may disclose your personal information to third parties, the court service and/or regulators or law enforcement agencies in connection with proceedings or investigations anywhere in the world where compelled to do so. Where permitted, we will direct any such request to you or notify you before responding unless to do so would prejudice the prevention or detection of a crime.	Legal obligation (to cooperate with law enforcement and regulatory authorities).

7. HOW LONG WE RETAIN YOUR PERSONAL DATA

We will hold the above information for as long as is necessary for the purposes relevant to the use of such information, as set out in this privacy policy. Once your account is terminated or deactivated, we shall delete the personal data relating to your account within 14 days.

Some Personal Data may need to be retained for longer than this to ensure The Pay Index can comply with applicable laws and internal compliance procedures, including retaining your email address for marketing communication suppression if you have opted not to receive any further marketing. If information is used for two purposes, we will retain it until the purpose with the latest period expires but we will stop using it for the purpose with a shorter period when that period expires.

We restrict access to your personal information to those persons who need to use it for the relevant purpose(s). Our retention periods are based on business needs and your information that is no longer needed is either irreversibly anonymized (and the anonymized information may be retained) or securely destroyed.

8. YOUR RIGHTS

General Data Protection Regulation (GDPR and GDPR UK)

Under the General Data Protection Regulation (EU) 2017/676 and General Data Protection Regulation (UK) and Data Protection Act 2018, you have various rights in relation to your Personal Data.

School Students, College Students, University Students, Business School Students, Alumni, Professionals/Executives and Parents should contact The Pay Index in the first instance as their Controller at dpo@thepayindex.com

The Data Controller, is primarily responsible for ensuring you can exercise these rights.

You have the following rights in relation to your Personal Data.

Rights	Details
Right to access	You have the right to access Personal Data held by the Controller(s), including a description of your data. Personal Data processed can be found in the profile section of your The Pay Index account.
Right to rectification	You have the right to rectify any details to ensure that your personal information is accurate. In order to assist with this, you should notify us of any changes to the personal information that you have provided by sending a request to rectify your personal data where you believe the personal data collected is inaccurate or incomplete.
Right to erasure/ ‘Right to be forgotten’	Asking the Controller(s) to delete all of your Personal Data will result in the deletion of your personal data held by that Controller without undue delay (unless there is a legitimate and legal reason why the Controller is unable to delete certain Personal Data, in which case you will be informed of this in writing).
Right to restriction of processing	You have the right to ask the Controller to stop processing your Personal Data at any time in certain circumstances. Such a request will result in the Controller restricting its processing of such data.
Right to data portability	You have the right to request that the Controller provides you with a copy of all of your Personal Data and to transmit your Personal Data to another Data Controller in a structured, commonly used and machine-readable format, where it is technically feasible to do so where such processing is based on consent or pursuant to contractual performance.
Right to object	You have the right to object to processing of personal information in certain circumstances, including where personal information is used for marketing purposes – you have a right to object to processing being carried out by us if (a) we are processing personal information based on legitimate interests or for the performance of a task in the public interest (including profiling), (b) if we are using personal information for direct marketing purposes, or (c) if information is being processed for scientific or historical research or statistical purposes.
Right to complain	You have the right to lodge a complaint to a supervisory authority such as the Information Commissioner’s Office in the UK (see www.ico.org.uk). Although we encourage our End Users and Clients to engage with us in the event they have any concerns or complaints.

The Pay Index will not ordinarily charge you in respect of any requests we receive to exercise any of your rights detailed above; however, if you make excessive, repetitive or manifestly unfounded requests, we may charge you an administration fee in order to process such requests or refuse to act on such requests. Where we are required to provide a copy of the Personal Data undergoing processing this will be free of charge; however, any further copies requested may be subject to reasonable fees based on administrative costs.

Requests to stop processing your Personal Data or deleting your Personal Data will likely mean that you are no longer able to use The Pay Index’s Client Microsite/s.

Where you exercise any of your rights above, the Controller may notify third parties to whom such Personal Data has been disclosed of such request. However, such third party may have the right to retain and continue to process such personal data in its own right.

To exercise the rights described above, you must send us a Subject Access Request/Valid Request that (1) provides sufficient information to allow us to verify that you are the person about whom we have collected Personal Data, and (2) describes your request in sufficient detail to allow us to understand, evaluate, and respond to it. Each request that meets both of these criteria will be considered a “Valid Request.” We may not respond to requests that do not meet these criteria. We will only use Personal Data provided in a Valid Request to verify you and complete your request. You do not need an account to submit a Valid Request.

We will work to respond to your Valid Request within 30 day period of receipt for all Valid requests under GDPR. We will not charge you a fee for making a Valid Request unless your Valid Request(s) is excessive, repetitive, or manifestly unfounded. If we determine that your Valid Request warrants a fee, we will notify you of the fee and explain that decision before completing your request.

You may submit a Valid Request using the following methods:

By sending an email to dpo@thepayindex.com

By post: The Pay Index, Equitable House, 47 King William Street, London, EC4R 9AF, United Kingdom, marked for the attention of the [Founder/CEO].

9. COOKIES

The Pay Index and our third-party partners, such as our analytics partners, use cookies and other tracking technologies (e.g., web beacons, device identifiers and pixels) to provide functionality and to recognize you across different Services and devices. For more information, please see our Cookie Policy, which includes information on how to control or opt out of these cookies and tracking technologies.

10. THIRD PARTY WEBSITES

Our Website may, from time to time, contain links to third party websites. If you follow a link to any of those third party websites, plug-ins or applications please note that they have their own Privacy Policies and that we do not accept any responsibility or liability for their policies or processing of your personal information. Please check these policies before you submit any personal information to such third party websites.

11. CHANGES TO THIS POLICY

Any changes we make to our privacy policy in the future will be posted on this page, and where appropriate, notified to you by email. We therefore encourage you to review the Website from time to time to stay informed of how we are processing your information. Your continued use of the Client Microsite/s and the Website shall be deemed your acceptance of the varied Privacy Policy.

12. CONTACT

If you have any questions and comments about this Privacy Policy or want to report a potential data breach please address these to dpo@thepayindex.com

If you have any cause for complaint about our use of your personal data, you have the right to lodge a complaint with the Information Commissioner’s Office. However, we welcome the opportunity to resolve your concerns ourselves, so please contact us first.

BACKGROUND:

The Pay Index understands that your privacy is important to you and that you care about how your personal data is used. We take privacy seriously and we respect and value the privacy of everyone who visits our website, www.thepayindex.com (“The Pay Index”). This notice tells you who we are, what information about you we collect process and share with our partners or sub-processors through your use of our website, including any data you may provide through our website when you sign up or open an account with us. This privacy policy also aims to give you information about what we do with your personal data, how we look after it when you visit our website (regardless of where you visit it from) and tell you about your privacy rights and how the law protects you.

Please read this Privacy Policy together with any other privacy policy or fair processing policy we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. This privacy policy supplements other notices and privacy policies and is not intended to override them. Please use the Glossary to understand the meaning of some of the terms used in this privacy policy .

1. Information About Us

The Pay Index is owned and operated by The Pay Index Limited, a limited company registered in England under company number 12098755 and with its registered address c/o Haines Watts (Berkhamsted) Ltd at 4 Claridge Court Lower Kings Road, Berkhamsted, Hertfordshire HP4 2AF, UK.

2. What Does This Policy Cover?

This Privacy Policy applies to your use of The Pay Index and the products and services we provide to you. The Pay Index may contain links to other websites, plug-ins and applications that are not owned or controlled by us. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. Please note that we are not responsible for the privacy practices of such other websites or third parties and have no control over how your data is collected, stored, or used by them. We advise you to check the privacy policies of any such websites before providing any data to them.

3. What is Personal Data

Personal data is defined by the General Data Protection Regulation (EU Regulation 2016/679) (the “GDPR”) and the Data Protection Act 2018 (collectively, along with superseding legislation, “the Data Protection Legislation”) as any information relating to an identifiable person who can be directly or indirectly identified in particular by reference to an identifier. It does not include data where the identity has been removed (anonymous data).

Personal data is, in simpler terms, any information about you that enables you to be identified. Personal data covers obvious information such as your name and contact details, but it also covers less obvious information such as identification numbers, electronic location data, and other online identifiers.

4. What Data we collect about you?

We may collect, use, store and transfer different kinds of personal data about you which is captured as encrypted. We have grouped together such data as follows:

Identity Data includes name (optional), username or similar identifier and gender.
Contact Data includes billing address, email address and telephone number (where appropriate).
Transaction Data includes details about payments to and from you and other details of products and services you have purchased from us.
Technical Data includes internet protocol (IP) address, your login data, 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.
Profile Data includes your username and password, purchases or orders made by you, preferences, feedback and survey responses.
Usage Data includes information about how you use our website, products and services.
Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.

We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data could be derived from your personal data but is not considered personal data in law as this data will not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. 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 in accordance with this privacy policy.

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.

5. 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 and Contact Data by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:
- apply for our products or services;
- create an account on our website;
- subscribe to our service or publications;
- request marketing to be sent to you;
- enter a competition, promotion or survey; or
- give us feedback or contact us.

Automated technologies or interactions. As you interact with our website, we will automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies, and other similar technologies. We may also receive Technical Data about you if you visit other websites employing our cookies. Please see below how we use our cookies for further details.

Third parties or publicly available sources. We will receive personal data about you from various third parties and public sources as set out below:

Technical Data from the following parties:

(a) our partners;

(b) analytics providers;

(c) advertising networks; and

(d) search information providers.

Contact and Transaction Data from providers of technical, payment and delivery services.
Identity and Contact Data from data brokers or aggregators.
Identity and Contact Data from our partners and publicly available sources.

6. Purposes for Which We Use Your Personal Data?

Under the Data Protection Legislation, we must always have a lawful basis for using personal data.

Most commonly, we will use your personal data in the following circumstances:

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.

The following table describes how we will use your personal data, the purposes for which we use your personal data, and our lawful basis for doing so.

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

What We Do	What Data We Use	Our Lawful Basis
Registering you on The Pay Index.	Login details and/or contact details	Legitimate Interests, Performance of Contract
Providing and managing your Account	Login details and/or contact details	Legitimate Interests, Performance of Contract
Providing and managing your Account	Login details and/or contact details	Legitimate Interests, Performance of Contract
Providing and managing your access to The Pay Index	Login details and/or contact details	Legitimate Interests, Performance of Contract
Administering The Pay Index	Non-personal data/ anonymised personal data submitted to The Pay Index	Suitable separation and anonymisation means that it is not subject to the Data Protection Legislation.
Supplying services to you[and providing certain information to our partners]	Name/ contact details and/or log-in details	Legitimate Interests, Performance of Contract
Managing payments for our services and collecting and recovering money owed to us	Name and contact details along of accounts payable person along with/ details of method of payment	Legitimate Interests, Performance of Contract
Communicating with you	Name/ contact details and/or log-in details	Legitimate interests, Performance of Contract
Managing our relationship with you which will include: (a) Notifying you about changes to our terms or privacy policy (b) Asking you to leave a review or take a survey	Name/ contact details and/or log-in details	Legitimate Interests, Performance of Contract (to keep our records updated and to study how customers use our products/services)
Protecting our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)	Name/ contact details/ technical	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), necessary to comply with a legal obligation
Using data analytics to improve our website, products/services, marketing, customer relationships and experiences	Technical/usage	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)
Making suggestions and recommendations to you about products or services that may be of interest to you	Name/ contact details/ log-in details/ technical/usage	Legitimate Interests, Performance of Contract

With your permission and/or where permitted by law, we may also use your personal data to communicate with our partners and for marketing purposes, which may include contacting you with information, news, and offers on our services. You will not be sent any unlawful marketing or spam. We will always work to fully protect your rights and comply with our obligations under the Data Protection Legislation and the Privacy and Electronic Communications (EC Directive) Regulations 2003, and you will always have the opportunity to opt-out. We will always obtain your express opt-in consent before sharing your personal data with third parties for marketing purposes and you will be able to opt-out at any time by following the opt-out links on any marketing message sent to you. You have the right to withdraw consent to marketing at any time by contacting us.

We will not use your personal data in any automated decision making and/or automated profiling. We will only use your personal data for the purpose(s) for which it was originally collected unless we reasonably believe that another purpose is compatible with that or those original purpose(s) and need to use your personal data for that purpose. If we do use your personal data in this way and you wish us to explain how the new purpose is compatible with the original, please contact us.

If we need to use your personal data for a purpose that is unrelated to, or incompatible with, the purpose(s) for which it was originally collected, we will inform you and explain the legal basis which allows us to do so.

7. 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.

8. 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.

9. How Long Will You Keep My Personal Data?

We will not keep your personal data for any longer than is necessary in light of the reason(s) for which it was first collected, 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.

10. Location of My Personal Data?

Generally, we will only store or transfer your personal data within the European Economic Area (the “EEA”). The EEA consists of all EU member states, plus Norway, Iceland, and Liechtenstein. This means that your personal data will be fully protected under the Data Protection Legislation including the GDPR and/or to equivalent standards by law.

From time to time, we may store or transfer some or all of your personal data in countries that are not part of the EEA. These are known as “third countries” and may not have data protection laws that are as strong as those in the UK and/or the EEA. This means that we will take additional steps in order to ensure that your personal data is treated just as safely and securely as it would be within the UK and under the Data Protection Legislation as follows:

If and to the extent that we share your personal data within group companies, of which we are a part, and this involves the transfer of personal data outside the EEA, our group shall ensure that personal data is protected by requiring all companies within the group to follow the same rules with respect to personal data usage. These are known as “binding corporate rules” and ensure compliance with the Data Protection Legislation.
If and to the extent that we share your personal data with external third parties that are based outside of the EEA, the following safeguards are applied to such transfers to ensure compliance with the Data Protection Legislation:
1. we will only transfer your personal data to third countries whose levels of data protection are deemed ‘adequate’ by the European Commission; and/or
2. we will use specific contracts terms with external third parties to require the same levels of personal data protection that would apply under the Data Protection Legislation; and/or
3. if and to the extent that we transfer your personal data to a third party based in the US, the data may be protected by the recipient’s registration under the EU-US Privacy Shield and/or by our imposition of the Standard Contract Clauses. This requires that third party to provide data protection to standards similar to those in Europe.

Please contact us for further information about the particular data protection mechanism(s) used by us when transferring your personal data to a third country.

11. Do You Share My Personal Data?

We will not share any of your personal data with any third parties for any purposes, subject to the following exceptions:

If we sell, transfer, or merge parts of our business or assets, your personal data may be transferred to a third party. Any new owner of our business may continue to use your personal data in the same way(s) that we have used it, as specified in this Privacy Policy.
In some limited circumstances, we may be legally required to share certain personal data, which might include yours, if we are involved in legal proceedings or complying with legal obligations, a court order, or the instructions of a government authority.
We may sometimes contract with third parties for the supply of certain services, such as web-hosting and data storage.

If any of your personal data is shared with a third party, as described above, we will take steps to ensure that your personal data is handled safely, securely, and in accordance with your rights, our obligations, and the third party’s obligations under the law, as described above.

If any personal data is transferred outside of the EEA, we will take suitable steps in order to ensure that your personal data is treated just as safely and securely as it would be within the UK and under the Data Protection Legislation, as explained above. 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.

12. How Can I Control My Personal Data?

In addition to your rights under the Data Protection Legislation, when you submit personal data via The Pay Index, you may be given options to restrict our use of your personal data. In particular, we aim to give you strong controls on our use of your data for direct marketing purposes including the ability to opt-out of receiving emails from us which you may do by unsubscribing using the links provided in our emails and/ or at the point of providing your details and by managing your Account.

You may also wish to sign up to one or more of the preference services operating in the UK: The Telephone Preference Service (“the TPS”), the Corporate Telephone Preference Service (“the CTPS”), and the Mailing Preference Service (“the MPS”). These may help to prevent you receiving unsolicited marketing. Please note, however, that these services will not prevent you from receiving marketing communications that you have consented to receiving.

13. Can I Withhold Information?

You may access certain areas of The Pay Index without providing any personal data at all. However, to use all features and functions available on The Pay Index you may be required to submit or allow for the collection of certain data.

You may restrict our use of Cookies. For more information, see below.

14. How Can I Access My Personal Data?

If you want to know what personal data we have about you, you can ask us for details of that personal data and for a copy of it (where any such personal data is held). This is known as a “subject access request”.

All subject access requests should be made in writing and sent to the email or postal addresses provided in the section below “How Do I contact You?”.

There is not normally any charge for a subject access request. If your request is ‘manifestly unfounded or excessive’ (for example, if you make repetitive requests) a fee may be charged to cover our administrative costs in responding.

We will respond to your subject access request within one month of receiving it or otherwise as required by the Data Protection Legislation. Normally, we aim to provide a complete response, including a copy of your personal data within that time. In some cases, however, particularly if your request is more complex, more time may be required up to a maximum of three months from the date we receive your request. You will be kept fully informed of our progress.

15. How Do You Use Cookies?

The Pay Index may place and access certain first-party Cookies on your computer or device. First-party Cookies are those placed directly by us and are used only by us. Third-party cookies might also be provided by third-party services providers used by us in our provision of the site, as described above. Such Cookies are used to facilitate and improve your experience of The Pay Index and to provide and improve our services. If and to the extent that Cookies are placed by us, have carefully chosen these Cookies and have taken steps to ensure that your privacy and personal data is protected and respected at all times.

All Cookies used by and on The Pay Index are used in accordance with current Cookie Law.

You can choose to enable or disable Cookies in your internet browser and/or when a pop-up requests your consent however certain features of The Pay Index may not function fully or as intended.

Most internet browsers also enable you to choose whether you wish to disable all Cookies or only third-party Cookies. By default, most internet browsers accept Cookies, but this can be changed. For further details, please consult the help menu in your internet browser or the documentation that came with your device.

You can choose to delete Cookies on your computer or device at any time, however you may lose any information that enables you to access The Pay Index more quickly and efficiently including, but not limited to, login and personalisation settings.

It is recommended that you keep your internet browser and operating system up-to-date and that you consult the help and guidance provided by the developer of your internet browser and manufacturer of your computer or device if you are unsure about adjusting your privacy settings.

16. How Do I Contact You?

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:

Full name of legal entity: The Pay Index

Email address: dpo@thepayindex.com

Postal address: C/O Haines Watts (Berkhamsted) Ltd

4 Claridge Court

Lower Kings Road

Berkhamsted

Hertfordshire

HP4 2AF

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, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.

17. 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.

18. Changes to this Privacy Policy

We keep our privacy policy under regular review. This version was last updated on [ ]. Historic versions can be obtained by contacting us.

19. What Are My Rights?

Under the Data Protection Legislation, you have the following rights, which we will always work to uphold:

The right to be informed about our collection and use of your personal data. This Privacy Policy should tell you everything you need to know, but you can always contact us to find out more or to ask any questions.
The right to access the personal data we hold about you. See below for more details about how to do this.
The right to have your personal data rectified if any of your personal data held by us is inaccurate or incomplete. Please contact us to find out more.
The right to be forgotten, i.e. the right to ask us to delete or otherwise dispose of any of your personal data that we hold. Please contact us to find out more.
The right to restrict (i.e. prevent) the processing of your personal data.
The right to object to us using your personal data for a particular purpose or purposes.
The right to withdraw consent. This means that, if we are relying on your consent as the legal basis for using your personal data, you are free to withdraw that consent at any time.
The right to data portability. This means that, if you have provided personal data to us directly, we are using it with your consent or for the performance of a contract, and that data is processed using automated means, you can ask us for a copy of that personal data to re-use with another service or business in many cases.
Rights relating to automated decision-making and profiling. We do not use your personal data in this way.

For more information about our use of your personal data or exercising your rights as outlined above, please contact us.

It is important that your personal data is kept accurate and up-to-date. If any of the personal data we hold about you changes, please keep us informed as long as we have that data.

20. Glossary

In this Policy the following terms shall have the following meanings:

“Account”	means an account required to access and/or use certain areas and features of The Pay Index;
“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;
“Cookie” “CTPS” “EEA”	means a small text file placed on your computer or device by The Pay Index when you visit certain parts of The Pay Index and/or when you use certain features of The Pay Index. Details of the Cookies used by The Pay Index are set out in paragraph 15; please refer to definition in paragraph 12; please refer to definition in paragraph 10;
“Legitimate Interest”	means the interest of our business in conducting and managing our business to enable us to give you the best service/product 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;
“GDPR” “MPS” “Performance of Contract” “TPS”	please refer to definition in paragraph 3; please refer to definition in paragraph 12; 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; please refer to definition in paragraph 12.