This section describes our privacy notice as it applies for you as an individual, as a direct customer, associate, staff member, or subscriber to ExcluServ.
By entering into a contract with ExcluServ, you agree that we may collect, hold and use your personal information in the way described in this notice.
You have the option to withhold or limit the use of some categories of personal data held and processed by us, but that may prevent us from being able to provide that service to you.
ExcluServ will not use your personal data for any purpose other than that described in this notice, unless we have your express permission or instruction to do so or are required to do so by law.
ExcluServ collects your Personal Data
Our service delivery, resourcing, operational management and development of our business, each require us to collect and process some personal information.
The personal data we require may include full name, bank account details, contact details and information of the goods and services provided. We may also collect business contact details such as job title, company information, billing information, payment records and due diligence information records needed to comply with regulatory obligations.
We may collect personal data from you when you express an interest in any of our service areas, and further data at the point when the service commences.
We may collect personal data from you when you apply for a role with ExcluServ or seek to become a supplier of services to ExcluServ.
ExcluServ use your Personal Data for limited purposes
This describes the limits of how we will use your personal data and process it.
Provision of Service:
- This is the primary purpose for which we process the data and is to provide you with the services you have contracted with us.
- Providing technical support.
- Review and feedback of service provided.
Communication with You:
- In relation to existing services contracted.
- To respond to a request for information from you.
- To make you aware of related services being offered by ExcluServ.
Related Purposes such as:
- Verifying your identity.
- Informing you of updates or additional services related to your account.
- Delivering training and guidance related to the services you subscribed to.
- Compliance with relevant laws and regulations (including AML).
- Employment and staff development.
ExcluServ use Lawful Bases to process your Personal Data
We rely on different lawful bases depending on the specific purpose of the processing of your personal data. These may include:
| Contract: | Processing is necessary to fulfil a contract with you or to take pre-contractual steps at their request. |
| Consent: | Where you have given clear, affirmative agreement for ExcluServ to process your data for a specific purpose. |
| Legal Obligation: | Where processing is necessary to comply with a law or statutory requirement. |
| Legitimate Interests: | Where processing is necessary for ExcluServ’s legitimate interests, provided these do not override your rights and freedoms. |
Who we share your data with
To fulfil our processing we need to routinely share your data with a number of different categories of organisations.
| Categories | Examples |
| Payment processors | All payments that may be made to you will be processed through a payment portal such as our bank’s electronic banking portal, or an online open banking solution, such as Telleroo. |
| Cloud hosting providers | Our client management solution is linked to Xero accounts and holds contact information for all of our clients. Our AML monitoring handled through a secure AML solution online. Our HR is managed through a cloud hosted HR system. |
| Professional advisers (lawyers, accountants) | From time-to-time ExcluServ may need to seek advice from Professional Advisers, such as employment lawyers, tax advisers etc, and in doing so may need to share your personal data. |
| Payroll providers | ExcluServ work with a third-party payroll provider to process our payroll and will share such information as is necessary to ensure that all staff are paid accurately and on time. |
| IT Service Provider | ExcluServ outsource our IT systems and that requires us to allow controlled access to them. In doing so we share any such personal data held in our systems with that provider. |
Data Subject Rights
This section relates to your rights as a Data Subject, where ExcluServ acts as a Data Controller: direct customer, associate, staff member or subscriber of ExcluServ.
Under GDPR, you have a number of rights as a Data Subject. These include, but are not limited to:
| Access | Request access to the information that we hold about you, and to request updates to such information. |
| Rectification | If you become aware of any inaccuracy in the personal data that we hold about you, you should inform us and we will correct it appropriately. |
| Erasure | If you wish for any of your personal data to be removed, this will be deleted as far as is legally permitted. |
| Communication | If you wish to change our records on how we should communicate with you then you may request that. |
| Withdraw consent | If you wish to withdraw your consent for us to process or hold your data |
| Data Portability | If you wish to move your data held on ExcluServ Systems to another provider |
| Complain | You have the right to complain directly to the supervisory authority (the ICO) |
Any such requests or complaints should be submitted
- in e-mail to GDPR@excluserv.com,
- or in writing to ExcluServ’s registered address.
The Data Privacy Officer, ExcluServ Ltd,
133 Deepcut Bridge Road, Camberley, GU16 6SD
You also have the right to complain to the Information Commissioner’s Office.
Unless we are legally prohibited from providing this information, we will process your request as soon as is reasonably practicable, and within one calendar month of receiving your request. If we are unable to process your request or extend time to respond, we will let you know why.