Privacy Policy
Last updated: 12 March 2023
Just Pay Limited t/a Event UK (“Just Pay”, “we”, “our” or “us”) has created its unique booking and payment software which we operate through our Just Pay website (justpay.co.uk) and our device application (“App”) (collectively referred to as our “Just Pay Software”). Our Just Pay Software enables us to provide intermediary services connecting our end clients and artists / workers / contractors.
This Privacy Policy governs those that will access and use our Just Pay Software as an authorised user (“Authorised User”) which means you will have a registered account with us enabling you to use the Just Pay Software, those that we work with in the provision of our services (“Services”), or those that are general visitors to either the Just Pay website or App (“you” or “your”) for the purpose of this Privacy Policy.
This Privacy Policy is not intended to cover off the use of personal data relating children and we do not knowingly collect or use personal information relating to children.
Overview
At Just Pay, we take privacy very seriously. We have prepared this Privacy Policy (“Privacy Policy”) to ensure that we communicate to you, in the clearest way possible, how we treat your personal information.
We are committed to ensuring that your personal information remains confidential and secure in accordance with applicable Data Protection Legislation.
This policy sets out how we look after your personal data if you are a:
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- Visitor to our Just Pay website or App;
- An Authorised User with a registered account;
- Supplier or business contact of Just Pay;
- A potential end client of Just Pay;
- Any third-party organisation that uses Just Pay.
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This Privacy Policy (together with any applicable terms and conditions of service, website terms of use, and any other documents or terms incorporated by reference) describe the types of information that we collect from you through the use of the Just Pay Software, and how that information may be used or disclosed by us and the safeguards we use to protect it. The personal information that we collect is used for providing and improving our Services. We will not use or share your information with anyone except as described in this Privacy Policy.
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.
We may update this notice from time to time, and you can find our latest version on our website or by asking us for a copy.
Who are Just Pay?
Just Pay Limited t/a Event UK, is a company incorporated in England and Wales, with its company number 12364222 and its registered office being 12 Northfields Prospect Putney Bridge Road, London, United Kingdom, SW18 1PE.
This Privacy Policy applies to any personal data we collect through our business and within the Just Pay Software to enable us to deliver our Services.
If you have any questions about this Privacy Policy, including any requests to exercise your legal rights, please contact us at support@justpay.co.uk.
We will only process personal information about you in accordance with the UK Data Protection Legislation which for the purposes of this Privacy Policy shall mean: all applicable data protection and privacy legislation in force from time to time in the UK including without limitation the UK GDPR; the Data Protection Act 2018 (and regulations made thereunder) and the Privacy and Electronic Communications Regulations 2003 (SI 2003/2426) as amended; and all other legislation and regulatory requirements in force from time to time which apply to a party relating to the use of personal data (including, without limitation, the privacy of electronic communications); and the guidance and codes of practice issued by the Commissioner or other relevant regulatory authority and which are applicable to a party (“Data Protection Legislation”).
1. What does Just Pay do?
We act as an intermediary and provide an intermediary service between our end clients and artists, workers or contractors providing the services to our end clients. Our Just Pay Software is used for the purpose of scheduling bookings, taking and making payments and providing administrative support to those artists, workers or contractors.
2. The purpose of this Privacy Policy
The purpose of this Privacy Policy is to set out how we collect and use your personal data when we directly control the personal data as a data controller in respect of Just Pay and the Just Pay Software.
3. The data we collect and how we collect it
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 depending on your relationship with us (for instance, whether you are an Authorised User benefitting from our Services, or a supplier) as follows:
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- Identity Data: includes first name, maiden name, last name, username or similar identifier, marital status, title, date of birth and gender.
- Financial / Transaction Information: details of bank account details or debit / credit card information for payment information.
- Contact Data: your email address, telephone number and postal address.
- Technical Log Data includes internet protocol (IP) address, device ID’s, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, geolocation data, social media preferences, operating system and platform and other technology on the devices you use to access the Just Pay Software.
- Profile Data includes your authorised username and password, complaints, preferences, and any feedback responses.
- Usage Data includes information about how you use the Just Pay Software, and our services.
- Cookies Data like many websites, we may use some “cookies” to enhance your experience and gather information about the visitors and number of visits to the Just Pay Software. Please refer to our Cookie Policy on our website about cookies, how we use them and what kind.
- Analytics includes third-party analytics services (such as Google Analytics) to evaluate your use of the Just Pay Software, compile reports on activity, collect demographic data, analyse performance metrics, and collect and evaluate other information relating to our website and internet usage. These third parties use cookies and other technologies to help analyse and provide us the data. By accessing and using the Just Pay Software, you consent to the processing of data about you by these analytics providers in the manner and for the purposes set out in this Privacy Policy.
- Location Data. We may collect location data in the use of our website or App, but you have the right to turn off location services at any time.
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You can withhold your personal data from us, but we may not be able to provide our Services to you if you do so.
We may collect your personal data from different sources:
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- We collect all the types of data listed above directly from you when you interact with us. This includes when you register or use the Just Pay Software.
- We collect Technical Data automatically when you interact with the Just Pay Software, by using cookies and other similar technologies.
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4. How we use your personal data
We (or third-party data processors, agents and sub-contractors acting on our behalf) may collect, store and use your personal information by way of different methods to collect data from and about you including through:
Direct interactions. This is information (including Identity, Contact and Financial Data) you consent to giving us about you when you fill in forms and sections through the Just Pay Software or send to us directly, or by corresponding with us (for example, by email or chat). It includes information you provide when you register or subscribe to any of our Services, visit or use the Just Pay Software, or when you create an account with us and finally when you report a problem with our Services, or Just Pay. If you contact us, we will keep a record of that correspondence.
Information we collect about you and your device either automated or otherwise. Each time you visit or use the Just Pay Software, we will automatically collect personal data including Technical Log Data. We collect this data using cookies and other similar technologies including server logs. We may also receive technical data about you if you visit other websites employing our cookies. We may also collect Technical Log Data if you contact us and use our services generally through Just Pay.
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, which include strict confidentiality and contractual terms.
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:
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- Where you have consented before the processing.
- Where we need to perform a 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 or regulatory obligation.
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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.
When we are acting as a data controller, we will use your personal data for the purposes set out in the table below.
The law sets out several different reasons for which we can collect and use your data. The legal grounds on which we collect and use your data are also set out in the table below. 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 for using your data | Legal ground for using your data for this purpose |
To allow you to access your account through the Just Pay Software and to register an account with us. To enable access to Just Pay and to enable you to benefit from our Services. | Necessary for our legitimate interests (to allow those with an account on the Just Pay Software to use it) / Performance of a contract with us. To comply with a legal obligation. |
To manage any account with us and to enable us to deliver our Services, including managing and making payments. | Necessary for our legitimate interests (to recover debts due to us and to make payments) / Performance of a contract with us / To perform a task carried out in the public interest. |
To provide support to you when you contact us. | Necessary for our legitimate interests (to respond to support calls as our users would expect) / Performance of a contract. |
To manage our relationship with you, which will include notifying you about changes to our Privacy Policy, and any key correspondence with you. | Necessary for our legitimate interests (to provide important updates to our users) / Performance of a contract. |
To administer and protect our business and the Just Pay Software (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data). | Necessary for our legitimate interests (to protect our business, software and website; to keep our services updated). |
To deliver relevant system, software and website content and advertisement and promotional activity to measure or understand the effectiveness of the business. | Necessary for our legitimate interests (to study how Authorised Users use our products/services, to develop them, to grow our business and to inform our marketing strategy). |
To use data analytics to improve our website, products/services, marketing, customer relationships and experiences. |
Necessary for our legitimate interests (to continuously improve our services for our customers and users). |
To create anonymous aggregated data, as set out below. | Necessary for our legitimate interests (to provide additional benefits and functionality to our customers and users without disclosing personal data). |
To comply with applicable laws and regulatory obligations. | To comply with a legal obligation. |
Aggregated Data
We may aggregate and use non-personally identifiable data we have collected from you and others. This data will in no way identify you or any other individual.
We may use this aggregated non-personally identifiable data to:
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- Assist us to better understand how our users are using the Just Pay Software and our services;
- Provide users with further information regarding the uses and benefits of Just Pay; and
- Otherwise, to improve our Just Pay Software.
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5. Who has access to your personal data and who do we share it with?
We may need to share your personal data when using your personal data as set out in the table above. We may share your personal data with the following third parties:
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- Our professional advisers, including lawyers, auditors, and insurers.
- Service providers who provide IT and system administration services, or who store data on our behalf.
- Third parties to whom we may choose to sell, transfer, or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this Privacy Policy.
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Where any of your personal data is required for such a purpose, we will take all reasonable steps to ensure that your personal data will be handled safely, securely, and in accordance with your rights, our obligations, and the obligations of the third party under the Data Protection Legislation. This type of external data processing is always subject to contractual assurances that personal data will be kept securely and used only in accordance with our specific directions.
We will not misuse your personal data for any other purpose other than as set out in this Privacy Policy.
6. International transfers
Subject to us complying with Data Protection Legislation and ensuring appropriate safeguards are in place, we may transfer your personal data to third parties providing services to us who are based outside of the UK without obtaining your specific written consent. This may include parties providing IT administration services and hosting services and other organisations which have products or services that are essential in the delivery of our Services; and finally, organisations providing assistance with managing our marketing databases.
Whenever we transfer your personal data outside of the UK, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:
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- The personal data is transferred to or processed in a territory which is subject to adequacy regulations under the Data Protection Legislation that the territory provides adequate protection for the privacy rights of individuals such as the EEA; or
- We participate in a valid cross-border transfer mechanism under Data Protection Legislation, so that we can ensure that appropriate safeguards are in place to ensure an adequate level of protection with respect to the privacy rights of individuals as required under the Data Protection Legislation; or
- The transfer otherwise complies with Data Protection Legislation.
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7. Retention period
We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.
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 requirements.
For more details of our specific retention periods, please contact us.
8. Data security
Data security is of great importance to us, and to protect your data we have put in place suitable physical, electronic and managerial procedures to safeguard and secure data collected through Just Pay and the Just Pay Software.
We have implemented significant security measures to maintain a high level of security.
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.
Notwithstanding the security measures that we take, it is important to remember that the transmission of data via the internet may not be completely secure and that you are advised to take suitable precautions when transmitting to us data via the internet and you take the risk that any sending of that data turns out to be not secure despite our efforts.
If we give you a password upon registration and use of the Just Pay Software, you must keep it confidential. Please don’t share it.
9. How do we protect your personal information?
We implement a variety of security measures to protect and maintain the safety of your personal information including encrypted software. Your personal information is contained behind secured networks and is only accessible by a limited number of persons who have special access rights to such systems and are required to keep the information confidential.
10. Your rights as a data subject
Under certain circumstances, you have rights under the Data Protection Legislation in relation to your personal data. These rights are set out below. If you wish to exercise any of the rights set out below, 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 may refuse to comply with your request in these circumstances.
Your rights are as follows:
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- Right of access – you have the right to request a copy of the personal data that we hold about you and to check that we are lawfully processing it.
- Right of rectification – you have a right to request that we correct personal data that we hold about you that is inaccurate or incomplete.
- Right to be forgotten / erasure – in certain circumstances you can ask for the data we hold about you to be erased from our records i.e., when there is no good reason for us continuing to process it.
- Right to restriction of processing – where certain conditions apply, you have a right to restrict or suspend the processing, for example if you want us to establish its accuracy or the reason for processing it.
- Right of portability – you have the right to have the data we hold about you transferred to another organisation.
- Right to object – you have the right to 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 situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms.
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There are some exceptions to the above rights:
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- Right to withdraw consent. In the limited circumstances where you have provided your consent to the collection, processing and transfer of the personal data referred to above, you may withdraw that consent at any time. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent, or to processing carried out on other legal grounds. 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.
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All the above requests will be forwarded to the relevant party should there be a third party involved in the processing of your personal data.
11. Complaints to the Information Commissioner’s Office
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 by emailing us at support@justpay.co.uk.