This privacy policy applies to you, the user of this website and Bnkability Ltd, the owner of the website. By using the website, you agree with Bnkability’s privacy policy which states how we use and process any data you provide on or we collect from this website.

Please read our privacy policy carefully.

1. Definitions and interpretations
1.1 The following definitions are used in this privacy policy:
Data - collectively all the information you submit to the Bnkability website. This definition incorporates, where applicable, the definitions provided in Data Protection laws;
Data Protection Laws - any applicable law committed to the processing of personal data, including but not limited to Directive 96/46/EC (Data Protection Directive) or the GDPR; and any national implementing laws, regulations and secondary legislation, for as long as the GDPR is effective in the UK;
GDPR - General Data Protection Regulation EU 2016/679;
Bnkability Ltd, we or us - Bnkability Ltd, a company incorporated in the United Kingdom with the registered number 989445 who registered office is at Runway East Moorgate, 10 Finsbury Square, City Road, London EC2A 1AF;
Use or you - any third party that accesses the Website and is not either:

(i) employed by Bnkability Ltd and acting in the course of their employment
or 

(ii) engaged as a consultant or otherwise providing services to Bankability Ltd and accessing the website in connection with the provision of such services; and
Site - the website that you are currently using, https://bnkability.com, and any sub-domains of this site unless expressly excluded by their own privacy policy.

1.2 In this privacy policy, unless the contact requires a different interpretation:
a. The singular includes the plural and visa versa;
b. References to sub-clauses, clauses, schedules or appendices are to those in this privacy policy;
c. A reference to a person includes firms, companies, government entities, trusts and partnerships;
d. “including” is understood to mean “including without limitation”;
e. Reference to any statutory provision includes any modifications or amendment of it.

2. Scope of this privacy policy
2.1 This privacy policy only applies to the action of Bnkability Ltd and user with respect to this Site. It does not extend to any Sites that can be accessed from the Site including, but not limited to, any links, we may provide to social media sites.

2.2 For purposes of the applicable Data Protection Laws, Bnkability Ltd is the “data controller”. This means that Bnkability Ltd determines the purposes for which, and the manner in which, your data is processed.

3. How we collect data
3.1 We collect data in the following ways:
a. Data is given to us by you; and
b. Data is collected automatically.

4. Data that is given to us by you
4.1 We will collect your data in a number of ways, for example when you contact us through the Site by email, forms, telephone, post or any other means. In each case, in accordance with this privacy policy.

5. Data that is collected automatically
5.1 When you access the Site we will collect data automatically, for example details of the use of the Site, length of visit, page views, your IP address, the way you interact with the Site and other communication data. This information helps us to make improvements to our Site content and navigation.

6. How is your data been processed
6.1 What are we processing your data for and why are we processing it? (‘Purposes of data processing’, ‘legal basis of the data processing’ and ‘storage periods’)

We will process your data when we have to perform a contract, and we will be processing your data as long as the contractual relationship with you is in force and during the five years following the end of said relationship. This results in us having to process your data for purposes of providing you with both the Services, as well as to perform our obligations under the Services Terms and Conditions.

6.2 Subject to obtaining your consent, and as long as you do not withdraw any such consent, we may also process your data for the following purposes:
a. To send you electronic commercial communications (if you subscribe to a newsletter) or to answer the requests you may address us when contacting us;
b. To process information obtained through cookies, as described in more detail in the Cookie Policy, and subject to the terms set forth therein;
c. When we have to comply with a legal obligation applicable to us from time to time, such as those set forth in The Money Laundering, Terrorist Financing and Transfer of Funds Regulation 2017. In any such cases, the data will be processed only during the periods set forth by said laws, being deleted thereafter.
d. Finally, we may also process your data to protect our legitimate interests, as long as said data is strictly necessary to fulfil the goals set forth below, namely:

6.3 To review, monitor, investigate, and analyse how to improve the Services and/or the Site, as well as to keep our Services and the Site secure and operational and prevent abusive activity (e.g. fraud, spam, phishing activities, etc.). This may include sending you a survey to assess any problems in the service or know how to improve your user experience. The interests at stake are ensuring a correct and safe environment for both other users and us, taking those interests prevalence over your legitimate interests (we need to create and maintain an environment which is in accordance with the law, the legitimate interests of other parties, what other users may expect from our end, and to protect other users’ security when accessing the Site and using the Services)

6.4 Besides any commercial electronic and non-electronic commercial communication sent when we have obtained your consent as mentioned above, we may also send you those kind of communications when you are our client. In this last case, we will only send you information belonging to us and concerning services and/or products identical or similar to the ones you have contracted with us. In these cases, we have a legitimate interest in processing your contact information to keep you informed about any of our products and services, prevailing this interest over your right to personal data given the non-sensitive nature of the data in question and the fact that the contractual relationship built with our clients results in those clients expecting these kinds of communications; and

6.5 Upon dissociating the data we have so as to be impossible to be associated to you or any other person, to perform statistical and other analysis on information we collect (technical and metadata) to analyse and measure user behaviour and trends, to understand how people use our services, in order to improve and optimise our performance of such services.

7. To which extent do we require to have access to your personal data?
7.1 We need to process your personal data to perform the legal and contractual obligations mentioned in section xx above. Otherwise, we are not able to provide you with the Services and/or access to the Site. On the other hand, for data processing which depends on your consent or on our legitimate interests, the data processing is not legally required.

8. Which companies will have access to your personal information?
8.1 We share your information with our service providers who help us to provide the Services to you, in which case those third parties are required to comply with our internal standards, policies, and technical and organisational measures that ensure that your data is protected and kept confidential at all times, and only in accordance with and to the extent authorised by this Privacy Policy.

8.2 When you authorise us to do so, we may also share your data with other companies so that they can process the data for other purposes, as explained more in detail when we request your prior consent. In addition, if you provide consent for the installation of cookies, your data may be processed by third companies for the purposes and in the territories mentioned in the Cookie Policy.

8.3 We may also share your information with competent courts and authorities, when we are legally required to do so (for instance, to allow such bodies to investigate, prevent, or take action against illegal activities), or we have to take action to protect our rights or any third party rights.

9. In which territories may your personal information be processed?
9.1 Your information may be transferred, processed, and stored in countries that do not have data protection laws as protective as those in your jurisdiction. Your agreement to the terms of this Privacy Policy, followed by your submission of information in connection with the Service, represents your agreement to this international transfer of personal data.

10. Data retention
10.1 Unless a longer retention period is required or permitted by law, we will only hold your data on our systems for the period necessary to fulfil the purposes outlined in the privacy policy or until you request that the data be deleted.

10.2 Even if we delete your data, it may exist on backup or archival media for legal, tax or regulatory purposes.

11. Your rights
11.1 You have the following rights in relation to your data:
a. Right to access - the right to request 

(i) copies of the information we hold about you at any time,
or 

(ii) that we modify, update or delete such information. If we provide you with access to the information we hold about you, we will not charge you for this. However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse your request in these circumstances. If we refuse your request, we will tell you the reasons why;
b. Right to correct - the right to have your data rectified if it is inaccurate or incomplete;
c. Right to erase - the right to request that we delete or remove your data from our systems;
d. Right to restrict our use of your data - the right to “block” us from using your data or limit the way in which we use it
 e. Right to data portability - the right to request the we move, copy or transfer your data; and
f. Right to object - the right to object to our use of your data including where we use for legitimate interest.

11.2 To make enquiries, exercise your rights set above, or withdraw your consent to the processing of your data (where consent is our legal basis for processing your data), please contact us via email address: hello@bnkability.com.

11.3 If you are not satisfied with the way a complaint you make in relation to your data is handled by us, you may be able to refer your complaint to the relevant protection authority. For the UK, this is the Information Commissioner’s Office (ICO). The ICO’ contact details can be found on their website at https://ico.org.uk.

11.4 It is important that the data we hold about you is accurate and current. Please keep us informed if your data changes during the period for which we hold it.

12. Links to other websites
12.1 The Site may, from time to time, provide links to other websites. We have no control over such websites and are not responsible for the content on these websites. This privacy policy does not extend to your use of such websites. You are advised to read the privacy policy or statement of other websites prior to using them.

13. Changes of business ownership and control
13.1 We may, from time to time, expand or reduce our business and this may involve the sale and/or the transfer of control of all or part of Bnkability Ltd. Data provided by users will, where it is relevant to any part of our business so transferred, be transferred along with the part and the new owner or newly controlling party will, under the terms of this privacy policy, be permitted to use the data for the purposes for was originally supplied to us.

13.2 We may also disclose data to a prospective purchaser of our business or any part of it.

13.3 In the above instances, we will take steps with the aim of ensuring your privacy is protected.

14. General
14.1 You may not transfer any of your right under this privacy policy to another person. We may transfer our right under this privacy policy where we reasonably believe your rights will not be affected.

14.2 If any court or competent legal authority finds any provision of this privacy policy (or part of any provision) is invalid, illegal or unenforceable, the provision or part provision will, to the extent required, be deemed to be deleted, and the validity and enforceability of other provisions of this privacy policy will not be affected.

14.3 . Unless otherwise agreed, no delay, act to omission by a party in exercising any right or remedy.

14.4 This privacy policy will be governed by an interpreted according to the law of England and Wales. All disputes arising under the agreement will be subject to the exclusive jurisdiction of the English and Welsh courts.

15. Changes to this privacy policy
15.1 We reserve the right to change this privacy policy as we may deem necessary from time to time or as may be required by law. Any changes will be immediately posted on the Site and you are deemed to have accepted the terms of the privacy policy on your first use of the Site following the alterations.

16. Contact
16.1 Any questions, comments or requests regarding this privacy policy and changes to your preference or data, or deletion of your data should be addressed to hello@bnkability.com.