Privacy Policy 

The detail

Privacy Policy last updated 26/02/2020
Disclaimer
Well Pay (“We”) take seriously your data privacy and how we handle that and also protect it with
respect.

This policy (together with our terms of use and any other documents referred to on it) sets out the
basis on which any personal data we collect from you, or that you provide to us, will be processed by
us. By visiting www.wellpayumbrella.co.uk you are accepting and consenting to the practices
described in this policy.

For the purpose of the General Data Protection Regulation (Regulation EU 2016/679), the data
controller is Well Pay Ltd, Parkway Five, Princess Rd, Manchester M14 7HR.

Visitors to www.wellpayumbrella.co.uk

When someone visits Well Pay we use the following third party services; Google
Analytics to collect standard internet log information and details of visitor behaviour patterns. We
do this to find out things such as the number of visitors to the various parts of the site. Specifically,
the information we collect will look at;

technical information, including the Internet protocol (IP) address used to connect your computer to
the Internet, browser type and version, time zone setting, browser plug-in types and versions,
operating system and platform;
information about your visit, including the full Uniform Resource Locators (URL) clickstream to,
through and from our site (including date and time); services you viewed or searched for; page
response times, download errors, length of visits to certain pages, page interaction information
(such as scrolling, clicks, and mouse-overs), and methods used to browse away from the page.

This information is processed in a way which does not identify anyone as site visitors IP is
anonymised. Where we do collect personally identifiable information through our site, we will make
it clear what we intend to do with it.

When you complete a ‘contact request’ through www.wellpayumbrella.co.uk
We will store information collected through contact forms for a minimum period of 3 years and we
will not share your information with any other organisations. The data is stored in a secure cloud
environment.

LinkedIn: When you make an enquiry about our services, we may conduct further research into you
and your organisation using LinkedIn. This is to help us understand as much about you and your
organisation as possible, such that we can provide the best possible advice with regards to our goods
and services.

The processing of personal data collected via contact forms is lawfully done on the basis of
legitimate interest. The legitimate interest being direct marketing and the provision of relevant,
requested product and services information from us to you.

Direct Marketing
Under the terms of the General Data Protection Legislation (GDPR), organisations are able to process
personal data for legitimate interests, provided that the interests or fundamental rights and
freedoms of the data subject are taken into consideration. Under the GDPR, direct marketing is
considered a legitimate interest.

Well Pay process personal data for the purposes of direct marketing, predominantly
electronic direct marketing (email). Well Pay subscribe to the following third party
providers for the provision of personal data use for electronic direct marketing;

LinkedIn
Well Pay will process data collected from previous ‘Contact Requests’, store them in our
secure 128 bit cloud based database and communicate periodically with people from these data sources, with news and
updates on products, services and resources we believe could be of interest to them.

If you receive an email from us and you don’t want to, you can opt-out of all Well Pay
electronic direct marketing by selecting the ‘Unsubscribe’ link that is included in all of our
communications. Equally you can request to be removed from our databases by contacting
data@wellpayumbrella.co.uk (see the ‘Your rights’ section of this privacy notice for more detail on
this).

DISCLOSURE OF YOUR INFORMATION
We may share your personal information with any member of our group, which means our
subsidiaries, our ultimate holding company and its subsidiaries, as defined in section 1159 of the UK
Companies Act 2006.

We may share your information with selected third parties including:

ClearCut Accounting, MASTRAW and ITPay.

In the event that we sell or buy any business or assets, in which case we may disclose your personal
data to the prospective seller or buyer of such business or assets.
If Well Pay or substantially all of its assets are acquired by a third party, in which case
personal data held by it about its customers will be one of the transferred assets.
If we are under a duty to disclose or share your personal data in order to comply with any legal
obligation, or in order to enforce or apply our Terms of Use or Terms and Conditions of Business and
End User Licence Agreement and other agreements; or to protect the rights, property, or safety of
Well Pay, our customers, or others. This includes exchanging information with other
companies and organisations for the purposes of fraud protection and credit risk reduction.
In these instances, processing and disclosure of your information is lawfully done on the basis of
legitimate interest, specifically, business or group restructuring and legal obligations.
Where we store your personal data
Your data is kept on a database that is securely stored within the cloud, unfortunately, the
transmission of information via the internet is not always completely secure. Although we will do
our best to protect your personal data, we cannot guarantee the security of your data transmitted to
our site; 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 unauthorised access.

Your rights
You have the right to ask us not to process your personal data for marketing purposes. We will
inform you (before collecting your data) if we intend to use your data for such purposes or if we
intend to disclose your information to any third party for such purposes. You can exercise your right
to prevent such processing by unsubscribing from electronic communications using the unsubscribe
link on all of our emails or by requesting in writing to data@wellpayumbrella.co.uk

Our site may, from time to time, contain links to and from the websites of our partner networks,
advertisers and affiliates. If you follow a link to any of these websites, please note that these
websites have their own privacy policies and that we do not accept any responsibility or liability for
these policies. Please check these policies before you submit any personal data to these websites.

You also have the right to;

Request that any personal information that we collect and hold on you be updated or corrected.
Request a copy of any personal information that we collect and hold on you.
Request that any personal information we hold on you be transferred to another data controller.

Request that we restrict the uses for which we process your personal data (sales, marketing, email
communications)
Object to any of the ways that we process your personal data.
Request that we delete any or all of your personal data.
You may exercise any of the above rights by getting in touch with us through the following routes;

By email to data@wellpayumbrella.co.uk
In writing to
The Data Controller,
Well Pay Ltd,
Parkway Business Centre
Parkway Five
Princess Rd
Manchester M14 7HR

Changes to our privacy policy
Any changes we may make to our privacy policy in the future will be posted on this page and, where
appropriate, notified to you by e-mail. Please check back frequently to see any updates or changes
to our privacy policy.

Contact
Questions, comments and requests regarding this privacy policy are welcomed and should be
addressed to data@wellpayumbrella.co.uk

Complaints procedure

If you have any objections to the way in which we process your personal data you can raise them
with us directly by contacting us through the following routes;

By email to data@wellpayumbrella.co.uk
In writing to
The Data Controller,
The Data Controller,

Well Pay Ltd,
Parkway Business Centre
Parkway Five
Princess Rd
Manchester M14 7HR

If you wish to lodge a formal complaint with our supervisory authority you can do so by contacting
the Information Commissioners Office (also known as the ICO). Contact and complaints procedures
can be found on the ICO’s website https://ico.org.uk/.

Cookie Policy
INFORMATION ABOUT OUR USE OF COOKIES
Our website uses cookies to distinguish you from other users of our website. This helps us to provide
you with a good experience when you browse our website and also allows us to improve our site. By
continuing to browse the site, you are agreeing to our use of cookies.

A cookie is a small file of letters and numbers that we store on your browser or the hard drive of
your computer if you agree. Cookies contain information that is transferred to your computer’s hard
drive.

Cookie expiration: All cookies are set to expire after 90 days from the first day of acceptance. We
periodically review our cookie expiration date, any changes to which will be reflected in this privacy
policy.

We use the following cookies:

Strictly necessary cookies. These are cookies that are required for the operation of our website. They
include, for example, cookies that enable you to log into secure areas of our website, use a shopping
cart or make use of e-billing services.
Analytical/performance cookies. They allow us to recognise and count the number of visitors and to
see how visitors move around our website when they are using it. This helps us to improve the way
our website works, for example, by ensuring that users are finding what they are looking for easily.
Functionality cookies. These are used to recognise you when you return to our website. This enables
us to personalise our content for you, greet you by name and remember your preferences (for
example, your choice of language or region).
Targeting cookies. These cookies record your visit to our website, the pages you have visited and the
links you have followed.

We will use this information to make our website and the advertising displayed on it more relevant
to your interests. We may also share this information with third parties for this purpose.

If you would like more information about the individual cookies we use and the purposes for which
we use them please contact us at : data@wellpayumbrella.co.uk

Please note that third parties (including, for example, advertising networks and providers of external
services like web traffic analysis services) may also use cookies, over which we have no control.
These cookies are likely to be analytical/performance cookies or targeting cookies.

You have the option to update your settings on your browser that helps you block some or all
cookies. However, if you use your browser settings to block all cookies (including essential cookies)
you may not be able to access all or parts of our site which could effect your personal user
experience.