Privacy Policy

Origami Labs UK Ltd, a company registered in England and Wales, with company number, 14169007 (we, us or our), understands that protecting your personal data is important. This Privacy Policy sets out our commitment to protecting the privacy of personal data provided to us, or otherwise collected by us when you visit our website (Services) or when otherwise interacting with you.

It is important that you read this Privacy Policy together with any other detailed privacy notices we may provide when we are collecting or processing personal data about you so that you understand our privacy practices in relation to your data.

The information we collect

Personal data: is information that relates to an identified or identifiable individual.

We may collect, use, store and disclose different kinds of personal data about you which we have listed below:

Identity Data including first name and last name.
Contact Data including email address and telephone numbers.
Financial Data including bank account and payment card details (through our third party payment processors).
Background Verification Data including any details requested as part of our onboarding process to comply with our due diligence obligations, anti-money laundering laws and related ongoing monitoring commitments.
Transaction Data including details about payments from you to us and other details of services you have purchased from us.
Technical and Usage Data including internet protocol (IP) address, your login data, statistics on page views and sessions, acquisition sources, search queries and/or browsing behaviour, information about your access and use of our website, including through the use of Internet cookies, your communications with our website, the type of browser you are using, the type of operating system you are using and the domain name of your Internet service provider.
Professional data including where you are a worker of ours or applying for a role with us, your professional history such as your previous positions and professional experience.
Special Categories of Personal Data is a special category of personal data that 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. We do not actively request special categories of data about you, nor do we collect any information about criminal convictions and offences. If at any time we need to collect special categories of data about you, we will only collect it and use it as required or authorised by law.

How we collect personal data

We collect personal data in a variety of ways, including:

Directly: We collect personal data which you directly provide to us, including e.g. through the ‘contact us’ form on our website or when you request our assistance via email, or over the telephone.
Indirectly: We may collect personal data which you indirectly provide to us while interacting with us, such as when you use our website, in emails, over the telephone and in your online enquiries.
From publicly available sources: We collect personal data from publicly available resources such as Companies House and professional networking sites such as LinkedIn.

Purposes and legal bases for processing

We collect and process personal data about you only where we have legal bases for doing so under applicable laws. We have set out below, in a table format, a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate. 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 reach out to us if you need further 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 of use / disclosure
    Type of data
    Legal basis for processing
  
    To assess whether to take you on as a new client, including to perform anti-money laundering, anti-terrorism, sanction screening, fraud and other background checks on you.
    Identity Data
Contact Data
Background Verification Data

    Performance of a contract with you
To comply with a legal obligation
Public interest
Legitimate interests: ensuring we do not deal with proceeds of criminal activities or assist in any other unlawful or fraudulent activities for example terrorism

    To contact and communicate with you about our Services including in response to any support requests you lodge with us or other enquiries you make with us.
    Identity Data
Contact Data
Background Verification Data

    Performance of a contract with you

    To contact and communicate with you about any enquiries you make with us via our website.
    Identity Data
Contact Data

    Legitimate interests: to ensure we provide the best client experience we can offer by answering all of your questions.

    For internal record keeping, administrative, invoicing and billing purposes.
    Identity Data
Contact Data
Financial Data
Transaction Data

    Performance of a contract with you
To comply with a legal oibligation
Legitimate interests: to recover debts due to us and ensure we can notify you about changes to our terms of business and any other administrative points

      If you have applied to work with us; to consider your application.
    
    Identity Data
Contact Data
Professional Data

    Legitimate interests: to consider your employment application

      To comply with our legal obligations or if otherwise required or authorised by law. 
    
    All relevant personal data
    To comply with a legal obligation

If you have consented to our use of data about you for a specific purpose, you have the right to change your mind at any time, but this will not affect any processing that has already taken place. Where we are using your data because we or a third party have a legitimate interest to do so, you have the right to object to that use though, in some cases, this may mean no longer using our services. Further information about your rights is available below.

Our disclosures of personal data to third parties

We may disclose personal data to:

our employees, contractors and/or related entities;
IT service providers, data storage, web-hosting and server providers such as Microsoft;
professional advisors, bankers, auditors, our insurers and insurance brokers;
payment systems operators;
our existing or potential agents or business partners;
anyone to whom our business or assets (or any part of them) are, or may (in good faith) be, transferred;
courts, tribunals and regulatory authorities, in the event you fail to pay for goods or services we have provided to you;
courts, tribunals, regulatory authorities and law enforcement officers, as required or authorised by law, in connection with any actual or prospective legal proceedings, or in order to establish, exercise or defend our legal rights; and
any other third parties as required or permitted by law, such as where we receive a summons.

Overseas transfers

Where we disclose personal data to the third parties listed above, these third parties may store, transfer or access personal data outside of the United Kingdom. The level of data protection in countries outside of the United Kingdom may be less comprehensive than what is offered in the United Kingdom. Where we transfer your personal data outside of the United Kingdom, we will perform those transfers using appropriate safeguards in accordance with the requirements of applicable data protection laws and we will protect the transferred personal data in accordance with this Privacy Policy. This includes:

only transferring your personal data to countries that have been deemed by applicable data protection laws to provide an adequate level of protection for personal data; or
including standard contractual clauses in our agreements with third parties that are overseas.

Data retention

We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, 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.

Your rights and controlling your personal data

Your choice: Please read this Privacy Policy carefully. If you provide personal information to us, you understand we will collect, hold, use and disclose your personal information in accordance with this Privacy Policy. You do not have to provide personal information to us, however, if you do not, it may affect our ability to provide our Services to you and your use of our Services.

Information from third parties: If we receive personal data about you from a third party, we will protect it as set out in this Privacy Policy. If you are a third party providing personal data about somebody else, you represent and warrant that you have such person’s consent to provide the personal data to us.

Access, correction, processing and portability: You may request details of the personal data that we hold about you and how we process it (commonly known as a “data subject request”). You may also have a right in accordance with applicable data protection law to have your personal data rectified or deleted, to restrict our processing of that information, to object to decisions being made based on automated processing where the decision will produce a legal effect or a similarly significant effect on you, to stop unauthorised transfers of your personal data to a third party and, in some circumstances, to have personal data relating to you transferred to you or another organisation.

Unsubscribe: To unsubscribe from our e-mail database or opt-out of communications (including marketing communications), please contact us using the details below or opt-out using the opt-out facilities provided in the communication.

Withdraw consent: Where we are relying on consent to process your personal data, you have the right to withdraw your consent at any time. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. 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.

Complaints: If you wish to make a complaint, please contact us using the details below and provide us with full details of the complaint. We will promptly investigate your complaint and respond to you, in writing, setting out the outcome of our investigation and the steps we will take to deal with your complaint. You have the right to make a complaint at any time to the Information Commissioner's Office (ICO), the UK regulator 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.

Storage and security

We are committed to ensuring that the personal data we collect is secure. In order to prevent unauthorised access or disclosure, we have put in place suitable physical, electronic and managerial procedures, to safeguard and secure personal data and protect it from misuse, interference, loss and unauthorised access, modification and disclosure.

While we are committed to security, we cannot guarantee the security of any information that is transmitted to or by us over the Internet. The transmission and exchange of information is carried out at your own risk.

Cookies

We may use cookies on our website from time to time. Cookies are text files placed in your computer's browser to store your preferences and to provide a better user experience. Cookies, by themselves, do not tell us your email address or other personally identifiable information.. If you choose to provide our online services with personal data, this data may be linked to the data stored in the cookie. Where required by law, we will always seek your consent before placing any non-essential cookies on your device.

For more information about the cookies we use, or to update your consent preferences, please see our cookies policy here.

Links to other websites

Our website may contain links to other party’s websites. We do not have any control over those websites and we are not responsible for the protection and privacy of any personal data which you provide whilst visiting those websites. Those websites are not governed by this Privacy Policy.

Amendments

We may change this Privacy Notice from time to time. We will notify you if we make a significant change to this Privacy Notice, by contacting you through the contact details you have provided to us and by publishing an updated version on our website. For any questions or notices, please contact us at:

Origami Labs UK Ltd, a company registered in England and Wales, with company number, 14169007.

Email: hello@origamilabs.co.uk

Last update: June 2024