We are committed to protecting your personal data and respecting your privacy.
F.D.N Holding Limited is the data controller and is responsible for your personal data (referred to as "Nextlayer", "we", "us" or "our" in this policy). We are a limited liability company registered at Companies House in England under registration number 11098463. We are registered with the Information Commissioner's Office ("ICO") with registration number is ZA540417.
If you want to contact us, you can do so by email firstname.lastname@example.org or by post to F.D.N Holding Limited, Unit 1, 1 Back Hill London EC1R 5EN, United Kingdom.
This policy sets out the basis on which any personal data we collect from you, or that you provide to us, will be processed by us. Our App is not intended for children and we do not knowingly collect data relating to children. Please read the following carefully to understand our practices regarding your personal data and how we will treat it.
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 our relationship with you.
We may collect, use, store and transfer different kinds of personal data about you as follows:
We do not intentionally collect and so please do not send or share with us the following types of information:
We will collect and process the following data about you:
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For detailed information on the cookies we use see our cookie banner.
We will only use your personal data when the law allows us to do so. Most commonly we will use your personal data in the following circumstances:
The table at 9 below sets out the lawful basis for processing for the different types of personal data. We appreciate that some of these terms can be confusing so we have included a glossary at the end of this policy which explains the types of lawful basis that we will rely on to process your personal data.
We will only send you direct marketing communications by email or text if we have your consent. You have the right to withdraw that consent at any time by contacting us, or by using the unsubscribe link included in each marketing email.
|Type of data
|Lawful basis for processing
|To install the App and register you as a new App user
|Contact Data, Device Data
|Necessary for our legitimate interests (to provide the Service to you)
|To deliver Services
Marketing and Communications Data,
|Performance of a contract with you. Necessary for our legitimate interests (to provide a good Service to you)
|To manage our relationship with you including notifying you of changes to the App or any Services
Marketing and Communications Data
|Performance of a contract with you. Necessary for our legitimate interests (to keep records updated and to analyse how customers use our Platform/ Services)Necessary to comply with legal obligations (to inform you of any changes to our terms and conditions)
|When you contact us with feedback, complaints and questions
Marketing and Communications Data
|Performance of a contract with you Necessary for our legitimate interests (to analyse how to improve our Platform/Services and to develop them and grow our business)
|To administer and protect our business and the Platform including troubleshooting, data analysis and system testing
|Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security)
|To deliver content and advertisements to you. To make recommendations to you about goods or services which may interest you. To measure and analyse the effectiveness of the advertising we serve you. To monitor trends so we can improve the Platform
Marketing and Communications Data,
|Your consent. Necessary for our legitimate interests (to develop our Platform/Services and grow our business)
When you consent to providing us with your personal data, we will also ask you for your consent to share your personal data with the third parties set out below:
Whenever we transfer your personal data out of the UK or the European Economic Area ("EEA"), we will ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:
Google Analytics: https://support.google.com/analytics/answer/7105316?hl=en;
Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the UK or EEA.
We keep the information you provide to us secure. Where we have given you (or where you have chosen) a password that enables you to access certain parts of our Platform, you are responsible for keeping this password confidential. We ask you not to share a password with anyone.
Once we have received your information, we will use strict procedures and security features to try to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way.
We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator when we are legally required to do so.
We will keep your personal data as long as you have an open account with us. We will delete your personal data once you close your account with us, except for data we may need for our legal, regulatory, accounting purposes, or where it is Aggregated Data.
In the event that you do not use the App for a period of 5 years then we will treat the account as expired, in which we would give you notice of this and your personal data may be deleted.
In some circumstances you can ask us to delete your data, see section 15 below for further information.
In some circumstances we will anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes, in which case we may use this information indefinitely without further notice to you.
Details of retention periods for different aspects of your personal data are available by contacting us.
Our Platform may, from time to time, contain links to and from the websites of our partner networks, advertisers and affiliates. Please note that these websites and any services that may be accessible through them have their own privacy policies and that we do not accept any responsibility or liability for these policies or for any personal data that may be collected through these websites or services, such as Contact and Location Data. Please check these policies before you submit any personal data to these websites or use these services.
Under certain circumstances you have the following rights under data protection laws in relation to your personal data.
You also have the right to ask us not to continue to process your personal data for marketing purposes.
You can exercise any of these rights at any time by contacting us at our details included at the beginning of this policy.
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 or other competent supervisory authority of an EU member state where the App is downloaded.
Consent means processing your personal data where you have signified your agreement by a statement or clear opt-in to processing for a specific purpose. Consent will only be valid if it is a freely given, specific, informed and unambiguous indication of what you want. You can withdraw your consent at any time by contacting us.
Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give you the best service/product and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us.
Performance of Contract means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.
Comply with a legal obligation means processing your personal data where it is necessary for compliance with a legal obligation that we are subject to.
End of policy