Silverwing is a trading name of Casqol Limited ('we') ('our') ('us') ('Silverwing'), a company registered in England and Wales (company number: 10716411), with the registered address: 243 High Street, Boston Spa, West Yorkshire LS23 6AL, VAT number 273673576.
Silverwing is committed to ensuring that your privacy is protected and we comply with the General Data Protection Regulation and other applicable data protection rules including the Data Protection Act 2018 and marketing and cookies laws, together with associated guidance (the "Data Protection Laws").
This privacy policy ("Policy") sets out how we use and protect any personal data that you give us or that we collect when you use this website (www.silverwing.co), any website powered by us or our Platform. This Policy is limited to the information that we collect and use about you. We ask that you read this Policy carefully as it contains important information about how we use personal data and how we will ensure that we meet our legal obligations to you under the Data Protection Laws.
It is important that you take the time to read this Policy so that you understand how we will use your personal data and your rights in relation to your personal data. If you have concerns about how we use your personal data, you can contact our Data Protection Officer at dpo@silverwing.co.
This Policy describes how we use personal data of:
This policy does not apply to information relating to limited liability companies. This is because Data Protection Laws only apply to information relating to natural persons. Information relating to corporate bodies may still be protected by other laws such as confidentiality and we take those obligations seriously as well.
Mostly, we operate as a processor of the data that you share with us when using the Silverwing Platform and our service. Our client (e.g. the Supplier, Buyer, Donor or Lessor on the Platform) is usually the data controller. This is because we process personal data on their behalf and as instructed by them. Our client's privacy policy governs such processing therefore please review their privacy policy to understand how your information is processed and refer any questions that you may have directly to them.
We act as a controller when we process the personal data of Customers, Customer Representatives and/or donors to promote and sell our services and to administer our relationship with our Customers, in these situations this Policy shall apply.
Under the Data Protection Laws, we are required to explain what information we collect from you and how and why we use your personal information. We are also required to have a "lawful basis" on which to process your personal information. This is summarised in the table below.
To enter into and administer our contracts with Customers, including setting up Customer accounts, administering our services, assessing trade credit applications and collecting payments due to us.
If you are a Customer, we process this information as it is necessary for us to enter a contract with you and to perform that contract.
If you are a Customer Representative, we process this information as it is necessary for our legitimate interest to provide our services to our Customers.
We collect information you provide when you:
For the duration you hold an account with us and for 6 years following the closure of your account.
To help us to improve our website or Platform.
The processing is necessary for our legitimate interest to conduct our business in an efficient manner.
Where data is collected via a cookie or other tracking mechanism this will subject to your consent.
Information from your device.
For the duration you hold an account with us and for 3 years following the closure of your account.
To promote our products and Services, including by providing you with information about other products and services we offer that are similar to those you have already used or asked about and if you agree, provide you with information about our partners’ or other organisations’ promotions or offers which we think you might be interested in.
The processing is necessary for our legitimate interest to promote our business and our products and services.
Please note: Our partners and such other organisations are the controllers of such information that you elect to provide to them therefore please review the privacy policy of the relevant partner or organisation in order to understand how your information is used.
From you via our website or the Silverwing Platform.
For the duration you hold an account with us and for 3 years following the closure of your account.
To manage our website and the Silverwing Platform, (including troubleshooting, data analysis, testing, research, statistical and survey purposes), and to make sure that content from our website is presented in the most effective way for you and your device.
The processing is necessary for our legitimate interest to conduct our business in an efficient manner.
From you via our website and the Silverwing Platform.
For the duration you hold an account with us and for 3 years following the closure of your account.
We prepare anonymised statistical datasets about our Customers’ spending or sales patterns for forecasting purposes or to help governments and third-party organisations in policy-making. These datasets may be shared internally or externally with others, including non-Silverwing companies. We produce these reports using information about you and other customers.
The information used and shared in this way is never personal data and you will never be identifiable from it. Anonymised statistical data cannot be linked back to you as an individual.
The processing is necessary for our legitimate interest to conduct research and analysis, including to produce statistical research and reports.
From you via our website and the Silverwing Platform.
For the duration you hold an account with us and for 3 years following the closure of your account.
To comply with legal and regulatory obligations.
The processing is necessary for us to comply with our legal obligations.
From you via our website, the Silverwing Platform or when you call or email us.
For the duration you hold an account with us and for 6 years following the closure of your account.
To prevent and detect unlawful activities such as fraud and money laundering.
The processing is necessary for our legitimate interests to protect our business and co-operate with law enforcement authorities and to meet our legal and regulatory duties.
From you via our Website or when you call or email us or from publicly available sources, such as media stories, online registers or directories, and websites for enhanced due diligence checks, security searches, and KYC purposes.
Occasionally, we will use publicly available information about you from selected social media websites or apps to carry out enhanced due diligence checks. Publicly available information from social media websites or apps may also be provided to us when we conduct general searches on you (for example, to comply with any anti-money laundering or sanctions screening obligations).
We also collect personal data from third parties, such as credit-reference agencies, financial or credit institutions, official registers and databases, as well as fraud-prevention agencies and partners who help us to provide our services.
We hold this information for 6 years after the relevant issue arises or, if litigation is pursued, until the issue is finally resolved.
To process job applications of perspective employees of Silverwing.
The processing is necessary for our legitimate interest to undertake recruitment.
From you via our website or via email.
For the duration you hold an account with us and for 3 years following the closure of your account.
To reply to and deal with complaints and queries.
The processing is necessary for our legitimate interest to provide Customers with a good service.
From you via our website through our chat function or contact page or via the Silverwing Platform.
If the data relates to a complaint, we will retain it for 6 years from when the issue is finally resolved.
Otherwise, we will hold this data for 1 year.
To provide customer support, training and quality control purposes.
If you are a Customer, we process this information as it is necessary for us to manage our contract with you and to perform that contract.
If you are not a Customer the processing is necessary for our legitimate interest to provide you with necessary support and ensure our services operate correctly.
We collect this from information provided by you when you contact us via the Silverwing Platform or our website.
For the duration you hold an account with us and for 3 years following the closure of your account.
To recover debt and exercise other rights we have under any agreement we have with you.
We process this information as it is necessary for us to manage our contract with you.
We collect information you provide when you register to use the Silverwing Platform or open an account or use any of our services.
For the duration you hold an account with us and for 6 years following the closure of your account.
Where we process personal data on the legal basis of 'legitimate interests' (as indicated in the above table), we have determined, acting reasonably and considering the circumstances, that we are able to do so after carrying out a balancing exercise to make sure that our legitimate interests are not overridden by your interests, rights and freedoms. Where we rely on this legal basis, (a) we process the data only to the extent that is necessary for the relevant purpose; and (b) the relevant processing activities can be reasonably expected. The legitimate interests we pursue are specified in the above table with respect to each relevant purpose.
Where we process personal data on the legal basis of 'consent' (as indicated in the above table), you may refuse to consent to our processing and you may also withdraw your consent at any time, by using the privacy settings in the Silverwing Platform or by emailing our Data Protection Officer at dpo@silverwing.co. This would not affect your ability to use any features of the Silverwing Platform. Withdrawing consent does not affect any processing carried out without your consent.
We do not seek or knowingly collect any personal data about anyone under 18 years of age. We ask that you do not voluntarily provide us with information about any person younger than 18 years old. If you provide us with such information and we are aware that it relates to some who is younger than 18, we will promptly and securely delete this information.
Depending on the Silverwing products or services you use, we may make automated decisions about you. This means that we may use technology that can evaluate your business’ specific circumstances and other factors to predict risks or outcomes. We do this for the efficient running of our services and to ensure decisions are fair, consistent and based on the right information. Where we make an automated decision about you or your company, you have the right to ask that it is manually reviewed by a person. For example, we may make automated decisions about you that relate to credit and affordability checks to see whether we or suppliers can accept your trade credit application; setting trade credit limits; or monitoring your account to detect fraud and financial crime.
We and third-party organisations including our lending partners may use credit-reference agencies (or other providers of credit information in relevant countries) to carry out credit checks on your company if you apply (or tell us you want to apply) for a Trade Credit Facility or Lease Product through Silverwing.
These checks may include checks against individuals where they are the Directors or relevant persons in relation to whom the credit facility would be offered and whose information would be needed in order to provide a Trade Credit Facility or Lease Product through Silverwing.
We may also share this personal data with credit-reference agencies (or other providers of credit information) to:
When you enter into a trade credit agreement with us, or a third party via Silverwing, we may continue sharing information with credit reference agencies or other providers of credit information (for example, information about your repayments and whether you repay in full or on time).
We may also check your credit history to help us develop and, in the future, offer credit products that meet the needs of our Customers. This will enable us to pre-filter the credit products that you may be eligible for by third parties and, in some cases, let you know before you apply if you will be accepted for a Trade Credit Facility.
However, if you would prefer that we do not use your data in this way you can use the privacy settings on the Silverwing Platform to opt out.
Credit-reference agencies will not store any of your information that we send them when we use their services for this purpose and these checks do not leave any ‘footprint’ (trace) whatsoever on your credit record held by the credit-reference agency.
| Your right | What it means |
|---|---|
| You have the right to be told about how we use your personal data. | We provide this Policy to explain how we use your personal data. If you ask, we will provide a copy of the personal data we hold about you. We can’t give you any personal data about other people, personal data which is linked to an ongoing criminal or fraud investigation, or personal data which is linked to settlement negotiations with you. We also won't provide you with any communication we've had with our legal advisers. |
| You can ask us to correct your personal data if you think it's wrong. | You can have incomplete or inaccurate personal data corrected. Before we update your file, we may need to check the accuracy of the new personal data you have provided. |
| You can ask us to delete your personal data. |
You can ask us to delete your personal data if:
|
| You can object to us processing your personal data for marketing purposes. | You can tell us to stop using your personal data for marketing. |
| You can object to us processing other personal data (if we are using it for legitimate interests). |
If our legal basis for using your personal data is 'legitimate interests' and you disagree with us using it, you can object. However, if there is an overriding reason why we need to use your personal data, we will not accept your request. If you object to us using personal data which we need in order to provide our services, we may need to close your account as we won’t be able to provide the services. |
| You can ask us to restrict how we use your personal data. |
You can ask us to suspend using your personal data if:
|
| You can ask us to transfer personal data to you. | If we can, and are allowed to do so under regulatory requirements, we will provide your personal data in a structured, commonly used, machine-readable format. |
| You can withdraw your permission. |
If you have given us any consent we need to use your personal data, you can withdraw your consent at any time by changing your privacy settings on the Silverwing Platform or sending an email to dpo@silverwing.co.
(Note, it will have been lawful for us to use the personal data up to the point you withdraw your permission). |
| You can ask us to carry out a human review of an automated decision we make about you. | If we make an automated decision about you that significantly affects you, you can ask us to carry out a manual review of this decision. |
Your ability to exercise these rights will depend on a number of factors. Sometimes, we will not be able to agree to your request (for example, if we have a legitimate reason for not doing so or the right does not apply to the particular information we hold about you).
To exercise any of your rights set out in the previous section, you can contact us through the Silverwing Platform or send us an email at dpo@silverwing.co. For security reasons, we can't deal with your request if we are not sure of your identity, so we may ask you for proof of your ID.
Silverwing will usually not charge you a fee when you exercise your rights. However, we are allowed by law to charge a reasonable fee or refuse to act on your request if it is manifestly unfounded or excessive.
If you have any concerns regarding our processing of your personal data, or are not satisfied with our handing of any request may by you, or would otherwise like to make a complaint, please contact our DPO in the first instance using the details at the start of this policy (see section 2), so that they can do their very best to sort out the problem. You can also contact the Information Commissioner's Office at Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF www.ico.org.uk.
The table below explains which Partners we normally share your personal data with.
| Type of Partner | Why we share your personal data |
|---|---|
| Organisations who provide us with IT, payment and delivery services | To help us provide our services to you. |
| Our service hosting, administration and development service providers | To help us provide our services to you. |
| Our Professional Advisors | To enforce or apply the terms of use and other agreements you have with us. |
| Our banking and financial-services partners and payments networks | To help us provide our services to you. |
| Analytics providers and search information providers | To help us improve our website or Platform. |
| Customer-service providers, survey providers and developers | To help us provide our services to you. |
| Communications services providers | To help us send you emails, push notifications and text messages. |
| Debt collection agencies | To manage and recover debts that you owe or may become owing if you have a supplier credit product. |
| Potential and actual buyers and/or funders of our business or assets; | In the event of a sale or purchase of other businesses connected with ours. |
| Credit Reference Agencies | To help us provide our services to you. |
| IT service providers | To help us provide our services to you. |
| Payment services providers | To process payments due to us. |
| Our programme manager, Consenna Limited | To offer services on the Devices for Education Platform, where applicable. |
| Administrators or liquidators | In the event that our business goes into administration, liquidation or a similar procedure. |
| Courts and tribunals | Where required for progressing claims. |
| Fraud prevention agencies | For the purposes of enforcing our rights and for detecting and preventing unlawful activities. |
| Law enforcement and regulatory agencies, including HMRC | In connection with any investigation to help prevent unlawful activity or as otherwise required by applicable law. |
| The Customer who you represent or who authorised your use of the Platform | To help us provide our services to you. |
Where we process personal data as a processor, we may also disclose the relevant personal data as instructed by and on behalf of the relevant client (as the controller).
The information you provide to us will be transferred to and stored on our secure services in the European Economic Area (EEA). However, from time to time, we may need to transfer your personal data outside the United Kingdom or EEA in order for us to provide our services.
Where we transfer your personal data outside the EEA, we will ensure that it is protected in a manner that is consistent with how your personal data will be protected by us in the EEA. This can be done in a number of ways, for instance:
In all cases we will ensure that any transfer of your personal data is compliant with Data Protection Law.
We may share your personal data with credit-reference agencies and fraud-prevention agencies that are based outside of the United Kingdom or EEA. We will take all reasonable steps to make sure that your personal data is handled securely and in line with this Policy and Data Protection Laws.
We recognise the importance of protecting and managing your personal data. Any personal data we process will be treated with the utmost care and security. This section sets out some of the security measures we have in place.
We use a variety of physical and technical measures to keep your personal data safe and prevent unauthorised access to, or use or disclosure of it. Electronic data and databases are stored on secure computer systems with control over access to information using both physical and electronic means. Our staff receive data protection and information security training. We have detailed security and data protection policies which staff are required to follow when they handle your personal data.
While we take all reasonable steps to ensure that your personal data will be kept secure from unauthorised access, we cannot guarantee it will be secure during transmission by you to our Platform, website or other services. We use HTTPS (HTTP Secure), where the communication protocol is encrypted through Transport Layer Security for secure communication over networks, for all our Platform, web and payment-processing services.
When you use our services, which includes our social network accounts, do not share any personal data that you don't want to be seen, collected or used by other customers, as this personal data will become publicly available.
We keep this Policy under regular review, if we change the way we use your personal data, we will update this Policy and, if appropriate, let you know by email, through the Silverwing Platform or through our website. Please check back frequently to see any updates to our Policy. This Policy is effective from 25th March 2021.
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Silverwing uses “cookie” technology and other similar technologies to collect additional website usage data and to improve our services. This includes technical information, such as the internet protocol (IP) address used to connect your computer to the internet; your log-in information; the browser type and version; the time-zone setting; the operating system and platform; the type of device you use; your mobile operating system; the type of mobile browser you use; information about your visit, including the links you have clicked on, 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 and clicks), and methods used to browse away from the page; and information on transactions (for example, orders, payments to Silverwing or Suppliers including the date, time, amount, details, details of the Buyer or Supplier associated with the transaction).
We only use cookies if you give your consent for us to do so, with the exception of cookies which are essential for the website to function. However, if you do not consent to the use of cookies, please ensure that your browser or computer/device is set to reject cookies or prompt you before accepting third party cookies. Not consenting to the use of cookies may prevent you from taking full advantage of the website. For more information about cookies and how we use them, please read our cookie policy.
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