1. Introduction
   • We are committed to safeguarding the privacy of our website visitors and service users.

• This policy applies when we act as a data controller concerning the personal data of our website visitors and service users; essentially, where we determine the purposes and methods of processing that personal data.

• We utilize cookies on our website. If these cookies are not strictly necessary for the provision of our website and services, we will request your consent to our cookie usage upon your initial visit to our website.

• Our website includes privacy controls that influence how we handle your personal data. Through these privacy controls, you can specify whether you wish to receive direct marketing communications and restrict the publication of your information. You can access the privacy controls via Pappayacloud.com.

• In this policy, “we,” “us,” and “our” refer to Pappaya Global Limited.

• Personal data we collect

• Information You Give Us: We collect any information you provide in relation to Pappaya Cloud Services.

• Automatic Information: We automatically collect certain types of information when you interact with Pappaya Cloud services.

• Information from Other Sources: We might collect information about you from other sources, including service providers, partners, and publicly available sources.

• How we use your personal data
  • In this Section we have set out:
    • The general categories of personal data that we may process;
    • In instances where we did not directly obtain personal data from you
    • The source and specific categories of that data;
    • The purposes for which we may process personal data; and
    • The legal bases of the processing.

• We may process data regarding your utilization of our website and services (“usage data”). Such usage data may encompass your IP address, geographical location, browser type and version, operating system, referral source, duration of visit, page views, website navigation paths, as well as details about the timing, frequency, and pattern of your service usage. Our analytics tracking system is the source of this usage data. The processing of this usage data may serve the purpose of analysing the usage of the website and services. The legal basis for this processing is consent OR our legitimate interests, specifically monitoring and enhancing our website and services OR delivering our services.

• We may process your account data (“account data”). This account data may consist of your name and email address. You or your employer are the sources of the account data. Processing of the account data may be conducted for the purposes of operating our website, providing our services, ensuring the security of our website and services, maintaining backups of our databases, and communicating with you. The legal basis for this processing is consent OR our legitimate interests. interests, Specifically, this involves the proper administration of our website and business OR the performance of a contract between you and us and/or taking steps, at your request, to enter such a contract.

• We may process the information included in your personal profile on our website (“profile data”). This profile data may comprise your name, address, telephone number, email address, profile pictures, gender, date of birth, relationship status, interests and hobbies, educational details, and employment details. Processing of the profile data may serve the purpose of enabling and monitoring your use of our website and provided services. The legal basis for this processing is consent OR our legitimate interests, specifically the proper administration of our website and business services offered OR the performance of a contract between you and us and/or taking steps, at your request, to enter such a contract.

• We may process your personal data provided during the use of our services (“service data”). Such service data may encompass company files, folders, data, and email. You or your employer are the sources of the service data. Processing of the service data may be conducted for the purposes of operating our website, providing our services, ensuring the security of our website and services, maintaining backups of our databases, and communicating with you. The legal basis for this processing is consent OR our legitimate interests, specifically the proper administration of our website and business OR the performance of a contract between you and us and/or taking steps, at your request, to enter such a contract.

• We may process information that you post for publication on our website or through our services (“publication data”). This publication data may be processed for the purposes of enabling such publication and administering our website and services. The legal basis for this processing is consent OR our legitimate interests, specifically the proper administration of our website and business OR the performance of a contract between you and us and/or taking steps, at your request, to enter such a contract.

• We may process information contained in any enquiry you submit to us regarding goods and/or services (“enquiry data”). Processing of the enquiry data may serve the purpose of offering, marketing, and selling relevant goods and/or services to you. The legal basis for this processing is consent.

• We may process information relating to our customer relationships, including customer contact information (“customer relationship data”). This customer relationship data may include your name, your employer, your job title or role, your contact details, and information contained in communications between us and you or your employer. You or your employer are the sources of the customer relationship data. Processing of the customer relationship data may be conducted for the purposes of managing our relationships with customers, communicating with customers, keeping records of those communications, and promoting our products and services to customers. The legal basis for this processing is consent OR our legitimate interests, specifically the proper management of our customer relationships.

• We may process information relating to transactions, including purchases of goods and services, that you make with us and/or through our website (“transaction data”). This transaction data may include your contact details, card details, and transaction details. Processing of the transaction data may serve the purpose of supplying the purchased goods and services and maintaining proper records of those transactions. The legal basis for this processing is the performance of a contract between you and us and/or taking steps, at your request, to enter such a contract, and our legitimate interests, specifically the proper administration of our website and business.

• We may process information that you provide to us for the purpose of subscribing to our email notifications and/or newsletters (“notification data”). This notification data may be processed for the purposes of sending you relevant notifications and/or newsletters. The legal basis for this processing is consent OR [the performance of a contract between you and us and/or taking steps, at your request, to enter such a contract.

• We may process information contained in or relating to any communication that you send to us (“correspondence data”). The correspondence data may include the communication content and metadata associated with the communication. The metadata associated with communications made using the website contact forms will be generated by our website. Processing of the correspondence data may serve the purposes of communicating with you and record-keeping. The legal basis for this processing is [our legitimate interests, specifically the proper administration of our website and business and communications with users.

• We may process business data. This data may include files, folders, business data, and emails. The source of this data is cloud-based. Processing of this data may serve the purpose of delivering service. The legal basis for this processing is consent OR our legitimate interests, specifically providing Cloud Services OR the performance of a contract between you and us and/or taking steps, at your request, to enter such a contract.

• We may process any of your personal data identified in this policy where necessary for the establishment, exercise, or defence of legal claims, whether in court proceedings or in an administrative or out-of-court procedure. The legal basis for this processing is our legitimate interests, specifically the protection and assertion of our legal rights, your legal rights, and the legal rights of others.

• We may process any of your personal data identified in this policy where necessary for the purposes of obtaining or maintaining insurance coverage, managing risks, or obtaining professional advice. The legal basis for this processing is our legitimate interests, specifically the proper protection of our business against risks.

• In addition to the specific purposes for which we may process your personal data set out in this Section 3, we may also process any of your personal data where such processing is necessary for compliance with a legal obligation to which we are subject, or to protect your vital interests or the vital interests of another natural person.

• Please do not supply any other person’s personal data to us unless we prompt you to do so.

• How we secure data

We employ a combination of physical, electronic, and procedural measures to safeguard the collection, storage, and disclosure of personal information. These security protocols may necessitate requesting proof of identity before providing access to personal information.

How we share your personal data

• We may disclose your personal data to any member of our group of companies (meaning our subsidiaries, our ultimate holding company, and all its subsidiaries) insofar as reasonably necessary for the purposes, and based on the legal bases, outlined in this policy. Information about our group of companies can be found at Pappayacloud.com.

• We may disclose your personal data to our insurers and/or professional advisers insofar as reasonably necessary for the purposes of obtaining or maintaining insurance coverage, managing risks, obtaining professional advice, or the establishment, exercise, or defence of legal claims, whether in court proceedings or in an administrative or out-of-court procedure.

• We may disclose information such as business data to our suppliers or subcontractors identified at www.Pappayacloud.com insofar as reasonably necessary for delivering our services.

• Financial transactions relating to our website and services are handled by our payment services providers, GoCardless. We will share transaction data with our payment services providers only to the extent necessary for the purposes of processing your payments, refunding such payments, and dealing with complaints and queries relating to such payments and refunds. Information about the payment services providers’ privacy policies and practices can be found at gocardless.com.

• We may disclose your enquiry data to one or more of those selected third-party suppliers of goods and services identified on our website for the purpose of enabling them to contact you so that they can offer, market, and sell to your relevant goods and/or services. Each such third party will act as a data controller in relation to the enquiry data that we supply to it; and upon contacting you, each such third party will supply to you a copy of its own privacy policy, which will govern that third party’s use of your personal data.

• In addition to the specific disclosures of personal data set out in this Section 5, we may disclose your personal data where such disclosure is necessary for compliance with a legal obligation to which we are subject, or to protect your vital interests or the vital interests of another natural person. We may also disclose your personal data where such disclosure is necessary for the establishment, exercise, or defence of legal claims, whether in court proceedings or in an administrative or out-of-court procedure.

• Location of personal information

Pappaya Cloud is in the United Kingdom, and our affiliated companies are located throughout the world. Depending on the scope of your interactions with our services, your personal information may be stored in or accessed from multiple countries, including the United Kingdom. Whenever we transfer personal information to other jurisdictions, we will ensure that the information is transferred in accordance with this Privacy Notice and as permitted by applicable data protection laws.

• Third party sites and services

Pappaya services may embed content provided by others or include links to other websites and applications. These companies may collect information about you when you interact with their content or services. We are not responsible for the practices of these companies. Please consult their privacy policies to learn about their data practices.

• International transfers of your personal data

• In this Section 8, we provide information about the circumstances in which your personal data may be transferred to countries outside the European Economic Area (EEA).
• The hosting facilities for our website are situated in the United Kingdom. The European Commission has made an “adequacy decision” regarding the data protection laws of each of these countries. Transfers to each of these countries will be protected by appropriate safeguards, namely the use of standard data protection clauses adopted or approved by the European Commission. You can obtain a copy of these clauses from the specified source OR specify appropriate safeguards and means to obtain a copy.
• Third-party companies we partner with are situated in the United Kingdom. The European Commission has made an “adequacy decision” regarding the data protection laws of each of these countries. Transfers to each of these countries will be protected by appropriate safeguards, namely the use of standard data protection clauses adopted or approved by the European Commission. You can obtain a copy of these clauses from The European Commission website.

You acknowledge that personal data that you submit for publication through our website or services may be available, via the internet, around the world. We cannot prevent the use (or misuse) of such personal data by others.

• Retaining and deleting personal data
  • This Section 9 outlines our data retention policies and procedures, designed to ensure compliance with our legal obligations regarding the retention and deletion of personal data.
  • Personal data processed for any purpose shall not be retained for longer than necessary for that purpose or those purposes.
  • We will retain your personal data as follows:
• Any personal data captured via our website or services, including name, email, and business data, will be retained for a minimum period of 24 months following the capture date.
  • In some cases, it is not possible for us to specify in advance the periods for which your personal data will be retained. In such cases, we will determine the retention period based on the following criteria:
• The retention period will be determined based on whether the person/business made an enquiry within the last 24 months.
  • Despite the other provisions of this Section 9, we may retain your personal data where such retention is necessary for compliance with a legal obligation to which we are subject or to protect your vital interests or the vital interests of another natural person.

• Amendments
  • We may update this policy from time to time by publishing a new version on our website.
  • You should check this page occasionally to ensure you are happy with any changes to this policy.
  • We may OR will notify you of changes OR significant changes to this policy by email or through the private messaging system on our website.

• Your rights

In this Section, we have summarised the rights that you have under data protection law. Some of the rights are complex, and not all the details have been included in our summaries. Accordingly, you should read the relevant laws and guidance from the regulatory authorities for a full explanation of these rights.

• Your principal rights under data protection law are:

                   (a) the right to access;

                   (b) the right to information;
                   (c) the right to rectification;
                   (d) the right to erasure;
                   (e) the right to restrict processing;
                   (f) the right to object to processing;
                   (g) the right to data portability;
                   (h) the right to complain to a supervisory authority; and
                   (i) the right to withdraw consent.

• You have the right to confirmation as to whether we process your personal data and, where we do, access to the personal data, together with certain additional information. That additional information includes details of the purposes of the processing, the categories of personal data concerned and the recipients of the personal data. Providing the rights and freedoms of others are not affected, we will supply to you a copy of your personal data. The first copy will be provided free of charge, but additional copies may be subject to a reasonable fee. You can access your personal data by visiting www.Pappayacloud.com when logged into our website.
• You have the right to have any inaccurate personal data about you rectified and, considering the purposes of the processing, to have any incomplete personal data about you completed.
• In some circumstances you have the right to the erasure of your personal data without undue delay. Those circumstances include: [the personal data are no longer necessary in relation to the purposes for which they were collected or otherwise processed; you withdraw consent to consent-based processing; you object to the processing under certain rules of applicable data protection law; the processing is for direct marketing purposes; and the personal data have been unlawfully processed]. However, there are exclusions of the right to erasure. The general exclusions include where processing is necessary: for exercising the right of freedom of expression and information; for compliance with a legal obligation; or for the establishment, exercise or defence of legal claims.
• In some circumstances you have the right to restrict the processing of your personal data. Those circumstances are: you contest the accuracy of the personal data; processing is unlawful but you oppose erasure; we no longer need the personal data for the purposes of our processing, but you require personal data for the establishment, exercise or defence of legal claims; and you have objected to processing, pending the verification of that objection. Where processing has been restricted on this basis, we may continue to store your personal data. However, we will only otherwise process it: with your consent; for the establishment, exercise, or defence of legal claims; for the protection of the rights of another natural or legal person; or for reasons of important public interest.
• You have the right to object to our processing of your personal data on grounds relating to your particular situation, but only to the extent that the legal basis for the processing is that the processing is necessary for: the performance of a task carried out in the public interest or in the exercise of any official authority vested in us; or the purposes of the legitimate interests pursued by us or by a third party. If you make such an objection, we will cease to process the personal information unless we can demonstrate compelling legitimate grounds for the processing which override your interests, rights and freedoms, or the processing is for the establishment, exercise, or defence of legal claims.
• You have the right to object to our processing of your personal data for direct marketing purposes (including profiling for direct marketing purposes). If you make such an objection, we will cease to process your personal data for this purpose.
• You have the right to object to our processing of your personal data for scientific or historical research purposes or statistical purposes on grounds relating to your situation, unless the processing is necessary for the performance of a task carried out for reasons of public interest.
• To the extent that the legal basis for our processing of your personal data is:

        (a) Consent; or
        (b) That the processing is necessary for the performance of a contract to which you are party or in order to take steps at your request prior to entering into a contract, and such processing is carried out by automated means, you have the right to receive your personal data from us in a structured, commonly used and machine readable format. However, this right does not apply where it would adversely affect the rights and freedoms of others.

• If you consider that our processing of your personal information infringes data protection laws, you have a legal right to lodge a complaint with a supervisory authority responsible for data protection. You may do so in the EU member state of your habitual residence, your place of work or the place of the alleged infringement.
• To the extent that the legal basis for our processing of your personal information is consent, you have the right to withdraw that consent at any time. Withdrawal will not affect the lawfulness of processing before the withdrawal.
• You may exercise any of your rights in relation to your personal data by written notice to us in addition to the other methods specified in this Section 11.

• About cookies

• A cookie is a file containing an identifier (a string of letters and numbers) that is sent by a web server to a web browser and is stored by the browser. The identifier is then sent back to the server each time the browser requests a page from the server.
• Cookies may be either “persistent” cookies or “session” cookies: a persistent cookie will be stored by a web browser and will remain valid until its set expiry date, unless deleted by the user before the expiry date; a session cookie, on the other hand, will expire at the end of the user session, when the web browser is closed.
• Cookies do not typically contain any information that personally identifies a user, but personal information that we store about you may be linked to the information stored in and obtained from cookies.

• Cookies that we use
  • We use cookies for the following purposes:
    • Authentication – we use cookies to identify you when you visit our website and as you navigate our website (cookies used for this purpose are: track and monitor visitors
      (b) Status – we use cookies to help us to determine if you are logged into our website cookies used for this purpose are: track and monitor visitors
      (c) Personalisation – we use cookies to store information about your preferences and to personalise the website for you (cookies used for this purpose are: Track and monitor visitors
      (d) Security – we use cookies as an element of the security measures used to protect user accounts, including preventing fraudulent use of login credentials, and to protect our website and services generally (cookies used for this purpose are: track and identify visitors
      (e) Advertising – we use cookies to help us to display advertisements that will be relevant to you (cookies used for this purpose are track and identify visitors
      (f) Analysis – we use cookies to help us to analyse the use and performance of our website and services(cookies used for this purpose are: track and identify visitors
      (g) Cookie consent – we use cookies to store your preferences in relation to the use of cookies more generally (cookies used for this purpose are track and identify visitors
  • Cookies used by our service providers
    • Our service providers use cookies, and those cookies may be stored on your computer when you visit our website.
    • We use Google Analytics to analyse the use of our website. Google Analytics gathers information about website use by means of cookies. The information gathered relating to our website is used to create reports about the use of our website. Google’s privacy policy is available at: https://www.google.com/policies/privacy/. The relevant cookies are: track and trace visitors.
    • We publish Google AdSense interest-based advertisements on our website. These are tailored by Google to reflect your interests. To determine your interests, Google will track your behaviour on our website and on other websites across the web using cookies. OR We publish Google AdSense advertisements on our website. To determine your interests, Google will track your behaviour on our website and on other websites across the web using cookies. This behaviour tracking allows Google to tailor the advertisements that you see on other websites to reflect your interests (but we do not publish interest-based advertisements on our website). You can view, delete or add interest categories associated with your browser by visiting: https://adssettings.google.com. You can also opt out of the AdSense partner network cookie using those settings or using the Network Advertising Initiative’s multi-cookie opt-out mechanism at: http://optout.networkadvertising.org. However, these opt-out mechanisms themselves use cookies, and if you clear the cookies from your browser your optout will not be maintained. To ensure that an opt-out is maintained in respect of a particular browser, you may wish to consider using the Google browser plug-ins available at: https://support.google.com/ads/answer/7395996. The relevant cookies are:
    • We use Google to track and trace. This service uses cookies for You can view the privacy policy of this service provider at google.com.

• Managing cookies
  • Most browsers allow you to refuse to accept cookies and to delete cookies. The methods for doing so vary from browser to browser, and from version to version. You can however obtain up-to-date information about blocking and deleting cookies via these links:

(a) https://support.google.com/chrome/answer/95647?hl=en (Chrome);
(b) https://support.mozilla.org/en-US/kb/enable-and-disable-cookies-website-preferences (Firefox);
(c) http://www.opera.com/help/tutorials/security/cookies/ (Opera);
(d) https://support.microsoft.com/en-gb/help/17442/windows-internet-explorerdelete-manage-cookies (Internet Explorer);
(e) https://support.apple.com/kb/PH21411 (Safari); and

• Blocking all cookies will have a negative impact upon the usability of many websites.
• If you block cookies, you will not be able to use all the features on our website.

• Our details

If you have any concerns about privacy at Pappaya, please contact us with a thorough description, and we will try to resolve the issue for you. 

• This website is owned and operated by Pappaya Global Limited.
• We are registered in England and Wales under registration number 15374134, and our registered office is at Svetlanas,St Anns Hill Road, United Kingdom, KT16 9NN
• Our principal place of business is at Svetlanas,St Anns Hill Road, United Kingdom, KT16 9NN
• You can contact us:

(a) By post, to the postal address given above;
(b) Using our website contact form;
(c) By telephone, on the contact number published on our website from time to time;
(d) By email, using the email address published on our website from time to time.

• Privacy Policy Updates

We might update our Privacy Policy periodically. Any changes we make will be posted on this page. Therefore, we encourage you to check back regularly to stay informed about our privacy practices.