Privacy Policy

FDJ Ecommerce Ltd, trading as ComplyFirst (“ComplyFirst”) is committed to protecting your personal information and respecting applicable data protection laws around the world. This privacy policy explains how we do this, and it applies to your use of our websites, products, and services.

How we use your personal information

We use personal information in order to promote and provide the ComplyFirst software service, to ensure the security of our websites, and to run our business. We have set out below more information on the categories of personal information that we collect, the specific ways in which that personal information is processed by us, the legal bases which permit us to do this, and the types of partners with whom we share your personal information.

In some cases where we ask for your personal information, we do so in order for us to fulfil your request or order (e.g. needing your email address to create your account with us). If you do not provide that personal information, we will not be able to process your request or order.

What information does ComplyFirst collect?

We collect and process personal data about you when you purchase our services and interact with us and our platform. We may also collect personal data about you without your direct input from various third parties and public sources, including the Financial Conduct Authority (FCA) Financial Services Register, and Companies House.

Information we may collect from you and about you include:

  • Your name, username, and password
  • Your address, email address, and phone number
  • Records of your engagement with any corporate entity (including directorships and shareholdings)
  • Your payment details
  • Your marketing preferences, including any consent you have given us
  • Technical information related to the device you use to access our websites, including internet protocol (IP) address, your login data, browser or mobile browser type and version, timezone setting and location, browser plug-in types and versions, operating system and platform, type of device, unique device identifier (including the IMEI number, the MAC address of the device’s wireless network interface, or the mobile phone number used by the device), mobile network data, mobile operating system and other technology on the devices you use to access our website or use our software
  • Records of your use of ComplyFirst services and correspondence with us, including information about how you use our website or our software, including the links you’ve clicked on through and from our website or our software (including date and time), services you viewed or searched for, page response times, download errors, length of visits to certain pages, page interaction data (such as scrolling and clicks) and methods used to browse away from the webpage or the software

How does ComplyFirst use your information?

We use your information as follows:

To fulfil a contract with you or take steps at your request before this:

  • When you use our platform to access our services
  • Providing information and technical support if you ask for this
  • Contacting you with information about changes to services
  • Handling card information provided through our websites using PCI-compliant payment services
  • Storing and analysing your information in order to review and progress your job application if you apply to work with us

As required by ComplyFirst to conduct our business and pursue our legitimate interests, in particular:

  • Giving you access to our products or services
  • Providing you with different content within a product or service, depending on how you use that product or service
  • Letting you know about ComplyFirst products and services by post, email, and phone in accordance with your marketing preferences and laws relating to direct marketing
  • Analysing how you use ComplyFirst products and services so we can improve our levels of service and develop future products and services, including through the use of surveys
  • Ensuring the security of ComplyFirst websites and information technology systems and protecting our rights.

Where you give us consent:

  • Where we need your consent to process your sensitive personal information
  • If we need your consent in order to send marketing for ComplyFirst products and services to you

For purposes which are required by law:

  • Sharing your personal information in order to comply with legal obligations to which ComplyFirst is subject.

How will ComplyFirst share your information?

We share your personal details:

  • Within ComplyFirst in order to carry out the processing described above
  • With third-party service providers who process your information on ComplyFirst’s behalf for the purposes above – such as payment processors, or IT service providers

We will also share your personal information:

  • If we think this is necessary in order to protect the rights, property, or safety of ComplyFirst, our employees, our commercial partners, or our customers. This includes sharing information for the purposes of fraud protection and credit risk reduction
  • With government authorities and/or law enforcement officials if required by law.

Managing your consent and updating your personal information

Where your consent is required for us to process your personal information, we will ask for your consent at the point at which you provide your data.  You have the right to withdraw that consent at any time. You can also update your personal information at any time. If you wish to do either, contact us at hello@complyfirst.co

Storing your personal information

Your personal information may be stored and processed outside of the country where it is collected, including outside of the United Kingdom or the European Economic Area. When transferring information to others, within the UK, the EEA or otherwise, we ensure that appropriate and suitable safeguards and technical measures are in place to protect your personal data. To do this, we make use of standard contractual clauses that have been approved by the UK authorities and the European Commission with our suppliers, or we implement other similar measures required by laws around the world.

We will only keep records of your personal information for as long as is reasonably necessary for the purposes for which we have collected it, and to comply with any statutory or regulatory obligations in relation to the retention of records. We respect requests to stop processing your personal data for marketing purposes. This includes keeping a record of your request indefinitely so that we can respect your request in future.

Your rights

You have the right to request access to and rectification or erasure of personal information, the right to restrict processing of your personal information, and the right to object to processing of your personal information. You have the right to object to your personal information being processed on the grounds of ComplyFirst’s legitimate interests. You have the right to object to us sending you direct marketing and profiling you for the purposes of direct marketing. You have the right to lodge a complaint regarding our processing of your personal information with a data protection supervisory authority in a country where you live, work, or where you believe a breach may have occurred.

Contacting us

The data controller for our websites, products and services is FDJ Ecommerce Ltd trading as ComplyFirst, of International House, 36-38 Cornhill, London, EC3V 3NG. We are registered with the Information Commissioners Office (ICO). Our ICO registration number is ZB341032.

You can contact us by email at hello@complyfirst.co in relation to any of the rights described in this privacy policy, or if you have any questions regarding this privacy policy.