Privacy Notice

PayPulse Limited referred to as PayPulse, 'we' or 'our' is committed to protecting the privacy and security of your personal information.

This Privacy Notice describes how we collect and use personal information about you during and after your relationship with us pursuant to the Data Protection (Jersey) Law 2018 ("DPJL").

PayPulse is a "Data Controller", which means we are responsible for deciding how we hold and use personal information. We are also registered with the Jersey Office of the Information Commissioner ("JOIC"): Registration No. 102459.

Data Protection Principles

We will comply with data protection law, the principles of which says that the personal information we hold about you must be:

• Used lawfully, fairly and in a transparent way.
• Collected only for valid purposes that we have clearly explained to you and not used in any way incompatible with those purposes.
• Relevant to the purposes we have told you about and limited only to those purposes.
• Accurate and kept up to date.
• Keep your data only as long as necessary for the purposes we collected it.
• Kept securely.

PayPulse is accountable to you and the Authorities to show compliance with ("DPJL") and demonstrate how we are compliant.

The Data Protection Manager ("DPM")

We have appointed a DPM to oversee compliance with this Privacy Notice.

If you have any questions about this Privacy Notice or how we handle your personal information, contact the DPM at dataprotection@paypulsehr.com.

You have the right to make a complaint to the JOIC at any time.

The Kind of Information We Hold About You

Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).

How Is Your Personal Information Collected?

We collect personal information about you when you contact us, engage us to provide a service or provide us with your data for another specific purpose.

What information do we collect about you when you open an account?

• Name
• Title
• Address
• Identification documents
• Telephone number
• Email address
• Signature
• Bank details

What information do we collect regarding your teams?

• ID
• Gender Identity
• Base Salary
• Weekly Hours
• Benefits
• Job Level
• Job Family
• Jurisdiction
• Employment Status
• Birth Year
• Industry

We would assign a suggested employment level for each team member based on the information you provide, compared to the salary average for the employment role.

What Special Category Data do we collect about you?

PayPulse does not collect Special Category data from clients.

How We Will Use Information About You?

We will only use your personal information when the law allows us to.

Most commonly, we will use your personal information in the following circumstances:

• You have entered a Contract with us to provide you with a service; an example of this would be when you open a subscription account with PayPulse.
• Where it is necessary for our Legitimate Interests (or those of a third party), your interests and fundamental rights do not override those interests. An example of this is when we make contact with local residents to inform them of ongoing work in the area.

We may also use your personal information in the following situations, which are likely to be rare:

• Where you have given, your Consent to contact you for a specific purpose, such as to receive marketing material about PayPulse services.

Change of purpose

We will only use your personal information for the purposes we collected it unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose.

If we need to use your personal information for an unrelated purpose, we will notify you and explain the legal basis that allows us to do so.

Data Sharing

We do not pass on information gained from your engagement with us without a clear legal basis for doing so. However, we may disclose your Personal Information to meet legal obligations, regulations, or valid governmental requests.

We use certain third parties also known as Processors to provide or support our services. We have appropriate agreements in place with those processors to ensure the safety of your information. We do not share your information with any processors for the purposes of direct marketing.

Current data processors used by PayPulse:

We use Office 365, OneDrive and SharePoint on an Azure deck to process and store our data. We have selected EEA storage locations for our data, so Dublin, Ireland and London, UK as our preferred data storage locations.

Data Security

We have put in place appropriate security measures to prevent your personal information from being accidentally lost, altered or disclosed, or accessed in an unauthorised way. In addition, we limit access to your personal information to those Staff, Agents, Contractors and other third parties on a need-to-know basis.

They will only process your personal information on our strict instructions, and they are subject to a duty of confidentiality.

We have put in place procedures to deal with any suspected data security breach and notify you and any applicable regulator of a suspected breach where we are legally required to do so.

Data Retention

We will only retain your personal information for as long as necessary to fulfil the purposes we collected it for, including to satisfy any legal, accounting, or reporting requirements.

To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, and the potential risk of harm from unauthorised use or disclosure of your data. The purposes for which we process your data and whether we can achieve those purposes through other means and the applicable legal requirements.

Rights of Access, Correction, Erasure, and Restriction

The personal information we hold about you must be accurate and current.

Please keep us informed if your information changes during your relationship with us.

Under certain circumstances, by law, you have the right to:

• Request access to your personal information (commonly known as a "data subject access request").
• Request correction of the personal information that we hold about you.
• Request the erasure of your personal information.
• Object to processing your personal information where we rely on a legitimate interest.
• Request the restriction of processing of your personal information.
• Request the transfer of your personal information to another party.

If you want to review, verify, correct or request the erasure of your personal information, object to the processing or request that we transfer a copy of your personal information to another party, contact our DPM at dataprotection@paypulsehr.com.

Right to Withdraw Consent

In the limited circumstances where you may have provided your consent to the collection, processing and transfer of your personal information for a specific purpose, you have the right to withdraw your consent for that specific processing at any time.

To withdraw your consent, contact our DPM at dataprotection@paypulsehr.com.

Changes to this Privacy Notice

We reserve the right to update this privacy notice at any time, and we will provide you with a new privacy notice when we make any substantial updates.

Complaints

We want the chance to resolve any complaints you have about how we process your information. You have the right to complain to the JOIC about how we have used your data.