This Site

This website (our “Site“) is operated by Archipal Ltd, a company registered in Scotland with company number SC658265 (“we“, “our“, “us“). Our registered office address is 272 Bath Street, Glasgow, Scotland, G2 4JR. Our VAT registration number is 373550296.

This Privacy Policy
- This privacy policy (our “Privacy Policy“) sets out the personal information we collect about you or from you and you give to us (your “personal data“), why we collect it, how we use it and when we may share or disclose it. It also sets out how to contact us and supervisory authorities for further information, and/or in the event you have a complaint that we cannot resolve with you.
- We collect, use and are responsible for certain personal data concerning you. When we do so we are regulated under various laws, including the Data Protection Act 2018. We are responsible as “controller” of that personal data for the purposes of those laws.
Contacting us
- If you have any questions about our Site or this Privacy Policy, including if you don’t understand any part of this Privacy Policy, please contact us:
  - by e-mail at info@archipal.io;

by telephone at +44 7459 702874; or
by post at 2/1, 89 Glencoe Street, Glasgow G13 1YS.

We will endeavor to respond to you promptly. Please note that our email and telephone facilities are monitored only during the hours of 0930 to 1630 UK time(excluding public and bank holidays in Scotland).

Please also note that we may keep a record of correspondence to enable us to properly manage our Site, to deal with your query, and for quality and training purposes.

Our Site
- This Privacy Policy relates to your use of our Site. The Site include the websites linked to the following domain names and all associated webpages, and the following apps available on the following platforms:

www.archipal.io

Please note that this Privacy Policy applies also to our social media accounts at:

[INSERT]

This Party Sites

Throughout our Site we may link to other websites owned and operated by third parties, including payment service providers, and sellers of services through our Site. These third party websites may also gather information about you. For privacy information relating to these other third party websites, and for information as to how they collect and use your personal data, please consult their privacy policies.

How We Collect Personal Data
- We collect personal data about you when you access our Site, register with us, contact us, send us feedback, purchase or sell services via our Site, telephone or write to us, post material to our Site, sign up to receive marketing information from us, compete customer surveys, visit our social media accounts, or participate in promotions via our Site.
- We collect this personal data from you either directly, such as when you register with us, contact us or purchase or sell services via our Site or indirectly, when you are browsing our Site, or via the providers of the facilities to us and to you, for example social media and payment service providers.
- Our collection of your personal data is aided by the use of cookies. For more information upon how we use cookies, please see our cookie policy at [INSERT].
Personal Data Collected
- The personal data we collect depends on the particular activities carried out through our Site or our social media profiles. Personal datamay include:
  - your name, address and contact details;
  - the location and/or device from which you are visiting our Site;
  - your date of birth;
  - your social media profile information;
  - your bank account and payment details;
  - here you are a business, details of your employees responsible for purchasing or selling products via our Site, details of the business you represent, the registrations, insurances or certifications that it holds, and the people that are engaged by it;
  - details of the services purchased and/or sold by you via our Site, and related contracts, agreements, disputes, correspondence and information concerning the services, their performance and completion;
  - details of any feedback you give us by phone, email, post or via social media;
  - your account details, such as username, login details; and/or
  - information concerning the elements of our Site that you visit, read, interact with, and information concerning the manner of that interaction.
- Uses of your Personal Data
  - We may use your personal data to:
    - create and manage your account with us;
    - verify your identity;
    - verify other information relating to you and your use of our Site;
    - verify your ability to buy or sell services lawfully via our Site, including with regulatory authorities;
    - enable you to purchase and sell services via our Site;
    - enable purchasers and sellers of services to fulfil their contracts with each other;
    - customise our Site and its content to your particular preferences;
    - notify you of any changes to our Site or to our services that may affect you;
    - improve our business, for example through product feedback, or via training our staff;
    - to protect the rights, property or safety of others; and
    - to operate our Site and our business.
  - This Site is not intended for use by, and is not available to, persons under eighteen (18) and we do not knowingly collect or use personal data relating to such persons.
- Our legal basis for processing your personal data
  - When we use personal data we are required to have a legal basis for doing so. There are various different legal bases upon which we may rely, depending on what personal data we process and why.
  - The legal bases we may rely on include:
    - consent – where you have given us clear consent for us to process your personal data for a specific purpose;
    - contract – where our use of your personal data is necessary for a contract we have with you, for example to enable you to use the facilities provided by our Site, or because you have asked us to take specific steps before entering into a contract;
    - legal obligation – where our use of your personal data is necessary for us to comply with the law; and
    - legitimate interests – where our use of your personal data is necessary for our legitimate interests, your legitimate interests, or the legitimate interests of a third party, for example to enable the fulfilment of contracts between buyers and sellers of products, or to prevent fraud (unless there is a good reason to protect your personal data which overrides those legitimate interests).
  - Further Information

For further details on when we collect personal data, what we collect as well as how we use it, please read the following sections:

When information is collected	What information we collect	How and why we use your information
When you register to receive information from us on our services and business including our newsletters and email or SMS updates.	Your name, telephone number and email address.	We collect this personal data directly from you. We will use this personal data to provide you with information on our services and business, including information on the availability of new services. We may do this by post, email, telephone, or text message (SMS). Our basis for processing this personal data is consent, which you give to us when you input your details into our Site. We will retain this personal data until you withdraw it. Please note unsubscribe links are included at the bottom of all of our marketing emails, or you can ask us to cease processing your personal data for these purposes by using the contact means set out in this Privacy Policy.
When you purchase or sell services via our Site.	Your name, address, email address, details of the business you represent (if applicable), details of the services, amounts paid and related requirements and obligations (including additional terms). Please note that your payment details are collected by our third party payment services provider [INSERT] whose website (and privacy policy) can be found at [INSERT].	We collect this personal data directly from you. We will use this personal data to enable the fulfillment of contracts for the purchase and sale of services you make with us or third parties via our Site. We may also use this personal data, in conjunction with our third party payment services provider or regulatory authorities, to prevent fraud or the breach of laws or regulations. Our basis for processing this personal data is to perform our contract with you for the provision of the purchase and sale facilities provided by our Site, and the provision of services to you by us. We will also disclose this information to parties with whom you have made a contract for the sale or purchase of services via our Site, to enable the performance of those contracts. This is pursuant to our (and their) legitimate interests. We may also disclose this information to regulatory authorities and our payment services providers, to prevent fraud or the breach of laws or regulations. The is pursuant to our legitimate interests. We will retain this personal data for [INSERT] to allow us to deal with any queries regarding such contracts.
When you visit our social medial profiles.	Our social media providers collect analytical information about the elements of our profiles that you visit and interact with. Also collected are any postings you make upon those profiles, and details of your sharing activities.	Our social media profile providers and us collect this information. The basis for collecting and using this information is consent, which is given to these social media profile providers when using their services. If you do not wish your information to be used in this manner please contact the relevant social media provider, or alter your data sharing settings upon their website or app. We retain only anonymised information. We do not retain any information from which we can identify you. The provider of the social media platform may retain such information, for example posting, sharing and profile information, and make it available to us to view. Please check their privacy policy for more information.

Personal Data Sharing
- If you submit someone else’s personal data you must have consent from them to do this.
- We routinely share personal data as follows:
  - Your name and address details (including where applicable your business name details) with the parties with whom you have agreed contracts for the purchase and sale of services via our Site, to enable performance of those contracts;
  - With our providers, who assist with enabling the operation of our Site, for example hosting providers, email service providers, and also our subcontractors who provide our services to you.
  - We will share personal data with law enforcement or other authorities, and/or our payment services providers, if required by applicable law, to check that you are not breaching applicable law or regulation, or to check that you are able to lawfully use our Site. Where we know you have breached, or where we suspect you may be breaching any obligations owed to us, for example the terms relating to the use of our Site, we may share your personal data with third parties to the enable us to help protect their rights, property or safety. This is includes sharing to prevent the risk of fraud.
- Some of these persons with whom we share personal data may be based outside the European Economic Area, in locations which do not provide the same level of protection as regards personal data under applicable law as that to which you are entitled in the United Kingdom.
- Our providers currently include the following:
Third Party Marketing
- From time to time, we may also like to share your personal data with selected third parties so that they may send you information about their products and/or services. We will only ever do this having obtained your consent first.
- If you have previously agreed to being contacted in this way, you can unsubscribe at any time by contacting us using the means set out in this Privacy Policy, or by clicking upon the unsubscribe links any emails or marketing material you receive.
Cookies and Similar Technologies

A cookie is a small text file which is placed onto your device when you use our Site. We use cookies and other similar technologies. For further information on our use of cookies, please see our cookie policy located at [INSERT].

Your Rights
- Under applicable law you have a number of important rights. In summary, those include rightsto:
  - fair processing of your personal data and transparency over how we use your use personal data;
  - access to your personal data;
  - require us to correct any mistakes in your personal data which we hold;
  - require the erasure of personal data concerning you in certain situations;
  - receive the personal data concerning you which you have provided to us, in a structured, commonly used and machine-readable format and to have us transmit that personal data to a third party in certain situations;
  - object at any time to processing of personal data concerning you for direct marketing;
  - object to decisions being taken by automated means which produce legal effects concerning you or similarly significantly affect you; and
  - object in certain other situations to our continued processing of your personal data.
  - For further information on each of those rights, including the circumstances in which they apply, see the Information Commissioner’s guidance located athttps://ico.org.uk/for-organisations/guide-to-data-protection/guide-to-the-general-data-protection-regulation-gdpr/individual-rights/.
- If you would like to exercise any of those rights, please email, call or write to us using the contact means set out in this Privacy Policy, and remember to let us have enough information to identify you, and the matter to which your correspondence relates. Please note we may require you to provide proof of your identity and address.
Keeping your PersonalData Secure
- We have appropriate security measures in place to prevent personal data from being accidentally lost, or used or accessed in an unauthorised way. We limit access to your personal data to those who have a genuine business need to know it. Those processing your personal data will do so only in an authorised manner and are subject to a duty of confidentiality.
- We also have procedures in place to deal with any suspected data security breach. We will notify you and any applicable regulator of a suspected data security breach where we are legally required to do so.
- We do not have access to your payment information. Our payment services providers are compliant with PCI standards (see http://www.pcisecuritystandards.org).
- If you want detailed information from Get Safe Online on how to protect your information and your computers and devices against fraud, identity theft, viruses and many other online problems, please visit www.getsafeonline.org.
How to Complain

We hope that we can resolve any query or concern you raise about our use of your personal data. Please contact us using the means set out above if you have any query or concern.

Changes to this Policy

Please note that we may update this policy from time to time, so if you revisit our Site at a later date you should check this policy again at that time to make sure you have seen the current version. This policy was last updated on [May 2022].