Privacy Policy

CTM Privacy Policy

The website www.ctmfile.com(oursite) is operated by J&W Associates, trading as Cash & Treasury Management File or CTMfile.

In this Privacy Policy we refer to J&W Associates as “we”, “us” and “our”.

The purpose of our site is to provide information to corporate treasury departments, including know-how, updates on the latest developments and details of new products and services, and to generate engagement with the CTMfile associate members and directory subscribers through our content.

We are committed to protecting and respecting your personal information. This Privacy Policy is designed to give you information about how we obtain and process your personal data in connection with your use of our site.

We may collect, use, store and transfer different kinds of personal data about you when you use our site. Examples of when we collect your personal data include if you subscribe to our newsletter or fill in an enquiry form on our site. We will also collect personal data about you if you are an associate member (or a representative of an associate member), a directory subscriber, or if you use our site to upload information, such as business directory information and/or demonstration videos.

Please read this Privacy Policy carefully (together with our Cookies Policy [https://ctmfile.com/pages/cookies-policy] and Website Terms & Conditions [https://ctmfile.com/pages/terms]). From time to time we may also issue other privacy or fair processing notices to you relating to the way in which we collect personal data about you which we will make available on our site.

1. How to contact us

Our site is operated by J&W Associates, trading as CTMfile. J&W Associates is a partnership and has its office address at 67 Marlborough Avenue, Cheadle Hulme, Cheadle, SK8 7AR.

If you have any questions or concerns about any information contained within our Privacy Policy, please email us at support@ctmfile.com

2. Your personal information
Personal data, or personal information, means any information relating to an identifiable individual. It does not include any data or information which relates to a person that cannot be identified or where the person’s identity has been removed (i.e. anonymous data). It also does not include information relating to a company, rather than an individual.

As a visitor to our site, we may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:

Identity data– data which identifies you, including your name, username (for accessing your account if you are a directory subscriber or associate member (or a representative of an associate member);
Contact data– your contact details, such as your email address and your employer;
Financial data– if you are an associate member or a representative of an associate member, we capture your name and email in connection with any payments; any payment details, such as bank account and payment card details are held securely by our third party payment provider (currently Stripe) and we do not have access to these;
Transaction data – details about any purchases you have made from us;
Profile Data– information relating to your account or subscription with us, including your username and password, membership history, transaction data, content uploaded/downloaded, newsletter preferences
Marketing data– data which we capture when you sign up to receive newsletters and emails from us, including your preferences regarding receiving these types of communications from us and third parties
Social media data– data we have access to through social media platforms when you connect with us or like or follow our social media accounts, including your social media handle, photograph, date of birth, location, occupation, interests and other information and content you make available via your social media accounts
Technical data– electronic information which is automatically logged/stored by processing equipment, including details of the device(s) you use to access our services, internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access our site;
Usage data– information about how you use our site, including how you navigate our site and if you encounter any problems

We also collect, use and share aggregated datasuch as statistical or demographic data for any purpose. Aggregated data may be derived from your personal data but is not considered personal data in law as this data does not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific feature of our site. However, if we combine or connect aggregated data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this Privacy Policy.

We do not collect any special categoriesof personal data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data). Nor do we collect any information about criminal convictions and offences.

2. How we collect information

Direct interactions:The majority of the personal data we hold about you is collected when you interact with us or correspond with us directly (via our site, by post, email, telephone or otherwise). This includes personal data you provide when you:

fill out an enquiry form on our site;
subscribe to receive our newsletters or other marketing communications;
purchase a subscription for our services as an associate member (or representative of an associate member);
register an account on our site;
provide feedback to us or otherwise correspond with us;
connect with us, follow us or “like” us on social media.

Automated technologies or interactions: When you interact with our site, our systems will automatically collect Technical data and Usage data (described above) about your equipment, browsing actions and patterns. We collect this personal data (namely technical and usage data) by using cookies server logs and other similar technologies. The personal data we collect via automated technologies or interactions will be very limited. Please see our Cookies Policy [https://ctmfile.com/pages/cookies-policy] and the section headed "Cookies" below for more information.

Other third parties:We may also receive personal data about you from various third parties as set out below, however the personal data we receive from third parties will be very limited:

Identity and Contact data from payment providers, such as Stripe;
Social media data from the operators of social media platforms, including Facebook, Twitter and LinkedIn who are based inside and outside of the EU;
Analytics providers, such as Google Analytics, Campaign Monitor, Expression Engine and Sumo.

3. How and why we use your personal information

We will only collect and process your personal data where we have a legal basis to do so. This legal basis will vary depending on the manner and purpose for which we are collecting your personal information. We will use your personal information as follows:

Where it is necessary for the performance of a contractto which you are a party or to take steps at your request before entering into such a contract;
Where it is necessary to comply with a legal or regulatory obligationthat we are subject to;
Where it is necessary for our legitimate interests(or those of a third party) and your interests and fundamental rights do not override those interests (see below); and
Where we have your consentto do so, subject to your right to withdraw consent (further details provided in the section headed “Your rights” below).

Our legitimate interests in processing your personal data for our own business purposes include (without limitation):

To deliver relevant website content;
To provide and improve our products and services and to operate our site;
To set up, manage access to, and maintain security of, your online account for our site;
To deliver our newsletters and other email content to directory subscribers;
To process orders for subscriptions for associate members, including managing payments and collecting and recovering money owed to us;
To respond to enquiries submitted to us via our site or social media accounts or by post, email or telephone;
To administer and protect our business and our site (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data);
To use data analytics to improve our site, services, marketing, customer relationships and experiences;
To manage our relationship with you and notify you of changes to our terms and conditions or privacy policy;
To promote our services, including sending marketing emails and offering promotions (as explained in the section headed “Marketing” below);
To monitor and improve the effectiveness of our marketing communications, which may include monitoring or tracking responses and engagement;
To fulfil our legal, regulatory and risk management obligations, including for the purpose of establishing, exercising or defending legal claims;
To ensure our site is being used in compliance with relevant terms and conditions;
For fraud prevention, anti-money laundering, and for the prevention or detection of crime.

Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you require further detail about the specific legal ground we are relying on to process your personal data.

4. Marketing

We may from time to time send you marketing communications by email if you have consented to receive marketing communications from us.

We will only share your personal data with another company for marketing purposes if you have expressly consented to us doing so.

You can ask us and/or third parties to stop sending you marketing communications at any time, by:

clicking on the unsubscribe link in the footer of any marketing email from us;
contacting us at support@ctmfile.com.

5. Change of purpose

We will only use your personal data for the purposes for which 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 wish to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.

We may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

6. If you fail to provide personal data

Where we need to collect personal data from you in order to provide you with services and you fail to provide that data when requested, we will not be able to deliver those services to you.

7. Cookies

A cookie is a small text file which is stored on your browser or the hard drive of your computer (or other electronic device) when you access our site, and which contains certain basic information on its users.We use cookies to distinguish you from other users of our site and to provide a browsing experience that is unique to you. Overall, cookies help us to provide you with a better website, by enabling us to monitor which pages you find useful and which you do not. You can find out more about the way cookies work at www.cookiecentral.com

For more information about the cookies we use and the reasons why we use them, please see our Cookies Policy [https://ctmfile.com/pages/cookies-policy].

You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies (and the above website tells you how to do this). If you disable or refuse cookies, please note that some parts of our site may become inaccessible or not function properly.

8. Sharing your personal information with third parties
We require third parties to respect the security of your data, keep it confidential, and to treat it in accordance with the law.

We may share your personal data with third parties, including third party service providers who provide the following services to us. The personal data we hold and share will typically be very limited:

Third party IT and software providers (including third party hosting providers and providers of IT support);
Payment services (such as Stripe);
Analytics services, including email analytics and reporting services (such as Google Analytics, Campaign Monitor, Expression Engine and Sumo).

We may also disclose personal data:

To other individuals involved in the management, operation and/or administration of our partnership, J&W Associates;
To our associate members to update them on subscriber engagement with their content and to help inform future articles;
If we are under a duty to disclose or share your personal data in order to comply with any legal obligation, or in order to enforce any agreements, or to protect the rights, property or safety of our business, our customers or others. This includes exchanging information with other companies and organisations for the purposes of fraud protection and credit risk reduction, with HM Revenue & Customs, the police, regulators and other authorities and public bodies where we are required to do so by law;
To third parties to whom we may choose to sell, transfer or merge parts of our business or assets. Alternatively, we may seek to acquire other businesses or merge with them;
To our professional advisers, including lawyers, bankers, auditors and insurers who provide consultancy, banking, legal, insurance and accountancy services.

9. Links to third party websites

From time to time we may direct you to third party websites through our site. We do not control the content of these third party websites. We encourage you to read the privacy policies for these third party websites before submitting personal information to them. If the third party has not been authorised to collect information on our behalf, your personal data will be controlled by that third party subject to their privacy policy.

10. Security
We only use trusted international corporations to help us to provide our services. The personal data we process will be stored on the servers of these third parties. We are confident that these third parties are complying with data protection legislation and have put in place appropriate security measures to protect your personal information from misuse, loss or unauthorised access, alteration and disclosure.

As the transmission of information via the Internet is not completely secure, we cannot guarantee the security of your data transmitted to our site, and any transmission is at your own risk.

Any personal data we process which is not publicly available, such as payment information, will be processed more securely than other personal data, which is why we use a third party to take payments on our behalf.

11. Data retention

We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for.

To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements. Our retention periods take into account legal and regulatory requirements and are subject to change. If you have any questions in this regard, please contact us using the contact details set out in this Privacy Policy.

In some circumstances we may anonymise your personal data and process it for research or statistical purposes, in which case we may use this information indefinitely without further notice to you.

We shall not have any liability whatsoever to you for the deletion of personal data in accordance with our data retention policy.

12. International transfers

The personal data that we collect from you may be transferred to, and stored at, a destination outside the European Economic Area (“EEA”).

We only use trusted companies to help us to provide our services. We are confident that these third parties are complying with data protection legislation and will ensure that your personal data is afforded the same level of protection whenever they transfer your personal data out of the EEA. For example, our third party service providers based in the US may be part of the Privacy Shield, and other third party service providers may transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data by the European Commission.

Please use the following links to the privacy policies of our third party service providers for more information.

13. Your rights

You have the following rights in respect of the personal data that we process about you (where we determine the purpose and means for which that personal data shall be processed):

the right to request accessto your personal data that we hold and to receive certain information relating to that data;
the right to ask us to rectifyinaccurate data or to complete incomplete data;
a right to receive or ask for your personal data to betransferred to a third party (note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you);
the right to request the erasureof personal data where there is no good reason for us continuing to process it (note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request);
the right to objectto how we process your personal data where we believe we have a legitimate interest in processing it (as explained above) (note that in some cases we may demonstrate that we have compelling legitimate grounds to process your data which override your rights and freedoms);
the right torestrict processing of your personal data in certain scenarios, for example if you want us to establish the accuracy of the data or you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it (note that when processing is restricted, we are allowed to retain sufficient information about you to ensure that the restriction is respected in future); and
where you 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 consentfor that specific processing at any time. Once we have received notification that you have withdrawn your consent, we will no longer process your information for the purpose or purposes you originally agreed to, unless we have another legitimate basis for doing so in law. If you withdraw your consent, we may not be able to provide certain services to you.

If you wish to exercise any of the rights set out above in respect of your personal data, please contact us by email at support@ctmfile.com or write to us at 67 Marlborough Avenue, Cheadle SK8 7AR United Kingdom.

We may ask you to verify your identity if you make a request to us to exercise any of the rights set out above.We may also contact you to ask you for further information in relation to your request to speed up our response.

You have the right to make a complaint at any time to the Information Commissioner's Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO, so please do contact us in the first instance and we shall endeavour to resolve your complaint.

14. Your duty to inform us of changes

It is important that the personal data we hold about you is accurate and current. Please let us know if you change your contact details. You have the right to question any information we hold about you that you think is wrong or incomplete. Please contact us if you want to do this.

This Privacy Policy was last updated in July 2018.

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