1. Introduction

This Privacy Policy sets out how we, Gateway Company Holdings Ltd, whose registered office is at 7 Bell Yard, The Strand, London WC2A2JR collect and process your personal data and explains your rights in relation to your personal data. If you have any questions about this Privacy Policy or wish to exercise any of your rights in relation to your personal data, you can contact us at this address or by email to support@gatewaycompanyholdings.com.

Our preferred contact method is email. This Privacy Policy affects your legal rights and obligations so please read it carefully. If you do not agree to be bound by this Privacy Policy, please do not provide your personal data to us or request that your employer does not do so. We may update this Privacy Policy from time to time at our discretion and in particular to reflect any changes in applicable laws. If we do so, and the changes substantially affect your rights or obligations, we shall notify you if we have your email address. Otherwise, you are responsible for regularly reviewing this Privacy Policy so that you are aware of any changes to it.
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We may need to collect your personal data because you provide it to us, or because your employer is our client and wishes to set up an account for you to access our platform. In such circumstances, we are the controller of your data. Or we may receive your personal data within our platform because one of our clients has uploaded payment details to make a payment to you such as salary or invoice payment. In such circumstances, we are the processor of your personal data, and we shall only process your personal data in accordance with the client’s instructions.

2. What personal data do we collect and from whom?

By personal data, we mean identifiable information about you, such as your name, email address, gender, date of birth, phone number and your IP address.

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Your Company

What we collect as a data controller

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Shareholders

• Full Name

• Date of Birth

• Nationality

• Photographic ID

• Proof of Residential Address

• Business Affiliations

• Reputation

• Political Association or Public Functions

• Sanctions checks

Directors

• Full Name

• Date of Birth

• Nationality

• Business Affiliations

• Reputation

• Political Association or Public Functions

• Sanctions checks

Authorised Person

• Full Name

• Date of Birth

• Nationality

• Photographic ID

• Proof of Residential Address

• Email Address

• Business Affiliations

• Phone Number

• Reputation

• Political Association or Public Functions

• Sanctions checks

• Physical and Mental Health data

Gateway Application Users

• IP Address

• Email Address

• Business Affiliations

• Phone Number

• Physical and Mental Health data

Potential Customers/Job Applicants

• Full Name

• Email Address

• Business Affiliations

• Reputation

What we collect as a Data Processor
Payees

• Full Name

• Business Affiliations

• Payslip or Payroll Report

• Invoices

• Bank Account

• Sanctions Checks

• Email Address

 

2.1 Data you provide to us

Most of the personal information we process is provided to us directly by you for one of the following reasons:

• Using our website

• Using our application

• Applying for a job with Gateway

• Providing services to us

• Subscribing to receive newsletter, marketing or product update emails from us

• Contacting us with queries, comments or complaints

 

2.2 Data we automatically collect about you

When you use our website or application, we automatically collect and store information about your device and your activities. This information could include:

• Technical information about your device such as type of device, web browser or operating system

• Your preferences and settings such as time zone and language

• How long you used the website / app and which services and features you used

Some of this information is collected using cookies and similar tracking technologies. If you want to find out more about the types of cookies we use, why, and how you can control them, please see our Cookies Policy.

 

2.3 Data we receive from others

As set out above, your employer or business partner may provide personal data that relates to you, so you can create an account on our platform, or receive payments via our platform.

We may also receive personal data about you from our payment providers and our website security service partners, particularly if there is any misuse of the platform including the introduction of viruses or other malicious software.

If you apply for a job with us, we may receive personal data about you from your previous employer or other references.

We also receive personal information indirectly, from the following sources in the following scenarios:

• Media Articles mentioning your name

• Political Associations lists

• Sanctions lists

We use the information to comply with Anti-Money Laundering Regulations and Sanctions Regulations. 

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3. Lawful use of your personal data

Under the UK General Data Protection Regulation (UK GDPR), the lawful bases we rely on for processing this information are:

• Your consent. We rely on your consent when you sign up. You can remove your consent at any time. You can do this by contacting support@gatewaycompanyholdings.com

• We have a contractual obligation to provide you services

• We have a legal obligation to comply with Anti-Money Laundering Regulations

• We have legitimate interests such as fraud prevention, information security, identifying possible criminal acts

 

3.1 Data Provided by your Employer who uses Telleroo

We may receive your personal data because you are employed at a company that uses Gateway as its payment platform. We will process your personal data to perform any contract we have entered with your employer or in relation to any steps we take at the request of your employer prior to entering a contract. Typically, this includes creating a recipient profile for your payment details so we can send payments to you when requested by your employer.

 

3.2 Using data, you uploaded or entered into the Gateway application.

If we have received your personal data because of your Employer/You uploaded it to our platform, we shall process that personal data for our legitimate interests and on the instructions of our client.

 

3.3 Using data for our legitimate interests

We may also use your personal data for our legitimate interests, including dealing with any customer services you require, for regulatory and legal purposes (for example anti-money laundering and fraud prevention purposes), for audit purposes and to contact you about changes to this Privacy Policy.

 

3.4 Using data to provide Product Update Emails

You may consent to receive product update email messages from us. You can choose to no longer receive marketing emails from us by contacting us or clicking unsubscribe in the email. Please note that it may take us a few days to update our records to reflect your request.

If you ask us to remove you from our product update mailing list, we shall keep a record of your name and email address to ensure that we do not send you any more product update information. We shall also continue to send you information relating to your use of our services if your employer has an account with us and has added you as a platform user.

 

3.5 Using data to improve our service

We also analyse data usage of our platform and use that information to improve our services and platform for our legitimate interests. Please see our Cookies Policy for detailed information.

 

3.6 Using data to process Job Applications

If you apply for a job with us, we shall use the personal data you provide to process your application and respond to you accordingly.

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4. Who do we share your data with?

To comply with our legal obligations, under certain circumstances, we may have to disclose your personal data under applicable laws and/or regulations, for example, as part of anti-money laundering regulations, fraud prevention or to protect a third party's rights, property, or safety.

We may share your information with our discretion as to where your funds are safeguarded. We may also share your personal data in connection with, or during negotiations of, any merger, sale of assets, consolidation or restructuring, financing, or acquisition of all or a portion of our business by or into another company, in which case we will send a notice to our users.

We may share your personal data with any service providers, sub-contractors and agents that we may appoint to perform functions on our behalf and in accordance with our instructions, including payment providers, IT service providers, accountants, auditors, lawyers and Know Your Customer and Transaction Monitoring service providers. We shall provide our service providers, sub-contractors and agents only with such of your personal data as they need to provide the service for us and if we stop using their services, we shall request that they delete your personal data or make it anonymous within their systems.

All personal data that you provide to us must be true, complete and accurate. At our request, you shall promptly provide evidence of your identity. If you provide us with inaccurate or false data, and we suspect or identify fraud, we will record this, and we may also report this to the Legal Enforcement Agencies. When you contact us by email or post, we may keep a record of the correspondence and we may also record any telephone call we have with you.

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5. Your Data Protection Rights‍

Under data protection law, you have rights including:

Your right of access - You have the right to ask us for copies of your personal information.

Your right to rectification - You have the right to ask us to rectify personal information you think is inaccurate. You also have the right to ask us to complete information you think is incomplete.

Your right to erasure - You have the right to ask us to erase your personal information in certain circumstances.

Your right to restriction of processing - You have the right to ask us to restrict the processing of your personal information in certain circumstances.

Your right to object to processing - You have the right to object to the processing of your personal information in certain circumstances.

Your right to data portability - You have the right to ask that we transfer the personal information you gave us to another organisation, or to you, in certain circumstances.

You are not required to pay any charge for exercising your rights. If you make a request, we have one month to respond to you.

Please contact us at support@gatewaycompanyholdings.com if you wish to make a request.

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6. Where we hold and process your personal data‍

Your information is securely stored. The Retention Period is based on the data category, legal and regulatory requirements, business needs, and Telleroo risk assessments.

In most cases, your personal data is kept for 5 years plus 1 year for operational reasons. We will then dispose of your information by deleting your data. For specific data retention cycles, please email support@gatewaycompanyholdings.com.

Some or all of your personal data may be stored, transited or transferred outside of the UK or European Economic Area (the EEA ), for example, if a data server is located in a country outside the EEA or if any of our service providers are based outside of the EEA.

Where your personal data is transferred outside the UK or EEA, we will ensure the appropriate safeguards are provided in relation to the transfer, such as the International Data Transfer Agreement (IDTA).

Should you require further information on the specific mechanism, please contact us on Please contact us at support@gatewaycompanyholdings.com.

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7. Analytics

Advertising

Facebook Audience Network, Reddit Ads, LinkedIn Ads, Google Ads and Microsoft Ads

‍Personal Data: Cookies; unique device identifiers for advertising (Google Advertiser ID or IDFA, for example); Usage Data

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Analytics

‍Google Analytics, Mixpanel, Hotjar Form Analysis & Conversion Funnels, Google Ads conversion tracking, FullStory and Facebook Ads conversion tracking (Facebook pixel)
Personal Data: Cookies; Usage Data

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Contacting the User

‍Contact form
‍Personal Data: Company name; Accountancy name; Email address; First name; Last name; Phone Number

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Remarketing and behavioural targeting

‍Facebook Remarketing and LinkedIn Retargeting
Personal Data: Cookies; Usage Data‍
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Facebook Custom Audience and LinkedIn Matched Audiences
Personal Data: Cookies; email address

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Displaying content from external platforms

‍Wistia widget and YouTube video widget
Personal Data: Cookies; Usage Data

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Registration and authentication‍

Direct registration
Personal Data: company name; company directors, company shareholders, director identification, email address; first name; last name; phone number; User ID; website

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8. How to complain

If you have any concerns about our use of your personal information, you can make a complaint to us at complaints@gatewaycompanyholdings.com

ICO website: https://www.ico.org.uk