This Privacy Policy explains how your personal data is collected, used and shared when you browse our Website, contact us, or otherwise provide your personal data through the Website. It also contains important information about your privacy rights. Please read it carefully.
If you provide personal data to us on behalf of another person, you should ensure that they are informed about the processing of their personal data and are provided with access to this Privacy Policy.
Who we are
STERLIQPAY LTD is a technology company registered in England and Wales. We provide technology services including API development and integration, system integrations, business process automation and technical infrastructure solutions.
For the purposes of the UK General Data Protection Regulation (“UK GDPR”), the Data Protection Act 2018 and other applicable UK data protection laws, SterliqPay Ltd is the controller of personal data collected through the Website and through direct business communications with us.
Company number: 16286931
Website: www.sterliqpay.co.uk
Address: Northway House, 257-258 Upper Street, Highbury & Islington, London, United Kingdom, N1 1RU
Email: general@sterliqpay.co.uk
1. Information we collect and how we use it
1.1. Information you provide to us
We may collect personal data that you voluntarily provide when you:
- submit an enquiry through the Website;
- contact us by email;
- communicate with us regarding our services or a potential project; or
- otherwise provide personal data to us in connection with our business activities.
Such personal data may include:
- your name;
- your email address;
- your company name;
- your job title or business role, where provided;
- information about your business, existing systems, technical requirements or project objectives;
- information contained in your enquiry; and
- correspondence and other communications between you and SterliqPay.
We may use this information to respond to your enquiry, understand your requirements, discuss potential projects, provide information about our services and manage our business relationship with you.
1.2. Technical and usage data
When you access or use the Website, we may automatically collect certain technical and usage information.
This may include:
- Internet Protocol (IP) address;
- browser type and version;
- device type;
- operating system;
- pages visited;
- date and time of access;
- time spent on the Website;
- referral source; and
- other technical or diagnostic information relating to the use of the Website.
We may use this information to operate and maintain the Website, monitor its performance, understand how visitors interact with it, improve its functionality and protect the Website and our systems against security threats, misuse and unauthorised access.
1.3. Cookies and similar technologies
A cookie is a small data file that is placed on your device when you visit or use the Website. Cookies help ensure the proper functioning and security of the Website, remember your preferences, and, where applicable, help us understand how the Website is used.
We use cookies for the following purposes:
- to ensure the proper operation and security of the Website;
- to remember your cookie consent choices and preferences;
- to analyse how visitors interact with the Website and improve its performance;
- where applicable, to support certain functionality or relevant content.
We use the following categories of cookies:
| Cookie type | Description |
|---|---|
| Strictly Necessary | Essential for the core operation of the Website, including page navigation, security, and remembering your cookie consent preferences. These cookies cannot be disabled where they are essential for the Website to function. |
| Preferences | Allow the Website to remember certain choices or settings to enhance your experience. |
| Statistics (Analytical) | Help us understand how visitors interact with the Website by collecting anonymised or pseudonymised usage data, to improve performance and usability. Used only with your consent, where required by applicable law. |
| Marketing | Where applicable, used to measure marketing activities or deliver relevant content. Used only with your consent. |
Some cookies may be placed by third-party service providers, such as analytics or hosting providers. Where third parties place cookies, they may process the related data in accordance with their own privacy policies.
Except for cookies that are strictly necessary for the operation of the Website, cookies requiring consent will not be placed before you have provided the required consent through the cookie banner available on the Website.
Managing Your Cookie Preferences. You can manage your cookie preferences at any time through the “Manage Preferences” option in the cookie banner on the Website, where you may accept, deny, or customise cookies by category. You can also control cookies through your browser settings, though blocking or deleting cookies may affect the functionality of the Website. Withdrawal of consent will not affect the lawfulness of processing carried out before withdrawal.
Consent management. We use CookieConsent, an open-source consent tool that runs on the Website itself, to display the cookie banner, record your cookie choices and prevent non-essential cookies from being placed before you have given consent. No third party is involved in managing your consent and your choices are not sent to anyone.
When you make a choice, your consent state is stored on your device in a strictly necessary first-party cookie named “cc_cookie” for up to six months, so that your choice is respected on later visits. The cookie holds the categories you allowed, the date of your choice and a random identifier generated in your browser; it is readable only by this Website and is not transmitted to any third party.
The list below shows the cookies currently used on the Website, including their provider, purpose and duration.
| Cookie | Provider | Purpose | Duration |
|---|---|---|---|
| cc_cookie | sterliqpay.co.uk | Stores your cookie choices so they are applied on later visits and the banner does not ask again. | 182 days |
1.4. Purposes for which we use your personal data
We may process personal data for the following purposes:
- responding to enquiries and communicating with you;
- understanding your business and technical requirements;
- assessing and discussing potential projects;
- preparing for and providing our services;
- managing relationships with existing and prospective clients;
- providing technical and project support;
- operating, maintaining and securing the Website and our systems;
- monitoring and improving the functionality and performance of the Website;
- preventing and detecting misuse, security incidents or unauthorised access;
- establishing, exercising or defending legal claims; and
- complying with applicable legal, regulatory, accounting and other obligations.
1.5. Change of purpose
We will generally process your personal data only for the purposes for which it was collected.
Where we intend to process personal data for another purpose, we will consider whether the new purpose is compatible with the purpose for which the personal data was originally collected and whether an appropriate lawful basis applies.
Where required by applicable data protection law, we will provide you with information about the new purpose and the relevant lawful basis before carrying out such further processing.
We may process personal data without your consent where this is required or permitted by applicable law.
2. Lawful basis for processing
We will only process personal data where we have a lawful basis to do so under Article 6 of the UK GDPR.
Depending on the purpose and circumstances of the processing, we may rely on the following lawful bases:
2.1. Contract — Article 6(1)(b) UK GDPR
We may process your personal data where processing is necessary:
- to take steps at your request before entering into a contract; or
- for the performance of a contract to which you are a party.
This may apply where you contact us regarding a potential project, request services, discuss specific project requirements or where we provide services under an existing contractual relationship.
2.2. Legitimate interests — Article 6(1)(f) UK GDPR
We may process personal data where processing is necessary for the purposes of our legitimate interests or those of a third party, except where those interests are overridden by your interests, rights or freedoms.
Our legitimate interests may include:
- responding to and managing business enquiries;
- developing and maintaining relationships with prospective and existing clients;
- operating and developing our business and services;
- maintaining and improving the Website;
- protecting the security and integrity of our Website, systems and infrastructure;
- preventing and detecting misuse, security incidents and unauthorised access;
- understanding the use and performance of the Website; and
- establishing, exercising or defending legal claims.
Where we rely on legitimate interests, we consider whether the processing is necessary for the identified purpose and balance our interests against the potential impact on your rights and freedoms.
2.3. Legal obligation — Article 6(1)(c) UK GDPR
We may process personal data where processing is necessary for compliance with a legal obligation to which SterliqPay is subject.
This may include applicable legal, regulatory, accounting, tax or other statutory requirements.
2.4. Consent — Article 6(1)(a) UK GDPR
Where required, we may process personal data on the basis of your consent.
This may include the use of certain non-essential cookies or similar technologies.
Where processing is based on consent, you may withdraw your consent at any time. Withdrawal will not affect the lawfulness of processing carried out before consent was withdrawn.
3. Who we share your personal data with
We may disclose or share your personal data with third parties where this is necessary for the purposes described in this Privacy Policy, for the provision and operation of our services, or where required or permitted by applicable law.
3.1. Service providers
We may share personal data with trusted third-party service providers that provide services to us or process personal data on our behalf.
These may include providers of:
- website hosting and infrastructure;
- IT and technical support;
- email and communication services;
- website security;
- analytics, where applicable;
- data storage and cloud services;
- accounting and professional services; and
- legal or compliance services.
Where a service provider acts as our processor, we require it to process personal data only in accordance with our instructions and applicable data protection requirements.
3.2. Professional advisers
We may disclose personal data to our lawyers, accountants, auditors, consultants and other professional advisers where reasonably necessary for professional advice, business administration, compliance or the establishment, exercise or defence of legal claims.
3.3. Legal and regulatory disclosures
We may disclose personal data where we reasonably believe that disclosure is necessary:
- to comply with applicable law or a legal obligation;
- to comply with a court order or lawful request from a competent authority;
- to establish, exercise or defend legal claims;
- to investigate suspected unlawful activity; or
- to protect the rights, property, systems or security of SterliqPay, our clients or other persons.
3.4. Corporate transactions
If SterliqPay is involved in a merger, acquisition, restructuring, financing, sale of assets or other corporate transaction, personal data may be disclosed to relevant parties, advisers and prospective counterparties where reasonably necessary for that transaction and subject to appropriate safeguards.
4. International transfers
Some of our service providers may process personal data outside the United Kingdom.
Where personal data is transferred outside the United Kingdom, we will ensure that the transfer is made in accordance with applicable UK data protection law.
Where required, we will rely on an applicable UK adequacy regulation or implement appropriate safeguards for the transfer, including appropriate contractual safeguards recognised under UK data protection law.
Where applicable, you may contact us for further information about the safeguards used in connection with international transfers of your personal data.
5. Data retention
We retain personal data only for as long as reasonably necessary for the purposes for which it was collected, including responding to enquiries, managing business relationships, providing services, and satisfying applicable legal, accounting or reporting requirements.
Retention periods vary depending on the type of data and the purpose of processing:
Enquiry and Communication Data. (e.g. data submitted via the Contact Us form, email correspondence): retained for the duration of our business discussions or relationship, and for up to 2 years after the last contact, unless a longer period is required for legal, accounting or compliance purposes.
Client and Project Data. (where a contractual relationship is established): retained for the duration of the relevant agreement and for up to 6 years thereafter, in accordance with applicable UK legal and accounting requirements.
Website Analytics Data.: retained for up to 14 months, or as configured within the relevant analytics tool.
Cookie Consent Records.: your cookie choices are stored in the “cc_cookie” cookie on your device for up to six months, after which you will be asked to make your choice again.
Where personal data is no longer required for these purposes, we will delete or anonymise it, unless continued retention is required or permitted by applicable law.
6. Data security
We take appropriate technical and organisational measures designed to protect personal data against unauthorised or unlawful processing and against accidental loss, destruction, damage, alteration or disclosure.
Access to personal data is limited to persons who require access for legitimate business purposes and, where applicable, service providers that process personal data on our behalf subject to appropriate contractual and security requirements.
However, no method of transmission over the Internet or electronic storage system can be guaranteed to be completely secure.
7. Your data protection rights
Under the UK GDPR and the Data Protection Act 2018, you may have the following rights in relation to your personal data, depending on the circumstances.
7.1. Right of access — Article 15 UK GDPR
You have the right to request confirmation as to whether we process your personal data and, where applicable, to request access to your personal data and certain information about how it is processed.
7.2. Right to rectification — Article 16 UK GDPR
You have the right to request correction of inaccurate personal data and completion of incomplete personal data.
7.3. Right to erasure — Article 17 UK GDPR
In certain circumstances, you may request that we delete your personal data.
This right is not absolute and we may retain personal data where there is a lawful reason for doing so.
7.4. Right to restriction of processing — Article 18 UK GDPR
In certain circumstances, you may request that we restrict the processing of your personal data.
7.5. Right to data portability — Article 20 UK GDPR
Where the applicable legal requirements are satisfied, you may have the right to receive personal data that you have provided to us in a structured, commonly used and machine-readable format and to transmit that data to another controller.
7.6. Right to object — Article 21 UK GDPR
You may have the right to object to the processing of your personal data where the processing is based on legitimate interests.
7.7. Right to withdraw consent
Where we rely on your consent as the lawful basis for processing, you may withdraw your consent at any time.
Withdrawal of consent does not affect the lawfulness of processing carried out before your consent was withdrawn.
7.8. Right to complain
If you have any concerns about how we process your personal data, you may contact us at general@sterliqpay.co.uk.
You also have the right to lodge a complaint with the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection matters.
7.9. Automated decision-making — Article 22 UK GDPR
SterliqPay does not currently use solely automated decision-making through the Website that produces legal effects concerning you or similarly significantly affects you.
8. How to exercise your rights
If you wish to exercise any of your data protection rights, please contact us at:
general@sterliqpay.co.uk
We may request additional information where reasonably necessary to verify your identity or clarify your request.
We will respond to requests in accordance with the time limits and requirements prescribed by applicable data protection law.
9. Third-party links
The Website may contain links to websites or services operated by third parties.
SterliqPay is not responsible for the privacy practices of third-party websites or services. We encourage you to review the applicable privacy notices before providing personal data to third parties.
10. Children’s privacy
The Website is intended for business use and is not directed at individuals under the age of 18. We do not knowingly collect personal data from individuals under the age of 18.
If you believe that a child under 18 has provided personal data to us, please contact us at general@sterliqpay.co.uk so that we can take appropriate steps, including deletion of that data where required.
11. Changes to this Privacy Policy
We may update this Privacy Policy from time to time to reflect changes to our processing activities, Website, services or applicable legal requirements.
Any updated version will be published on the Website with the revised “Last Updated” date.
We encourage you to review this Privacy Policy periodically to remain informed about how we process personal data.
12. Contact us
If you have any questions about this Privacy Policy, the processing of your personal data or your data protection rights, please contact us:
STERLIQPAY LTD
Address: Northway House, 257-258 Upper Street, Highbury & Islington, London, United Kingdom, N1 1RU
Email: general@sterliqpay.co.uk
Questions about this document?
general@sterliqpay.co.uk