Data Protection Policy

Plain English Summary

At Paydesk, we value your privacy and are committed to protecting your personal data. Here's a quick overview of our data protection policy:

• What We Collect: We collect various types of personal data including your name, contact details, financial information, published articles and data about your use of our services.
• How We Use Your Data: We use your data to provide our services, manage your account, improve our website, and communicate with you. We may also use your data for marketing, but only with your consent.
• Your Rights: You have rights regarding your data, such as accessing it, correcting it, or requesting its deletion. You can also object to how we process your data or withdraw your consent.
• Security Measures: We use advanced security measures to protect your data, including encryption and secure access controls.
• Data Sharing: We may share your data with trusted third parties to help us provide our services. These parties are required to protect your data and use it only as we direct.
• International Transfers: Some of your data may be transferred outside the UK. We ensure it is protected through appropriate safeguards.
• Contact Us: If you have any questions or concerns about your data, you can contact our Data Privacy Manager at support@paydesk.co

Please read the full policy for detailed information on how we handle your personal data.

Data Protection Policy

Paydesk respects your privacy and is committed to protecting your personal data. This data protection policy will inform you how we look after your personal data and tell you about your privacy rights and how the law protects you.

This data protection policy is provided in a layered format so you can click through to the specific areas set out below. Please also use the Glossary to understand the meaning of some of the terms used in this data protection policy.

Your rights are summarized in section 9 below. This includes the right to object to (a) processing of your personal data at any time on grounds relating to your particular situation, where our legal basis for processing is necessity for our (or a third party’s) legitimate interests and (b) processing of your personal data at any time for direct marketing purposes. See section 9 for further details of your rights.

1. Important Information and Who We Are

   • Purpose of this data protection policy: Paydesk Limited is the controller and responsible for your personal data (referred to as "Paydesk", "we", "us" or "our" in this data protection policy).

     We have appointed a data privacy manager who is responsible for overseeing questions in relation to this data protection policy. If you have any questions about this data protection policy, including any requests to exercise your legal rights, please contact the data privacy manager using the details set out below.

   • Contact Details: If you have any questions about this data protection policy or our privacy practices, please contact our data privacy manager in the following ways:

     • Full name of legal entity: Paydesk, Ltd.
     • Email address: support@paydesk.co
     • Postal address: Data Policy Manager, Paydesk Limited, c/o WeWork, 12 Hammersmith Grove, London, W6 7AP

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

   • Changes to the Data Protection Policy and Your Duty to Inform Us of Changes: We keep our data protection policy under regular review. This version was last updated in May 2024. Historic versions can be obtained by contacting us.

     It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.

   • Third-party Links: This website may include links to third-party websites, plug-ins, and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the data protection policy of every website you visit.

2. The Data We Collect 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). We may collect, use, store, and transfer different kinds of personal data about you, which we have grouped together as follows:

   • A) Identity Data: Includes first name,last name,username or similar identifier, title, photograph, date of birth, gender, and identity details as collected from a government ID, such as document number and document expiration date.
   • B) Profile Data: Includes your username and password, joining date, bookings or jobs completed or made by you, biographical details, language abilities, journalism skills, photograph, work samples, feedback, articles written by you that we scrape from the internet (including publication name, publication date, link to the article, summary of the article, and other related metadata), and the political opinion of each article as extracted using AI tools. The extraction and processing of political opinion is based on our legitimate interests under Article 6(1)(f) of the UK GDPR, as it is necessary for the purposes of maintaining an accurate and comprehensive database of news professionals.
   • C) Contact Data: Includes billing address, location (town/city and country), work address, email address, telephone numbers and social media account details.
   • D) Financial Data: Includes bank or other payment account details and payment card details.
   • E) Usage Data: Includes information about how and when you use our website, bookings you made or jobs you completed. It also includes messages that you send and receive via Paydesk, and other details of services you have used or provided via Paydesk.
   • F) Transaction Data: Includes details about payments to and from you.
   • G) TechnicalData: Includes internet protocol (IP) address, 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 this website and our services.
   • H) Marketing and Communications Data: Includes your preferences in receiving marketing from us and, if applicable, third parties, your subscriptions to Paydesk communications, and your communication preferences.

   We may also collect, use, and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data could be derived from your personal data but is not considered personal data in law as this data will not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. 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 data protection policy.

   Aside from political opinion (as derived from your published articles, in accordance with Article 6(1)(f) of the UK GDPR), we do not collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity (save as apparent from your photograph), religious or philosophical beliefs, sex life, sexual orientation, trade union membership, information about your health, and genetic and biometric data). Nor do we collect any information about criminal convictions and offenses.

   If You Do Not Provide Personal Data When Requested

   Where we need to collect personal data by law, or under the terms of a contract we have with you, and you do not provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with services). In this case, we may have to cancel a service you have with us but we will notify you if this is the case at the time.

3. How Is Your Personal Data Collected?

   We use different methods to collect data from and about you including through:

   • Direct interactions: You may give us your Identity, Contact, Financial, Transaction, Profile, and Marketing & Communications Data by filling in forms or by corresponding with us by post, phone, email, or otherwise. This includes personal data you provide when you:
     • apply to join Paydesk or otherwise to use Paydesk’s services;
     • create or use an account on our website;
     • submit changes to your details or settings;
     • subscribe to our service or publications;
     • provide or obtain services using Paydesk;
     • request marketing to be sent to you;
     • enter a survey, give us feedback, or otherwise contact us.
   • Automated technologies or interactions: As you interact with our website, we will automatically collect Technical and Usage Data about your equipment, browsing actions, and patterns. We collect this personal data by using cookies, server logs, and other similar technologies. Please see our cookie policy for further details.
   • Third parties or publicly available sources: We will receive personal data about you from various third parties and public sources as set out below:
     • Technical Data from the following parties:
       • analytics providers such as Google based outside the UK;
       • search information providers.
     • Contact, Financial, and Transaction Data from providers of technical, payment, and delivery services if you provide links to such information for use on our service.
     • Identity, Contact, and Profile Data from publicly available sources such as your website or social media profiles based inside or outside the UK.
     • Transaction, Profile, and Usage data from third parties to whom you provide or from whom you receive communications or services using the Paydesk platform.
     • Crawling the Internet: We crawl the internet to identify articles written by you. We then use AI tools to extract metadata from these articles, including publication name, publication date, link to the article, summary of the article, and other related metadata. This data is then added to your profile. This processing is based on our legitimate interests under Article 6(1)(f) of the UK GDPR, as it is necessary for the purposes of our business in maintaining an accurate and comprehensive database of news professionals.

4. How We Use Your Personal Data

   We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:

   • Where we need to perform the contract we are about to enter into or have entered into with you.
   • 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.
   • Where we need to comply with a legal obligation.

   Purposes for Which We Will Use Your Personal Data

   We have set out below, in a table format, a description of all the ways we may use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.

   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 need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below.

   Purpose/Activity	Type of data	Lawful basis for processing including basis of legitimate interest
   To register you as a new user including contacting you where you have not finished the registration process	(a) Identity (b) Profile (c) Contact (d) Financial	Performance of a contract with you, or in order to take steps at your request prior to entering into a contract
   To offer and provide our services to you including: (a) Manage and maintain our database of media professionals (b) Enable you to promote your services to Paydesk clients, including by making available Paydesk’s database of media professionals to clients, and featuring media professionals on our website (c) Introduce Paydesk clients and media professionals to each other, including by making available Paydesk’s database of media professionals and featuring media professionals on our website, and contacting you about requests from our clients (d) Enable shortlisting for jobs, booking of jobs, and tracking of jobs (e) Manage payments, fees and charges and provide a record of your earnings and payments (f) Collect and recover money owed to us (g) Provide a messaging facility between media professionals, and between clients and media professionals, and review message content where Paydesk considers it appropriate to do so in order to provide our services effectively to clients and media professionals and ensure compliance with our terms (h) Provide you with publications and subscriptions to Stories and other communications that we may make available from time to time	(a) Identity (b) Profile (c) Contact (d) Financial (e) Usage (f) Transaction (h) Marketing & Communications Data	(a) Performance of a contract with you (b) Necessary for our legitimate interests (to maintain records, to recover debts due to us, to ensure compliance with our terms, and to maintain quality control in respect of our business and that of media professionals and clients)
   To manage our relationship with you which will include: (a) Notifying you about changes to our terms or privacy policy (b) Asking you to provide feedback (c) Handling any complaint that we receive (d) To remove you from our database where appropriate	(a) Identity (b) Profile (c) Contact (d) Financial (h) Marketing & Communications	(a) Performance of a contract with you (b) Necessary to comply with a legal obligation (c) Necessary for our legitimate interests (to keep our records updated and to study how customers use our products/services)
   To administer and protect our business and website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)	(a) Identity (b) Profile (c) Contact (d) Financial (e) Usage (f) Transaction (g) Technical	(a) Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise) (b) Necessary to comply with a legal obligation
   To use data analytics to improve our website, products/services, marketing, customer relationships and experiences	(e) Usage (g) Technical	Necessary for our legitimate interests (to define types of customers for our products and services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy)
   To make suggestions and recommendations to you about services, events or news that may be of interest to you (including marketing of third party products or services where you have opted in to receive such marketing)	(a) Identity (b) Profile (c) Contact (e) Usage (f) Transaction (g) Technical (h) Marketing & Communications	(a) Necessary for our legitimate interests (to develop our products/services and grow our business) where we are permitted by law to send you marketing on an opt-out basis (b) Consent (to provide you with third party marketing that you have opted in to receive)
   To deliver relevant website content and marketing to you and measure or understand the effectiveness of our marketing.	(a) Identity (b) Contact (c) Transaction (d) Technical (e) Profile (f) Usage (g) Marketing and Communications	Necessary for our legitimate interests (to study how users make use of our services, to develop them, to promote and grow our business, and to inform our marketing strategy)
   To maintain records after you cease to use our services	(a) Identity (b) Contact (c) Financial (d) Transaction (e) Technical (f) Profile (g) Usage (h) Marketing and Communications	(a) Necessary to comply with a legal obligations (b) Necessary for our legitimate interests (to satisfy our legal, regulatory, tax, accounting or reporting requirements to keep our records archived for a reasonable or statutory period)

5. Disclosures of Your Personal Data

   We may share your personal data with the parties set out below for the purposes set out in the table above:

   • Internal Third Parties as set out in the Glossary.
   • External Third Parties as set out in the Glossary.
   • Third parties to whom we may choose to sell, transfer, or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this data protection policy.

   We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.

6. International Transfers

   Many of our clients are based outside the UK. Therefore, their access to and use of news professionals’ personal data in relation to Paydesk’s services, including accessing the Paydesk website to make bookings, will involve transferring such data outside the UK. Additionally, we use third-party data hosting providers located outside the UK, including data centers in the US, to ensure site speed and availability.

   Whenever we transfer your personal data out of the UK, we ensure it receives a similar degree of protection by implementing one or more of the following safeguards:

   • We may transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data.
   • Where we use certain service providers, we may use specific contracts approved for use in the UK which give personal data essentially the same protection it has in the UK and EU.
   • Where the transfer is necessary for the performance of a contract between you and Paydesk for the implementation of pre-contractual measures taken at your request, or for the conclusion or performance of a contract concluded in your interest between Paydesk and another person or company. This includes enabling Paydesk clients to access necessary data when considering booking you, arranging their work with you, or enabling Paydesk to pay you via a payment services provider.
   • Clients who have access to personal information through Paydesk are bound by our terms and the Data Protection Policy. Any violations of these terms or the Data Protection Policy may result in the suspension or termination of the client's account. This ensures that personal data is handled responsibly and securely by all parties involved.

   Please contact us if you require further information on the specific mechanisms used by us when transferring your personal data out of the UK.

7. Data Security

   We take the security of your data seriously and are committed to ensuring your personal information is protected. We have implemented robust security measures designed to protect your data from unauthorized access, disclosure, alteration, or destruction. Our security practices adhere to industry best practices and regulatory requirements. Below is an overview of our security protocols:

   • Reputable Cloud Compute Provider: We utilize a leading cloud service provider known for its exceptional security and compliance standards. Our cloud provider offers a highly secure infrastructure with numerous certifications and attestations, including ISO/IEC 27001, SOC 2, and GDPR compliance. Leveraging this provider allows us to benefit from:
     • Advanced Security Features: Our cloud provider offers state-of-the-art security features, including encryption, network firewalls, DDoS protection, and continuous monitoring.
     • Global Infrastructure: The global data centers of our cloud provider ensure high availability and redundancy, minimizing the risk of data loss and downtime.
     • Compliance Certifications: Our cloud provider complies with a wide range of global security standards and regulations, ensuring our infrastructure meets or exceeds industry requirements.
   • Access Controls: Access to personal data is restricted to authorized personnel only.
     • We use a role-based access control (RBAC) system to ensure that individuals only have access to the data necessary for their role. All access is logged and monitored for suspicious activity.
     • All individuals with access undergo thorough identity and background checks to ensure the highest level of trustworthiness and security.
     • Two-factor authentication is mandated across systems for all employees and contractors.
   • Encryption: All data is encrypted both in transit and at rest using advanced encryption standards.
     • We use TLS (Transport Layer Security) for data transmission and AES-256 for data storage.
     • Highly sensitive data, including financial information and metadata related to government-issued IDs, is encrypted at both the row-level and table-level to provide additional layered protection.
   • Employee Training Programs: All employees receive regular cybersecurity training to ensure they are aware of and adhere to our security practices.
   • Data Minimization: We follow data minimization principles to ensure we only collect and retain the personal data necessary for our operations.
   • Regular Review of Security Measures: We regularly review and update our security measures to adapt to new threats and vulnerabilities.
   • Third-Party Vendor Management: We conduct thorough due diligence and regular security assessments of our third-party vendors to ensure they meet our security standards.
   • Data Anonymization and Pseudonymization: We use data anonymization and pseudonymization techniques to enhance the security of personal information.
   • Incident Response Plan: We have a comprehensive incident response plan in place to address any data breaches promptly and effectively. Our procedures for handling any suspected personal data breaches are robust, and we will notify you and any applicable regulator of a breach where we are legally required to do so.

   By incorporating these robust security measures and practices, we ensure the highest level of protection for your personal data.

8. Data Retention

   We will only retain your personal data for as long as reasonably necessary to fulfill the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting, or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.

   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 unauthorized 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, regulatory, tax, accounting, or other requirements.

   By law, we have to keep some information about our users (including Contact, Identity, Financial, and Transaction Data) for six years after they cease being customers for tax purposes.

   In some circumstances, you can ask us to delete your data: see your legal rights below for further information.

   In some circumstances, we will anonymize your personal data (so that it can no longer be associated with you) for research or statistical purposes, in which case we may use this information indefinitely without further notice to you.

9. Your Legal Rights

   Under certain circumstances, you have rights under data protection laws in relation to your personal data:

   • Request access to your personal data: This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
   • Request correction of the personal data that we hold about you: This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
   • Request erasure of your personal data: This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully, or where we are required to erase your personal data to comply with local law. 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.
   • Object to processing of your personal data: You can do this where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
   • Request restriction of processing of your personal data: This enables you to ask us to suspend the processing of your personal data in the following scenarios:
     • If you want us to establish the data's accuracy.
     • Where our use of the data is unlawful but you do not want us to erase it.
     • Where you need us to hold the data even if we no longer require it as you need it to establish, exercise, or defend legal claims.
     • You have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
   • Request the transfer of your personal data: You can request this to yourself or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. 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.
   • Withdraw consent at any time: You can do this where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.

   If you wish to exercise any of the rights set out above, please contact us.

   No Fee Usually Required

   You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive, or excessive. Alternatively, we could refuse to comply with your request in these circumstances.

   What We May Need From You

   We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

   Time Limit to Respond

   We try to respond to all legitimate requests within one month. Occasionally it could take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.

10. Glossary

    • Legitimate Interest: Means the interest of our business in conducting and managing our business to enable us to give you the best service/product and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us.
    • Performance of Contract: Means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.
    • Comply with a legal obligation: Means processing your personal data where it is necessary for compliance with a legal obligation that we are subject to.
    • Internal Third Parties:P aydesk staff have limited access to personal data. Access is restricted, monitored, and only allowed in order to maintain the Paydesk service and fulfill our obligations.
    • External Third Partiess
      • Clients or prospective clients of Paydesk who use news professionals.
        • You can choose to limit access only to clients, using the privacy controls in the “Account” section of Paydesk.
      • Other news professionals with whom you as a media professional communicate using the Paydesk platform or who use the Paydesk database.
      • Service providers acting as processors based in the United States who provide data hosting and IT and system administration services.
      • Payment services providers based mainly, but not exclusively, in the United Kingdom.
      • Professional advisers and service providers acting as processors or joint controllers including lawyers, bankers, auditors, and insurers based in the United Kingdom who provide consultancy, banking, legal, insurance, and accounting services.
      • HM Revenue & Customs, regulators, and other authorities acting as processors or joint controllers based in the United Kingdom who require reporting of processing activities in certain circumstances.

11. Cookie Policy

    Please refer to our cookie policy for information about the cookies we use and how to manage your cookie preferences.

Last Updated on 17th May 2024