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Privacy policy

At Ermi we want you to have access to our effective Transaction monitoring tools and educational materials about Transaction Monitoring. We also occasionally want to email you to tell you about updates, changes to our rules and new materials which may be of interest to you. To do this, we have to collect some personal information about you, any potentially corporate entities we may deal with and the people that work for them.

Ermi respects your privacy and is committed to protecting your Personal Data. This privacy policy explains how we collect, look after and use your Personal Data when you visit our website and/or use our services and to tell you about your privacy rights and how the law protects you.

Please also use the Glossary to understand the meaning of some of the terms used in this privacy policy. If you have any questions, please reach out to support@ermitm.com

1. Important information and who we are

This privacy policy is issued on behalf of Ermi. Ermi is the trading name of Ermi Software Limited so when we mention "Ermi", "we", "us" or "our" in this privacy policy, we are referring to our legal entity.

Controller

Ermi’s legal name is Ermi Software Limited, a Company registered at 11 Melton Gardens, Romford, RM1 2AS, with company registration number 10931416. Ermis Software Limited is responsible for this website and is the controller of all data received via this site or through the use of our monitoring tools.

Purpose of this privacy policy

This privacy policy aims to give you information on how Ermi collects and processes Personal Data we collect from you. This Personal Data may be obtained through the provision of our services in accordance with our terms and conditions and through interactions with our website.

This website is not intended for children, and we do not knowingly collect data relating to children.

It is important that you read this privacy policy together with and any other privacy notice or fair processing notice we may provide on specific occasions when we are collecting or processing Personal Data about you so that you are fully aware of how and why we are using your data. If you are a client of Ermi Software Limited, you should also read our terms and conditions in conjunction with this privacy policy.

We have appointed a Data Privacy Manager who is responsible for overseeing questions in relation to this privacy policy. If you have any questions about this privacy 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 privacy policy or our privacy practices, please contact us at support@ermitm.com

You have the right to make a complaint at any time to the Information Commissioner's Office (the "ICO"), the UK regulator for data protection issues (www.ico.org.uk) if you feel we have not processed your data in accordance with this privacy policy or UK law.

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 privacy policy and your duty to inform us of changes

We keep our privacy policy under regular review.

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.

This website may include links to various third-party websites, plug-ins and applications.

Our website currently contains a link to our LinkedIn page, BlueSky social media page and our Github technical page. Visiting external pages with social media plugins may result in your data being collected by the social media or website company (depending on your browser’s configuration). This includes data such as an IP address and a record of pages you visit at the relevant time. Social media features may also set third-party cookies (or similar technologies eg tracking pixels). Social media providers linked to by the site will be considered their own controllers for the purposes of data processing.

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 those websites or their privacy statements. When you leave our website and/or before you click on any third-party links, we encourage you to read the privacy policy of every website you visit before you submit or share any Personal Data with them.

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 and last name
  • (b) Contact Data includes email address and telephone numbers
  • (c) Technical Data includes 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 this website
  • (d) Usage Data includes information about how you use our website, products and services.
  • (e) Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences (Email, Phone, Slack etc).

Special Category Personal Data

Special Category Personal Data includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health, bank account details and genetic and biometric data. We do not collect this data through this site. Specific information such as bank account details may be collected as part of your ongoing contract with Ermi, if you are a client.

If you fail to provide Personal Data

Where we need to collect Personal Data under the terms of a contract we have with you and you fail to 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 goods or services).

In this case, we may have to cancel a product or 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 and contact data by filling in forms on this site or by corresponding with us by post, phone, email or otherwise. This includes Personal Data you provide when you:

  • (a) apply for our products or services
  • (b) subscribe to our service or publications;
  • (d) request marketing to be sent to you;
  • (e) enter a competition, promotion or survey; or
  • (f) give us feedback or contact us.

Automated technologies or interactions. As you interact with our website, we will automatically collect technical data about your equipment, browsing actions and patterns. We collect this using Tracking Pixels.

Identity and Contact Data from publicly available sources such as Companies House (UK) for the completion of contracts.

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:

  • (a) Where we need to perform the contract we are about to enter into or have entered into with you.

  • (b) To provide you with access to, or to communicate to you details of a marketing nature, such as articles, blogs, white papers or information relating to our products and services which we believe may be of legitimate interest to you.

Please see the paragraph below (purposes for which we will use your Personal Data) to find out more about the types of lawful basis that we will rely on to process your Personal Data.

Generally, we rely on consent as a legal basis for processing your Personal Data. You have the right to withdraw consent to marketing at any time by contacting us.

Purposes for which we will use your Personal Data

We have set out below, a description of all the ways we plan to 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 customer (a) Identity
(b) Contact		 Performance of a contract with you
To use data analytics to improve our website, products/services, marketing, customer relationships and experiences. (a) Technical
(b) Usage		 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)
For Marketing and sharing relevant materials such as articles and educational detail (a) Identity Consent - We will only perform this is we have your consent to send you material and marketing. All email newsletters or marketing emails have an unsubscribe link and all opt-outs will be actioned and respected. You can ask us to stop sending you marketing messages at any time.

Promotional offers from us

We may use your Identity, Contact, Technical, Usage and Profile Data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which products, services and offers may be relevant for you (we call this marketing).

You will receive marketing communications from us if you have requested information from us.

Opting out

You can ask us stop sending you marketing messages by contacting us at any time on support@ermitm.com or by unsubscribing to our emails.

Change of purpose

We will only use your Personal Data for the purposes for which we collected it, If we need 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.

Please note that we may process your Personal Data without your explicit knowledge or consent, in compliance with the above rules, but only where this is required by law.

5. Disclosures of your Personal Data

We may share your Personal Data with the parties set out below in order to perform your contract with us, process your data and handle the transfer of data from you to us, or to handle marketing and the generation of emails:

  • (a) AWS - AMAZON WEB SERVICES EMEA SARL, UK BRANCH, Ermi utilises AWS as its primary hosting partner and so your contact details will be shared with AWS for the purposes of data storage and the performance of our contract with you. This will include all relevant transactional data, if you are a client of Ermi’s.
  • (b) Xero - Xero (UK) Limited, Ermi utilises Xero for billing purposes. We will provide your contact details to Xero for the purposes of invoice and billing purposes if you have a contract with us to provide services. This information will be limited to your name and corporate email address.
  • (c) Google LLC - Google is the provider of Ermi’s email services and Google Drive services. Your data will be shared with Google if you email us, or if you share data with us via Google Drive.

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.

We may also disclose your Personal Data for the following additional purposes where permitted or required by applicable law:

  • (a) to comply with legal obligations.
  • (b) if a business transfer or change in ownership occurs and the disclosure is necessary to complete the transaction. In these circumstances, we will limit data sharing to what is absolutely necessary and we will anonymise data where possible.

6. Data security

We have put in place appropriate security measures to prevent your Personal Data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your Personal Data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your Personal Data on our instructions and they are subject to a duty of confidentiality.

We have put in place procedures to deal with any suspected Personal Data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

7. Data retention

How long will you use my Personal Data for?

We will only retain your Personal Data for as long as reasonably necessary to fulfil 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 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, regulatory, tax, accounting or other requirements.

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

(a) Request access to your Personal Data.

Commonly known as a "Data Subject access request". This enables you to receive a copy of the Personal Data we hold about you and to check that we are lawfully processing it.

(b) Request correction of your Personal Data.

You have the right to 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.

(c) 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.

(d) Object to processing of your Personal Data.

You have the right to object to processing of your Personal Data 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.

(e) Request restriction of processing 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.

(f) Request transfer of your Personal Data.

You have the right to request the transfer of your Personal Data to you 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.

You have the right to withdraw consent at any time 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 support@ermitm.com

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.

9. Glossary (Definitions and Terms)

Consent of the Data Subject means any freely given, specific, informed and unambiguous indication of the Data Subject’s wishes by which he or she, by a statement or by a clear affirmative action, signifies agreement to the processing of personal data relating to him or her;

Controller means the natural or legal person, public authority, agency or other body which, alone or jointly with others, determines the purposes and means of the processing of Personal Data. It is responsible for establishing practices and policies in line with Data Protection Legislation. We are the Controller of all Personal Data relating to our Company Personnel and Personal Data used in our business for our own commercial purposes;

UK GDPR: has the meaning given to it in section 3(10) (as supplemented by section 205(4)) of the Data Protection Act 2018;

Legal Basis for Processing means the lawful bases for processing as set out in Article 6 of the GDPR and UK GDPR. At least one of these must apply whenever Ermi process Personal Data. We must also provide this data to the client so that they understand what data we are processing, and why:

Consent means that the individual has given clear consent for you to process their Personal Data for a specific purpose.

Contract means that the Processing is necessary for a contract you have with the individual, or because they have asked you to take specific steps before entering into a contract.

Legal obligation means that the processing is necessary for you to comply with the law (not including contractual obligations).

Vital interests means the processing is necessary to protect someone’s life.

Public task means that the Processing is necessary for you to perform a task in the public interest or for your official functions, and the task or function has a clear basis in law.

Legitimate interests means that the Processing is necessary for your legitimate interests or the legitimate interests of a third party unless there is a good reason to protect the individual’s Personal Data which overrides those legitimate interests. 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 to by law);

Personal Data means any information that relates to an identified or identifiable natural person or individual (‘Data Subject’) (Article 4 GDPR); or any information relating to an identified or identifiable living individual (Section 3(2) DPA 2018).

Personal Data Breach means a breach of security leading to the accidental or unlawful destruction, loss, alteration, unauthorised disclosure of, or access to, Personal Data transmitted, stored or otherwise processed;

Special Categories of Personal Data includes any data we hold which is Personal data about an individual's racial or ethnic origin, political opinions, religious or similar beliefs, trade union membership (or non-membership), physical or mental health or conditions, sexual life, sexual orientation, biometric or genetic data. Any use of sensitive Personal Data must be strictly controlled in accordance with this policy. Any Criminal Convictions Data which we hold will also be considered to be special category of Personal Data.

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. 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