Privacy Policy

This policy sets out the basis on which any personal data we collect from you, or that you provide to us, will be processed by us in connection with the RaidsApp application and related services (the "Service").

Please read the following carefully to understand our views and practices regarding your personal data and how we will treat it.

1 WHO WE ARE

Immigration Compliance ("us" or "we") are committed to protecting and respecting your privacy. For the purposes of data protection law, the data controller with conduct of your personal data (as described in this policy) is Immigration Compliance.

2 OUR ROLE IN RELATION TO EVIDENCE YOU RECORD

2.1 Where you (a "Client") use the Service to record video, audio, photographs, GPS location, or other evidence relating to an immigration enforcement visit ("Evidence Data"), you are the data controller of that Evidence Data, including in respect of any third parties (for example officers or other individuals present) who appear within it. You are responsible for ensuring you have a lawful basis to capture and process that data.

2.2 In relation to Evidence Data, we act as a data processor on your instructions, and process it only to host, store, transmit, transcribe, and make it available to you through the Service, and as otherwise set out in this policy or in our agreement with you.

2.3 In relation to your own account, billing, and usage data described in section 3 below, we are the data controller.

3 HOW WE USE YOUR INFORMATION

3.1 The following sections explain what information we hold about you, why we are processing that information, the legal basis for the processing, the duration for which we keep your information and (if applicable) who your information will be shared with and where those recipients are based.

3.2 Which information do we process and for what purpose?

We will collect and process the following data about you:

3.2.1 Information you give us. This is information about you that you give us by filling in forms on our site, entering that information into the application, or by corresponding with us by phone, e-mail or otherwise. It includes information you provide when you register to use the Service, subscribe to a plan, add or manage team members, or report a problem to us. The information you give us may include your name, company name, address, e-mail address, phone number, and billing/payment information.

3.2.2 Evidence Data. When you or your team members use the Service to document a raid, we process the video, audio, and photographic recordings you capture, together with associated GPS location and accuracy, timestamps, session notes, and automatically generated transcripts of that content. This data may include information about third parties present during the recording, and may reveal or relate to immigration or legal status, which is special category personal data. See section 2 above for our role in relation to this data, and section 5 below for the legal basis on which it is processed.

3.2.3 Information we collect about you. When you use our site or the application we will automatically collect the following information:

3.2.3.1 technical information, including the Internet protocol (IP) address used to connect to the internet, your login information, device and browser type and version, time zone setting, and operating system and platform; and

3.2.3.2 information about your use of the Service, including pages or screens viewed, upload and session activity, error and diagnostic logs, and any phone number used to call our customer service number.

3.2.4 Information we receive from other sources. This is usually only the case where your details are passed to us by another member of your organisation when inviting you as a team member, or, if you are a sole trader or partner in a legal partnership, by your employees or fellow partners. This will typically comprise your name and contact information.

3.3 How is my information used?

We use information held about you in the following ways:

3.3.1 to carry out our obligations arising from any contract entered into between you (or the organisation you work for or represent) and us, including providing the Service, storing and processing Evidence Data, generating transcripts, and supporting your response to official notices;

3.3.2 to provide access to optional human consulting services where you request them;

3.3.3 to notify you about changes to the Service or to respond to your enquiries;

3.3.4 to administer your account, manage your subscription and billing, and provide client support;

3.3.5 to provide you with information about other goods and services we offer that are similar to those you have already subscribed to or enquired about; and

3.3.6 to administer our site and the Service, including for troubleshooting, security, data analysis, testing, and statistical purposes.

3.4 What are the grounds for processing your information?

We are processing your data on the following grounds:

3.4.1 because the processing is necessary for the performance of the contract between you and us, including the taking of pre-contractual steps at your request;

3.4.2 if you are an employee or representative of a Client, because we have a legitimate interest in processing your information in order to perform the contract between us and your employer, including taking pre-contractual steps at their request;

3.4.3 in certain circumstances, the processing is necessary for us to comply with our legal or regulatory obligations;

3.4.4 in all other cases, the processing is necessary for achieving our legitimate interests of maintaining accurate internal records, responding to enquiries, operating and securing the Service, and (where you have consented) sending you marketing information, which you can unsubscribe from at any time; and

3.4.5 we are otherwise processing your data on the basis of your consent, typically where you have opted into marketing communications.

3.5 What is the legal basis for processing Evidence Data?

3.5.1 We process Evidence Data as a processor, on your instructions and for the purpose of providing the Service to you. As between you and us, you determine the lawful basis on which Evidence Data (including data about third parties) is captured and processed, and you are responsible for that determination.

3.5.2 To the extent we process any special category data within Evidence Data ourselves (for example to provide storage, transcription, or technical support), we rely on the processing being necessary for reasons of substantial public interest connected with the prevention or detection of unlawful acts and the establishment, exercise, or defence of legal claims, in accordance with the UK GDPR and the Data Protection Act 2018.

3.6 Duration and further processing.

We only keep your information for so long as it is reasonably necessary. Generally speaking, we keep information for the following periods of time:

3.6.1 account, billing, and contact information for Clients, team members, suppliers, and contractors–for the duration of your subscription and 7 (seven) years afterwards, or as required by law;

3.6.2 account and contact information where a contract is not entered into between us–1 (one) year from the last communication between us; and

3.6.3 Evidence Data (recordings, photographs, GPS data, and transcripts)–for the duration of your subscription, plus any additional period specified in your plan or agreed with you, after which it is deleted unless we are required to retain it for longer to comply with the law, respond to an official notice, or resolve a dispute.

If we need to keep your information for a longer period then we will notify you of the reason and grounds for doing so.

3.7 Who is your information shared with?

Your personal information is not shared with anyone except where we are required to do so to comply with the law, to protect our rights, to provide the Service, or to efficiently operate our business. In order to achieve these purposes, we will share data with the following people or groups of people:

3.7.1 our cloud hosting and infrastructure providers (including Amazon Web Services), who store and process Evidence Data and other account data on our behalf, subject to contractual obligations to keep it confidential and secure;

3.7.2 third-party transcription and content-processing providers, where used to generate transcripts or extract information from Evidence Data on our behalf;

3.7.3 our outsourced IT providers, who may require access to data held on our systems, for example to troubleshoot a technical issue, and who are subject to strict contractual obligations to treat your personal information with the utmost sensitivity and to comply with data protection law at all times;

3.7.4 our professional advisers and associates, such as our accountants, solicitors, and barristers, who are subject to professional duties of confidentiality; and

3.7.5 regulators, courts, or public authorities (including the Home Office), where you choose to submit Evidence Data in response to an official notice, or where we are required to disclose information by law.

3.8 International transfers

Evidence Data and account data are hosted with our cloud hosting provider in the European Union (Ireland). Some other service providers we use, such as certain transcription, analytics, or support tools, may process limited data outside the UK or European Economic Area. Where this happens, we ensure appropriate safeguards are in place, such as the UK International Data Transfer Addendum or standard contractual clauses approved for this purpose, or that the transfer is otherwise permitted under data protection law. If this changes we will let you know.

3.9 Automated decision making

We do not make automated decisions about you based on your information that produce legal or similarly significant effects. If this changes in the future then we will let you know.

3.10 Where we store your personal data

All information you provide to us, including Evidence Data, is stored within our secure cloud storage, with encryption in transit and at rest. Any payment transactions are handled and encrypted pursuant to our payment processor's protocols; we do not store full card details ourselves. Where we have given you (or where you have chosen) a password or other credential which enables you to access the Service, you are responsible for keeping it confidential and should not share it with anyone outside your organisation.

Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of data transmitted to our site or the Service. Any transmission is at your own risk. Once we have received your information, we use strict procedures and security safeguards to try to prevent unauthorised access.

4 YOUR RIGHTS

4.1 Under data protection law you have the following rights:

4.1.1 the right to be informed as to what we do with your information. This includes but is not limited to the right to know what information we gather, process and store, what we do with it, who we share it with and how long we keep it for. This information is set out in this policy;

4.1.2 if we are processing your data on the basis of your consent then you have the right to withdraw that consent at any time. One way of doing so would be to notify us using the details set out below. Please note that the lawfulness of our historic processing based on your consent will not be retrospectively affected by your subsequent withdrawal of consent;

4.1.3 the right to access a copy of your information which we hold. This is called a 'subject access request'. Additional details on how to exercise this right are set out in section 5, below;

4.1.4 the right to prevent us processing your information for direct marketing purposes;

4.1.5 the right to object to decisions being made about you by automated means;

4.1.6 the right to object to us processing your personal information in certain other situations;

4.1.7 the right, in certain circumstances, to have your information rectified, blocked, erased or destroyed if it is inaccurate; and

4.1.8 the right, in certain circumstances, to claim compensation for damages caused by us breaching data protection law.

4.2 Where we act as a data processor in respect of Evidence Data submitted by a Client (see section 2 above), requests relating to that Evidence Data, including from third parties who appear within it, should in the first instance be directed to the relevant Client, who is the data controller. We will assist the Client in responding to such requests where required by our agreement with them.

4.3 You also have the general right to complain to us (in the first instance) and to the Information Commissioner's Office (if you are not satisfied by our response) if you have any concerns about how we hold and process your information. Our contact details are set out below. The Information Commissioner's Office website is www.ico.org.uk.

4.4 For further information on your rights under data protection law and how to exercise them, you can contact Citizens Advice Bureau www.citizensadvice.org.uk (or the Information Commissioner's Office www.ico.org.uk).

4.5 Sell, resell, sublicense, licence, assign, transfer, distribute or otherwise make the App or any of its services available to any other person, business or organisation. Provide, share or permit access to the App, including any account, login credentials, functionality or services, to any other business or organisation.

4.6 Use the App, or any service provided through the App, for the purpose of providing services to, or on behalf of, another business or organisation. Subcontract, outsource, white-label or otherwise commercially exploit any service, functionality or access provided through the App. Allow any third party to use the App as though they were a customer or authorised user in their own right.

5 ACCESS TO INFORMATION

Under data protection law you can exercise your right of access by making a written request to receive copies of some of the information we hold on you. You must send us proof of your identity, or proof of authority if making the request on behalf of someone else, before we can supply the information to you. Requests should be sent to us using the contact details in section 7 below.

6 COOKIES

Information about our use of cookies

6.1 A cookie is a small file of letters and numbers that we store on your browser or the hard drive of your device if you agree. Cookies contain information that is transferred to your device's hard drive.

6.2 Our site uses cookies to distinguish you from other users. This ensures we can provide you with an optimal user experience and allows us to improve our site. By continuing to browse the site, you are agreeing to our use of cookies.

6.3 We use the following cookies:

6.3.1 Strictly necessary cookies.

These are cookies required for the operation of our site and the Service, for example cookies that keep you logged in to secure areas.

6.3.2 Analytical/performance cookies.

These allow us to recognise and count the number of visitors and to see how visitors move around our site when they are using it. This helps us to improve the way our site works.

6.3.3 Functionality cookies.

These are used to recognise you when you return to our site and to remember your preferences.

6.4 Third party cookies

Please note that third parties (for example, analytics and payment processing providers) may also use cookies over which we have no control.

6.5 Blocking cookies.

You can block cookies by activating the setting on your browser that allows you to refuse the setting of all or some cookies. Please note that if you use your browser settings to block all cookies (including essential cookies) then you may not be able to access all or parts of our site or the Service.

7 CHANGES TO OUR PRIVACY AND COOKIES POLICY

Any changes we make to this policy in the future will be posted on this page and, where appropriate, notified to you by email. Please check back frequently to see any updates or changes to this policy.

8 CONTACT

Questions, comments and requests regarding this privacy and cookies policy are welcomed and should be emailed to kb@immigration-compliance.co.uk