Asora Privacy Notice

Last Modified: 4 November 2024

Asora Technologies Limited t/a Asora, a company incorporated under the laws of Ireland under company number 706300 with registered office 20 Hatch Street Lower, Dublin, D02 XH02 Ireland (“Asora”, “us” or “our”).  We operate the website www.asora.com (the “Website”).

Where we act as a controller in respect of your personal data, we are obliged to provide this Privacy Notice to you under Irish data protection laws, including the General Data Protection Regulation (EU) 2016/679 (“GDPR”), and the Data Protection Acts 1988 to 2018, as such laws may be updated from time to time (“Data Protection Laws”).

This Privacy Notice applies where Asora acts as a controller of your personal data.

We at Asora and our Affiliates are committed to protecting your privacy. This Privacy Notice applies to the information and data collected by Asora when you interact with us on our Website or through other channels (for example, by communicating with us or attending one of our events), and when you use our products and services. This Privacy Notice describes how we collect, receive, use, store, share, transfer, and process your personal data. It also describes your choices and rights with respect to your personal data, including your rights of access and correction of your personal data. If you do not agree with this Privacy Notice, you should not use our Website or the Subscription Service.

Customers may collect and manage personal data when using the Subscription Service. Asora processes such data as a processor under the direction of our customers. Our customers, as controllers, are responsible for complying with any regulations or laws that require providing notice, disclosure, and/or obtaining consent prior to collecting their customers’ personal data using the Subscription Service.  Please see the below Privacy Notice and our Customer Data Processing Agreement for more information.

We update this Privacy Notice from time to time and we encourage you to review this Privacy Notice periodically. We will post any Privacy Notice changes on this page and, if the changes are material, we will provide a more prominent notice by sending you an email notification, or if you subscribe to our products and services, through the Notification app in your Asora account. Terms not otherwise defined in this Privacy Notice will have the meaning as set forth in the Master Terms.

If you have any questions about this Privacy Notice or our treatment of your personal data, feel free to reach out to us at the detail in the contact us section at the end of this Privacy Notice.

Who does this notice apply to?

The Website is intended for use by people who wish to learn about, purchase and use our products and services.

We provide businesses with tools and solutions to help them more easily and effectively manage their financial assets (the “Service”).

This Website and the Service are not intended for children.  We do not knowingly collect any personal data relating to children.

This Privacy Notice applies to you when you access, browse and use our Website (through various domains), set up and account with us and use our Service, join our mailing lists to receive our newsletter communications, and interact with us on the Website, our social media pages, by telephone, email and by other means.

What information we collect about you

“Personal data” means information about an individual from which that person can be identified. It does not include information where an individual’s identity has been removed (anonymous data).  Throughout this Privacy Notice we use the term “processing” to refer to all activities involving your personal data, including collecting, handling, storing, sharing, accessing, using, transferring, erasing and disposing of it.

The personal data we receive about you depends on how you interact with us, and whether your data is processed as part of the provision of our Service.

Typically, we process the following kinds of personal data when you use our Website:

• Identity and Contact Data includes your name and email address, and any personal data provided when contacting us or when placing an order online;
• Profile Data includes your email address, password, login and user account details, preferences, subscriptions, feedback and survey responses and other details that you provide when setting up a user account for the purposes of placing an order and using our Service;
• Transaction Data includes details about payments from and to you (and other details of services you have subscribed for with us where you purchase a subscription to the Service. However, this does not include payment card or bank details, as you provide this information directly to the secure payments service providers we make available to you on our Website;
• Technical Data may include internet protocol (IP) address, browser type and version, time zone setting and location, country and language, browser plug-in types and versions, domain names, internet service provider, computer hardware, operating system, platform and other technology on the devices you use to access our Website click stream data, access times and referring website addresses;
• Usage Data includes information about how you use our Website such as the services you view or search for, page response times, download errors, length of visits and page interaction information (such as scrolling, clicks and mouse-overs), traffic data, web logs and other communication data and the resources that you access; files viewed on our site; and
• Marketing and Communications Data includes your preferences in receiving electronic newsletters and marketing communications from us and your communication preferences.
• Voice Data includes a recording of any phone call with us, and a transcript of the words contained on that call.
• Customer Testimonial Data: includes your name, your business, your title and other information connected to a testimonial about our services.

We also collect, use and share aggregated data such as statistical or demographic data for various purposes.  Aggregated data may be derived from your personal data but is not considered personal data in law as this data does not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific page or Service 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 Privacy Notice.  We may share externally or provide other companies with this aggregated statistical information about our users, but this information will not be used to identify any individual user and will only be shared on an aggregate and de-identified basis. For example, we may publish blog posts on trends or insights into how users are interacting with our Service.

We do not collect any special categories of personal data about you (this is personal data that reveals racial or ethnic origin, political opinions, religious or philosophical beliefs or trade union membership; genetic data; biometric data for the purpose of uniquely identifying an individual or data concerning health or sexual orientation).  Where we need to collect personal data by law, or in accordance with our contract with you/your employer (i.e. the Asora Customer Terms of Service), and you do not provide that personal data when requested, you may not be able to subscribe for or use some of our products or services. We will let you know at the time of collecting personal data from you whether you must provide the personal data in order to receive any of our products or services, and whether the provision of personal data requested by us is optional.

How your personal data is received

We may receive your personal data through various means including:

• Direct interactions: As a user of our Website and/or Services, you may give us your Identity and Contact Data, Profile Data and/or Transaction Data by creating and managing your user account, which is used for purchasing and subscribing for our Services, selecting preferences, filling in website forms, sharing product details or by corresponding with us by post, phone, email, social media or otherwise. This includes personal data you provide when you enter a promotion or survey, give us feedback, register for an Asora event or contact us.
• Automated technologies or interactions: As you interact with our Website and/or use the Service we collect Technical Data and Usage Data. We collect this by using cookies, tracking codes, server logs and other similar technologies. We may also receive Technical Data if you visit other websites using our cookies. Please see our Cookie Policy for further details.
• Third party sources:

We may receive personal data about you from third parties, as set out below:

• Technical Data from the following parties: We use Google Analytics to better understand how our Website is used. These features use cookies and anonymous identifiers to collect information and help target advertising; and
• Identity and Contact Data and Transaction Data from providers of payment services such as Go Cardless and Stripe.

Information We Process on Behalf of Customers

Our online Subscription Service allows our customers to collect and share financial information. When customers use the Subscription Service, they may collect personal data such as first and last name, email address, physical address, phone number, financial or other information about you. We do not control the types of personal data that our customers may choose to collect or manage using the Subscription Service. We store our customers’ information on our service providers’ servers but process it as a processor under our customers’ instructions and in accordance with our Customer Terms of Service, which prohibit us from using the information except as necessary to provide and improve the Subscription Service and as required by law.

Our customers control and are responsible for correcting, deleting or updating the information they process using the Subscription Service and for complying with any regulations or laws that require providing notice, disclosure, and/or obtaining consent prior to transferring the personal data to Asora for processing purposes.

How We Use Your Information

We have set out below a description of the ways we typically process your personal data and the legal reasons we rely on to do so.

Purpose / activity	Type of Data	Grounds for processing
To allow you to create and manage a user account on our Website; to subscribe to our Services; to facilitate your payments for our Services; to receive and manage your feedback and survey responses; to receive and manage referrals; and to conduct profiling based on the preferences you choose in your user account to ensure you receive relevant content.	·       Identity and Contact Data ·       Profile Data ·       Transaction Data	Necessary for the performance of a contract with you or in order to take steps at your request prior to entering into a contract.   Necessary for our legitimate interests of enabling users to create and develop personalised accounts; to request and manage subscriptions; and for running and managing our Services.
To fulfil your subscription for our Services; to send you confirmations and updates relating to your orders; to manage cancellations in accordance with our Customer Terms of Service and other policies.	·       Identity and Contact Data ·       Profile Data ·       Transaction Data	Necessary for the performance of a contract with you.   Necessary to comply with a legal obligation.   Necessary for our legitimate interests of providing a good purchase and subscription experience.
To respond to queries submitted through the Website, telephone, social media or other means and to manage our relationship with you including: (i) notification of changes to our Services, Customer Terms of Service; Terms of Use; Cookie Policy, Privacy Notice or other policies; (ii) to operate customer feedback and survey facilities; (iii) managing complaints and disputes; (iv) administering your marketing and communication preferences; and (v) administering your data protection, privacy and other rights including to allow you to download personal data into a portable file.	·       Identity and Contact Data ·       Profile Data ·       Transaction Data ·       Technical Data ·       Usage Data ·       Marketing and Communications Data	Necessary for the performance of a contract with you or in order to take steps at your request prior to entering into a contract.   Necessary to comply with a legal obligation.   Necessary for our legitimate interests for responding to queries; attracting new users and customers; running our business and to develop new business; managing disputes or complaints; protecting our interests; keeping our records updated and to gauge customer satisfaction with our services and/or the products/services they purchase.
To administer and protect our business, products, services, networks, systems, the Website and data and property hosted on or made available through the Website including implementing and monitoring security measures and access authentication controls; troubleshooting; data and usage analysis; testing; system maintenance; user support; reporting; hosting of data; and to use the outcome of support services to improve and protect our services, networks and systems.  To anonymise personal data for statistical purposes.	·       Identity and Contact Data ·       Profile Data ·       Transaction Data ·       Technical Data ·       Usage Data ·       Marketing and Communications Data	Necessary for the performance of a contract with you.   Necessary to comply with a legal obligation.   Necessary for our legitimate interests for running our business; network and systems security; to identify and/or prevent unlawful activity or other misconduct; manage disputes and to protect our interests; collate statistical information to enhance our services and business; and in the context of a business reorganisation or group restructuring exercise.
To use data analytics and other technologies to monitor usage of the Website; measure the performance of the Website and to optimise the Website; improve our services, marketing strategy and output, user interactions, relationships and experiences. We may also process information collected when you browse and use our Website to set default options for you (such as language and country).	·       Technical Data ·       Usage Data	Necessary for our legitimate interests to obtain insights into how our services are used; improve the services; identify technical issues; fix technical issues; keep our Website updated and relevant; balance web traffic; develop and manage our business and strategies for growth and marketing.
To record phone calls we have with you to for training and quality purposes	·       Voice Data	Your consent
To manage your attendance at Asora events and to contact you about your attendance at Asora events.	·       Identity and Contact Data ·       Marketing and Communications Data	Necessary for the performance of a contract with you.   Necessary for our legitimate interests to in running events you attend and improving our events; attracting new users and customers; running our business and to develop new business.
If you post comments about Asora, tag us or post photos to our social media pages we may process this information to highlight our products, services and branding or to respond to you.	·       Identity and Contact Data ·       Profile Data	Necessary for our legitimate interests to develop our products and services and to gauge and react to customer sentiment which helps us improve our products and services.
To post testimonials about our Services on our Website and on social media platforms.	·       Customer Testimonial Data	Your consent

 

Marketing: We would like to send you information about our services, insights and offers, which may be of interest to you. Where we have your consent or it is in our legitimate interests to do so, we may do this by email, post and telephone.  We will only ask whether you would like us to send you marketing messages when you subscribe to our mailing list on our Website. You can unsubscribe at any time by using the ‘unsubscribe’ link in our marketing communications. You can also manage your personal data associated with your user account via the Settings page. If you tell us you do not want to receive marketing messages it might take a few days for all our systems to be updated to reflect this. Please note that opting out of marketing messages will not stop service communications, such as order confirmations or updates.

If you agree as part of our cookies framework, we will use certain technologies that allow us to see whether electronic newsletters you subscribed to through our Website have been viewed and read by you. As explained in the table above, we use this information for our legitimate interests to develop our products and services, direct market and grow our business.

Advertising: If you agree, we may use cookies and similar technologies that allow us to include ads for our products on other websites and apps, such as social media. The ads you see are based on information we hold about you or your previous use of our Website (e.g. your search history and the content you read on our Website) or on Asora adverts you have previously clicked on. For more information on our use of advertising technologies and cookies, please see our Cookie Policy.

How we share information we collect

Third Parties and Service Providers

We employ other third-parties and service providers to provide services on our behalf to our Website visitors, our customers, and users of our products and services. We may need to share your information with service providers to provide information about products or services to you. Examples may include removing repetitive information from prospect lists, analysing data or performing statistical analysis on your use of the Subscription Service or interactions on our Website, providing marketing assistance, processing credit card payments, supplementing the information you provide us in order to provide you with better service, developing and improving the products and services, and providing customer service or support. These service providers are prohibited from using your personal data except for these purposes, and they are required to maintain the confidentiality of your information. In all cases where we share your personal data with such third parties, we explicitly require them to acknowledge and adhere to our privacy and data protection policies and standards.

Additionally, we may share the personal data you provide to us when registering for an Asora event with third-party service providers in order to provide event information and improve your experience at the event or future Asora events.

Please note: No mobile information will be shared with third parties/affiliates for marketing/promotional purposes. All the above categories exclude text messaging originator opt-in data and consent; this information will not be shared with any third parties.

Corporate Events

If we (or our assets) are acquired by another company, whether by merger, acquisition, bankruptcy or otherwise, that company would receive all information gathered by Asora on the Website and the Subscription Service. In this event, you will be notified via email and/or a prominent notice on our Website, of any change in ownership, uses of your personal data, and choices you may have regarding your personal data.

Public and Government Authorities

Entities that regulate or have jurisdiction over us. We will disclose personal data in order to comply with any legal obligation, if we are ordered to do so by a court of competent jurisdiction, law enforcement, regulatory or administrative authorities.  We may also do so where we consider necessary in order to enforce our legal notices and other policies published on our Website and other agreements we may have with you, and/or to protect the rights, property and/or safety of our staff, users and others.

Corporate activity

If we acquire other businesses or merge with them it may be necessary for us to disclose your personal data to them and their professional and other advisors in the course of the transaction.

How We Transfer Data We Collect Internationally

In some circumstances, it may be necessary for us to process or transfer your personal data outside of the European Economic Area for the purposes described in this Privacy Notice.  In which case, we comply with Data Protection Laws when doing so, such as by ensuring that the country or territory where your personal data will be processed is deemed by the European Commission to have an adequate level of protection for personal data or by using a lawful safeguard, such as the European Commission’s standard contractual clauses.  For further information, including details of the specific legal mechanism used to ensure the lawful transfer of your personal data, please use the information provided in the Contact us section below.

 

How We Store and Secure Your Information

1. Data Storage and Security

We use a variety of security technologies and procedures to help protect your personal data from unauthorised access, use or disclosure. We secure the personal data you provide on computer servers in a controlled, secure environment, protected from unauthorised access, use or disclosure. All personal data is protected using appropriate physical, technical and organisational measures. For more on security at Asora, please see www.asora.com/security.

1. Retention of Personal Data

We retain your personal data for as long as you continue to subscribe to our Services and/or newsletter and for as long as we are required to keep it to ensure we meet our legal requirements. If you no longer wish to have a user account, you can delete you user account through the Account page of your user account. However, we may have a requirement to keep some of your personal data even after you have asked us to delete it. We will only keep what we need to, and only to make sure we can meet our legal and regulatory requirements, resolve disputes, prevent fraud and abuse, and/or enforce our Customer Terms of Service or Website Terms of Use.

Updating your personal data

It is important that the personal data we hold about you is accurate and current. Please keep us informed, using your user account Settings page, if any of your personal data changes during your relationship with us.  You can also contact us using the information provided in the Contact us section below to update your personal data.

Your legal rights

Under certain circumstances, you may have the following rights:

• You have the right to request a copy of your personal data we control.
• You can request to have any incomplete or inaccurate personal data we control corrected.
• 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 exercised your right to object to processing (see below), where we may have processed your personal data unlawfully or where we are required to erase your personal data to comply with local law.  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, following our receipt of your request.
• Object. You may object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and you wish to object to processing on this ground because you consider it impacts your fundamental rights and freedoms.  You also have the right to object where we process your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your personal data which override your rights and freedoms.
• Restriction. You can ask us to suspend the processing of your personal data in the following scenarios: (i) if you want us to establish its accuracy; (ii) where you consider our use of the personal data is unlawful but you do not want us to erase it; (iii) where you need us to hold the personal data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (iv) you have objected to our use of your personal data but we need to verify whether we have overriding legitimate grounds to use it.
• Data portability. You can ask us to provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. This right only applies to automated information which you initially provided consent for us to process or where we processed the personal data to perform a contract with you. If you have a user account, we provide a facility to download certain of the personal data we hold about you.
• Withdraw consent. If you provided your consent to the processing of your personal data for a specific purpose, you have the right to withdraw your consent for that specific processing at any time. Once we have received notification that you wish to withdraw your consent, we will take steps to ensure we no longer process your personal data for the purpose(s) you originally agreed to, unless we have another legitimate basis for doing so in law. Withdrawal of consent will not affect the lawfulness of processing based on consent before withdrawal.

Exercising your rights: In order to exercise one or more of your rights in respect of your personal data, please contact us in writing using the information provided in the Contact us section below.

Data Protection Commission (DPC): You have the right to make a complaint at any time to the Data Protection Commission, the Irish supervisory authority for data protection issues (www.dataprotection.ie). However, we would appreciate the chance to deal with your concerns before you contact the supervisory authority and therefore ask that you please contact us in the first instance.

Tips, warnings and THIRD-PARTY links

Our Website may include links to third party websites and other online assets.  Clicking on those links or enabling those connections may allow third parties to collect or share information about you. We do not control these third-party websites and are not responsible for their privacy notices.

We partner with Microsoft Clarity and Microsoft Advertising to capture how you use and interact with our website through behavioral metrics, heatmaps, and session replay to improve and market our products/services. Website usage data is captured using first and third-party cookies and other tracking technologies to determine the popularity of products/services and online activity. Additionally, we use this information for site optimization, fraud/security purposes, and advertising. For more information about how Microsoft collects and uses your data, visit the Microsoft Privacy Statement

When you leave our Website, we encourage you to read the privacy notices of every website you visit.

Please see our Cookie Policy for details of the cookies served by us and third parties and how to control these.

Care should be taken when accessing any third-party apps or websites which you may be able to access via our Website. If you find anything suspicious or encounter suspicious activity in relation to your use of our Website or the Service, please contact us immediately using the Contact us information below.

Contact Us

If you have any questions about this Privacy Notice or our privacy practices, or if you have a disability and need to access this notice in a different format, please contact us at dataprivacy@asora.com or by mail at:

FAO Data Protection Officer
Asora Technologies Ltd
20 Hatch Street Lower
Dublin 2
Ireland