Privacy Policy

This Privacy Policy aims to give you information as to how FSB collects and processes your personal data through your use of this website, including any data you may provide through this 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 any other policy 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. This Privacy Policy supplements other notices and privacy policies and is not intended to override them.

FSB is made up of the following legal entities: FSB Technology (UK) Limited, a company incorporated in England and Wales under company number 06401555; FSB Technology (IOM) Limited, a company incorporated in the Isle of Man under company number 018400; FSB Technology (Malta) Limited, a company incorporated in Malta under company number 95800 ;FSB Technology (USA) Inc, a company incorporated in the State of Delaware, USA, under company number 85-3385640; together the “FSB Group”.

This Privacy Policy is issued on behalf of the FSB Group so when we mention “we”, “us” or “our” in this Privacy Policy, we are referring to the relevant company in the FSB Group responsible for processing your data. FSB Technology (UK) Limited is the controller and responsible for this website. We have appointed a data protection officer (DPO) who is responsible for overseeing questions in relation to this Privacy Policy. If you have any questions about this Privacy Policy, including submitting a subject access request, please contact us at [email protected] 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 ( We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.

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 this website, we encourage you to read the privacy policy of every website you visit. The data we collect about your personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where all personally identifiable information has been removed. When you use this website or when we interact with you, the personal data we collect may include (but is not limited to): contact information, such as your name, job title, postal address, telephone number, mobile phone number, fax number and email address; professional information, such as job titles, previous roles, and professional experience and qualifications; profile and usage data, including passwords to this website or password-protected platforms or services; your preferences in receiving marketing information from us; your communication preferences; information about how you use this website.

To learn more about our use of cookies or similar technology, please check our Cookie Policy; and physical access data, relating to details of your visits to our premises. If you connect to us from a social network, such as LinkedIn or Facebook, we will collect personal information from the social network in accordance with your privacy settings on that social network. The connected social network may provide us with information such as your name, profile picture, network, gender, username, user ID, age or age range, language, country, friends list, follower list, and any other information you have agreed it can share or that the social network provides to us. We do not collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sexual orientation, information about your health, and genetic and biometric data). Where we are required to collect personal data in accordance with applicable law, or 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 provide you with our services. 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.

We use different methods to collect data from and about you which may include the following: when you make an inquiry about our services or otherwise interact on this website or via our social media pages; when you attend an event with us or a third party we are working with or sign up to receive publications from us; when you or your organisation provide services to us or seek to provide such services; when you apply to join us or express an interest in joining us; when you interact with us by telephone, email and other electronic communication, including the use of virtual conferencing facilities; from third parties, such as government agencies, a credit reporting agency, information service providers, or from publicly available records; from social media sites; by making enquiries from your organisation, other organisations with whom you have dealings such as former employers and educational institutions, or from third-party sources; automatically in the ways we describe below.

As you interact with this website, we will automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies, server logs and other similar technologies. We may also receive Technical Data about you if you visit other websites employing our cookies.
Please see our cookie policy for further details. Technical Data may be obtained from the following parties: analytics providers; advertising networks; and search information providers.

We will only use your personal data when permitted to do so by applicable law. Most commonly, we will use your personal data in the following circumstances: to provide services as instructed or requested by you or your organisation; to manage and administer you or your organisation's relationship with us, including billing and collection, marketing and support services, and taking other steps linked to the performance of our business relationship; to comply with our legal and regulatory obligations such as for anti-money laundering, financial and credit checks, audit requirements, fraud and crime prevention and detection, and record keeping. This may include automated checks of personal data you or your organisation provide about your identity against relevant databases, and contacting you to confirm your identity, or making records of our communications with you for compliance purposes; to analyse and improve our services and promote our business, such as by sending you publications and invites; to protect the security of and managing access to our premises, IT and communication systems, online platforms, websites and other systems, preventing and detecting security threats, fraud or other criminal or malicious activities; for insurance purposes; where applicable, and only as permitted by applicable law with respect to the specific category of personal data, to assess your application to join us; to comply with our legal and regulatory obligations and requests anywhere in the world, including reporting to and/or being audited by national and international regulatory bodies; to comply with court orders and to exercise and/or defend our legal rights; to help us manage health and safety risks to employees and visitors to our offices; to personalise and improve the quality of our communications and interaction with you; and for any other purposes related and/or ancillary to any of the above, or any other purposes for which your personal data was provided to us.

We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising. We will only provide you with marketing-related information after you have, where legally required to do so, opted-in to receive those communications. If you have not opted-in to our providing you with information promoting our business, we will use your personal information for our legitimate interests, provided that those interests are not overridden by your interests or fundamental rights and freedoms. We will give you the opportunity to opt out at any time. We will get your express opt-in consent before we share your personal data with any third party for marketing purposes. You can ask us or third parties to stop sending you marketing messages at any time by following the opt-out links on any marketing message sent to you or by contacting us at any time.

You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of this website may become inaccessible or not function properly. For more information about the cookies we use, please see our cookie policy.

We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us. 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 knowledge or consent, in compliance with the above rules, where this is required or permitted by applicable law. We keep your information confidential, but may disclose it to our personnel, other companies within the FSB Group, suppliers or subcontractors insofar as it is reasonably necessary for the purposes set out in this Privacy Policy. We carry out checks to ensure that the companies we work with will provide the same level of safeguards to protect your data as we do, and we put contractual measures in place to reinforce those obligations. We require all third parties to respect the security of your personal data and to treat it in accordance with applicable 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 share your personal data within the FSB Group; the personal information we collect may therefore be collected, transferred to and stored in countries outside of the jurisdiction you are in, or from the location of the FSB office you provide the information to, for the purposes specified in this Privacy Policy. Any international transfers of your personal data will be made pursuant to appropriate safeguards in accordance with applicable laws and regulations, such as standard data protection clauses adopted by the European Commission.

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.

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. In some circumstances you can ask us to delete your data: see section 9 below for further information. In some circumstances we will anonymise 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.
Under certain circumstances, you have rights under data protection laws in relation to your personal data. You have the right to:

- 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.

- 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, although 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. Please 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 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 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. Please 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 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 our Data Protection Officer.

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.
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.

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.

We will take all reasonable technical and organisational precautions to prevent the loss or misuse of your personal information. Please be aware that, although we endeavour to provide reasonable security for information we process and maintain, no security system can prevent all potential security breaches.

We keep our Privacy Policy under regular review. This version was last updated in November 2022. We reserve the right to update and change this Privacy Policy from time to time in order to reflect any changes to the way in which we process your personal data or to comply with any legal or regulatory requirements. We will notify you of any significant changes to this policy by email or by way notice on this website.

Re the Privacy Policy, then the only other thing to highlight is what to do should a user wish to exercise one of the rights highlighted within it e.g. their right of access or right of erasure. Take the 'right of access' one, if we have stored someone's personal information via the site and they made that request, you have 30 days to present it to them - for end-users, we created a template report and kept it in Custodian so if a customer asked, we could run it instantly. If the site had collected a variety of personal data about them, where is that data stored and how would you/we then present that to them? Let me know if you want to discuss that side of it. We may also need a mechanism to handle right of erasure requests - again, if we'd collected and stored anyone's personal data via the site, they made the request and we have no legal or other reason to justify continuing to process that data, we need to be able to erase it. When that data is in our end-user database we developed a mechanism to do that, but for data captured by the corporate site again I don't know where it's kept and how we would erase it at the present time.

FSB respects your privacy and is committed to protecting your personal data. This Privacy Policy will inform you as to how we look after your personal data when you visit this website (regardless of where you visit it from) and tells you about your privacy rights and how the law protects you.