Privacy Notice for Thallo Ltd
This notice tells you how we look after your personal data when you visit our website at https://www.thallo.io/ (Website) and access our Thallo platform (Platform). It sets out what information we collect about you, what we use it for, whom we share it with, explains your rights and what to do if you have any concerns about your personal data. We may sometimes need to update this notice, to reflect any changes to the way our Website and/or Platform are provided or to comply with new legal requirements. We will notify you of any important changes before they take effect.
Last updated: [04/011/22]
Who we are and other important information
We are Thallo Limited, a company registered in England and Wales with company number 13578541 whose registered address is 4 Capricorn Centre, Cranes Farm Road, Basildon, Essex, SS14 3JJ (we/us/our).
For all visitors to our Website and the users of our Platform, we are the controller of your information (which means we decide what information we collect and how it is used). [We are registered with the Information Commissioner’s Office (ICO), the England and Wales regulator for data protection matters, under number ZB380902.
If you have any questions about this privacy notice or the way that we use information, please contact us at firstname.lastname@example.org.
The information we collect about you
Personal data means any information which does (or could be used to) identify a living person. We have grouped together the types of personal data that we may collect from you below:
Identity Data – first name and last name;
Contact Data – email address;
Communication Data – any correspondence between you and us;
Financial Data – crypto wallet addresses, transaction records, and/or other payment method used on our Website;
Technical Data – internet protocol (IP) address, browser type and version, time zone setting and generic location, browser plug-in types and versions, operating system and platforms on the devices you use to access our Website and/or Platform;
Usage Data – information about your visit to our Website and/or Platform including the clickstream to, through and from our site, information you viewed or searched on our Website and/or Platform, page response times, download errors, length of visits, page interaction;
If you contact us directly, we may receive additional information about you such as your name, email address, phone number, the contents of the message and/or attachments you may send us, and any other information you may choose to provide.
Feedback – information and responses you provide about our Website and/or Platform; and
Marketing Data – your marketing preferences data, for example if you wish to unsubscribe from receiving emails from us. If at any time you wish to unsubscribe from emails you receive from us, you may click the unsubscribe link in the footer of the email.
When you register for an Account, we may ask for your contact information, including items such as name, company name, address, email address, and telephone number.
How we use your information
We are required to identify a legal justification (also known as a lawful basis) for collecting and using your personal data. There are six legal justifications which organisations can rely on. The most relevant of these to us are where we use your personal data to:
fulfil our contract with you;
pursue our legitimate interests (our justifiable business aims) but only if those interests are not outweighed by your other rights and freedoms (e.g. your right to privacy);
comply with a legal obligation that we have; and
do something for which you have given your consent.
The table below sets out the lawful basis we rely on when we use your personal data. If we intend to use your personal data for a new reason that is not listed in the table, we will update our privacy notice.
|Providing our Platform to you (as set out in our
Thallo Platform Terms and Conditions)
|Contract (when you access our Platform)|
|Keeping you informed about our Platform||Contract (when you access our Platform)|
|Asking you to provide feedback about our Website
|Consent (the feedback is always optional)|
|Providing insight on how our Website and/or Platform are being used||Legitimate interest (necessary to improve and
optimise our Website and/or Platform)
|Administering and protecting our Website and/or
|Legitimate interests (necessary to provide our
Website and/or Platform, monitor and improve
Website and Platform security and prevent fraud)
|Handling requests for technical support and other
|Legitimate interests (necessary to provide our
Website and/or Platform to you and ensure the
proper functioning of our Website and/or Platform)
|Defending against legal claims||Legitimate interests (to protect our business and
defend ourselves against legal claims)
|Notifying you about changes to our privacy notice||Legal obligation (necessary to comply with our
obligations under data protection law)
We may anonymise the personal data we collect (so it can no longer identify you) and then combine it with other anonymous information so it becomes aggregated data. Data protection law does not govern the use of aggregated data and the various rights described below do not apply to it.
Who we share your information with
We share (or may share) your personal data with:Our personnel: our employees (or other types of workers) who have contracts containing confidentiality and data protection obligations;
Our supply chain: other organisations that help us provide our Website and/or Platform. We ensure these organisations only have access to the information required to provide the support we use them for and have a contract with them that contains confidentiality and data protection obligations;
Regulatory authorities: such as the ICO;
Strategic Partners: such as platform providers;
Our professional advisers: such as our accountants or legal advisors where we require specialist advice to help us conduct our business; and
Any actual or potential buyer of our business.
If we were asked to provide personal data in response to a court order or legal request (e.g. from the police), we would seek legal advice before disclosing any information and carefully consider the impact on your rights when providing a response.
Where your information is located or transferred to
We will only transfer information outside of England and Wales where we have a valid legal mechanism in place (to make sure your personal data is guaranteed a level of protection, regardless of where in the world it is located).
If you access our Website and/or use our Platform whilst abroad then your personal data may be stored on servers located in the same country as you are.
How we keep your information safe
We have implemented security measures to prevent your personal data from being accidentally or illegally lost, used or accessed by those who do not have permission. These measures include:access controls and user authentication;
internal IT and network security;
regular testing and review of our security measures;
staff policies and training;
incident and breach reporting processes; and
business continuity and disaster recovery processes.
If there is an incident which has affected your personal data and we are the controller, we will notify the regulator and keep you informed (where required under data protection law).
Where we act as the processor (which means we only collect and process information on the instructions of a controller) for the affected personal data, we notify the controller and support them with investigating and responding to the incident.
If you notice any unusual activity on our Website and/or Platform, please contact us at email@example.com.
How long we keep your information
Where we act as the controller, we will only retain your personal data for as long as necessary to fulfil the purposes we collected it for.
To decide how long to keep personal data (also known as its retention period), we consider the volume, nature, and sensitivity of the personal data, the potential risk of harm to you if an incident were to happen, whether we require the personal data to achieve the purposes we have identified or whether we can achieve those purposes through other means (e.g. by using aggregated data instead), and any applicable legal requirements.
We may keep Identity Data, Contact Data and certain Communications Data for up to six years after the end of our contractual relationship with you. If you browse our Website and/or Platform, we keep personal data collected through our analytics tools for only for as long as necessary to fulfil the purposes we collected it for. If you have asked for information from us or you have subscribed to our mailing list, we keep your details until you ask us to stop contacting you.
Your legal rights
You have specific legal rights in relation to your personal data.
It is usually free to exercise your rights and we aim to respond within one month (although we may ask you if we can extend this deadline up to a maximum of two months if your request is particularly complex or we receive multiple requests at once).
We can decide not to take any action in relation to a request where we have been unable to confirm your identity (this is one of our security processes to make sure we keep information safe) or if we feel the request is unfounded or excessive. We may charge a fee where we decide to proceed with a request that we believe is unfounded or excessive. If this happens, we will always inform you in writing.
We do not respond directly to requests which relate to personal data for which we act as the processor. In this situation, we forward your request to the relevant controller and await their instruction before we take any action.
Your legal rights in respect of your personal data include:Access: You must be told if your personal data is being used and you can ask for a copy of your personal data as well as information about how we are using it;
Correction: You can ask us to correct your personal data if it is inaccurate or incomplete;
Deletion: You can ask us to delete or remove your personal data if there is no good reason for us to continuing holding it or if you have asked us to stop using it. If we think there is a good reason to keep the information you have asked us to delete, we will let you know and explain our decision;
Restriction: You can ask us to restrict how we use your personal data;
Objection: You can object to us using your personal data. If we think there is a good reason for us to keep using the information, we will let you know and explain our decision;
Portability: You can ask us to send you an electronic copy of your personal data; and
Complaints: If you are unhappy with the way we collect and use your personal data, you can complain to the ICO or another relevant supervisory body.
If you wish to make any of the right requests listed above, you can reach us at firstname.lastname@example.org.
Cookies are not harmful to your devices (unlike a virus or malicious code), but some individuals prefer not to share their information (for example, to avoid targeted advertising).
track how visitors use our Website and/or Platform;
record whether you have seen specific messages we display on our Website;
keep you signed into our Website and/or Platform; and
capture and analyse information such as number of your views and shares.
You can choose to decline cookies but if you turn off necessary cookies, some pages and functions on our Website and/or Platform may not work properly. You can also manage cookies through your browser settings or device settings (your user manual should contain additional information).
You can also delete cookies directly with the relevant third parties (for example, you can disable Google Analytics on their website).