Privacy policy

Effective From: 15th September 2022

1. Introduction

This Privacy Policy sets out how we, Hpillars Limited (trading as Telleroo), whose registered office is at 86-90 Paul Street, London, EC2A 4NE collect and process your personal data and explains your rights in relation to your personal data. If you have any questions about this Privacy Policy or wish to exercise any of your rights in relation to your personal data, you can contact us at this address or by email to support@telleroo.com.

Our preferred contact method is email. This Privacy Policy affects your legal rights and obligations so please read it carefully. If you do not agree to be bound by this Privacy Policy, please do not provide your personal data to us or request that your employer does not do so. We may update this Privacy Policy from time to time at our discretion and in particular to reflect any changes in applicable laws. If we do so, and the changes substantially affect your rights or obligations, we shall notify you if we have your email address. Otherwise, you are responsible for regularly reviewing this Privacy Policy so that you are aware of any changes to it.


We may need to collect your personal data because you provide it to us, or because your employer is our client and wishes to set up an account for you to access our platform. In such circumstances, we are the controller of your personal data. Or we may receive your personal data within our platform because one of our clients has uploaded your details within their account on our platform. In such circumstances, we are the processor of your personal data, and we shall only process your personal data in accordance with the client’s instructions.


2. What personal data do we collect and from whom?

By personal data we mean identifiable information about you, such as your name, email address, gender, date of birth, mobile and home telephone number, and your IP address.

Your Company

What we collect as a data controller

Shareholders

  • Full Name
  • Date of Birth
  • Nationality
  • Photographic ID
  • Proof of Residential Address
  • Business Affiliations
  • Reputation
  • Political Association or Public Functions
  • Sanctions checks

Directors

  • Full Name
  • Date of Birth
  • Nationality
  • Business Affiliations
  • Reputation
  • Political Association or Public Functions
  • Sanctions checks

Authorised Person

  • Full Name
  • Date of Birth
  • Nationality
  • Photographic ID
  • Proof of Residential Address
  • Email Address
  • Business Affiliations
  • Phone Number
  • Reputation
  • Political Association or Public Functions
  • Sanctions checks

Telleroo Application Users

  • IP Address
  • Email Address
  • Business Affiliations
  • Phone Number


What we collect as a data controller

Payees

  • Full Name
  • Business Affiliations
  • Payslip or Payroll Report
  • Invoices
  • Bank Account
  • Sanctions Checks

2.1 Data you provide to us

Most of the personal information we process is provided to us directly by you for one of the following reasons:

  • Using our website
  • Using our application
  • Applying for a job with Telleroo
  • Providing services to us
  • Subscribing to receive product update e-mails from us
  • Contacting us including with queries, comments or complaints

2.2 Data we automatically collect about you

When you use our website or application, we automatically collect and store information about your device and your activities. This information could include:

  • Technical information about your device such as type of device, web browser or operating system
  • Your preferences and settings such as time zone and language
  • How long you used the website / app and which services and features you used

Some of this information is collected using cookies and similar tracking technologies. If you want to find out more about the types of cookies we use, why, and how you can control them, please see our Cookies Policy.

2.3 Data we recieve from others

As set out above, your employer may from time to time provide personal data to us that relates to you so that you can create an account on our platform, or one of our clients may upload personal data from our clients when they upload that data into our platform.

We may also receive personal data about you from our payment providers and our website security service partners, particularly if there is any misuse of the platform including the introduction of viruses or other malicious software.

If you apply for a job with us, we may receive personal data about you from your previous employer or other references.

We also receive personal information indirectly, from the following sources in the following scenarios:

  • Media Articles mentioning your name
  • Political Associations lists
  • Sanctions lists

We use the information to comply with Anti-Money Laundering Regulations and Sanctions Regulations. 

3. Lawful use of your personal data

Under the UK General Data Protection Regulation (UK GDPR), the lawful bases we rely on for processing this information are:

  • Your consent. We rely on your consent when you sign up. You can remove your consent at any time. You can do this by contacting support@telleroo.com
  • We have a contractual obligation to provide you services
  • We have a legal obligation to comply with Anti-Money Laundering Regulation
  • We have legitimate interests such as fraud prevention, information security, identifying possible criminal acts

3.1 Data Provided by your Employer who uses Telleroo

We may receive your personal data because you are employed at a company that uses Telleroo as its payment platform. We will process your personal data to perform any contract we have entered with your employer or in relation to any steps we take at the request of your employer prior to entering a contract. Typically, this includes creating a recipient profile for your payment details so we can send payments to you when requested by your employer.

3.2 Using data, you uploaded or entered into the Telleroo application.

If we have received your personal data because of your Employer/You uploaded it to our platform, we shall process that personal data for our legitimate interests and on the instructions of our client.

3.3 Using data for our legitmate interests

We may also use your personal data for our legitimate interests, including dealing with any customer services you require, for regulatory and legal purposes (for example anti-money laundering and fraud prevention purposes), for audit purposes and to contact you about changes to this Privacy Policy.

3.4 Using data to provide Produce Update E-Mails

You may consent to receive product update email messages from us. You can choose to no longer receive marketing emails from us by contacting us or clicking unsubscribe in the email. Please note that it may take us a few days to update our records to reflect your request.

If you ask us to remove you from you from our product update mailing list, we shall keep a record of your name and email address to ensure that we do not send to you anymore product update information. We shall also continue to send you information relating to your use of our services if your employer has an account with us and added you as a platform user.

3.5 Using data to improve our service

We also analyse data usage of our platform, and use that information to improve our services and platform for our legitimate interests. Please see our Cookies Policy for detailed information.

3.6 Using data to process Job Applications

If you apply for a job with us, we shall use the personal data you provide to process your application and respond to you according.

4. Who do we share your data with?

To comply with our legal obligations, under certain circumstances we may have to disclose your personal data under applicable laws and/or regulations, for example, as part of anti-money laundering regulations, fraud prevention or to protect a third party's rights, property, or safety.

We may share your information with our Principle Firm Moorwand Ltd and Clearbank Ltd where your funds are safeguarded. We may also share your personal data in connection with, or during negotiations of, any merger, sale of assets, consolidation or restructuring, financing, or acquisition of all or a portion of our business by or into another company in which case we will send a notice to our users.

We may share your personal data with any service providers, sub-contractors and agents that we may appoint to perform functions on our behalf and in accordance with our instructions, including payment providers, IT service providers, accountants, auditors and lawyers. We shall provide our service providers, sub-contractors and agents only with such of your personal data as they need to provide the service for us and if we stop using their services, we shall request that they delete your personal data or make it anonymous within their systems.

All personal data that you provide to us must be true, complete and accurate. At our request, you shall promptly provide evidence of your identity. If you provide us with inaccurate or false data, and we suspect or identify fraud, we will record this, and we may also report this to the Legal Enforcement Agencies. When you contact us by email or post, we may keep a record of the correspondence and we may also record any telephone call we have with you.

5. Your Data Protection rights

Under data protection law, you have rights including:

Your right of access - You have the right to ask us for copies of your personal information.

Your right to rectification - You have the right to ask us to rectify personal information you think is inaccurate. You also have the right to ask us to complete information you think is incomplete.

Your right to erasure - You have the right to ask us to erase your personal information in certain circumstances.

Your right to restriction of processing - You have the right to ask us to restrict the processing of your personal information in certain circumstances.

Your right to object to processing - You have the right to object to the processing of your personal information in certain circumstances.

Your right to data portability - You have the right to ask that we transfer the personal information you gave us to another organisation, or to you, in certain circumstances.

You are not required to pay any charge for exercising your rights. If you make a request, we have one month to respond to you.

Please contact us at support@telleroo.com if you wish to make a request.

6. Where we hold and process your personal data

Your information is securely stored.

We keep the personal and Transactional data for the period of 5 years. We will then dispose of your information by deleting your data. 

Some or all of your personal data may be stored or transferred outside of the UK or European Economic Area (the EEA ), for example, if our email server is located in a country outside the EEA or if any of our service providers are based outside of the EEA

Where your personal data is transferred outside the UK or EEA, it will only be transferred to countries that have been identified as providing adequate protection for EEA data or to a third party where we have approved transfer mechanisms in place to protect your personal data;

Telleroo uses IDTA ( International Data Transfer Agreement) or the Addendum as a transfer tool to comply with Article 46 of the UK GDPR when making restricted transfers.


Should you require further information on the specific mechanism, please contact us on Please contact us on support@tellero.com 

7. Analytics

Advertising

Facebook Audience Network, Google Ads and Microsoft Ads
Personal Data: Cookies; unique device identifiers for advertising (Google Advertiser ID or IDFA, for example); Usage Data

Analytics

Google Analytics, Hotjar Form Analysis & Conversion Funnels, Google Ads conversion tracking, FullStory and Facebook Ads conversion tracking (Facebook pixel)
Personal Data: Cookies; Usage Data

Contacting the User

Contact form
Personal Data: Company name; Accountancy name; Email address; First name; Last name; Phone Number

Remarketing and behavioural targeting

Facebook Remarketing and LinkedIn Retargeting
Personal Data: Cookies; Usage Data
Facebook Custom Audience and LinkedIn matched Audiences
Personal Data: Cookies; email address

Displaying content from external platforms

Wistia widget and YouTube video widget
Personal Data: Cookies; Usage Data

Registration and authentication‍

Direct registration
Personal Data: company name; company directors, company shareholders, director identification, email address; first name; last name; phone number; User ID; website

User database management‍

Intercom and Hubspot
Personal Data: Cookies; email address; Usage Data; various types of Data as specified in the privacy policy of the service

8. How to complain

If you have any concerns about our use of your personal information, you can make a complaint to us at complaints@telleroo.com

You can also complain to the ICO if you are unhappy with how we have used your data.

The ICO’s address:            

Information Commissioner’s Office

Wycliffe House

Water Lane

Wilmslow

Cheshire

SK9 5AF

Helpline number: 0303 123 1113

ICO website: https://www.ico.org.uk

9. How to Contact Us

You can contact us with any questions or comments about your Personal Data, this Policy or any other privacy-related enquiries by emailing support@telleroo.com

Company Name: HPillars Limited, trading as Telleroo

Address: 86-90 Paul Street, London, EC2A 4NE

Phone Number: 0203 6334 810