Privacy

Two roles, and which one applies

For everything inside an institution's book, being its customers, their payments and the documents behind them, the institution is the controller and Pruvyo is the processor. We hold that data on its instruction and nothing else. Those obligations are in the data processing agreement.

For the people who work at that institution, and for anybody who fills in the application form on this site, Pruvyo is the controller. The rest of this page is about them.

Who we are, and how to reach us

Pruvyo is operated by Pruvyo Limited, a company registered in England and Wales, which is the controller for the processing described below.

Anything about this notice, or any request about your own data, goes to info@pruvyo.com and is answered by a person.

Pruvyo is a product for regulated institutions. It is not offered to consumers and is not directed at children.

Which law applies

The company is established in the United Kingdom, so the UK GDPR and the Data Protection Act 2018 govern what it does. Because the service is offered to institutions in the European Union, the EU GDPR applies to that processing as well.

Where the two say the same thing, which is almost everywhere, this notice says it once.

What we hold as controller

• Your name, work email address and the role your institution gave you.
• What you did in the system: what you looked at, what you decided, what you approved, and when. This is an audit trail, and it exists because anti money laundering supervision requires one.
• Technical records needed to run the service securely, including sign-in events.
• If you applied for access: what you wrote in the form, being your name, your institution, your contact details and what you told us you run.

Where it came from

If you work at an institution using Pruvyo, we did not collect your details from you. Your institution gave them to us when it created your account, and everything else is a record of what you did in the system afterwards.

If you applied for access, you gave it to us yourself.

Why we hold it, and on what basis

• To provide the service to your institution and to keep your account working: performance of a contract.
• To keep the audit trail your institution's supervisor expects: our legitimate interest in operating a supervised product, and your institution's legal obligation.
• To keep the service secure and to investigate misuse: our legitimate interest in protecting it and everybody on it.
• To answer an application for access: our legitimate interest in replying to somebody who asked us to.
• Giving us your details is not optional if you are to have an account, because an account nobody can be held to is no use to a compliance function.

What we never do with it

We do not sell it, we do not share it with other customers, we do not use it to train any model, and we do not profile anybody or take automated decisions that produce legal effects about them.

Where it is held

In the European Union. The database and its file storage are hosted in Ireland and the application runs in Dublin.

The company that operates Pruvyo is established in the United Kingdom, so the people who support the service reach that data from there. The European Commission has decided that the United Kingdom offers an adequate level of protection, and that decision is what those transfers rest on. If it lapses, they move to standard contractual clauses and you will be told.

The single exception is the counter on these public pages described below, part of which runs outside the European Economic Area under standard contractual clauses. Nothing from an institution's book is involved.

Who else touches it

Only the suppliers needed to run the service: hosting and file storage, platform email, and a service used to read documents. Each is bound by obligations no weaker than ours, and each processes inside the European Union.

They are named to the institution that holds the account, before it signs and whenever the list changes, under the data processing agreement. They are not published here, because who a firm runs on is not a fact a stranger needs.

We will disclose data where the law requires it or a court orders it, and we will tell you unless we are forbidden from doing so.

How long

Account and audit records are kept while the account exists and afterwards for as long as the institution's own retention obligations run, which for anti money laundering records is commonly five years.

An application for access that goes nowhere is kept for twelve months and then deleted.

Retention is enforced by a scheduled job rather than by anybody remembering to run one.

How it is kept safe

Data is encrypted in transit and at rest, credentials you give us for your own providers are encrypted before storage and are read only, and authority is enforced in the database rather than in the interface, so a second signature cannot be skipped by a crafted request. The security page sets out the rest.

Your rights

You can ask for a copy of what we hold about you, ask us to correct it, ask us to delete it, ask us to restrict what we do with it, object to processing we do on the basis of legitimate interest, and ask for it in a portable form. Exercising any of them is free and we will answer within one month.

Some of these give way to law: an audit record that anti money laundering rules require cannot be deleted on request, and we will say so plainly rather than quietly refuse.

If your data sits inside an institution's book, that institution is the controller and the request goes to them. We help them answer it.

Cookies, and the counter on these pages

These public pages set no cookie. They do carry a counter that tells us how many people read them: it stores nothing in your browser, sets nothing, identifies nobody, and produces visitor numbers rather than profiles. That is the category the law does not require consent for, which is why you are not being asked for any.

Inside the workspace there are two cookies, both strictly necessary: a session cookie so the application knows who you are between one page and the next, and a preference cookie holding which reporting entity you last had open. There is no analytics, no tag manager and no advertising pixel anywhere in the workspace.

If anything that follows you across the internet is ever added to this site, the banner asking you about it arrives in the same change as the thing itself, refusing is as easy as accepting, and nothing loads until you have answered.

Complaining

Come to us first and you will get an answer from a person.

If it does not satisfy you, you can complain to the Information Commissioner's Office, which is the United Kingdom's data protection authority. If you are in the European Union you may instead complain to the supervisory authority where you live or work.

Changes

If this notice changes in a way that matters, we will tell the institutions using Pruvyo rather than quietly change the page. The date at the foot says when it last changed.