At Grilla Capital Limited we take the issue of your Privacy very seriously. You share your data with us so that we can help stop fraud and scammers, and that is a privilege which we respect.
Please read the following carefully to understand our views and practices regarding your personal data and how we will treat it.
For the purposes of data protection legislation, the data controller is Grilla Capital Limited of Level 3 207 Regent Street, London, England, W1B 3HH and registered at the Information Commissioners Office in the UK with 13599533.
Our Data Protection Officer is Dan Winchester and he can be contacted on email@example.com
Who we are and what we do
We have developed Grilla Capital’s investigative capabilities and intelligence gathering within different forums and we are adept at finding new information sources, and translating the raw data into relevant reports, to suit the client’s purpose.
We collect the personal data of the following types of people to allow us to undertake our business;
We collect information about you to carry out our core business and ancillary activities.
Information you give to us or we collect about you.
This is information about you that you give us by filling in forms through our Grilla Capital website (our site) or anti-fraud solution portal (our portal) or by corresponding with us by phone, e-mail or otherwise. It includes information you provide when you register to use our site, to enter our database, subscribe to our services, attend our events, or complete a feedback survey, and when you report a problem with our site. It also includes any personal data you may provide to a third party on behalf of whom we process your data via our anti-fraud API (our API).
This is data relating to you as a user, for example the data you entered to create a dating profile. It might include:
This is data relating to the device you use or the network you connect from. It might include:
This is data relating to payments you made to a dating site. It might include:
This is stored in our main user database.
Information we collect about you when you visit our website.
With regard to each of your visits to our site or portal we will collect information such as technical information, including the Internet protocol (IP) address used to connect your computer to the Internet, your login information if applicable, browser type and version, browser plug-in types and versions, operating system and platform.
Purposes of the processing and the legal basis for the processing
We use information held about you in the following ways:
To carry out our obligations arising from any contracts we intend to enter into or have entered into between you and us and to provide you with the information, products and services that you request from us in terms of anti-fraud and protection from fraudsters and scammers.
The core service we offer to our clients is the automated review of users of dating sites, consisting of the following:
Our legal basis for the processing of personal data is our legitimate business interests, described in more detail below, although we will also rely on contract, legal obligation and consent for specific uses of data.
Our Legitimate Business Interests
Our legitimate interests in collecting and retaining your personal data is described below:
As an anti-fraud prevention and detection solution our legitimate interest includes for the purposes strictly necessary for the prevention of Fraud.
In particular we rely on our legitimate business interest of the prevention of fraud to retain data on alleged scammers who arise through our shared database.
This includes retaining such information on an ongoing basis so that we can prevent other companies from being attacked in the future.
Fulfil a legal obligation
We rely on the fulfilment of a legal obligation if we are to disclose any data relating to fraudsters or scammers as part for a criminal or civil investigation by the relevant authorities as required by the law.
We rely on your consent to retain your data and to share indicators which may have identified a potential scammer through our shared blacklist.
Other Uses we will make of your data:
We will use this information:
Disclosure of your information inside and outside of the EEA
Information may be accessed by users of the Grilla Capital portal who have travelled or reside outside of the EEA.
As a global service we may also transfer data outside of the EEA to service providers located in such areas, in such circumstances we will seek to ensure that appropriate safeguards are put in place, and perform the necessary due diligence.
Selected third parties may include:
We will disclose your personal information to third parties:
The lawful basis for the third party processing will include:
Where we store and process your personal data
The data that we collect from you will be stored in servers within the EEA however it may be transferred to, and accessed, in destinations outside the European Economic Area (”EEA”).
It may be transferred to third parties outside of the EEA for the purpose of fulfilling our anti-fraud detection and prevention services. It may also be processed by staff operating outside the EEA who work for us or for one of our suppliers. This includes staff engaged in, among other things, our anti-fraud services and the provision of support services. By submitting your personal data and that of your users you agree to this transfer, storing or processing. Grilla Capital Limited will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this privacy notice.
All information you provide to us is stored on our secure servers. Any payment transactions will be encrypted using SSL technology. Where we have given you (or where you have chosen) a password which enables you to access certain parts of our site, you are responsible for keeping this password confidential. We ask you not to share a password with anyone.
Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted to our site; any transmission is at your own risk. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorized access.
Retention of your data
We understand our legal duty to retain accurate data and only retain personal data for as long as we need it for our legitimate business interests Accordingly, we regularly review our use of data with the aim of removing data that we no longer have a legitimate business interest in maintaining.
We segregate our data so that we keep different types of data for different time periods. The criteria we use to determine whether we should retain your personal data includes:
In terms of the retention of personal data relating to alleged scammers or fraudsters, Grilla Capital maintains a ‘blacklist’ of users who have been banned from accounts of their clients. In order to fulfil our legitimate interests and to seek the prevention of fraud in the dating industry then we may retain this data to help us to identify these users and prevent them targeting other dating sites.
You have the right to ask us not to process your personal data for marketing purposes. We will usually inform you (before collecting your data) if we intend to use your data for such purposes or if we intend to disclose your information to any third party for such purposes and we will collect express consent from you if legally required prior to using your personal data for marketing purposes.
The GDPR provides both you and your end users the following rights. To:
Protecting your information
Grilla Capital Limited are dedicated to keeping your data safe as such we have the following policies in place to help us do this.
We have a Data Breach Policy to help guide us in the event of a data loss or data breach, a copy of this is available on request.
To help guide us and ensure we manage data safety, we also have a data security policy.
At Grilla Capital Limited we require all passwords to be changed at regular intervals and to be of minimum complexities. We would ask that if you are a user of our portal that you keep your password safe and report any loss/breach of your passwords to us as soon as practically possible.
Access to information
The Data Protection Act 1998 and the GDPR give you the right to access information held about you or your end user.
If you would like to exercise any of the above rights then you should contact Melmac Solutions Limited and we will seek to work with you to provide any information required.
A subject access request should be submitted to Dan Winchester, and we will seek to get you the necessary information within 72 hours.
Changes to our privacy notice
Any changes we make to our privacy notice in the future will be posted on this page and, where appropriate, notified to you by e-mail. Please check back frequently to see any updates or changes to our privacy notice.
Questions, comments and requests regarding this privacy notice are welcome and should be addressed to Dan Winchester who can be contacted at firstname.lastname@example.org