Privacy Policy

Please read this privacy policy carefully as it contains important information on who we are, how and why we collect, store, use, and share your information. It also explains your rights in relation to your information and how to contact us or supervisory authorities in the event you have a complaint.

We collect, use and are responsible for certain information about you. When we do so we are subject to various laws in the United States and the General Data Protection Regulation which applies across the European Union (including in the United Kingdom), and we are responsible as “controller” of personal information for the purposes of those laws.

1. Key Terms. It would be helpful to start by explaining some key terms used in this policy:

2. Personal Information We Collect About You. We may collect and use the following personal information that identifies, relates to, describes, is reasonable capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household:

This personal information is required to provide products and services to you. If you do not provide personal information when we ask for, it may delay or prevent us from providing products and services to you.

3. How Your Personal Information is Collected. We collect most of this personal information directly from you—in person, by telephone, email and/or via our website. However, we may also collect information:

• From publicly accessible sources (e.g., property records);
• Directly from a third party (e.g., sanctions screening providers, credit reporting agencies, or customer due diligence providers);
• From a third party with your consent (e.g., your bank); and
• From cookies on our website.

4. How and Why We Use Your Personal Information. Under data protection law, we can only use your personal information if we have a proper reason for doing so, e.g.:

• To comply with our legal and regulatory obligations;
• For the performance of our services for you and clients or to take steps at your request;
• For our legitimate interests or those of a third party; or
• Where you have given consent.

A legitimate interest is when we have a business or commercial reason to use your information, so long as this is not overridden by your own rights.

The table below explains what we use (process) your personal information for and our reasons for doing so:

5. Account Communications. We may use your personal information to send you updates (by email, text message, telephone or post about your account with our organization.

   We have a legitimate interest in processing your personal information for the Last Demand Inc. application and site (see above “How and why we use your personal information”). This means we do not usually need your consent to attempt to communicate with you. However, where consent is needed, we will ask for this consent separately and clearly.

   We will always treat your personal information with the utmost respect and never sell it to other organizations for marketing purposes.

   You have the right to opt out of receiving communications at any time by:

• Contacting us at support@lastdemand.com; or
• Using the “unsubscribe” link in emails or “STOP” number in texts.

  We may ask you to confirm or update your preferences if you instruct us to provide further products and/or services in the future, or if there are changes in the law, regulation, or the structure of our business.

6. Who We Share Your Personal Information With. We may share personal information with the following, if permissible by applicable law, to operate our business and provide our products and services.

• Service providers, vendors, clients, and subcontractors we use to help deliver our products and/or services to you, in accordance with applicable law(s);
• Information providers;
• Third parties approved by you, including third-party payment providers;
• Communication service providers;
• Our insurers and attorneys;
• Our banks;
• Our parent, subsidiaries, and affiliates, when necessary (e.g., to provide products or services, or as part of a merger, acquisition, or corporate restructuring); and
• With state and federal regulators in accordance with a lawful order, request, or inquiry.

  We only allow our service providers to handle your personal information if we are satisfied they take appropriate measures to protect your personal information. We also impose contractual obligations on service providers relating to ensure they can only use your personal information to provide services to us and to you. We may also share personal information with external auditors, e.g. in relation to accreditation and the audit of our accounts.

  We may disclose and exchange information with law enforcement agencies and regulatory bodies to comply with our legal and regulatory obligations.

  We may also need to share some personal information with other parties, such as potential buyers of some or all of our business or during a re-structuring. We will typically anonymize information, but this may not always be possible. The recipient of the information will be bound by confidentiality obligations.

7. Personal Information We Sold or Disclosed for a Business Purpose. In the preceding 12 months, we have not sold any personal information to third parties. In the preceding 12 months, we have disclosed for a business purpose to one or more third parties the following categories of personal information that identifies, relates to, describes, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household:

• Identifiers (e.g., a real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, social security number, driver’s license number, passport number, or other similar identifiers);
• Information that identifies, relates to, describes, or is capable of being associated with, a particular individual, including, but not limited to, his or her name, signature, social security number, physical characteristics or description, address, telephone number, passport number, driver’s license or state identification card number, insurance policy number, education, employment, employment history, bank account number, credit card number, debit card number, or any other financial information, medical information, or health insurance information;
• Commercial information (e.g., records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies);
• System, internet or other electronic network activity information (e.g., browsing history, search history, and information regarding a consumer’s interaction with an Internet Web site, or application), cookies, and geolocation data;
• Statistical analysis to help us manage our business, e.g. in relation to our financial performance, customer base, product range or other efficiency measures;
• Professional or employment-related information;
• Education information, defined as information that is not publicly available personally identifiable information as defined in the Family Educational Rights and Privacy Act (FERPA); and
• Inferences drawn from any of the information identified above to create a profile about a consumer reflecting the consumer’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.

  We have not sold to a third party any personal information that identifies, relates to, describes, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household.

8. Where Your Personal Information is Held. Information may be held at our offices and if permissible by law, those of our service providers, representatives and agents as described above (see above: “Who We Share Your Personal Information with”). Some of these third parties may be based outside the European Economic Area. For more information, including on how we safeguard your personal information when this occurs, see below: “Transferring Your Personal Information Out of the EEA”.

9. How Long Your Personal Information Will Be Kept. We will keep your personal information while we are providing products and/or services to you. Thereafter, we will keep your personal information for as long as is necessary:

• To respond to any questions, complaints or claims made by you or on your behalf;
• To show that we treated you fairly; or
• To keep records required by law and retention policy.

  We will not retain your personal information for longer than necessary for the purposes set out in this policy. Different retention periods apply for different types of personal information.

10. Transferring Your Personal Information Out of the EEA. To deliver services to you, it is sometimes necessary for us to share your personal information outside the European Economic Area (EEA), e.g.:

• With our offices outside the EEA;
• With your and our service providers located outside the EEA;
• If you are based outside the EEA; or
• Where there is an international dimension to the services we are providing to you.

  These transfers are subject to special rules under European and UK data protection law.

  The following countries to which we may transfer personal information have been assessed by the European Commission as providing an adequate level of protection for personal information: Andorra, Argentina, Canada (commercial organizations), Faroe Islands, Guernsey, Israel, Isle of Man, Japan, Jersey, New Zealand, Switzerland and Uruguay. A current list may be found here: GDPR Adequacy Decisions.

  Except for the countries listed above, non-EEA countries do not have the same data protection laws as the United Kingdom and EEA. We will, however, ensure the transfer complies with data protection law and all personal information will be secure. Our standard practice is to use standard data protection contract clauses. If you would like further information, please contact us (see “How To Contact Us” below).

11. If applicable, you may have the following rights under the GDPR:

For further information on each of those rights, including the circumstances in which they apply, see the guidance from the UK Information Commissioner’s Office (ICO) on individual rights under the General Data Protection Regulation.

12. Your Rights Under the CCPA. You may have certain rights under the California Consumer Privacy Act of 2018 (CCPA) and certain other privacy and data protection laws, as applicable, to exercise free of charge:

13. Keeping Your Personal Information Secure. We have appropriate security measures in place to prevent personal information from being accidentally lost or used or accessed in an unauthorized way. We limit access to your personal information to those who have a genuine business need to access it. Those processing your information will do so only in an authorized manner and are subject to a duty of confidentiality. We also have procedures in place to deal with any suspected data security breach. We will notify you and any applicable regulator of a suspected data security breach where we are legally required to do so.
14. How to Exercise Your Rights. If you would like to exercise any of your rights as described in this Privacy Policy, please:

• Complete and send our online request form: ; or,
• Email us at support@lastdemand.com.

  Please note that you may only make a CCPA-related data access or data portability disclosure request twice within a 12-month period.

  If you choose to contact directly by website, email, phone or in writing, you will need to provide us with:

• Enough information to identify you [(e.g., your full name, address and customer or matter reference number)];
• Proof of your identity and address (e.g., a copy of your driving license or passport and a recent utility or credit card bill); and
• A description of what right you want to exercise and the information to which your request relates.

  We are not obligated to make a data access or data portability disclosure if we cannot verify that the person making the request is the person about whom we collected information or is someone authorized to act on such person’s behalf.

  Any personal information we collect from you to verify your identity in connection with you request will be used solely for the purposes of verification.

15. How to File a GDPR Complaint. We hope that we can resolve any query or concern you raise about our use of your information. The General Data Protection Regulation also gives you right to lodge a complaint with a supervisory authority, in the European Union (or European Economic Area) state where you work, normally live, or where any alleged infringement of data protection laws occurred.
16. Changes to This Privacy Notice. This privacy notice was published on May 2, 2022.

    We may change this privacy notice from time to time–when we do, we will inform you via website or other means of contact such as email.

17. How to Contact us. Please contact us, email or telephone if you have any questions about this privacy policy or the information we hold about you.

Our contact details are shown below:

18. Do You Need Extra Help? If you would like this notice in another format, please contact us (see “How to contact us” above).