Privacy Policy

Last Updated: 28 April 2025

1. Introduction

BORDERLESSTECH LTD ("we", "our", "us", "the Company") is committed to protecting and respecting your privacy. This Privacy Policy explains how we collect, use, and safeguard your information when you use our salary transparency platform.

We are headquartered at 128 City Road, London, United Kingdom, EC1V 2NX and act as the data controller for personal information collected through our platform.

2. Information We Collect

We collect the following types of information:

  • Personal Information: Name, email address, professional role, job title, industry, and location.
  • Employment and Compensation Data: Salary information, bonus details, benefits, and other compensation components as voluntarily shared through our platform.
  • Payslip Information: When you upload payslips for verification, we collect data contained within these documents to verify salary information. This may include payment amounts, employer information, tax details, and other compensation-related information.
  • User Account Information: Login credentials and authentication details.
  • Technical Information: IP address, browser type, device information, operating system, and cookies.
  • Usage Information: How you interact with our platform, pages visited, features used, and time spent on the platform.

3. How We Collect Your Information

We collect information through:

  • Direct submission through our platform (when you create an account, upload payslips, or submit salary information)
  • Automated technologies including cookies and similar tracking technologies
  • Third-party services that help us operate our platform

4. How We Use Your Information

We use your information for the following purposes:

  • To provide and maintain our salary transparency platform
  • To verify the accuracy of salary data through payslip validation
  • To generate anonymized industry insights and salary trends
  • To improve our services and develop new features
  • To communicate with you about your account and provide customer support
  • To detect, prevent, and address technical issues or fraudulent activities
  • To comply with legal obligations

5. Legal Basis for Processing

Under UK and EU data protection laws, we process your personal data based on:

  • Consent: Where you have explicitly agreed to our processing of your data for specific purposes.
  • Contractual Necessity: Where processing is necessary to fulfill our contractual obligations to you.
  • Legitimate Interests: Where processing is necessary for our legitimate interests, such as improving our services or preventing fraud, provided these interests do not override your fundamental rights and freedoms.
  • Legal Obligations: Where processing is necessary to comply with our legal obligations.

6. Data Anonymization and Aggregation

We take privacy seriously when handling compensation data:

  • Individual salary data is anonymized before being included in any public-facing insights or reports.
  • We aggregate data to prevent identification of individual contributors.
  • Sensitive identification data from payslips is removed during our verification process.

7. How We Share Your Information

We may share your information with:

  • Service Providers: Third-party vendors who help us operate our platform and provide services.
  • Business Partners: Organizations we collaborate with to provide related services, always with appropriate data protection agreements in place.
  • Legal Requirements: When required by law, court order, or governmental authority.
  • Business Transfers: In connection with a merger, acquisition, or sale of assets, where your data may be transferred as part of that transaction.

We do not sell your personal data to third parties.

8. Data Retention

We retain personal information for as long as necessary to fulfill the purposes outlined in this Privacy Policy, unless a longer retention period is required by law. When determining retention periods, we consider:

  • The amount, nature, and sensitivity of the personal data
  • The potential risk of harm from unauthorized use or disclosure
  • The purposes for which we process the data
  • Whether we can achieve those purposes through other means
  • Legal, regulatory, and contractual requirements

9. Security

We implement appropriate technical and organizational measures to protect your personal data, including:

  • Encryption of sensitive data
  • Secure handling protocols for payslip processing
  • Regular security assessments and penetration testing
  • Access controls and authentication requirements
  • Staff training on data protection and security practices

10. Your Rights

Under applicable data protection laws, you have the following rights:

  • Access: Request access to your personal data.
  • Rectification: Request correction of inaccurate data.
  • Erasure: Request deletion of your data in certain circumstances.
  • Restriction: Request restriction of processing in certain circumstances.
  • Data Portability: Request transfer of your data to you or a third party in a structured, commonly used format.
  • Objection: Object to processing based on legitimate interests or for direct marketing.
  • Withdrawal of Consent: Withdraw consent where processing is based on consent.
  • Complaint: Lodge a complaint with a supervisory authority (in the UK, the Information Commissioner's Office).

To exercise these rights, please contact us at info@wagely.fyi.

11. International Transfers

While we primarily store and process data within the UK and European Economic Area (EEA), we may transfer your information to countries outside these regions. When we do, we ensure appropriate safeguards are in place through standard contractual clauses, adequacy decisions, or other legally approved mechanisms.

12. Cookies and Tracking Technologies

Our platform uses cookies and similar technologies to enhance user experience, analyze usage patterns, and deliver personalized content. You can manage your cookie preferences through your browser settings. For more details, please see our Cookie Policy.

13. Children's Privacy

Our platform is not intended for children under 16 years of age. We do not knowingly collect personal information from children. If you believe we have collected information from a child, please contact us immediately.

14. Changes to This Privacy Policy

We may update this Privacy Policy periodically to reflect changes in our practices or legal requirements. We will notify you of any material changes by posting the updated policy on our platform with a new effective date.

15. Contact Us

If you have questions, concerns, or requests regarding this Privacy Policy or our data practices, please contact:

Data Protection Officer
BORDERLESSTECH LTD
128 City Road
London, United Kingdom
EC1V 2NX
Email: info@wagely.fyi