Data subject requests and erasure policy

THEMIS holds two kinds of personal information, and who decides what happens to it differs.

• Information we hold as controller: the details of the people who have accounts, who sign in, who write to us or use our website, and the records we keep of our own business. We decide how it is used, and requests about it come to us.
• Information a law practice or another organisation puts into the service about its own clients, counterparties, staff and matters. The practice is the controller and we are its processor. The practice decides what happens to that information, and we act on its instructions.

If you write to us about information in a practice's records, we will tell you that the practice must decide, and we will pass your request to it if you tell us which practice it is. We do not look through a practice's records ourselves.

• A copy of the information held about you, and what it is used for.
• Correction of information that is wrong or incomplete.
• Erasure of information that is no longer needed, that you gave on consent you now withdraw, that is used unlawfully, or that the law says must be erased.
• Restriction of its use while a question is settled.
• Objection to uses based on a legitimate interest, and to direct marketing.
• A copy in a form you can move, where we use the information by automated means on the basis of contract or consent.

Some of these rights have exceptions. This policy says where they apply.

Use the page at https://www.themislaw.app/privacy-request, or write to privacy@olympuspay.co. Say what you want and give an email address we can write to. You do not have to say why. If your request is about a practice's records, name the practice.

A practice that receives a request directly can log and handle it in THEMIS under Settings, Data requests.

We must be sure that a request comes from the person it is about, because giving or erasing someone's information on a false request does real harm. We ask only for what we need, usually a reply from the email address we hold, and for an identity number or other detail we already have. We do not ask for more identification than the request needs. If we cannot be satisfied who you are, we will say so and explain what would help, and we will not release or erase anything until we are.

We reply without undue delay and within one month of receiving your request. If the request is complex, or we have received many, the law allows us to take up to two further months. We will tell you within the first month if we need longer, and why.

There is no fee, unless a request is clearly unfounded or excessive, in which case we may charge a reasonable fee or refuse, and we will tell you why.

We give you the information held about you in a common format, and what it is used for, who it was shared with and how long it is kept. We leave out information about other people, and information we are not allowed to give you, for example where a law bars it, and we tell you when we have done so.

When we agree to erase information, we delete it, or, where deleting it would break a record we must keep, we remove the details that identify you. We do this in the live service, and it leaves our backups within 90 days.

We keep information the law requires us, or the practice, to keep. The main cases are:

• Records of a person who became a client, and of matters, kept under the Money Laundering Regulations 2017 (regulation 40, five years after the relationship ends) and the practice's professional rules.
• Invoices, payments and other tax and accounting records, for the period that tax and company law set.
• Debts being recovered, and the ledger of what was paid, for the limitation period.
• Signing records and their evidence, because they show that a document was validly signed.
• The permanent audit trail of who did what in an account. It records an email address or name used at the time and cannot be altered.
• Information needed to establish, exercise or defend a legal claim, or that a court or regulator has asked us to keep.

Where we keep something, we tell you what and why. We restrict who can see it and use it only for that purpose. While a legal hold is in place on an account, information that may be evidence is not erased until the hold ends.

A practice that receives a request logs it, checks who the person is, searches its records for the person by email address and identity number, and decides what to give and what to erase. THEMIS shows what each record is linked to, so that a record on a matter file, an invoice, a debt or a signing record is kept and the reason is recorded. A name match alone is not enough to include a record, and a person has to confirm it. A plan to erase is approved by a second person before it is carried out, because it cannot be undone. The practice's reply to the person is drafted for the practice to send.

We will tell you in writing if we cannot do what you ask, and why. You may complain to the Information Commissioner's Office, and you may ask a court to review our decision. We would like the chance to put things right first, so please write to privacy@olympuspay.co.

We keep a record of each request, when it came, how we checked who made it, what we did and when. We keep it for three years after the request is closed, so we can show that we dealt with it properly, and we keep only what is needed for that.

You can reach us at privacy@olympuspay.co for data protection matters, legal@olympuspay.co for legal notices, and support@olympuspay.co for help. Our address for notices is 1111B S Governors Ave, STE 25834, Dover, DE 19904, USA. A written notice sent to that address, or an email to legal@olympuspay.co, is treated as delivered when received.