PLEASE READ THESE TERMS AND CONDITIONS CAREFULLY BEFORE USING THIS ONLINE PORTAL TO ACCESS THE ANTIDOLUS INTELLIGENCE SHARING SYSTEM

1 Whats in these terms?

These Terms of Use (Terms) tell you the rules for using the Antidolus Intelligence Sharing System (the System) which is accessed via this online portal (Portal).

Any capitalised terms are as defined in the Definitions section below.

2 By accessing and using the System you accept these Terms

By accessing and using the System, you confirm that you accept these Terms and that you agree to comply with them.

If you do not agree to these Terms, you must not use the System.

We recommend that you print a copy of these Terms for future reference.

3 Who we are and how to contact us

The System and Portal are owned and operated by Montague Sykes (we, our and us). We are registered in England and Wales under company number 12593575 and have our registered office at 130 Shaftesbury Avenue, 2nd Floor, London, W1D 5EU.

4 There are other terms that may apply to you

These Terms refer to the following additional terms, which also apply to your use of the System/Portal:

• our Privacy Policy [below];

the Data Sharing Agreement which we have entered into with the Partners and the Vetting Standards which the Partners are obliged to comply with.

5 We may make changes to these Terms

We amend these Terms from time to time. Every time you wish to use the System, please check these Terms to ensure you understand the terms that apply at that time. These Terms were most recently updated on 21 October 2020.

6 We may make changes to the System/Portal

We may update and change the System/Portal from time to time to reflect legal or regulatory changes, changes in our users or our own commercial interests or any other reason at our sole discretion. If we make any material changes to the System/Portal, we will try to give you reasonable notice prior to the change becoming effective. You should stop using the System/Portal if you do not agree to any changes.

7 We may suspend or withdraw the System/Portal or terminate your access to the System/Portal

We do not guarantee that the System/Portal, or any content on it, will always be available or be uninterrupted. We may suspend or withdraw or restrict the availability of all or any part of the System/Portal for business and operational reasons. We will try to give you reasonable notice of any suspension or withdrawal.

You are responsible for ensuring that only you access the System/Portal through your internet connection that you are aware of these Terms and other applicable terms and conditions, and comply with them.

We reserve the right to suspend or terminate your access to the System, without any liability to you, where, in our reasonable opinion, you have failed to comply with any of these Terms or the Data Sharing Agreement or the Vetting Standards.

Your right to use the System shall automatically terminate (and we shall disable your username and password):

• if you cease to be employed or engaged by the applicable Partner (who has given you access to the System); or

on termination (for whatever reason) of the Data Sharing Agreement in respect of the applicable Partner (who has given you access to the System).

8 The System/Portal is only for users in the UK

The System/Portal is directed to people residing in the United Kingdom. We do not represent that content available on or through the System/Portal is appropriate for use or available in other locations.

9) You must keep your account details safe

If you choose, or you are provided with a non transferrable, user name, password or any other piece of information as part of our security procedures, you must treat such information as confidential. You must not disclose it to any third party or work colleague.

If you know or suspect that anyone other than you knows your user identification code or password, you must promptly notify. A new user identification code and password will then be issued free of charge.

10 How you may use material on the System/Portal

We are the owner or the licensee of all intellectual property rights in the System/Portal, and in the material published on it. Those works are protected by copyright laws and treaties around the world. All such rights are reserved.

Whenever you make use of a feature that allows you to search, view and/or download Data on the System/Portal (including personal data), you shall ensure that you only use such Data at all times in strict compliance with the Data Sharing Agreement. This means, without limitation, that you shall treat such Data as confidential and only use such Data for the Agreed Purposes (unless otherwise agreed in advance by us and/or the Partner who originally submitted the relevant Data to the System).

You may print off one copy, and may download extracts, of any page(s) from the System/Portal for the Agreed Purposes and you may draw the attention of others within your organisation to content posted on the System/Portal for the Agreed Purposes.

You must not modify the paper or digital copies of any materials you have printed off or downloaded in any way.

You must not use any part of the content on the System/Portal for commercial purposes without obtaining a licence to do so from us or our licensors.

If you print off, copy or download any part of the System/Portal in breach of these Terms, your right to use the System/Portal will cease immediately and you must, at our option, return or destroy any copies of the materials you have made.

11 Do not rely on information on the System/Portal

Each of the Partners that shares Data via the System is require to comply with the terms of the Data Sharing Agreement, which requires (amongst other things) that the Partners ensure that such Data is accurate, reliable, up to date and suitable for sharing via the System.

We will work hard to try to ensure that any Data on the System is reliable and up-to-date, including by monitoring use of the System by the Partners and the quality of Data that is submitted to the System and deleting any Data which is not suitable or deemed to be unreliable. However, we make no representations, warranties or guarantees, whether express or implied that the content on the System/Portal is accurate, complete or up to date.

The content on the System/Portal is provided for general information only and we accept no liability for any decision or action taken in reliance on any Data viewed via or extracted from the System.

12 Uploading content to the System/Portal

Whenever you make use of a feature that allows you to upload or submit Data to the System/Portal (including personal data), you shall ensure that you comply with the requirements of the Data Sharing Agreement at all times. This includes, without limitation, ensuring that you have the right to share such Data via the System/Portal and that such Data:

• relates to a Confirmed Economic Crime or Suspicious Activity, which occurred within 6 ½ years prior to the date such content is submitted to the System; and
• does not contain Excluded Personal Data;
• is relevant, accurate and up-to-date;
• complies with all applicable laws in England and Wales (including (without limitation) the Data Protection Legislation);
• does not infringe any copyright, trade mark or other intellectual property rights of any third party; and
• does not breach any legal duty owed to a third party, such as a contractual duty or a duty of confidence, (together the Content Standards).

You warrant that any such contribution does comply with the Content Standards, and you will be liable to us and indemnify us for any breach of that warranty. This means you will be responsible for any loss or damage we suffer as a result of your breach of warranty.

Any content you upload/submit to the System will be considered non-proprietary. As it is not possible to disaggregate any content once it has been submitted to the System, ownership of any content passes to us at the time it is uploaded/submitted to the System.

We also have the right to disclose your identity to any third party who is claiming that any content posted or uploaded by you to the System constitutes a violation of their intellectual property rights, or of their right to privacy.

We have the right to remove and delete any content that you upload to the System if, in our opinion, the content does not comply with the Contents Standards.

You are solely responsible for securing and backing up your content.

13 Acceptable Use

You may use the System/Portal only for the Agreed Purposes. You may not use the System/Portal or any Data contained on the System/Portal:

• in any way that breaches any applicable local, national or international law or regulation (including (without limitation) the Data Protection Legislation);
• in any way that is unlawful or fraudulent, or has any unlawful or fraudulent purpose or effect;
• for the purpose of harming or attempting to harm minors in any way;
• to share, send, knowingly receive, upload, download, use or re-use any data or other material which does not comply with the Content Standards; or
• to transmit, or procure the sending of, any unsolicited or unauthorised advertising or promotional material or any other form of similar solicitation (spam).

You also agree:

• not to reproduce, duplicate, reverse engineer, copy or re-sell any part of the System/Portal in contravention of these Terms; and
• not to access without authority, interfere with, damage or disrupt:
• any part of the System/Portal;
• any equipment or network on which the System/Portal is stored;
• any software used in the provision of the System/Portal; or
• any equipment or network or software owned or used by any third party.

14 Breach of these Terms

When we consider that a material breach of these Terms has occurred (to be determined at our sole discretion), we may take such action as we deem appropriate which may include:

• immediate, temporary or permanent withdrawal of your right to use the System/Portal;
• immediate, temporary or permanent removal of any content uploaded or submitted by you to the System/Portal;
• issue of a warning to you;
• legal proceedings against you for reimbursement of all costs on an indemnity basis (including, but not limited to, reasonable administrative and legal costs) resulting from the breach;
• further legal action against you; and/or
• disclosure of such information to law enforcement authorities as we reasonably feel is necessary or as required by law.

We exclude our liability for all action we may take in response to breaches of these Terms. The actions we may take are not limited to those described above, and we may take any other action we reasonably deem appropriate.

15 We are not responsible for viruses and you must not introduce them We take measures to ensure that the system is free from bugs and viruses but do not guarantee that the System/Portal will be secure or free from bugs or viruses.

You are responsible for configuring your information technology, computer programmes and platform to access the System/Portal. You should use your own virus protection software.

You must not misuse the System/Portal by knowingly introducing viruses, trojans, worms, logic bombs, keystroke loggers, spyware, adware or any other harmful or malicious programs or similar computer code designed to adversely affect the operation of any computer software or hardware.

You must not attempt to gain unauthorised access to the System/Portal, the server on which the System/Portal is stored or any server, computer or Site connected to the System/Portal. You must not attack the System/Portal via a denial-of-service attack or a distributed denial-of service attack. By breaching this provision, you would commit a criminal offence under the Computer Misuse Act 1990. We will report any such breach to the relevant law enforcement authorities and we will co-operate with those authorities by disclosing your identity to them. In the event of such a breach, your right to use the System/Portal will cease immediately.

16 Our responsibility for loss or damage suffered by you

We do not exclude or limit in any way our liability to you where it would be unlawful to do so. This includes liability for death or personal injury caused by our negligence or the negligence of our employees, agents or subcontractors and for fraud or fraudulent misrepresentation.

We will not be liable to you for any loss or damage, whether in contract, tort (including negligence), breach of statutory duty, or otherwise, even if foreseeable, arising under or in connection with:

• use of, or inability to use, the System/Portal; or
• use of or reliance on any content displayed on the System/Portal.

In particular, we will not be liable for:

• loss of profits, sales, business, or revenue;
• business interruption;
• loss of anticipated savings;
• loss of business opportunity, goodwill or reputation; or
• any indirect or consequential loss or damage.

Subject to the above, our total aggregate liability in contract, tort (including negligence or breach of statutory duty), misrepresentation, restitution or otherwise, arising in connection with the performance or contemplated performance of this agreement shall be limited to the annual fee we charge you for access.

We exclude all implied conditions, warranties, representations or other terms that may apply to the System/Portal or any content on it.

17 How we may use your personal information

We will only use your personal information as set out in our Privacy Policy [below].

18 Governing law and jurisdiction

These Terms, and any dispute or claim (including non-contractual disputes or claims) arising out of or in connection with them or their subject matter shall be governed by, and construed in accordance with the law of England and Wales.

The courts of England and Wales shall have exclusive jurisdiction to settle any dispute or claim (including non-contractual disputes or claims) arising out of or in connection with these Terms or their subject matter.

19 Definitions

In these Terms, the following definitions shall apply:

Agreed Purposes: means the sharing, use or processing of Data by the Partners via the System for the following purposes:

• in order to create a centralised, searchable database which can be used by the Partners in order to identify individuals who have committed a Confirmed Economic Crime or undertaken Suspicious Activity against a Partner during the past 6½ years;
• to allow the Partners to search the Data via the System and use such Data as is returned by their search for the purposes of assessing applications for Membership of their organisation and allowing them to make an informed choice about accepting or declining applications for Membership from organisations which are associated with an individual(s) who has(have) committed a Confirmed Economic Crime or Suspicious Activity in the past 6½ years; and/or
• the detection, investigation and prevention of crime or suspected crime or obtaining a civil law outcome (in respect of a Confirmed Economic Crime). Applicant means an entity that applies to become a Member of, or applies for a licence operated by, one of the Partner organisations; Confirmed Economic Crime means a confirmed fraud or other economic crime which has been committed by an Applicant or Member against the Partner disclosing the relevant Data, which may include (without limitation):
• Account irregularities / Money laundering;
• Travel arrangements not provided / Bust out;
• Financial failure;
• Fraud against suppliers;
• Package travel / ATOL regulation breach;
• Promoting false membership information; or
• Bogus website/ Cloned website / Cybercrime.

Data means the data (including personal data) which may be shared or obtained by the Partners via the System, as specified in the Data Sharing Agreement.

Data Protection Legislation means: (i) any data protection legislation from time to time in force in the UK including the Data Protection Act 2018 or any successor legislation; (ii) (for so long as and to the extent that the law of the European Union has legal effect in the UK) the General Data Protection Regulation ((EU) 2016/679) (GDPR) and any other directly applicable European Union regulation relating to privacy; and (iii) all other applicable laws and regulations relating to the processing of personal data and privacy, including where applicable the guidance and codes of practice issued by the UK Information Commissioners Office (ICO) or any other supervisory authority, and the equivalent of any of the foregoing in any relevant jurisdiction.

Excluded Personal Data means the following data which is expressly excluded and may not be shared by the Partners via the System. If this information is submitted to the System, it will be removed.

• Payment card details;
• Special Categories of Personal Data; and
• Unsubstantiated information, including rumour, gossip, hearsay or unconfirmed reports.

Member means a company that has been accepted for membership of, or granted a licence by, one of the Partner organisations (subject to the relevant company being subject to the Vetting Standards) and the term Membership shall be construed accordingly;

Partner means one of the Membership organisations (all of which provide financial protection to travel customers, as required by UK law), The Civil Aviation Authority, police or insurance provider which is a party to this Agreement. Together they shall be the Partners.

Suspicious Activity in the context of this agreement means any observed behaviour that is unorthodox, secretive, or unexplained and which is yet to be confirmed, or is typical of the early stages of, or is under investigation but has yet to be established as, a Confirmed Economic Crime.

Vetting Standards means the Antidolus Vetting Standards, which set out the core identity, financial and other checks that the Partners are required to carry out before accepting an applicant for Membership of their organisations.

PRIVACY STATEMENT

Who Are We?

We are Montague Sykes, the UK travel industry's counter fraud and cybercrime body.

In this policy:

Antidolus, we, us or our means:

Montague Sykes (Registered in England No. 12593575) of 130 Shaftesbury Avenue, 2nd Floor, London, W1D 5EU.

Our websites, means: businessagainstfraud.co.uk.

Our websites are not intended for children and we do not knowingly collect data relating to children.

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Contact details

If you have any questions about this policy or our privacy practices, please write to us at the following address:

Full name of legal entity:  Montague Sykes (Registered in England No. 12593575) of 130 Shaftesbury Avenue, 2nd Floor, London, W1D 5EU.

You have the right to make a complaint at any time to the Information Commissioner's Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.
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Changes to this Policy

Any changes we may make to this policy in the future will be posted on this website so please check this page occasionally to ensure that you're happy with any changes. If we make any significant changes we'll make this clear on this website.

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Review of this Policy

We keep this policy under regular review. This policy was last updated in October 2020.

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Your Duty to Inform Us of Changes

It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.

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Definitions Of terms Used In This Policy

Applicant for Membership means an entity that applies to become a Member of, or applies for a licence operated by, one of the Partner organisations.

Crime means an act or omission that violates the law and is punishable by a sentence of incarceration. This website is specifically concerned with economic crime.

Current Member means an entity that is an existing Member of, or licence holder of, one of the Partner Organisations.

Economic Crime means a crime which involves the misappropriation of money examples of which include: bilking, deception, fraud, money laundering, or theft.

IP Address means the Internet Protocol which is a unique string of numbers and letters that identify every device internet enabled device (computer, laptop, palm top, smart phone, tablet) and allows it to communicate over the internet.

Partner Organisation means one of the Membership organisations (all of which provide financial protection to travel customers, as required by UK law), the Civil Aviation Authority, an insurance provider, or a police force which is a party to this Agreement. Together they shall be the Partners.

Previous Member means an entity that once was a Member of, or licence holder of, one of the Partner Organisations but has now ceased to be so.

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How do We Collect Information from You?

We obtain information about you in the following ways:

Data Held Within the Antidolus System

Our Partner Organisations only provide and manage confirmed fraud data relating to officers of:

• Applicants for membership,
• Current members,
• Previous or ex-employees of Partner Organisations.

Data held within existing databases managed by the parties.

Specifically:

• Individuals full names, alias, date of birth, personal addresses and position;
• Telephone and Mobile Phone numbers;
• IP Addresses;
• Directors and Company names;
• Company Addresses and website address;
• Companies House numbers;
• Company VAT numbers;
• Data relating to actual or alleged criminal convictions and offences;
• Trial court references;
• Civil court debt references;
• Other related data such as vehicle registration numbers; and
• Publicly accessible information showing whether a person is banned from holding office.

Information you Give us Directly

We may ask you for information if you approach us with a complaint or enquiry in order to help you by directing you to the correct place to deal with your issue. We will only ask you for the basic information required to understand and refer your issue to the appropriate destination organisation and once the issue has been dealt with we will not retain your data.

Information you Give us Indirectly

Your information may be shared with us by third parties, which might include:

• Partner Organisations seeking our assistance on finding the best solution for a problem you have.
• You should check any privacy policy provided to you where you give your data to a third party.

When you Visit our Websites

General Visitors - We do NOT collect and use any other personal information directly or through cookies on our website.

Users from Partner Organisation

When you, as an authorised user, logs on to use the system Antidolus uses internal algorithms to track and record every action you undertake in a secure audit log which is accessible to the site Administrators and is used to identify and deal with any instances of misuse.

Public Information

We supplement information of data held within our system using information from publicly available official sources such as details of directors who have been banned from holding office for a period by the Insolvency Service, Sanctions Information published by HM Treasury, press reports of court cases, and Companies House in order to create a fuller record of someones criminal behaviour.

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What Type of Information is Collected from Visitors and Users of the Website?

Data protection laws recognise certain categories of personal information as sensitive and therefore requiring greater protection, for example information about your health, ethnicity and religion.

We do NOT collect sensitive data about you.

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How and Why is Your Information Used?

We may use your information for a number of different purposes, which may include:

Data Held in Antidolus:

• Preventing crime or tax evasion,
• Detecting crime or tax evasion, and
• Reporting crime or tax evasion to the police, other enforcement bodies.

Data obtained through our interactions with users and visitors to the websites:

• Providing you with the services, products or information you asked for.
• carrying out our obligations under any contracts entered into between you and us;
• keeping a record of your relationship with us;
• conducting analysis and market research to better understand how we can improve our services, products or information;
• seeking your views or comments on the services we provide;
• notifying you of changes to our services;
• sending you communications which you have requested and that may be of interest to you. These may include information about analysis we have conducted on the data, fraud alerts and research; and
• dealing with complaints and enquiries.

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How Long is Your Information Kept for?

We keep your information for no longer than is necessary for the purposes it was collected for. The length of time we retain your personal information for is determined by operational and legal considerations. For example, we are legally required to hold some types of information to fulfil our statutory and regulatory obligations (e.g. health/safety and tax/accounting purposes).

We review our retention periods on a regular basis.

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Who has Access to Your Information?

We do not sell or rent your information to third parties.

We do not share your information with third parties for marketing purposes.

However, we may disclose your information to third parties in order to achieve the other purposes set out in this policy. These third parties may include:

• Partner Organisations,
• The Police,
• Tax Authorities,
• Enforcement Bodies, and
• Insurance Providers.

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Lawful Processing

Data protection law requires us to rely on one or more lawful grounds to process your personal information. We consider the following grounds to be relevant:

Specific Consent

Where you have provided specific consent to us using your personal information in a certain way, such as to send you email, text and/or telephone communications to assist you with an issue.

Performance of a Contract

Where we are entering into a contract with you or performing our obligations under it, like when you join our Partners using Antidolus.

Legal Obligation

Where necessary so that we can comply with a legal or regulatory obligation to which we are subject, for example where we are ordered by a court or the Information Commissioners Office.

Legitimate Interests

Where it is reasonably necessary to achieve our or others legitimate interests (as long as what the information is used for is fair and does not duly impact your rights).

We consider our legitimate interests to be running Antodulus in pursuit of our aims and purposes. For example to:

• identify crime and tax evasion;
• prevention of crime and tax evasion; and
• report crime and tax evasion to the police and relevant authorities or enforcement bodies.

When we legitimately process your personal information in this way, we consider and balance any potential impact on you (both positive and negative), and your rights under data protection laws. We will not use your personal information where our interests are overridden by the impact on you, for example, where use would be excessively intrusive (unless, for instance, we are otherwise required or permitted to by law).

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Your Rights

Under UK data protection law, you have certain rights over the personal information that we hold about you. Here is a summary of the rights that we think apply:

Right of Access

You have a right to request access to the personal data that we hold about you.

You also have the right to request a copy of the information we hold about you, and we will provide you with this unless legal exceptions apply.

If you want to access your information, please send a description of the information you would like to see and proof of your identity by post to the address provided above.

Right to Have Your Inaccurate Personal Information Corrected

You have the right to have inaccurate or incomplete information we hold about you corrected.

The accuracy of your information is important to us so we're working on ways to make it easier for you to review and correct the information that we hold about you. Please contact us if you think there is an inaccuracy in your data.

If you are contacting us about inaccurate or incomplete information within the Antindolus system that we hold about you we will refer you directly to the organisation that provided that information as and confirmed it as an accurate record of a crime that has the access and ability to modify the record if necessary. Antindolus  is not in a position to know why the partner organisation confirmed the data when entering it.

Right to Restrict Use

You have a right to ask us to restrict the processing of some or all of your personal information if there is a disagreement about its accuracy, or we're not lawfully allowed to use it.

Right of Erasure

You may ask us to delete some or all of your personal information and in certain cases, and subject to certain exceptions; we will do so as far as we are required to. In many cases, we will anonymise that information, rather than delete it.

Right for Your Personal Information to be Portable

If we are processing your personal information (1) based on your consent, or in order to enter into or carry out a contract with you, and (2) the processing is being done by automated means, you may ask us to provide it to you or another service provider in a machine-readable format.

Right to Object

You have the right to object to processing where we are using your personal information (1) based on legitimate interests, (2) or for statistical/research purposes.

If you want to exercise any of the above rights, please write to Data Protection Office, Montague Sykes (Registered in England No. 12593575 of 130 Shaftesbury Avenue, 2nd Floor, London, W1D 5EU.

We may be required to ask for further information and/or evidence of identity. We will endeavour to respond fully to all requests within one month of receipt of your request, however if we are unable to do so we will contact you with reasons for the delay.

Please note that exceptions apply to a number of these rights, and not all rights will be applicable in all circumstances. For more details we recommend you consult the guidance published by the UKs Information Commissioners Office.

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Keeping Your Information Safe

When we receive personal information, we take steps to ensure that appropriate technical and organisational controls are in place to protect it.

All personal data held within the Antidolus system is encrypted and protected. When you are on a secure page, a green padlock icon will appear adjacent to the web browser such as Microsoft Internet Explorer.

Personal information details (your email communications etc.) are transmitted normally over the internet and this can never be guaranteed to be 100% secure. As a result, while we strive to protect your personal information, we cannot guarantee the security of any information you transmit to us, and you do so at your own risk. Once we receive your information, we make our best effort to ensure it is secure on our systems. Where we have given (or where you have chosen) a password and other authentication which enables you to access certain parts of our website, you are responsible for keeping this password and authentication confidential. We ask you not to share your password with anyone.

We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so

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Keeping Your Information up to Date

We take reasonable steps to ensure your information is accurate and up to date.

We really appreciate it if you let us know when your contact details change.

Use of 'cookies'

We do not use Cookies on this website. 'Cookies' are small pieces of information sent by an organisation to your computer and stored on your hard drive to allow that website to recognise you when you visit.

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Links to Other Websites

Our website may contain links to other websites run by other organisations. This policy applies only to our website so we encourage you to read the privacy statements on the other websites you visit. We cannot be responsible for the privacy policies and practices of other websites even if you access those using links from our website.

In addition, if you linked to our website from a third party site, we cannot be responsible for the privacy policies and practices of the owners and operators of that third party site and recommend that you check the privacy policy of that third party site.

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Transferring Your Information Outside of Europe

As part of the services offered to you through this website, the information which you provide to us may be transferred to countries outside the European Economic Area (EEA).

By way of example, this may happen if any of our servers are from time to time located in a country outside of the EEA. You should be aware that these countries may not have similar data protection laws to the UK. By submitting your personal data, you are agreeing to this transfer, storing or processing.

If we transfer your information outside of the EEA in this way, we will take steps to ensure that appropriate security measures are taken with the aim of ensuring that your privacy rights continue to be protected as outlined in this policy.

If you use our services while you are outside the EEA, your information may be transferred outside the EEA in order to provide you with those services.

We undertake regular reviews of who has access to information that we hold to ensure that your info is only accessible by appropriately trained staff, volunteers and contractors.