You have the right to make a complaint at any time to theInformation Commissioner’s Office (ICO), the UK supervisory authority for dataprotection 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.
The data we collect about you
Personal data, or personal information, means any information about an individual from which that person can be identified. It does notinclude data where the identity has been removed (anonymous data). We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:
Usage Data includes information about how you use our website, products andservices, including the fullUniform Resource Locators (URL), clickstream to, through and from our site(including date and time), page response times, length of visits to certainpages, page interaction information, methods used to browse away from the page,and any phone number used to call us.
Marketingand Communications Data includes your preferences in receiving marketingfrom us and our third parties and your communication preferences.We also collect, use and share AggregatedData such as statistical or demographic data for any purpose.
If you fail to provide personal data
Where we need to collect personal data by law, or under the terms of a contract wehave with you, and you fail to provide that data when requested, we may not beable to perform the contract we have or are trying to enter into with you (forexample, to provide you with goods or services). In this case, we may have tocancel a product or service you have with us but we will notify you if this isthe case at the time.
How is your personal data collected?
We use different methods to collect data from and about youincluding through:
Information you give us. You may give us your Identity, Contact, Profile and FinancialData by filling in forms or by corresponding with us by post, phone, email orotherwise.
This includes personal data you provide when you:
Information we receive from other sources. We will receive personal data about you fromvarious third parties as set out below:
How we use your personal data
We will only use your personal data when the law allows us to.Most commonly, we will use your personal data in the following circumstances:
Where we need to perform the contract we areabout to enter into or have entered into with you.
Where it is necessary for our legitimateinterests (or those of a third party) and your interests and fundamental rightsdo not override those interests.
Where we need to comply with a legal obligation.Generally, we do not rely on consent as a legal basis forprocessing your personal data although we will get your consent before sendingthird party direct marketing communications to you via email or text message.You have the right to withdraw consent to marketing at any time by contacting us.
Purposes for which we will use your personal data
We need all the categories of information in the list aboveprimarily to allow us to perform our contract with you and to enable us tocomply with legal obligations. In some cases we may use your personalinformation to pursue legitimate interests of our own or those of thirdparties, provided your interests and fundamental rights do not override thoseinterests. The situations in which we will process your personal informationare listed below:
Information you give us
We will use this information:
Information we collect about you
We will use this information:
Information we receive from other sources
We will combine this information withinformation you give us and information we collect about you. We will use this information and the combined information for the purposes set out above(depending on the types of information we receive).Note that we may process your personal data formore than one lawful ground depending on the specific purpose for which we areusing your data. Please contact us if you need details about the specific legalground we are relying on to process your personal data where more than oneground has been set out in the table below.
We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising. Promotional offers from usWe may use your Identity, Contact, Technical, Usage and ProfileData to form a view on what we think you may want or need, or what may be ofinterest to you. This is how we decide which products, services and offers maybe relevant for you (we call this marketing).You will receive marketing communications from us if you haverequested information from us or purchased products or services from us and youhave not opted out of receiving that marketing.
We will get your express opt-in consent before we share your personal data withany third party for marketing purposes.Opting outYou can ask us or third parties to stop sending you marketing messagesat any time by following the unsubscribe links on any marketing message sent toyou or by contacting us at any time.Where you opt out of receiving these marketing messages, this willnot apply to personal data provided to us as a result of a product/servicepurchase or other transactions.
Change of purpose
We will only use your personal data for the purposes for which wecollected it, unless we reasonably consider that we need to use it for anotherreason and that reason is compatible with the original purpose. If you wish toget an explanation as to how the processing for the new purpose is compatiblewith the original purpose, please contact us. If we need to use your personal data for an unrelated purpose, wewill notify you and we will explain the legal basis which allows us to do so.Please note that we may process your personal data without yourknowledge or consent, in compliance with the above rules, where this isrequired or permitted by law.
Disclosures of your personal data
We may share your personal data with selected third parties,including those set out below, for the purposes set out in the Purposes for which we will use your personaldata above:
Business partners, suppliers and sub-contractors;
Service providers acting as processors for example:
analytics and search engine providers that assist us in the improvement and optimisation of our site;
credit reference agencies for the purpose ofassessing your credit score where this is a condition of us entering into acontract with you.
Professional advisers acting as processors or joint controllers including lawyers, bankers,auditors and insurers who provide consultancy, banking, legal, insurance andaccounting services.
HMRevenue & Customers, regulators and other authorities acting as processorsor joint controllers based in the United Kingdom.Wewill also disclose your personal information to third parties:
Many of our external third parties are based outside the EEA sotheir processing of your personal data will involve a transfer of data outsidethe EEA.Whenever we transfer your personal data out of the EEA, we ensurea similar degree of protection is afforded to it by ensuring at least one ofthe following safeguards is implemented:
We will only transfer your personal data tocountries that have been deemed to provide an adequate level of protection forpersonal data by the European Commission.
We use certain service providers, we mayuse specific contracts approved by the European Commission which give personaldata the same protection it has in Europe.
Where we use providers based in the US, we maytransfer data to them if they are part of the Privacy Shield which requiresthem to provide similar protection to personal data shared between Europe and theUS. Please contact us if you want further information on the specificmechanism used by us when transferring your personal data out of the EEA.
We have put in place appropriate security measures to prevent yourpersonal data from being accidentally lost, used or accessed in an unauthorisedway, altered or disclosed. In addition, we limit access to your personal datato those employees, agents, contractors and other third parties who have abusiness need to know. They will only process your personal data on ourinstructions and they are subject to a duty of confidentiality.We have put in place procedures to deal with any suspectedpersonal data breach and will notify you and any applicable regulator of abreach where we are legally required to do so.Ifyou have reason to believe that your interaction with us is no longer secureplease contact us immediately.
How long will you use mypersonal data for?
We will only retain your personal data for as long as reasonablynecessary to fulfil the purposes we collected it for, including for thepurposes of satisfying any legal, regulatory, tax, accounting or reportingrequirements. We may retain your personal data for a longer period in the eventof a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you. We have a variety of obligations to retain your personal data,including ensuring that transactions can be appropriately processed, settled,refunded or charged-back. This means that even if you end your membership with us we may retain your personal data in order to meet our obligations. To determine the appropriate retention period forpersonal data, we consider the amount, nature and sensitivity of the personaldata, the potential risk of harm from unauthorised use or disclosure of yourpersonal data, the purposes for which we process your personal data and whetherwe can achieve those purposes through other means, and the applicable legal,regulatory, tax, accounting or other requirements.In some circumstances you can ask us to delete your data: see your legal rights below for furtherinformation.In some circumstances we will anonymise your personal data (sothat it can no longer be associated with you) for research or statisticalpurposes, in which case we may use this information indefinitely withoutfurther notice to you.
Your legal rights
Under certaincircumstances, you have rights under data protection laws in relation to yourpersonal data. If you wish to exercise any of the rights set out below, please contact us. If you are a member you cansign in to your Dashboard to access, rectify or update your personal data.
Access. This enables you to receive a copy of the personal information we hold aboutyou and to check that we are lawfully processing it.
Rectification. This enables you to have any incomplete or inaccurate information we hold aboutyou corrected.
Erasure. This enables you to ask us to delete or remove personal information where thereis no good reason for us continuing to process it.
Object. This enables you to object to processing of your personal information where weare relying on a legitimate interest (or those of a third party) and there issomething about your particular situation which makes you want to object toprocessing on this ground. You also have the right to object where we areprocessing your personal information for direct marketing purposes. In somecases, we may demonstrate that we have compelling legitimate grounds to processyour information which overrides your rights and freedoms.
This enables you to ask us to suspend the processing ofpersonal information about you, for example if you want us to establish itsaccuracy or the reason for processing it.
This enables you to request the transfer of your personalinformation to another party. We will provide to you, or a third partyyou have chosen, your personal data in a structured, commonly used,machine-readable format. Note that this right only applies to automatedinformation which you initially provided consent for us to use or where we usedthe information to perform a contract with you.No fee usually requiredYou will not have to pay a fee to access your personal data (or toexercise any of the other rights). However, we may charge a reasonable fee ifyour request is clearly unfounded, repetitive or excessive. Alternatively, we could refuse to comply with your request in these circumstances.
What we may need from you
We may only implement requests with respect to the personal dataassociated with the particular email address that you use to send us yourrequest. We may need to request specific information from you to help usconfirm your identity and ensure your right to access your personal data (or toexercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to yourrequest to speed up our response.
Time limit to respond
We try to respond to all legitimate requests within one month.Occasionally it could take us longer than a month if your request isparticularly complex or you have made a number of requests. In this case, we willnotify you and keep you updated.
Right to withdraw consent
In the limited circumstances where you may have provided your consent to the collection, processing and transfer of your personal information for a specificpurpose, you have the right to withdraw your consent for that specificprocessing at any time. To withdraw your consent, please contact our data privacy manager on the details above. Once we have received notification thatyou have withdrawn your consent, we will no longer process your information forthe purpose or purposes you originally agreed to, unless we have anotherlegitimate basis for doing so in law.