Registered address: Highdown House, 11 Highdown Road, Leamington Spa, CV31 1XT
Email address: email@example.com
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.
If You Would Like To Opt Out
You can opt out by unsubscribing to any marketing communication you receive or contacting us in writing at the address above.
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 not include 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:
“Identity and Contact Data” includes first name, maiden name, last name, username, email address and telephone numbers.
“Technical Data” includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, and other technology on the devices you use to access this website.
“Profile Data” includes your username and password, any feedback and survey responses.
“Usage Data” includes information about how you use our websites, products and services.
“Financial and Credit Data” includes information from credit reference agencies providing information on your credit history and any financial and credit card information relevant to the services you have requested.
“Business Requirements Data” includes information provided about your business requirements in relation to the services we offer.
We do not collect any “Special Categories of Personal Data” about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health, and genetic and biometric data). Nor do we collect any information about criminal convictions and offences.
If you fail to provide personal data where we need to collect personal data by law, or under the terms of a contract we have with your employer/business, and you fail to provide that data when requested, we may not be able to perform the contract we have or you may not be able to access our services, we will notify your employer/business.
How Is Your Personal Data Collected?
We use different methods to collect data from and about you including through:
Direct interactions. You may give us your Identity and Contact Data by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:
Use our website, subscribe or contract to use our products or services, search for a product, obtain a quote, place an order, create an account on our websites, subscribe to any of our publications, enter a competition, promotion or survey, participate in discussion boards or social media functions, give us feedback or contact us.
Third parties or publicly available sources. We will receive personal data about you from your employer/business and also various third parties and public sources as set out below:
– Analytics providers, Identity and Contact Data from publicly available sources, Identity and Contact Data from data brokers, aggregators or 3rd parties who refer clients to us who may require our services, Contact, Financial and Transaction Data from providers of technical, payment and delivery services, advertising networks, search information providers and credit reference agencies.
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 are about to enter into or have entered into with your employer/business, where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests and where we need to comply with a legal obligation.
Purposes for which we will use your personal data:
To make suggestions and recommendations to you about goods or services that may be of interest to your employer/business.
To use data analytics to improve our websites, products/services, marketing, customer relationships and experiences.
To deliver relevant website content and advertisements to your employer/business and measure or understand the effectiveness of the advertising we serve to you.
To administer and protect our business and websites (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data).
To enable you to partake in a prize draw, competition or complete a survey.
To consider requests to enter into contracts with us – this is done on the basis of our considering entering a contract.
To carry out obligations arising from any contracts entered into between you and us and to provide you with the information, products and services that you request from us – where the contract is with you this is done on the basis of our contract, if you are not a party to the contract it is done because it is in our legitimate interests and those of your employer/business.
To process and deliver the services including: (a) Manage payments, fees and charges from your employer/business (b) Collect and recover money owed to us from your employer/business (c) prevent fraud.
To provide you, or permit selected third parties to provide you, with information about other goods or services we feel may interest you. If you want us to use your data in this way, or to pass your details on to third parties for marketing purposes, please tick the relevant box situated on the form on which we collect your data – the consent provided is the basis for this use of data.
If you are a company or unincorporated business, to search records of individuals who are your major shareholders, directors, principles, partners, other officers, guarantors and or indemnifiers – this is done on the basis necessary to enter a contract.
To check individual identity to prevent money laundering, this is completely as part of our regulatory obligations and consideration of entering into a contract process.
For training purposes.
Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below.
We may provide you with choices regarding certain personal data uses, particularly around marketing and advertising.
Change of Purpose
We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.
If we need to use your personal data for an unrelated purpose, we will 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 your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.
Disclosure of Your Personal Data
We may share your personal data with the third parties including:
Business partners, suppliers and sub-contractors for the performance of any contract we enter into or are considering entering into with them or you.
When searching your record at one or more credit reference agencies from time to time for the purpose of assessing your credit score where there is a condition of us entering a contract with you. Please be aware that these agencies will add to your record details of our searches and this will be seen by other organisations carrying out later searches.
When checking your details with one or more fraud prevention agencies and recording any false or inaccurate information.
To check an individual’s identity to prevent money laundering, unless the individual furnishes us with other satisfactory proof of identity.
To trace debtors, recover debt, prevent fraud and to manage individual’s accounts or insurance policies.
To help us make decisions about credit and credit-related services for individuals and members of their household.
By adding to your record with any relevant credit reference agency the details of any agreement with us and your performance under it.
If you wish to transfer to any business providing a similar service to ours, including (without limitation) insurers, guarantors and professional advisors to whom you may wish to transfer, any business to which we may wish to transfer our rights or duties and any merchant acquirer which we consider may be suitable for your business.
We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.
Some of our external third parties may be based outside the EEA so their processing of your personal data will involve a transfer and storage of data outside the EEA. It may also be processed by staff operating outside of the EEA who work for us or one of our suppliers. By submitting your personal data, you agree to this transfer, storing or processing.
Whenever we transfer your personal data out of the EEA, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:
All data transferred outside of the EEA is done so under contracts with our data processors to ensure they meet the appropriate standards.
Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the EEA.
We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.
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.
Where we have given you a password which enables you to access certain parts of our site, you are responsible for keeping this password confidential and it is not to be shared with anyone.
Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted to our site. Any transmissions are at your own risk.
Data Retention – How long will you use my personal data for?
We will only retain your personal data for as long as is reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you or your employer.
To determine the appropriate retention period for personal data, we consider the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements.
By law we must keep basic information about our customers and our users (including Contact, Identity, Financial and Transaction Data) for six years after they cease being customers for tax purposes.
In some circumstances you can ask us to delete your data: see below for further information.
In some circumstances we will anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes, in which case we may use this information indefinitely without further notice to you.
Your Legal Rights
Under certain circumstances, you have rights under data protection laws in relation to your personal data, as set out in this policy. If you wish to exercise any of your rights, please contact us. No fee is usually required.
You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your 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 need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise 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 your request 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 is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.
You have the right to:
“Request access” to your personal data (commonly known as a “data subject access request”). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
“Request correction” of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
“Request erasure” of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
“Object to processing” of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
“Request restriction of processing” of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios:
If you want us to establish the data’s accuracy.
Where our use of the data is unlawful but you do not want us to erase it.
Where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims.
You have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
“Request the transfer” of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
“Withdraw consent at any time” where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.