Why We Collect & Use Your Personal Data

Typically, we will use your personal data where:

• We must comply with a legal or regulatory obligation

• We need to enact and undertake work relating to the contract we are about to enter into or have entered into with you

• It is necessary for our legitimate interests and your interests, and fundamental rights do not override those interests

 

We will only use your personal data when the law allows us to so we can provide you with the best possible service.  We do not generally rely on consent as a legal basis for processing your personal data, other than in relation to sending direct marketing communications to you.  You have the right to withdraw consent to marketing at any time, and should contact us to do so.  When we collect and use your personal data for purposes mentioned above or for other purposes, we will inform you before or at the time of collection.

​

Purposes for Which We Use Your Personal Data

We have laid out a description of the purposes for which we may use your personal data below, and which legal basis we rely on to do so.  We may process your personal data for more than one lawful ground.  You are welcome to contact us if you wish to have details on specific legal ground(s) we are relying on to process your personal data.

​

To register you as a new customer

Identity and Contact Data for the performance of a contract with you

​

To progress the delivery of services to you, for example, management of charges, fees, and payments, management of recruitment, recovery of money owed 

Identity, Contact, Financial, Transaction and Marketing & Communications Data for the performance of a contract with you and necessary for our legitimate interests (the recovery of debts owed to us)

​

To maintain our relationship with you, for example, informing you of changes to terms or policies, requesting completion of a survey or review

To allow you to take part in promotional activities such as competitions, prize draws and surveys

To deliver marketing content to you and measure its effectiveness

To suggest services that may be of interest to you

To use analytics to improve all aspects of our business

Identity, Contact, Profile, Usage, Technical and Marketing & Communications Data for the performance of a contract with you, necessary to comply with a legal or regulatory obligation, and necessary for our legitimate interests (keeping records up to date and understanding how customers use our services, developing services and grow our business)
 

To undertake administration and protection of all aspects of our business, for example, troubleshooting, testing, and maintenance

Identity, Contact and Technical Data that is necessary for our legitimate interests (for running our business, digital risk and security, and fraud prevention) 

​

The term “legitimate interests” means the interests of our company in conducting and managing our business to enable us to give you the best service.  When we process your personal information for our legitimate interests, we consider and balance any potential impact (positive and negative) on you, and your rights under data protection laws.  We will not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law).

​

The term "performance of contract" means processing your data where it is necessary for undertaking what is being or has been defined in a contract to which you are a party.

​

The term "comply with a legal or regulatory obligation" means processing your personal data where it is necessary for us to comply with legal or regulatory requirements or demands to which we are subjected. 

​

Personal Data Control

We may use your personal data to generate a view on products, services and offers we think may be of interest to you.  You will receive marketing communications from us if you have requested information or services from us or if you provided us with your details when you entered a competition or registered for a promotion and, in each case, you have not opted out of receiving that marketing.  We will get your express opt-in consent before we share your personal data with any other organisation.  You can ask us to stop sending you marketing messages at any time by contacting us, however this will not apply to personal data provided to us as a result of purchasing a service from us where it is used in relation to that specific service.

 

We may have to share your personal data for the purposes set out above with the following parties:

• Other External Organisations, defined as:

  • Service providers acting as processors based in the UK who provide IT (including website) and system administration services

  • Professional advisers and recruitment support advisors acting as processors or joint controllers including associates, lawyers, bankers, auditors and insurers based in the UK who provide consultancy, banking, legal, insurance and accounting services

  • HM Revenue & Customs, regulators and other authorities acting as processors or joint controllers based in the United Kingdom who require reporting of processing activities in certain circumstances.

• Other organisations to whom we may choose to sell, transfer, or merge parts of our business or our assets.   Similarly, we may seek to acquire other businesses or merge with them.  Should such a change occur in our business, then the new owners may use your personal data in the same way as set out in this Privacy Notice.

 

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 in accordance with our instructions.

​

We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed, altered or disclosed in an unauthorised way.  We limit access to your personal data only to those employees, agents, contractors and other organisations 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 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.

​

Retaining Your Personal Data

We will only retain your personal data for as long as is necessary to fulfil the purposes for which it was collected.  This includes satisfying any legal, accounting, or reporting requirements.  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 requirements.  By law we have to keep basic information about our customers (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. Please see ‘the right to erasure of your personal data’ below for further information.  In some circumstances we may 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 Rights

You are entitled to a series of rights where we process your personal data and you can exercise these rights at any point; an overview of these rights is below which you can exercise by contacting us.

​