1. What does this Policy cover?
This Privacy Information explains how we use your personal data: how it is collected, how it is held, and how it is processed. It also explains your rights under the law relating to your personal data.
2. What is Personal Data?
Personal data is defined by the General Data Protection Regulation (EU Regulation 2016/679) (the “GDPR”) as ‘any information relating to an identifiable person who can be directly or indirectly identified in particular by reference to an identifier’.
Personal data is, in simpler terms, any information about you that enables you to be identified. Personal data covers obvious information such as your name and contact details, but it also covers less obvious information such as identification numbers, electronic location data, and other online identifiers.
The personal data that we use is set out in Section 4, below.
3. What are my rights?
Under the GDPR, if you are a resident in the EEA, you have the following rights, which we will always work to uphold:
The right to be informed about our collection and use of your personal data. This Privacy Notice should tell you everything you need to know, but you can always contact us to find out more or to ask any questions using the details in Section 10.
The right to access the personal data we hold about you. Section 9 will tell you how to do this.
The right to have your personal data rectified if any of your personal data held by us is inaccurate or incomplete. Please contact us using the details in Section 10 to find out more.
The right to be forgotten, i.e. the right to ask us to delete or otherwise dispose of any of your personal data that we have. Please contact us using the details in Section 10 to find out more.
The right to restrict (i.e. prevent) the processing of your personal data.
The right to object to us using your personal data for a particular purpose or purposes
The right to data portability. This means that you can ask us for a copy of your personal data held by us to re-use with another service or business in many cases.
Rights relating to automated decision-making and profiling. We do not use your personal data in this way.
For more information about our use of your personal data or exercising your rights as outlined above, please contact us using the details provided in Section 10.
4. What Personal Data do you collect?
We may collect some or all of the following personal data (this may vary according to your relationship with us:
Information provided by third parties;
Information about how you access and use our services (e.g.: pages visited, referral website);
Information about your device (e.g.: anonymized IP address, type of device);
Comments and opinions that you express when you contact us via email, phone or chat.
5. How is my personal data used?
Under the GDPR, we must always have a lawful basis for using personal data. This may be because the data is necessary for our performance of a contract with you, because you have consented to our use of your personal data, or because it is in our legitimate business interests to use it. Your personal data will be used for the following purposes:
Providing and managing your account (legal basis: contractual).
Supplying our products and services to you. Your personal details are required in order for us to enter into a contract with you (legal basis: contractual).
Personalising, improving and tailoring our products and services for you (legal basis: legitimate interests).
Communicating with you. This may include responding to emails or calls from you (legal basis: contractual and legitimate interests).
Supplying you with information by email or post that you have opted-in to. You may unsubscribe or opt-out at any time by updating your communication preferences in the user profile page of your product or by clicking the unsubscribe link in our emails to you (legal basis: legitimate interests).
With your permission and/or where permitted by law, we may also use your personal data for marketing purposes, which may include contacting you by email or telephone or post with information, news, and offers on our products and services. You will not be sent any unlawful marketing or spam. We will always work to fully protect your rights and comply with our obligations under the GDPR and the Privacy and Electronic Communications (EC Directive) Regulations 2003, and you will always have the opportunity to opt-out.
6. For how long will you keep my personal data?
We will not keep your personal data for any longer than is necessary in light of the reason(s) for which it was first collected. Your personal data will therefore be kept for the following periods (or, where there is no fixed period, the following factors will be used to determine how long it is kept):
We will use and store your personal data for as long as it is necessary to provide our service to you and for the purpose of satisfying any legal, accounting or reporting requirements. Thereafter we will only keep data in anonymised form so that it can no longer be associated with you to help improve our products and services;
if you are not a customer and we have your personal data for the purpose of communicating with you we will use it and store it until either you let us know that you no longer want to receive communications from us or for a period of up to 24 months;
7. How and Where do you store my personal data?
We may store or transfer some or all of your personal data in countries that are not part of the European Economic Area (the “EEA” consists of all EU member states, plus Norway, Iceland, and Liechtenstein). These are known as “third countries” and may not have data protection laws that are as strong as those in the UK and/or the EEA. This means that we will take additional steps in order to ensure that your personal data is treated just as safely and securely as it would be within the UK and under the GDPR including:
Having a GDPR-compatible Data Processing Addendum with sub-processors in third countries;
Making sure that such sub-processors have adequate security procedures in place.
The security of your personal data is essential to us, and to protect your data, we take a number of important measures, including the following:
Encrypting your data while it is in transit;
Where possible, encrypting your data when it is stored;
8. Do you share my personal data?
We may sometimes contract with the following third parties to supply products and services to you on our behalf. These may include payment processing, delivery, and marketing. In some cases, those third parties may require access to some or all of your personal data that we hold. You can check the list of sub processors here.
If any of your personal data is required by a third party, as described above, we will take steps to ensure that your personal data is handled safely, securely, and in accordance with your rights, our obligations, and the third party’s obligations under the law.
We may sometimes contract with third parties (as described above) that are located outside of the European Economic Area (the “EEA” consists of all EU member states, plus Norway, Iceland, and Liechtenstein). If any personal data is transferred to a third party outside of the EEA, we will take suitable steps in order to ensure that your personal data is treated just as safely and securely as it would be under the GDPR, as explained above in Section 7.
In some limited circumstances, we may be legally required to share certain personal data, which might include yours, if we are involved in legal proceedings or complying with legal obligations, a court order, or the instructions of a government authority.
9. How can I access my personal data?
If you want to know what personal data we have about you, you can ask us for details of that personal data and for a copy of it (where any such personal data is held). This is known as a “subject access request”.
All subject access requests should be made in writing and sent to the email or postal addresses shown in Section 10.
There is not normally any charge for a subject access request. If your request is ‘manifestly unfounded or excessive’ (for example, if you make repetitive requests) a fee may be charged to cover our administrative costs in responding.
We will respond to your subject access request within 21 days and, in any case, not more than one month of receiving it. Normally, we aim to provide a complete response, including a copy of your personal data within that time. In some cases, however, particularly if your request is more complex, more time may be required up to a maximum of three months from the date we receive your request. You will be kept fully informed of our progress.
10. How can I contact you?
To contact us about anything to do with your personal data and data protection, including to make a subject access request, visit the contact us page
11. Changes to this Privacy Notice
We may change this Privacy Notice from time to time. This may be necessary, for example, if the law changes, or if we change our business in a way that affects personal data protection.
Any changes will be made available here and where applicable we might also notify you via email and/or in our products.
Version 1.0, 15 January 2020