Privacy Policy Notice

We take your privacy very seriously. Please read this privacy policy carefully as it contains important information on who we are and how and why we collect, store, use and share your personal information. It also explains your rights in relation to your personal information and how to contact us or supervisory authorities in the event you have a complaint.

We collect, use and are responsible for certain personal data about you. When we do so we are subject to the UK General Data Protection Regulation (UK GDPR).

Key terms

It would be helpful to start by explaining some key terms used in this policy:

Personal information we collect about you

We may collect and use the following personal information about you:

• your name and contact information, including email address and telephone number
• information to enable us to check and verify your identity, eg your date of birth
• your gender information, if you choose to give this to us
• location data, if you choose to give this to us
• your billing information, transaction and payment card information
• your contact history, purchase history and saved items
• information from accounts you link to us, eg Facebook
• information to enable us to undertake credit or other financial checks on you
• information about how you use our website, IT, communication and other systems
• your responses to surveys, competitions and promotions

We may collect and use this personal data to provide products and services to you. If you do not provide personal information we ask for, it may delay or prevent us from providing products and services to you.

How your personal information is collected

We collect most of this personal information directly from you—in person, by telephone, text or email and/or via our website and apps. However, we may also collect information: 

• from publicly accessible sources, eg Companies House or HM Land Registry;
• directly from a third party, eg:
  • sanctions screening providers
  • credit reference agencies
  • customer due diligence providers
• from a third party with your consent, eg your bank or building society
• from cookies on our website—for more information on our use of cookies, please see our cookie policy

How and why we use your personal information

Under data protection law, we can only use your personal information if we have a proper reason for doing so, eg:

• to comply with our legal and regulatory obligations;
• for the performance of our contract with you or to take steps at your request before entering into a contract;
• for our legitimate interests or those of a third party; or
• where you have given consent.

A legitimate interest is when we have a business or commercial reason to use your information, so long as this is not overridden by your own rights and interests.

The table below explains what we use (process) your personal information for and our reasons for doing so:

The above table does not apply to special category personal information, which we will only process with your explicit consent.

Promotional communications

We may use your personal information to send you updates (by email, text message, telephone or post) about our products and services, including exclusive offers, promotions or new products and services.

We have a legitimate interest in processing your personal information for promotional purposes (see above ‘How and why we use your personal information’). This means we do not usually need your consent to send you promotional communications. However, where consent is needed, we will ask for this consent separately and clearly.

We will always treat your personal information with the utmost respect and never sell it with other organisations for marketing purposes.

You have the right to opt out of receiving promotional communications at any time by:

• contacting us
• using the ‘unsubscribe’ link in emails

We may ask you to confirm or update your marketing preferences if you instruct us to provide further products and services in the future, or if there are changes in the law, regulation, or the structure of our business.

Who we share your personal information with

We routinely share personal information with:

• third parties we use to help deliver our products and services to you, eg payment service providers;
• other third parties we use to help us run our business, eg marketing agencies or website hosts;
• third parties approved by you, eg social media sites you choose to link your account to or third party payment providers; and
• credit reference agencies.

We only allow our service providers to handle your personal information if we are satisfied they take appropriate measures to protect your personal information. We also impose contractual obligations on service providers relating to ensure they can only use your personal information to provide services to us and to you. We may also share personal information with external auditors.

We may disclose and exchange information with law enforcement agencies and regulatory bodies to comply with our legal and regulatory obligations.

We may also need to share some personal information with other parties, such as potential buyers of some or all of our business or during a re-structuring. Usually, information will be anonymised but this may not always be possible. The recipient of the information will be bound by confidentiality obligations.

Where your personal information is held

Personal data may be held at our offices and those of our group companies, third party agencies, service providers, representatives and agents as described above (see above: ‘Who we share your personal information with’).

Some of these third parties may be based outside the UK. For more information, including on how we safeguard your personal data when this happens, see below: ‘Transferring your personal data out of the UK’.

How long your personal information will be kept

We will keep your personal information while you have an account with us or we are providing products and services to you. Thereafter, we will keep your personal information for as long as is necessary:

• to respond to any questions, complaints or claims made by you or on your behalf;
• to show that we treated you fairly;
• to keep records required by law.

We will not retain your personal information for longer than necessary for the purposes set out in this policy. Different retention periods apply for different types of personal information.

Transferring your personal information out of the UK

To deliver services to you, it is sometimes necessary for us to share your personal data outside the UK, eg:

• with your and our service providers located outside the UK;
• if you are based outside the UK; or
• where there is a European and/or international dimension to the services we are providing to you.

Under data protection law, we can only transfer your personal data to a country or international organisation outside the UK where:

• the UK government or, where the EU GDPR applies, the European Commission has decided the particular country or international organisation ensures an
• adequate level of protection of personal data (known as an ‘adequacy decision’);
• there are appropriate safeguards in place, together with enforceable rights and effective legal remedies for data subjects; or
• a specific exception applies under data protection law

These are explained below.

Adequacy decision

We may transfer your personal data to certain countries, on the basis of an adequacy decision. These include:

• all European Union countries, plus Iceland, Liechtenstein and Norway (collectively known as the ‘EEA’);
• Gibraltar; and
• Andorra, Argentina, Canada, Faroe Islands, Guernsey, Israel, Isle of Man, Japan, Jersey, New Zealand, Switzerland and Uruguay.

The list of countries that benefit from adequacy decisions will change from time to time. We will always seek to rely on an adequacy decision, where one exists.

Other countries or international organisations we are likely to transfer personal data to do not have the benefit of an adequacy decision. This does not necessarily mean they provide poor protection for personal data, but we must look at alternative grounds for transferring the personal data, such as ensuring appropriate safeguards are in place or relying on an exception, as explained below.

Transfers with appropriate safeguards

Where there is no adequacy decision, we may transfer your personal data to another country or international organisation if we are satisfied the transfer complies with data protection law, appropriate safeguards are in place, and enforceable rights and effective legal remedies are available for data subjects.

The safeguards will usually include using legally-approved standard data protection contract clauses

To obtain a copy of the standard data protection contract clauses and further information about relevant safeguards please contact us (see ‘How to contact us’ below).

Transfers under an exception

In the absence of an adequacy decision or appropriate safeguards, we may transfer personal data to a third country or international organisation where an exception applies under relevant data protection law, eg:

• you have explicitly consented to the proposed transfer after having been informed of the possible risks;
• the transfer is necessary for the performance of a contract between us or to take pre-contract measures at your request;
• the transfer is necessary for a contract in your interests, between us and another person; or
• the transfer is necessary to establish, exercise or defend legal claims.

We may also transfer information for the purpose of our compelling legitimate interests, so long as those interests are not overridden by your interests, rights and freedoms. Specific conditions apply to such transfers and we will provide relevant information if and when we seek to transfer your personal data on this ground.

Further information

If you would like further information about data transferred outside the UK, please contact us (see ‘How to contact us’ below).

Your rights

You have the following rights, which you can exercise free of charge:

For further information on each of those rights, including the circumstances in which they apply, please contact us or see the Guidance from the UK Information Commissioner’s Office (ICO) on individuals’ rights under the General Data Protection Regulation.

If you would like to exercise any of those rights, please:

• email, call or write to us—see below: ‘How to contact us’;
• let us have enough information to identify you;
• let us have proof of your identity and address (a copy of your driving licence or passport and a recent utility or credit card bill); and
• let us know what right you want to exercise and the information to which your request relates.

Keeping your personal information secure

We have appropriate security measures to prevent personal information from being accidentally lost, or used or accessed unlawfully. This includes the use of SSL technology, two-factor authentication and Wordfence security. We limit access to your personal information to those who have a genuine business need to access it. Those processing your information will do so only in an authorised manner and are subject to a duty of confidentiality.

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

If you want detailed information from Get Safe Online on how to protect your information and your computers and devices against fraud, identity theft, viruses and many other online problems, please visit www.getsafeonline.org. Get Safe Online is supported by HM Government and leading businesses.

How to complain

We hope to resolve any query or concern you may raise about our use of your information.

The General Data Protection Regulation also gives you right to lodge a complaint with a supervisory authority, in particular in the European Union (or European Economic Area) state where you work, normally live or where any alleged infringement of data protection laws occurred. The supervisory authority in the UK is the Information Commissioner who may be contacted at https://ico.org.uk/concerns or telephone: 0303 123 1113.

Changes to this privacy policy

This privacy notice was published on 15/02/2021 and last updated on 15/02/2021.

We may change this policy from time to time, when we do we will inform you via email.

How to contact us

Please contact us by post, email or telephone if you have any questions about this privacy policy or the information we hold about you.

Our contact details are shown below:

Do you need extra help?

If you would like this notice in another format (for example audio, large print, braille) please contact us (see ‘How to contact us’ above).

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