Privacy Policy

This privacy notice tells you what to expect us to do with your personal information.

· Contact details

· What information we collect, use, and why

· Lawful bases and data protection rights

· Where we get personal information from

· How long we keep information

· Who we share information with

· How to complain

We collect or use the following information for the operation of customer accounts and guarantees:

· Names and contact details

· Addresses

· Payment details (including card or bank information for transfers and direct debits)

· Account information, including registration details

· Information used for security purposes

· Marketing preferences

We collect or use the following information for service updates or marketing purposes:

· Names and contact details

· Marketing preferences

· Purchase or viewing history

· Records of consent, where appropriate

We collect or use the following information to comply with legal requirements:

· Name

· Contact information

· Financial transaction information

· Any other personal information required to comply with legal obligations

We collect or use the following personal information for dealing with queries, complaints or claims:

· Names and contact details

· Address

· Payment details

· Purchase or service history

Under UK data protection law, we must have a “lawful basis” for collecting and using your personal information. There is a list of possible lawful bases in the UK GDPR. You can find out more about lawful bases on the ICO’s website.

Which lawful basis we rely on may affect your data protection rights which are set out in brief below. You can find out more about your data protection rights and the exemptions which may apply on the ICO’s website:

· Your right of access - You have the right to ask us for copies of your personal information. You can request other information such as details about where we get personal information from and who we share personal information with. There are some exemptions which means you may not receive all the information you ask for. Read more about the right of access.

· Your right to rectification - You have the right to ask us to correct or delete personal information you think is inaccurate or incomplete. Read more about the right to rectification.

· Your right to erasure - You have the right to ask us to delete your personal information. Read more about the right to erasure.

· Your right to restriction of processing - You have the right to ask us to limit how we can use your personal information. Read more about the right to restriction of processing.

· Your right to object to processing - You have the right to object to the processing of your personal data. Read more about the right to object to processing.

· Your right to data portability - You have the right to ask that we transfer the personal information you gave us to another organisation, or to you. Read more about the right to data portability.

· Your right to withdraw consent – When we use consent as our lawful basis you have the right to withdraw your consent at any time. Read more about the right to withdraw consent.

If you make a request, we must respond to you without undue delay and in any event within one month.

To make a data protection rights request, please contact us using the contact details at the top of this privacy notice.

Our lawful bases for collecting or using personal information for the operation of customer accounts and guarantees are:

· Legitimate interests – we’re collecting or using your information because it benefits you, our organisation or someone else, without causing an undue risk of harm to anyone. All of your data protection rights may apply, except the right to portability. Our legitimate interests are:

o Personal information is collected so that questions and enquiries raised by customers can be answered quickly and effectively.

For more information on our use of legitimate interests as a lawful basis you can contact us using the contact details set out above.

Our lawful bases for collecting or using personal information for service updates or marketing purposesare:

· Legitimate interests – we’re collecting or using your information because it benefits you, our organisation or someone else, without causing an undue risk of harm to anyone. All of your data protection rights may apply, except the right to portability. Our legitimate interests are:

o Personal information is collected so that questions and enquiries raised by customers can be answered quickly and effectively.

For more information on our use of legitimate interests as a lawful basis you can contact us using the contact details set out above.

Our lawful bases for collecting or using personal information for legal requirements are:

· Legitimate interests – we’re collecting or using your information because it benefits you, our organisation or someone else, without causing an undue risk of harm to anyone. All of your data protection rights may apply, except the right to portability. Our legitimate interests are:

o Where called to to so, to comply with relevant legislation.

For more information on our use of legitimate interests as a lawful basis you can contact us using the contact details set out above.

Our lawful bases for collecting or using personal information for dealing with queries, complaints or claimsare:

· Legitimate interests – we’re collecting or using your information because it benefits you, our organisation or someone else, without causing an undue risk of harm to anyone. All of your data protection rights may apply, except the right to portability. Our legitimate interests are:

o Personal information is collected so that questions and enquiries raised by customers can be answered quickly and effectively.

For more information on our use of legitimate interests as a lawful basis you can contact us using the contact details set out above.

· Directly from you

Two months 

· Financial or fraud investigation authorities

· Relevant regulatory authorities

· Organisations we’re legally obliged to share personal information with

If you have any concerns about our use of your personal data, you can make a complaint to us using the contact details at the top of this privacy notice.

If you remain unhappy with how we’ve used your data after raising a complaint with us, you can also complain to the ICO.

The ICO’s address:           

Information Commissioner’s Office
Wycliffe House
Water Lane
Wilmslow
Cheshire
SK9 5AF

Helpline number: 0303 123 1113

Website: https://www.ico.org.uk/make-a-complaint