Privacy and cookie notice

4.2. We envisage collecting the following types of information from you:

a. From you when you agree to take a service or product from us, in which case this may include your contact details, date of birth, how you will pay for the product or service and your bank details.

b. From you when you contact us with an enquiry or in response to a communication from us, in which case, this may tell us something about how you use our services.

c. As you interact with this Website, we may automatically collect technical information about your equipment, browsing actions and patterns (such as your 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). We may collect this personal information by using cookies and other similar technologies.

d. From documents that are available to the public, such as the electoral register.

e. From third parties to whom you have provided information with your consent to pass it on to other organisations or persons – when we receive such information we will let you know as soon as is reasonably practicable.

4.3. If you refuse to provide information requested, then if that information is necessary for a service we provide to you we may need to stop providing that service.

4.4. If at any point you think we’ve invited you to provide information without explaining why, feel free to object and ask for our reasons.

5. Using your personal information

5.1. Data protection, privacy and security are important to us, and we shall only use your personal information for specified purposes and shall not keep such personal information longer than is necessary to fulfil these purposes. The following are examples of such purposes. We have also indicated below which UK GDPR justification applies, however it will depend on the circumstances of each case.

a. To help us to identify you when you contact us. This will normally be necessary for the performance of our contract.

b. To help us to identify accounts, services and/or products which you could have from us or selected partners from time to time. We may do this by automatic means using a scoring system, which uses the personal information you’ve provided and/or any information we hold about you and personal information from third party agencies (including credit reference agencies). We will only use your information for this purpose if you agree to it.

c. To help us to administer and to contact you about improved administration of any accounts, services and products we have provided before, do provide now or will or may provide in the future. This will often be necessary, but sometimes the improvements will not be necessary in which case we will ask whether you agree.

d. To allow us to carry out marketing analysis and customer profiling (including with transactional information), conduct research, including creating statistical and testing information. This will sometimes require that you consent, but will sometimes be exempt as market research.

e. To help to prevent and detect fraud or loss. This will only be done in certain circumstances when we consider it necessary or the law requires it.

f. To allow us to contact you by written electronic means (such as email, text or multimedia messages) about products and services offered by us where:

• • • these products are similar to those you have already purchased from us,
    • you were given the opportunity to opt out of being contacted by us at the time your personal information was originally collected by us and at the time of our subsequent communications with you, and
    • you have not opted out of us contacting you.

g. To allow us to contact you in any way (including mail, email, telephone, visit, text or multimedia messages) about products and services offered by us and selected partners where you have expressly consented to us doing so.

h. We may monitor and record communications with you (including phone conversations and emails) for quality assurance and compliance.

• • • Before doing that, we will always tell you of our intentions and of the specific purpose in making the recording. Sometimes such recordings will be necessary to comply with the law. Alternatively, sometimes the recording will be necessary for our legitimate interest, but in that case we’ll only record the call if our interest outweighs yours. This will depend on all the circumstances, in particular the importance of the information and whether we can obtain the information another way that’s less intrusive.
    • If we think the recording would be useful for us but that it’s not necessary for our legitimate interest, we’ll ask whether you consent to the recording, and will provide an option for you to tell us that you consent. In those situations, if you don’t consent, the call will either automatically end or will not be recorded.

i. When it’s required by law, we’ll check your details with fraud prevention agencies. If you provide false or inaccurate information and we suspect fraud, we intend to record this.

5.2. We will not disclose your personal information to any third party except in accordance with this Notice, and then only in one of the following circumstances:

a. They will be processing the data on our behalf as a data processor (where we’ll be the data controller). In that situation, we’ll always have a contract with the data processor as set out in the UK GDPR. This contract provides significant restrictions as to how the data processor operates so that you can be confident your data is protected to the same degree as provided in this Notice.

b. Sometimes it might be necessary to share data with another data controller. Before doing that we’ll always tell you. Note that if we receive information about you from a third party, then as soon as reasonably practicable afterwards we’ll let you know; that’s required by the UK GDPR.

c. Alternatively, sometimes we might consider it to be in your interest to send your information to a third party. If that’s the case, we’ll always ask whether you agree before sending.

5.3. Where you give us personal information on behalf of someone else, you confirm that you have provided them with the information set out in this Notice and that they have not objected to such use of their personal information.

5.4. In connection with any transaction which we enter into with you:

a. If you provide false or inaccurate information to us and we suspect fraud, we will record this and may share it with other people and organisations. We, and other credit and insurance organisations, may also use technology to detect and prevent fraud.

b. We may need to transmit the payment and delivery information provided by you during the order process for the purpose of obtaining authorisation from your bank or from PayPal.

5.5. We may allow other people and organisations to use personal information we hold about you in the following circumstances:

a. If we, or substantially all of our assets, are acquired or are in the process of being acquired by a third party, in which case personal information held by us, about our customers, will be one of the transferred assets.

b. If we have been legitimately asked to provide information for legal or regulatory purposes or as part of legal proceedings or prospective legal proceedings.

c. We may employ companies and individuals to perform functions on our behalf and we may disclose your personal information to these parties for the purposes set out above, for example, for fulfilling orders, delivering packages, sending postal mail and email, removing repetitive information from customer lists, analysing data, providing marketing assistance, providing search results and links (including paid listings and links) and providing customer service. From time to time, these other people and organisations to whom we may pass your personal information may be outside the European Economic Area. We will take all steps reasonably necessary to ensure that your personal information is treated securely and in accordance with this Notice and the UK GDPR. We require all third-party service providers processing your personal information for us (as our data processor) to respect the security of your personal data and to treat it in accordance with the law. We do not allow them 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.