Privacy Policy

2.2.We may collect, use, store and transfer different kinds of personal data about you as follows:

a) Identity Data includes first name, last name, phone number, title, date of birth and gender.

b) Contact Data includes postal address, email address and telephone numbers.

c) Financial Data includes bank account and payment card details.

d) Transaction Data includes details about payments you make to us and other details of services you have purchased from us.

e) Technical Data includes 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 or use our services.

f) Profile Data includes your username and password, orders you’ve placed, your preferences, feedback and survey responses.

g)Marketing Data includes your preferences in receiving marketing from us and our third parties and details on how you would prefer to be contacted.

h) Communications Data includes call data records, voicemail, call recordings, email logs, mailboxes, faxes and web logs.

i) Usage Data includes information about how you use our website and services, the third party listed organisations you were looking for and those you contacted.

2.3.We also collect, use and share aggregated data such as statistical or demographic data for any purpose. Aggregated data may be derived from your personal data but is not considered personal data in law as this data does not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website or service feature. However, if we combine or connect aggregated data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy policy.

2.4.We do not collect any special categories of personal data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data). Nor do we collect any information about criminal convictions and offences.

2.5.Our website and our services are not intended for children and we do not knowingly collect data relating to children.

a) Direct interactions. You may give us your Identity, Contact and Financial Data by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:

i) Request our products and services (including completing order forms for our services);

ii) Create an account on our website;

iii) Request marketing to be sent to you;

iv) Enter a competition, promotion or survey;

v) Use our services;

vi) Contact us about queries concerning our services or any other matter;

vii) Give us feedback about our services;

viii) Use the social media functions of our website;

ix) Make a complaint.

b) Automated technologies or interactions. As you interact with our websites and use our services, we may automatically collect Technical Data and Communications Data about your equipment, browsing actions and patterns, and device type. We collect this personal data by using cookies, server logs and other similar technologies.We may also engage Third Parties to provide analytical data which we use to help us improve our services (see below). You can manage your privacy preferences in your browser settings, please refer to the Cookie Policy for further details.

c) Third parties or publicly available sources. We may receive personal data about you from external parties conducting their business activities, as well as the following Technical Data from the following parties:

i) Analytics providers, such as Google;

ii) Search information providers, such as Google and Bing;

iii) Credit reference agencies.

a) Where we need to perform a contract -processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract. Where we need it to deal with your query, feedback or complaint you send to us.

b)Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override these. This enables us to give you the best service/product and the best and most secure experience. We consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do 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).

c)Where we need to comply with a legal or regulatory obligation that we are subject to.

d) Where specific consent has been provided by the data subject.

e) In order to protect the vital interests of a person.

f) To perform a task in the public interest or exercise official authority. Further information can be found on the ICO website.

4.2.Generally, we do not rely on consent as a legal basis for processing your personal data other than in relation to sending third party direct marketing communications to you via email or text message. You have the right to withdraw consent to marketing at any time by contacting us.

Purposes for which we will use your personal data

4.3.We have set out in the table below, the lawful bases that may apply to collect and process your personal data

4.4. It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes or corrections are required during your relationship with us. We will update our records without undue delay.
Marketing

4.5. We provide you with choices regarding the use of your personal data, particularly around marketing and advertising. If you decide to opt-out, we will not use your data for marketing purposes and only contact you with operational communications.

4.6. We use your Identity, Contact, Technical, Usage and Profile Data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which products, services and offers may be relevant for you (we call this ‘marketing’).

4.7. You will receive marketing communications from us if you have requested information from us or purchased goods 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.

4.8. We never share your personal data with another company for marketing purposes without your express consent.
Opting out

4.9. You can opt-out of marketing messages at any time by selecting the ‘Unsubscribe’ links in the message or by contacting us.

4.10. Please refer to the Cookie Policy for managing privacy settings whilst visiting our website.
Change of purpose

4.11. We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason where sound lawful justification applies. If we need to use your personal data for an unrelated purpose, we will notify you and explain the legal basis which allows us to do so.

4.12. In some circumstances we may anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes and for reasons to improve our products and services, in which case we may use this information indefinitely without further notice to you.

4.13. Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

a) Internal Third Parties

These are other companies within the same group as Gradwell (that is, having common shareholders and directors) acting as processors and who are based in the UK and provide and use shared IT and system administration services and undertake leadership reporting.

b) External Third Parties

These are:

i) Service providers providing IT, sales-support, service-delivery, marketing analysis and system administration services which we require or wish to use in connection with providing our services to you.

ii) The relevant select partner Gradwell has appointed (where you remain a customer of Gradwell as a result of the ongoing involvement of that select partner).

iii) Secure data centre providers whose services we use as part of providing our services.

iv) Credit reference agencies for the purpose of assessing your credit score.

v) Professional advisers acting as joint processors and controllers including lawyers, bankers, accountants, auditors and insurers based the UK who provide consultancy, banking, legal, insurance and accounting services.

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

vii) Relevant regulators in the UK including but not limited to Ofcom, the Phone-paid Services Authority and the Information Commissioner’s Office.

c) Third parties to whom we may choose to sell, transfer, or merge parts of our business or our assets.

Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy policy.

5.2.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 and in accordance with our instructions.

6.1.Following the departure of the UK from the European Union, personal data transfers from the European Economic Area (EEA)to the UK will be affected. If you wish or are required to pass to Gradwell personal data belonging to your users, customers or employees as part of Gradwell providing services to you, until the EU Commission rules in favour of the UK an ‘adequacy decision’ for the purposes of chapter V of the GDPR, the parties will use their reasonable endeavours to promptly enter into an agreement comprised of the standard contractual clauses recognised by the EU as an ‘appropriate safeguard’ under article 46 of the GDPR

6.2. We engage third parties who are based outside the European Economic Area (‘EEA’) and their processing of your personal data will involve a transfer of data outside the EEA to assist us fulfil our contract with you. Such transfers are only undertaken where law permits, and the appropriate safeguards are applied to protect your data. This may be via:

a) a recognised Adequacy Agreement,

b) Standard Contractual Clauses, or

c) Binding Corporate Rulesapproved by the European Commission.

And will be on a case-by-case basis.

EU Representation

6.3. We have appointed IT Governance Europe Limited to act as our EU representative. If you wish to exercise your rights under the EU General Data Protection Regulation (EU GDPR), or have any queries in relation to your rights or general privacy matters, please email our Representative at eurep@itgovernance.eu. Please ensure you include our company name in all correspondence you send to our Representative.