Key terms used in this policy:
Genetic and biometric data
Data concerning health, sex life or sexual orientation
PERSONAL INFORMATION WE COLLECT ABOUT YOU
We may collect and use the following personal information about you:
- your name, and any emergency contact’s name, contact information, including, address, email address and telephone number
- your employer’s details, your job title and the benefits you receive
- Information to enable us to check and verify your identity and book services on your/your company’s behalf eg your date of birth, drivers licence, passport details, home address
- your gender information
- details of who you reside with and their use of our services
- location data, where you use our applications or inform us of it
- your billing information, transaction and payment card information and history
- details of the modes of transport you use, destinations you travel to, accommodation preferences, your travel habits and who may travel with you
- your contact history, purchase history and saved items
- information from accounts you link to us eg social media accounts
- information to enable us to undertake credit or other financial checks on you
- information about how you use our website, including where you navigate to once you leave our website, IT, communication and other systems
- your responses to surveys, competitions and promotions
This personal information is required to provide products and/or services to you, to enable us to improve our services and tailor them to your and our corporate customers’ needs. If you do not provide personal information we ask for, it may delay or prevent us from providing our services to you.
HOW YOUR PERSONAL INFORMATION IS COLLECTED
We collect most of this personal information directly from you or your employer by telephone, text or email, in person, through our website and our applications. However, we may also collect information:
- from publicly accessible sources, eg Companies House or HM Land Registry;
- directly from a third party, eg:
- government organisations where you or your employer has provided consent for us to obtain it;
- a local authority where you have accessed our services through that organisation;
- credit reference agencies;
- customer due diligence providers;
- other companies where we provide services on their behalf.
- from a third party with your consent, eg your bank or building society
- via our IT systems, eg:
- door entry systems and reception logs;
- automated monitoring of our websites and other technical systems, such as our computer networks and connections, CCTV and access control systems, communications systems, email and instant messaging systems;
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:
Screening for financial and other sanctions or embargoes
Other processing necessary to comply with professional, legal and regulatory obligations that apply to our business, eg under health and safety regulation or rules issued by our professional regulator
To comply with our legal and regulatory obligations
To comply with our legal and regulatory obligations
For our legitimate interests or those of a third party, eg making sure that we can keep in touch with our customers about existing orders and new products
For our legitimate interests or those of a third party, eg to make sure we are following our own internal procedures and working efficiently so we can deliver the best service to you
• existing and former customers;
• third parties who have previously expressed an interest in our services;
• third parties with whom we have had no previous dealings.
To comply with our legal and regulatory obligations
The above table does not apply to special category personal information, which we will only process with your explicit consent. In circumstances where you, your employer or any other party you access our services through provide us with health data to enable us to provide our services to you, we will ask you for your consent to process such data.
We may use your personal information to send you updates (by email, text message, telephone or post) about our products and/or services, including exclusive offers, promotions or new products and/or 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 to other organisations for marketing purposes. You have the right to opt out of receiving promotional communications at any time by:
- contacting us at email@example.com
- using the ‘unsubscribe’ link in emails or ‘STOP’ number in texts
We may ask you to confirm or update your marketing preferences if you instruct us to provide further products and/or 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 services to you, eg payment service providers, transport business (i.e. car rental/leasing companies, ride haling, taxi, rail and airlines) and cloud computing businesses;
- your employers where your employer uses our services to deliver services to you;
- local authorities where you have access to our services through a local authority
- 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;
- credit reference agencies;
- our insurers, brokers, bank, accountants, solicitors and auditors.
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, where appropriate, to ensure they can only use your personal information to provide services to us and to you.
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.
There may be occasions where we share your data with other third parties and in circumstances not set out above, if that happens, we will only share your data if it is necessary.
WHERE YOUR PERSONAL INFORMATION IS HELD
Information 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 European Economic Area. For more information, including on how we safeguard your personal information when this occurs, see below: ‘Transferring your personal information out of the EEA’.
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/or 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 and to protect our legal interests.
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 but, generally, we will retain your data for seven years after the date on which you or your employer interacted with us.
Further details of retention policy and the periods which apply are available on request. When it is no longer necessary to retain your personal information, we will delete or anonymise it.
TRANSFERRING YOUR PERSONAL INFORMATION OUT OF THE EEA
To deliver services to you, it is sometimes necessary for us to share your personal information outside the European Economic Area (EEA), eg:
- with your and our service providers located outside the EEA;
- if you are based outside the EEA;
- where there is an international dimension to the services we are providing to you.
These transfers are subject to special rules under European and UK data protection law.
The following countries to which we may transfer personal information have been assessed by the European Commission as providing an adequate level of protection for personal information: Andorra, Argentina, Canada (commercial organisations), Faroe Islands, Guernsey, Israel, Isle of Man, Japan, Jersey, New Zealand, Switzerland, Uruguay and the United States of America (subject to the privacy regulations).
Except for the countries listed above, non-EEA countries do not have the same data protection laws as the United Kingdom and EEA. We will, however, ensure the transfer complies with data protection law and all personal information will be secure. Our standard practice is to use standard data protection contract clauses that have been approved by the European Commission.
If you would like further information, please contact us (see ‘How to contact us’ below).
You have the following rights, which you can exercise free of charge:
• at any time to your personal information being processed for direct marketing (including profiling);
• in certain other situations to our continued processing of your personal information, eg processing carried out for the purpose of our legitimate interests.
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’; and
- let us have enough information to identify you (eg your full name, address and customer or matter reference number);
- 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. 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 that we can 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.
This privacy notice was published on 01.06.20.
We may change this privacy notice from time to time – when we do we will let you know.
HOW TO CONTACT US
3rd Floor, The Waterfront Building
Salts Mill Road
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).