Welcome to the Pearson 1860 privacy and cookie policy.

We respect your privacy and are committed to protecting your personal data. This privacy policy will inform you as to how we look after your personal data when you visit our website (regardless of where you visit it
from) and tell you about your privacy rights and how the law protects you.  It will also provide you with information about the cookies we use on our website.

This privacy and cookie policy is provided in a layered format so you can click through to the specific areas set out below. Please also use the Glossary to understand the meaning of some of the terms used in this
privacy and cookie policy.

1. IMPORTANT INFORMATION AND WHO WE ARE

2. THE DATA WE COLLECT ABOUT YOU

3. HOW IS YOUR PERSONAL DATA COLLECTED?

4. HOW WE USE YOUR PERSONAL DATA

5. DISCLOSURES OF YOUR PERSONAL DATA

6. INTERNATIONAL TRANSFERS

7. DATA SECURITY

8. DATA RETENTION

9. YOUR LEGAL RIGHTS 

10. GLOSSARY

 

1.  IMPORTANT INFORMATION AND WHO WE ARE  

PURPOSE OF THIS PRIVACY POLICY  

This privacy policy aims to give you information on how Pearson 1860 Limited collects and processes your personal data through your use of this website, including any data you may provide through this website when you
sign up to our newsletter, purchase a product or service or enter a promotion or respond to a survey.

This website is not intended for children and we do not knowingly collect data relating to children.

It is important that you read this privacy policy together with any other privacy policy or fair processing policy we may provide on specific occasions when we are collecting or processing personal data about you so
that you are fully aware of how and why we are using your data. This privacy policy supplements other notices and privacy policies and is not intended to override them.

CONTROLLER  

Pearson 1860 Limited is the controller and responsible for your personal data (collectively referred to as “Company”, “we”, “us” or “our” in this privacy policy).

We have appointed a data privacy manager who is responsible for overseeing questions in relation to this privacy policy. If you have any questions about this privacy policy, including any requests to exercise your legal
rights, please contact the data privacy manager using the details set out below.

CONTACT DETAILS  

If you have any questions about this privacy policy or our privacy practices, please contact our data privacy manager in the following ways:

Full name of legal entity: Pearson 1860 Limited

Email address: care@pearson1860.com

Postal address: 232 Upper Richmond Road. East Sheen, London, SW14 8AG

Telephone number: (+44) 208 642 2095

 

You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.

CHANGES TO THE PRIVACY POLICY AND YOUR DUTY TO INFORM US OF CHANGES   

We keep our privacy policy under regular review. This version was last updated on 1 February 2021. Historic versions can be obtained by contacting us.

It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.

 

THIRD-PARTY LINKS  

This website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy policy of every website you visit.

 

2.  THE DATA WE COLLECT ABOUT YOU  

Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).

We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:

  • Identity Data includes first name, last name, username or similar identifier, title, date of birth and gender.
  • Contact Data includes billing address, delivery address, email address and telephone numbers.
  • Financial Data includes bank account and payment card details.
  • Transaction Data includes details about payments to and from you and other details of products and services you have purchased from us.
  • 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.
  • Profile Data includes your username and password, purchases or orders made by you, your interests, preferences, feedback and survey responses.
  • Usage Data includes information about how you use our website, products and services.
  • Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.

We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data could be derived from your personal data but is not considered personal data in law as this data will 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 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.

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.

Privacy - If you elect to use a Klarna payment option,  we will pass to Klarna certain aspects of your personal information, such as contact and order details, in order for Klarna to assess whether you qualify for their payment options and to tailor the payment options for you. General information on Klarna you can find here. Your personal data will be handled in accordance with applicable data protection law and in accordance with the information in Klarnas privacy statement.

IF YOU FAIL TO PROVIDE PERSONAL DATA  

Where we need to collect personal data by law, or under the terms of a contract we have with you, and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to
enter into with you (for example, to provide you with goods or services). In this case, we may have to cancel a product or service you have with us but we will notify you if this is the case at the time.

3.  HOW IS YOUR PERSONAL DATA COLLECTED?  

We use different methods to collect data from and about you including through:

  • 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:
  • purchase a product or service;
  • create an account on our website;
  • subscribe to our service or publications;
  • request marketing to be sent to you;
  • enter a competition, promotion or survey; or
  • give us feedback or contact us.
  • Automated technologies or interactions. As you interact with our website, we will automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies and other similar technologies. Please see our cookie policy below for further details.
  • Third parties or publicly available sources. We will receive personal data about you from various third parties as set out below:

Technical Data from the following parties:

(a)  analytics providers such as Google based outside the EU;

(b)  advertising networks based inside or outside the EU; and

(c)  search information providers based inside or outside the EU.

(d) Contact, Financial and Transaction Data from providers of technical, payment and delivery services such as PayPal Ltd. Or Sage Pay Europe Limited, Klarna & V12 Retail Finance.

4.  HOW WE USE YOUR PERSONAL DATA   

We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:

  • Where we need to perform the contract we are about to enter into or have entered into with you.
  • Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
  • Where we need to comply with a legal obligation.

Click here to find out more about the types of lawful basis that we will rely on to process your personal data. 

Generally, we do not rely on consent as a legal basis for processing your personal data although we will get your consent before 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  

We have set out below, in a table format, a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.

Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below. 

Purpose/Activity

Type of data

Lawful basis for processing including basis of legitimate interest

To register you as a new customer

(a) Identity

(b) Contact

Performance of a contract with you

To process and deliver your order including:

(a) Manage payments, fees and charges

(b) Collect and recover money owed to us

(a) Identity

(b) Contact

(c) Financial

(d) Transaction

(e) Marketing and Communications

(a) Performance of a contract with you

(b) Necessary for our legitimate interests (to recover debts due to us)

To manage our relationship with you which will include:

(a) Notifying you about changes to our terms or privacy policy

(b) Asking you to leave a review or take a survey

(a) Identity

(b) Contact

(c) Profile

(d) Marketing and Communications

(a) Performance of a contract with you

(b) Necessary to comply with a legal obligation

(c) Necessary for our legitimate interests (to keep our records updated and to study how customers use our products/services)

To enable you to partake in a prize draw, competition or complete a survey

(a) Identity

(b) Contact

(c) Profile

(d) Usage

(e) Marketing and Communications

(a) Performance of a contract with you

(b) Necessary for our legitimate interests (to study how customers use our products/services, to develop them and grow our business)

To administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)

(a) Identity

(b) Contact

(c) Technical

(a) Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group
restructuring exercise)

(b) Necessary to comply with a legal obligation

To deliver relevant website content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you

(a) Identity

(b) Contact

(c) Profile

(d) Usage

(e) Marketing and Communications

(f) Technical

Necessary for our legitimate interests (to study how customers use our products/services, to develop them, to grow our business and to inform our marketing strategy)

To use data analytics to improve our website, products/services, marketing, customer relationships and experiences

(a) Technical

(b) Usage

Necessary for our legitimate interests (to define types of customers for our products and services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy)

To make suggestions and recommendations to you about goods or services that may be of interest to you

(a) Identity

(b) Contact

(c) Technical

(d) Usage

(e) Profile

(f) Marketing and Communications

Necessary for our legitimate interests (to develop our products/services and grow our business)

to provide a consistent chat experience across the user's session on the website 

a) Identity

b) Contact

Necessary for our legitimate interests to ensure (to make appropriate recommendation and support and grow our business )

 

MARKETING  

We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising.

PROMOTIONAL OFFERS FROM US  

We may 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).
 

You will receive marketing communications from us if you have requested information from us or purchased goods or services from us and you have not opted out of receiving that marketing.

THIRD-PARTY MARKETING  

We will get your express opt-in consent before we share your personal data with any third party for marketing purposes.

OPTING OUT  

You can ask us or third parties to stop sending you marketing messages at any time by following the opt-out links on any marketing message sent to you.

Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of a product/service purchase, warranty registration, product/service experience or other transactions.

COOKIES  

You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of this website may become inaccessible or not function properly.

Our website uses cookies to distinguish you from other users of our website. This helps us to provide you with a good experience when you browse our website and also allows us to improve our site. By continuing to browse the site, you are agreeing to our use of cookies.

A cookie is a small file of letters and numbers that we store on your browser or the hard drive of your computer if you agree. Cookies contain information that is transferred to your computer’s hard drive.

We use the following cookies:

  • Strictly necessary cookies. These are cookies that are required for the operation of our website. They include, for example, cookies that enable you to log into secure areas of our
    website, use a shopping cart or make use of e-billing services.
  • Analytical/performance cookies. They allow us to recognise and count the number of visitors and to see how visitors move around our website when they are using it. This helps us to
    improve the way our website works, for example, by ensuring that users are finding what they are looking for easily.
  • Functionality cookies. These are used to recognise you when you return to our website. This enables us to personalise our content for you, greet you by name and remember your
    preferences (for example, your choice of language or region).
  • Targeting cookies. These cookies record your visit to our website, the pages you have visited and the links you have followed. We will use this information to make our website and the
    advertising displayed on it more relevant to your interests. We may also share this information with third parties for this purpose.

You can find more information about the individual cookies we use and the purposes for which we use them in the table below:

Cookie

Name

Purpose

More information

Cloudflare

__cfduid

Cookie associated with sites using CloudFlare, used to speed up page load times. According to CloudFlare it is used to override any security restrictions based on the IP address the visitor is coming from. It
does not contain any user identification information.

Cloudfare

_ga

This cookie name is associated with Google Universal Analytics – which is a significant update to Google’s more commonly used analytics service. This cookie is used to distinguish unique users by assigning a
randomly generated number as a client identifier. It is included in each page request in a site and used to calculate visitor, session and campaign data for the sites analytics reports. By default it is set to expire after 2 years,
although this is customisable by website owners.

Cloudfare

_mkto_trk

This cookie is associated with an email marketing service provided by Marketo. This tracking cookie allows a website to link visitor behaviour to the recipient of an email marketing campaign, to measure
campaign effectiveness.

Cloudfare

cfmrk_userLangRedirect

Google

SIDCC

This cookie carries out information about how the end user uses the website and any advertising that the end user may have seen before visiting the said website.

Google

SID

This is a very common cookie name but where it is found as a session cookie it is likely to be used as for session state management.

Google

SAPISID

This DoubleClick cookie is generally set through the site by advertising partners, and used by them to build a profile of the website visitor’s interests and show relevant ads on other sites. This cookie works
by uniquely identifying your browser and device.

Google

NID

This cookie is set by DoubleClick (which is owned by Google) to help build a profile of your interests and show you relevant ads on other sites.

Google

1P_JAR

This cookie carries out information about how the end user uses the website and any advertising that the end user may have seen before visiting the said website.

Google

APISID

This DoubleClick cookie is generally set through the site by advertising partners, and used by them to build a profile of the website visitor’s interests and show relevant ads on other sites. This cookie works
by uniquely identifying your browser and device.

Google

SSID

This cookie carries out information about how the end user uses the website and any advertising that the end user may have seen before visiting the said website.

Google

HSID

This cookie is set by DoubleClick (which is owned by Google) to build a profile of the website visitor’s interests and show relevant ads on other sites.

Google

CONSENT

This cookie carries out information about how the end user uses the website and any advertising that the end user may have seen before visiting the said website.

Pearson1860

_ga

This cookie name is associated with Google Universal Analytics – which is a significant update to Google’s more commonly used analytics service. This cookie is used to distinguish unique users by assigning a
randomly generated number as a client identifier. It is included in each page request in a site and used to calculate visitor, session and campaign data for the sites analytics reports. By default it is set to expire after 2 years,
although this is customisable by website owners.

Pearson1860

_gid

This cookie name is associated with Google Universal Analytics. This appears to be a new cookie and as of Spring 2017 no information is available from Google. It appears to store and update a unique value for
each page visited.

Pearson1860

_cfduid

Cookie associated with sites using CloudFlare, used to speed up page load times. According to CloudFlare it is used to override any security restrictions based on the IP address the visitor is coming from. It
does not contain any user identification information.

Trustpilot

__hstc

This cookie name is associated with websites built on the HubSpot platform. It is reported by them as being used for website analytics.

Trustpilot

_biz_pendingA

This cookie is used to record website and server performance with each visit to the site. The data is aggregated and analyzed; therefore, it remains anonymous upon use.

Trustpilot

hideBusinessAccountsSelectorModal_5d6675c32d9411001eee0afb

Trustpilot

ajs_group_id

These cookies track visitor usage and events within the website. Cookies in this domain have lifespan of 1 year.

Trustpilot

_vis_opt_s

This cookie name is associated with the product Visual Website Optimiser, by USA based Wingify. The tool helps site owners measure the performance of different versions of web pages. This cookie distinguishes
between new and returning visitors.

Trustpilot

tp-b2b-selected-business-unit-id

This cookie helps track visitor usage, events, target marketing, and can also measure application performance and stability. Cookies in this domain have lifespan of 1 year.

Trustpilot

ajs_anonymous_id

These cookies are generally used for Analytics and help count how many people visit a certain site by tracking if you have visited before. This cookie has a lifespan of 1 year.

Trustpilot

_gcl_au

Used by Google AdSense for experimenting with advertisement efficiency across websites using their services

Trustpilot

_ga

This cookie name is associated with Google Universal Analytics – which is a significant update to Google’s more commonly used analytics service. This cookie is used to distinguish unique users by assigning a
randomly generated number as a client identifier. It is included in each page request in a site and used to calculate visitor, session and campaign data for the sites analytics reports. By default it is set to expire after 2 years,
although this is customisable by website owners.

Trustpilot

TP.uuid

These cookies are used by the TrustPilot service to identify you and enable you to leave reviews of our products and services.

 

Trustpilot

ajs_user_id

This cookie helps track visitor usage, events, target marketing, and can also measure application performance and stability. Cookies in this domain have lifespan of 1 year.

Trustpilot

_vwo_uuid_v2

This cookie name is associated with the product Visual Website Optimiser, by USA based Wingify. The tool helps site owners measure the performance of different versions of web pages. This cookie ensures a
visitor always sees the same version of a page and is used to track behaviour to measure the performance of different page versions.

Trustpilot

_biz_nA

This cookie is used to record website and server performance with each visit to the site. The data is aggregated and analyzed; therefore, it remains anonymous upon use.

Trustpilot

hubspotutk

This cookie name is associated with websites built on the HubSpot platform. HubSpot report that its purpose is user authentication. As a persistent rather than a session cookie it cannot be classified as
Strictly Necessary.

Trustpilot

__auc

This cookie is used to collect information on consumer behavior, which is sent to Alexa Analytics.

Trustpilot

_hjid

Hotjar cookie. This cookie is set when the customer first lands on a page with the Hotjar script. It is used to persist the random user ID, unique to that site on the browser. This ensures that behavior in
subsequent visits to the same site will be attributed to the same user ID.

Trustpilot

amplitude_id_de1e2fc13cf22ef1024015ecc1bb8ccdtrustpilot.com

These cookies are used by the TrustPilot service to identify you and enable you to leave reviews of our products and services. TrustPilot’s Privacy Policy

Trustpilot

amplitude_id_67f7b7e6c8cb1b558b0c5bda2f747b07trustpilot.com

These cookies are used by the TrustPilot service to identify you and enable you to leave reviews of our products and services. TrustPilot’s Privacy Policy

Trustpilot

_biz_uid

This cookie is used to record website and server performance with each visit to the site. The data is aggregated and analyzed; therefore, it remains anonymous upon use.

Trustpilot

_biz_flagsA

Trustpilot

__zlcmid

Live chat widget sets the cookies to store the Zopim Live Chat ID used to identify a device across visits.

Trustpilot

tp-b2b-current-language

This cookie helps track visitor usage, events, target marketing, and can also measure application performance and stability. Cookies in this domain have lifespan of 1 year.

Google

DV

These cookies are used to collect information about how visitors use our Site. We use the information to compile reports and to help us improve the Site. The cookies collect information in an anonymous form,
including the number of visitors to the Site, where visitors have come to the Site from and the pages they visited. If you do not allow these cookies we will not be able to include your visit in our statistics. You can read the full
Google Analytics privacy policy at: http://www.google.com/policies/privacy/.

Google

OTZ

Google plus cookies which allow sharing of a page on Google plus account.

Google

_ga

This cookie name is associated with Google Universal Analytics – which is a significant update to Google’s more commonly used analytics service. This cookie is used to distinguish unique users by assigning a
randomly generated number as a client identifier. It is included in each page request in a site and used to calculate visitor, session and campaign data for the sites analytics reports. By default it is set to expire after 2 years,
although this is customisable by website owners.

Google

UULE

These cookies are used to collect information about how visitors use our Site. We use the information to compile reports and to help us improve the Site. The cookies collect information in an anonymous form,
including the number of visitors to the Site, where visitors have come to the Site from and the pages they visited. If you do not allow these cookies we will not be able to include your visit in our statistics. You can read the full
Google Analytics privacy policy at: http://www.google.com/policies/privacy/.

Pearson1860

__stripe_mid

Stripe is used to making credit card payments. Stripe uses a cookie to remember who you are and to enable the website to process payments without storing any credit card information on its own servers.

Pearson1860

wp_woocommerce_session_2d362db24a8b26bc2860b709a0f506b3

Contains a unique code for each customer so that it knows where to find the cart data in the database for each customer.

Pearson1860

mailchimp_landing_site

This cookie is used to measure which page was visited first

Klaviyo

__kla_id

Tracks when someone clicks through a Klaviyo email to your website

Klaviyo

KL_FORMS_MODAL

Tracks when someone subscribes (opts in) to a form

Pearson1860

wordpress_logged_in_2d362db24a8b26bc2860b709a0f506b3

which indicates when you’re logged in, and who you are, for most interface use.

Pearson1860

wordpress_sec_2d362db24a8b26bc2860b709a0f506b3

This cookie is used to store your authentication details. Its use is limited to the admin console area, /wp-admin/

Pearson1860

wordpress_test_cookie

Used on sites built with WordPress. Tests whether or not the browser has cookies enabled

Pearson1860

woocommerce_items_in_cart

This cookie is used by woocommerce and contains the end user’s cart information.

Pearson1860

wp-settings-1

Used to persist a user’s wp-admin configuration.

Pearson1860

wp-settings-time-1

WordPress also sets a few wp-settings-{time}-[UID] cookies. The number on the end is your individual user ID from the users database table. This is used to customize your view of admin interface, and possibly
also the main site interface.

Pearson1860

cookie_notice_accepted

Records that cookie notice has been accepted

Pearson1860

woocommerce_cart_hash

This cookie is used by woocommerce and contains the end user’s cart information.

Hubspot
__hs_opt_out
This cookie is used by the opt-in privacy policy to remember not to ask the visitor to accept cookies again.
Hubspot
__hs_do_not_track
This cookie can be set to prevent the tracking code from sending any information to HubSpot.
Hubspot
__hs_initial_opt_in
This cookie is used to prevent the banner from always displaying when visitors are browsing in strict mode.
Hubspot
__hs_cookie_cat_pref
This cookie is used to record the categories a visitor consented to.
Hubspot
hs_ab_test
This cookie is used to consistently serve visitors the same version of an A/B test page they’ve seen before.
Hubspot
messagesUtk
This cookie is used to recognize visitors who chat with you
Hubspot
<id>_key
When visiting a password-protected page, this cookie is set so future visits to the page from the same browser do not require login again.
Hubspot
hs-messages-is-open
This cookie is used to determine and save whether the chat widget is open for future visits.
Hubspot
hs-messages-hide-welcome-message
This cookie is used to prevent the chat widget welcome message from appearing again for one day after it is dismissed.
Hubspot
__hstc
The main cookie for tracking visitors.
Hubspot
hubspotutk
This cookie keeps track of a visitor's identity. It is passed to HubSpot on form submission and used when deduplicating contacts.
Hubspot
__hssc
This cookie keeps track of sessions.
Hubspot
__hssrc
Whenever HubSpot changes the session cookie, this cookie is also set to determine if the visitor has restarted their browser.

Please note that third parties (including, for example, advertising networks and providers of external services like web traffic analysis services) may also use cookies, over which we have no control. These cookies are
likely to be analytical/performance cookies or targeting cookies.

You block cookies by activating the setting on your browser that allows you to refuse the setting of all or some cookies. However, if you use your browser settings to block all cookies (including essential cookies) you may not be able to access all or parts of our site.

Except for essential cookies, all cookies will expire after 2 years. 

CHANGE OF PURPOSE  

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 and that reason is compatible with the original purpose. If you
wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.
 

If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.

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.

5.  DISCLOSURES OF YOUR PERSONAL DATA  

We may share your personal data with the parties set out below for the purposes set out in the table above.

  • Internal Third Parties as set out in the Glossary.
  • External Third Parties as set out in the Glossary
  • 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.

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.  INTERNATIONAL TRANSFERS  

Some of our external third parties are based outside the EEA so their processing of your personal data may involve a transfer of data outside the EEA.

Whenever we transfer your personal data out of the EEA, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:

Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the EEA.

7.  DATA SECURITY  

We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.

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

 

8.  DATA RETENTION  

HOW LONG WILL YOU USE MY PERSONAL DATA FOR?  

We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.

To determine the appropriate retention period for personal data, we consider the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements.

By law we have to keep basic information about our customers (including Contact, Identity, Financial and Transaction Data) for six years after they cease being customers for tax purposes.

In some circumstances you can ask us to delete your data: see [your legal rights] below for further information.

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

9.  YOUR LEGAL RIGHTS  

Under certain circumstances, you have rights under data protection laws in relation to your personal data. Please click on the links below to find out more about these rights:

If you wish to exercise any of the rights set out above, please contact us.

NO FEE USUALLY REQUIRED  

You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively,
we could refuse to comply with your request in these circumstances.

WHAT WE MAY NEED FROM YOU  

We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

TIME LIMIT TO RESPOND  

We try to respond to all legitimate requests within one month. Occasionally it could take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.

10.  GLOSSARY  

LAWFUL BASIS  

Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give you the best service/product and the best and most secure experience. We make sure 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). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us.

Performance of Contract means 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.

Comply with a legal obligation means processing your personal data where it is necessary for compliance with a legal obligation that we are subject to.

THIRD PARTIES  

  • Service providers acting as processors who provide IT and system administration services.
  • Professional advisers acting as processors or joint controllers including lawyers, bankers, auditors and insurers based who provide consultancy, banking, legal, insurance and accounting services.
  • HM Revenue & Customs, regulators and other authorities acting as processors or joint controllers based in the United Kingdom who require reporting of processing activities in certain circumstances.

YOUR LEGAL RIGHTS  

You have the right to:

    Request access to your personal data (commonly known as a “data subject access request”). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.

    Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected,
though we may need to verify the accuracy of the new data you provide to us.

    Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are
required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your
request.

    Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your
particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing
purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.

    Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios:

  • If you want us to establish the data’s accuracy.
  • Where our use of the data is unlawful but you do not want us to erase it.
  • Where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims.
  • You have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.

    Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a
structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.

    Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any
processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.