For the purpose of the Data Protection Act 1998 (the Act), Regulation (EU) 2016/679 (General Data Protection Regulation) and Privacy and Electronic Communications Regulations (PECR), the data controller is Charles & Dean Limited of Willoughby House, 2 Broad Street, Stamford, PE9 1PB. Our nominated representative for the purpose of the Act is Simon Grace.
INFORMATION WE MAY COLLECT FROM YOU
We may collect and process the following data about you:
Information you give us. You may give us information about you by filling in forms on our site http://charlesanddean.spd.agency (our site) or by corresponding with us by phone, e-mail or otherwise. This includes information you provide when you register to use our site, subscribe to our service, search for a product, participate in discussion boards or other social media functions on our site, enter a competition, promotion or survey, and when you report a problem with our site. The information you give us may include your name, address, e-mail address and phone number, financial and credit card information, personal description and photographs.
Information we collect about you. With regard to each of your visits to our site we may automatically collect the following information:
technical information, including the Internet protocol (IP) address used to connect your computer to the Internet, your login information, browser type and version, time zone setting, browser plug-in types and versions, operating system and platform;
information about your visit, including the full Uniform Resource Locators (URL) clickstream to, through and from our site (including date and time); products you viewed or searched for; page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs), and methods used to browse away from the page and any phone number used to call our customer service number.
Information we receive from other sources. We may receive information about you if you use any of the other websites we operate or the other services we provide. In this case we will have informed you when we collected that data that it may be shared internally and combined with data collected on this site. We are also working closely with third parties (including, for example, business partners, sub-contractors in technical, payment and delivery services, advertising networks, analytics providers, search information providers, credit reference agencies) and may receive information about you from them.
We make sure that we have appropriate security measures to protect your information. We will periodically review your personal information to ensure that we do not keep it for longer than is permitted.
Note that it is your responsibility to check and ensure that all information, content, material or data you provide on the Sites is correct, complete, accurate and not misleading and that you disclose all relevant facts.
We do not knowingly collect or store any personal information about children under the age of 16. If you are aged under 16 please get your parent or guardian’s permission before you provide any personal information to us.
In order to ensure the Services we provide you continue to meet your needs we may ask you for feedback on your experience of using the Site. Any feedback you provide will only be used as part of our programme of continuous improvement and will not be published on the Site.
USES MADE OF THE INFORMATION
We use information held about you in the following ways:
Information you give to us. We will use this information:
sending you renewal information based on information you previously provided to us (if you have requested quotes) – when our systems indicate that your renewal is due (based on the dates you entered for your most recent quote).
sending you a confirmation email of your quote – when you obtain a quote with us, you will be sent confirmation of your quote by email so that you have a record of it and can easily retrieve your quote in the future. This is a standard part of our Services and by using the Services you agree to receive these communications;
to process a transaction between you and a third party;
to carry out our obligations arising from any contracts entered into between you and us and to provide you with the information, products and services that you request from us;
to provide you with information about other goods and services we offer that are similar to those that you have already purchased or enquired about;
If you agree, we will contact you (depending on your contact preferences) via email, post, telephone, sms, or by other electronic means such as via social and digital media this may include new product launches, newsletters and opportunities to participate in market research;
to notify you about changes to our service;
to ensure that content from our site is presented in the most effective manner for you and for your computer.
Information we collect about you. We will use this information:
to administer our site and for internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes;
to improve our site to ensure that content is presented in the most effective manner for you and for your computer;
to allow you to participate in interactive features of our service, when you choose to do so;
as part of our efforts to keep our site safe and secure;
to measure or understand the effectiveness of advertising we serve to you and others, and to deliver relevant advertising to you;
to make suggestions and recommendations to you and other users of our site about goods or services that may interest you or them.
Information we receive from other sources. We may combine this information with information you give to us and information we collect about you. We may us this information and the combined information for the purposes set out above (depending on the types of information we receive).
DISCLOSURE OF YOUR INFORMATION
We will only collect and use your personal information in accordance with data protection laws. Our grounds for processing your personal information are as follows:
1. Consent – Where necessary we will only collect and process your personal information if you have given your consent for us to do so, for example, we will only send you certain marketing emails and process any sensitive information about you if we have your consent.
2. Legitimate Interests – We may use and process some of your personal information where we have sensible and legitimate business grounds for doing so. Under European privacy laws there is a concept of “legitimate interests” as a justification for processing your personal information. Our legitimate interests for processing your personal information are:
2.1 to enable you to access and use the Services by: searching the websites of our partners to get you the best quotes; processing any transaction between you and a third party; and tracking sales. Using your information in this way is an essential part of us being able to provide the Services to you;
2.2 to communicate with you about the Services. We need to keep you informed about your use of the Services for example sending you a confirmation email of your quotes. This won’t include marketing communications unless you have given us your consent to receive these; and
2.3 to improve our Services. We may use your personal information to: personalise aspects of our service; for market research. We constantly aim to improve our Services to you and using your personal information in this way helps us to do this.
2.4 Analytics and search engine providers that assist us in the improvement and optimisation of our site.
2.5 Credit reference agencies for the purpose of assessing your credit score where this is a condition of us entering into a contract with you.
2.6 We may disclose your personal information to third parties:
2.7 In the event that we sell or buy any business or assets, in which case we may disclose your personal data to the prospective seller or buyer of such business or assets.
2.8 If Charles & Dean Limited or substantially all of its assets are acquired by a third party, in which case personal data held by it about its customers will be one of the transferred assets.
From May 2018, you will have a right to object to our use of your personal information for these legitimate interests including where we may use your personal information to create a profile to inform customer demographics. If you raise an objection we will stop processing your personal information unless very exceptional circumstances apply, in which case we will let you know why we are continuing to process your personal information. Please contact our Customer Services Team at firstname.lastname@example.org if you wish to exercise this right.
WHO DO WE SHARE YOUR PERSONAL INFORMATION WITH?
When you use any of our Services, we may disclose your personal information to the following parties:
2. our channel operators: whilst the majority of the channels on our Site are run by us, some of our channels are designed and maintained for us by our service providers. We may receive your personal information from these service providers and use it in accordance with section 4 above. We will only use the personal information we receive from third parties where the relevant third party can show that it was collected and processed in accordance with the law;
3. other service providers that we engage to help us provide certain services and/or functionality, such as whether products are suitable for you. These include:
(i) our CRM system
(ii) our web designers and digital marketers
(iii) our telecommunications provider
(iv) our IT system and support
4. the Financial Conduct Authority and/or other regulatory/governing bodies, for the purposes of compliance monitoring;
Where permitted by data protection and privacy law, we may also disclose information about you (including electronic identifiers such as IP addresses) and/or access your account:
1. if required or permitted to do so by law;
2. if required to do so by any court, the Financial Conduct Authority, the Competition and Markets Authority or any other applicable regulatory, compliance, Governmental or law enforcement agency;
3. if necessary in connection with legal proceedings or potential legal proceedings; and/or
4. in connection with the sale or potential sale of all or part of our business.
If we reasonably believe false or inaccurate information has been provided and fraud is suspected, details may be passed to fraud prevention agencies to prevent fraud and money laundering.
WHO MIGHT OUR LENDERS SHARE YOUR PERSONAL INFORMATION WITH?
Some of our lenders will use your personal information to assess your circumstances and verify the information that you have provided before providing finance to you.
Some lenders may carry out checks with fraud prevention and credit reference agencies, both when you first apply for finance and at renewal. If providers do these checks, they will be quotation searches only, but will be visible to other organisations. Both public data (e.g. the electoral roll) and private data (e.g. your personal credit history) may be checked in this way.
Some lenders may carry out checks against data they already hold on you, (or is held by the company whose brand they administer the product for, or members of their group of companies) such as data from existing products, account data, data from previous product transactions, accounts you may hold with them or loyalty scheme data to share with insurers in order to determine your premium.
This information exchange allows providers to verify the information that is provided during the quote process (including information about any third party who is named on the agreement), and also helps to detect fraudulent claims.
WHERE WE STORE YOUR PERSONAL DATA
Your personal data’s security is very important to us. This is why, where it’s appropriate, our Sites use HTTPS to help keep information about you secure. However, no data transmission over the internet can be guaranteed to be totally secure. Certain information, for example, your credit card details, is encrypted to minimise the risk of interception during transit.
All information you provide to us is stored on our secure servers. Although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted to our site; any transmission is at your own risk. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorised access.
You have certain rights under existing data protection legislation including the right to request a copy of the personal information we hold about you, if you request it from us in writing.
From May 2018 you will have the following rights:
(i) Right to access: the right to request copies of your personal information from us;
(ii) Right to correct: the right to have your personal information rectified if it is inaccurate or incomplete;
(iii) Right to erase: the right to request that we delete or remove your personal information from our systems;
(iv) Right to restrict our use of your information: the right to ‘block’ us from using your personal information or limit the way in which we can use it;
(v) Right to data portability: the right to request that we move, copy or transfer your personal information;
(vi) Right to object: the right to object to our use of your personal information including where we use it for our legitimate interests or where we use your personal information to carry out profiling to inform our market research and customer demographics
If you are not satisfied with the way any complaint you make in relation to your personal information is handled by us then you may be able to refer your complaint to the relevant data protection regulator which in the UK is the Information Commissioner’s Office.
ACCESS TO INFORMATION
The Act gives you the right to access information held about you. Your right of access can be exercised in accordance with the Act. Any access request may be subject to a fee of £10 to meet our costs in providing you with details of the information we hold about you.
AMENDING YOUR PREFERENCES
Any electronic marketing communications we send you will include clear and concise instructions to follow should you wish to unsubscribe at any time. You may also amend your marketing preferences by emailing us at email@example.com.
Should you no longer wish to be contacted by us, you can advise us at any time by contacting our Customer Services team on 01780763836 (within the UK) or +441780763836 (outside the UK) – lines are open Monday to Friday 9.00 to 5.30 or by sending an email to firstname.lastname@example.org
If you no longer wish to be contacted by lenders for marketing purposes, please follow the instructions in their marketing communications, or consult their privacy policies for further information about unsubscribing.