This policy is effective from 1st January 2023.
Our Privacy Promise
- To keep your data safe and private
- Not to sell your data
- To give you ways to manage and review your marketing choices at any time
Identity and contact details of the Data Controller and Data Protection Officer
Luca Caruana is the Data Controller and is committed to protecting the rights of individuals in line with the Data Protection Act 1998 (DPA) and the new General Data Protection Regulation (GDPR).
The person responsible for Data Protection can be contacted at firstname.lastname@example.org.
What information do we collect about you?
We may collect the following information:
- contact information including email address
- demographic information such as postcode
- other information relevant to customer surveys and/or offers
- Details about products and services we provide to you
- Data we get about where you are such as IP address
- Details on devices and technology you use
- Other data about how you use our products and services
- Consents, permissions or preferences you give us– including how you want us to contact you
Where we collect personal information?
Data you give to us:
- When you use our website or app
- When you ask for our products or services
- When you talk to us on the phone
- When you give us a business card
- In emails and letters
- In customer surveys
What is our legal basis for processing your personal data?
The new law says we are allowed to use personal information only if we have a proper reason to do so. This includes sharing it outside the Money Coaching Hub. The law says we must have one or more of these reasons:
- When you have given consent
- To fulfil a contract we have with you
- When it is in our legitimate interest
- When it is our legal duty to do so
How will your information be used?
|What we use your information for||Why||Our legitimate interest|
|· To manage our relationship with you or your business · To develop new ways to meet our customers’ needs and to grow our business· To develop and carry out marketing activities· To study how customers use products and services from us· To provide advice and guidance about our products and services||· Following your consent ·Fulfilling a contract · Our legitimate interests· Our legal duty||· Keeping our records up to date · Working out which of our products or services may interest you and telling you about them· Developing products and services and how we charge for them· Defining types of customers for new products and services· Seeking your consent when we need to contact you|
|· To develop and manage our products and services ·To test new products·To manage how we work with other companies that provide services to us and our customers||· Fulfilling contracts · Our legitimate interests· Our legal duty||· Developing products and services and how we charge for them · Defining types of customers for new products and services· Being efficient about how we fulfil our legal and contractual duties|
|· To deliver our products and services · To manage customer payments· To collect and recover money that is owed to us||· Fulfilling contracts · Our legitimate interests· Our legal duty||· Being efficient about how we fulfil our legal and contractual duties|
|· To obey laws and regulations that apply to us · To respond to complaints and seek to resolve them||· Fulfilling contracts · Our legitimate interests· Our legal duty||· Complying with regulations that apply to us · Being efficient about how we fulfil our legal and contractual duties|
|· To run our business in an efficient and proper way including managing our business capability, planning and communication||· Our legitimate interests · Our legal duty||· Complying with regulations that apply to us Being efficient about how we fulfil our legal and contractual duties|
|· To exercise our rights set out in agreements and contracts||· Fulfilling contracts|
We may use your personal information to tell you about relevant products and offers. The personal information we have for you is made up of what you tell us and data we collect when you use our services. We use this to form a view on what we think you may want or need, or what may be of interest to you.
We can only use your personal information to send you marketing messages if we either have your consent or a ‘legitimate interest’
You can ask us to stop sending you marketing messages by contacting us on email@example.com at any time, or clicking on the unsubscribe link that appears on every email.
Sending data outside the EEA
When we transfer information outside the EEA we make sure that it is protected in the same ways as if it was being used in the EEA. We only transfer it to organisations that are part of the Privacy Shield. This is a framework that sets privacy standards for data sent between the US and EU countries. It makes sure those standards are similar to what is used within the EEA.
Who we share your personal information with
We share your personal information with agents and advisers who we use to help run your accounts and services, collect what you owe, and explore new ways of doing business.
How long will your information be held?
We will keep your personal information until you request otherwise.
We may keep your data for up to 7 years afterwards for one of these reasons:
- To respond to any questions or complaints
- To show we treated you fairly
- To maintain records according to rules that apply to us
We may keep your data for longer than 7 years if we cannot delete it for legal, regulatory or technical reasons.
What are your rights?
You have the right to access your personal information, to object to the processing of your personal information, to rectify, to erase, to restrict and to ‘port’ (ask for the transfer of your personal information in an easy to use format to another organisation). Any requests or objections should be made in writing to firstname.lastname@example.org
How to get a copy of your personal information
You can request a copy of the personal information we hold by sending a request in writing to us at email@example.com
Letting us know your personal information is incorrect
If you think any information we hold about you is wrong or incomplete, you have the right to ask for it to be changed. Please contact us and we will take reasonable steps to correct the data.
Letting us know you want us to stop using your personal information
You have the right to object to our use of your personal information, or to ask us to delete, remove or stop using your personal information if there is no need for us to keep it. This is known as the ‘right to object’ and ‘right to erasure,’ or the ‘right to be forgotten’
If you want to object to how we use your data, or ask us to delete it or restrict how we use it, please contact us.
There may be legal or other official reasons why we need to keep or use your data but please tell us if you think that we should not be using it.
You have the right to withdraw consent
You can withdraw your consent at any time. Please contact us if you want to do so. If you withdraw your consent we may not be able to provide certain products or services to you. If that is so we will tell you.
How to make a complaint
We hope you won’t ever need to, but if you are unhappy with how we have used your personal information please send an email to firstname.lastname@example.org with details of your complaint. We will look into and respond to any complaints we receive.
You also have the right to register a complaint with the Information and Data Protection Commissioner (IDPC). For further information on your rights and how to complain please go to the IDPC Website – the link is here.