How
do we use the personal information?
We may use personal information for the following purposes:
To
verify your identity and establish and manage your account
As part of providing services, or information about our
services, to you, we will need to verify your identify to set you up as a
customer and we will need to use those details in order to effectively manage
your account with us to ensure that you are getting the best possible service
from us. This may include third parties carrying out credit or identity checks
on our behalf. It is not only in our legitimate interest to do so but the use
of your personal information in this way is necessary for us to know who you
are as we have a legal obligation to comply with certain Know Your Customer
regulatory obligations.
To
provide you with products and services, or information about our products and
services, and to review your ongoing needs
Once you open an account with us, or subscribe to an update
or webinar, we will need to use your personal information to perform our
services and comply with our obligations to you. It is also in our legitimate
interests to ensure that we are providing the best products and services so we
may periodically review your needs to ensure that you are getting the benefit
of the best possible products and services from us.
To
help us improve our products and services, including customer services, and
develop and market new products and services
We may from time to time use personal information provided
by you through your use of the services and/or through customer surveys to help
us improve our products and services. It is in our legitimate interests for us
to use your personal information in this way to ensure that we provide you with
the best products and services we can and to continue to be a market leader in
our industry.
To
form a profile about you
We may from time to time use personal information about you
to form profiles about you so that we can understand you and provide the very
best products and services we can. We may also make decisions about you through
automated profiling or automated credit checks which may affect your ability to
use our services. We may need to do this either to perform our legal
obligations or because it is in our legitimate interest to use your personal
information in such a way.
To
investigate or settle enquiries or disputes
We may need to use personal information collected from you
to investigate issues and/or settle disputes with you as it is in our
legitimate interests to ensure that issues and/or disputes get investigated and
resolved as quickly and efficiently as possible.
To
comply with applicable law, court order, other judicial process, or the
requirements of any applicable regulatory authorities
We may need to use your personal information to comply with
applicable law, court order or other judicial process, or the requirements of
any applicable regulatory authority. We do this not only to comply with our
legal obligations but because it may also be in our legitimate interest to do
so.
To
provide references about you
From time to time, third parties, such as credit agencies
may approach us to provide a credit reference about you for credit and identity
checks. It may be in our legitimate interest to comply with our legal
obligations or we may be obliged to provide such a reference in order to comply
with a legal obligation. However if we are unsure we will speak to you first
before providing any reference.
To
send you surveys
From time to time, we may send you surveys as part of our
customer feedback process and it is in our legitimate interest to ask for
feedback to ensure that we provide the best service to you. However, we may
from time to time also ask you to participate in other surveys and if you agree
to participate in such surveys we rely on your consent to use the personal
information we collect as part of such survey. All responses to any survey we
send out whether for customer feedback or otherwise will be aggregated and
depersonalised before survey results are shared with any third parties.
Data
analysis
Our web pages and e-mails may contain web beacons or pixel
tags or any other similar type of data analysis tools which allow us to track
receipt of correspondence and to count the number of users that have visited
our webpage or opened our correspondence. Where your personal information is
completely anonymised, we do not require a legal basis as the information will
no longer constitute personal information. However where your personal
information is not in an anonymised form, it is in our legitimate interest to
continually evaluate that personal information to ensure that the products and
services we provide are relevant to the market.
Marketing
by us
We may use your personal information to send you marketing
communications by email or phone or other agreed forms (including social media
campaigns) to ensure that you are always kept up to date with our latest
products and services. Where we send you marketing communications we will
either do so as it is in our legitimate interest or with your consent.
Internal
business purposes and record keeping
We may need to process your personal information for
internal business and research purposes and record keeping purposes. Such
processing is in our own legitimate interests and is required in order to
comply with our legal obligations. This may include any communications that we
have with you in relation to the services we provide to you and our
relationship with you. We will also keep records to ensure that you comply with
your obligations under any contract you have entered into with us.
Corporate
restructuring
If we undergo a corporate restructure or part or all of our
business is acquired by a third party, we may need to use your personal
information in association with that restructure or acquisition. Such use may
involve disclosing your details as part of a due diligence exercise. It is our
legitimate interest to use your information in this way provided we comply with
any legal obligation we have to you.
Security
If you enter any of our premises we may record your image on
our CCTV for security reasons. We may also take your details to keep a record
of who has entered our premises on any given day. It is in our legitimate
interest to do this to maintain a safe and secure working environment.
The
personal information we hold about you
The information about any rights that might be available to
you in relation to the personal information we hold about you is set out below.
Access
If you ask us, we will confirm whether we are processing
your personal information and, if so, provide you with a copy of that personal
information (along with certain other details). If you require additional
copies, we may need to charge a reasonable administration fee.
Rectification
If the personal information we hold about you is inaccurate
or incomplete, you are entitled to have it rectified. If we have shared your
personal information with others, we will let them know about the rectification
where possible. If you ask us, where possible and lawful to do so, we will also
tell you who we have shared your personal information with so that you can
contact them directly.
Erasure
You can ask us to delete or remove your personal information
in certain circumstances such as where we no longer need it or you withdraw
your consent (where applicable) provided that we have no legal obligation to
retain that data. Such request will be subject to any retention limits we are
required to comply with in accordance with applicable laws and regulations and
subject to section 'How do we store personal information and for how long'. If
we have shared your personal information with others, we will let them know
about the erasure where possible. If you ask us, where possible and lawful to
do so, we will also tell you who we have shared your personal information with so
that you can contact them directly.
Processing
restrictions
You can ask us to ‘block’ or suppress the processing of your
personal information in certain circumstances such as where you contest the
accuracy of that personal information or object to us processing it. It will
not stop us from storing your personal information though. We will tell you
before we lift any restriction. If we have shared your personal information
with others, we will let them know about the restriction where possible. If you
ask us, where possible and lawful to do so, we will also tell you who we have
shared your personal information with so that you can contact them directly.
Data
Portability
Under the General Data Protection Regulation (679/2016), you
have the right, in certain circumstances, to obtain personal information you
have provided us with (in a structured, commonly used and machine readable
format) and to reuse it elsewhere or ask us to transfer this to a third party
of your choice.
Objection
You can ask us to stop processing your personal information,
and we will do so, if we are:
- relying on our own or someone else’s legitimate
interests to process your personal information except if we can
demonstrate compelling legal grounds for the processing;
- processing your personal information for direct marketing;
or
- processing your personal information for research
unless such processing is necessary for the performance of a task carried
out in the public interest.
Automated
decision-making and profiling
If we have made a decision about you based solely on an
automated process (e.g. through automatic profiling) that affects your ability
to use the services or has another significant effect on you, you can ask to
not to be subject to such a decision unless we can demonstrate to you that such
decision is necessary for entering into, or the performance of, a contract
between you and us. Even where a decision is necessary for entering into or
performing a contract, you may contest the decision and require human
intervention.
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